Justia U.S. 6th Circuit Court of Appeals Opinion Summaries

Louis Alford was stopped by Cannon County Sheriff’s Deputies outside Woodbury, Tennessee for minor traffic violations. During the stop, Deputy Deffendoll observed a syringe filled with clear liquid inside Alford’s truck. A subsequent search revealed additional empty syringes, powder in a baggie, paper with residue, empty baggies, prescription pills not belonging to either occupant, and digital scales. Alford was arrested and charged with three state drug offenses. He spent time in jail, and his parole was revoked, resulting in over a year in prison. The drug charges were later dismissed. Forensic analysis showed the powder contained methamphetamine, but other items either contained noncontrolled substances or were not tested.Alford filed suit in the United States District Court for the Middle District of Tennessee against Deputies Deffendoll and Smith, and Cannon County, asserting false arrest, malicious prosecution, and Monell liability under 42 U.S.C. § 1983. After discovery, the district court granted summary judgment to the defendants on the federal claims, finding no genuine issue of material fact as to Smith’s involvement, and that Deffendoll had probable cause for arrest and prosecution. The court also rejected the Monell claim, finding no underlying constitutional deprivation. Alford appealed only the federal claims.On review, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s rulings. The court held that Smith was not personally involved in the arrest, and Deffendoll had probable cause to arrest and charge Alford for simple possession and possession of drug paraphernalia. The court applied the proper summary judgment and qualified immunity standards, and clarified that probable cause existed for the charges that led to Alford’s seizure. Without a constitutional violation, Alford’s Monell claim failed. The court affirmed summary judgment for all defendants. View "Alford v. Deffendoll" on Justia Law

After receiving an anonymous tip, law enforcement in Mercer County, Kentucky, stopped Steven Fellmy, who was driving a silver Ford Mustang matching the tip’s description. The stop was based on observed traffic violations, including a non-illuminated license plate and failure to signal a turn. After backup arrived, Fellmy was asked to exit the vehicle. He declined consent for a search, so a trained drug dog was led around the car. The dog briefly jumped up onto the car door and partially sniffed through the open window, ultimately alerting officers to drugs. A subsequent search revealed methamphetamine and heroin, leading to Fellmy’s arrest and charge for possession of methamphetamine with intent to distribute.The United States District Court for the Eastern District of Kentucky reviewed and denied Fellmy’s pretrial motion to suppress the drugs. The court found that officers lawfully ordered Fellmy out of the vehicle after a valid traffic stop and that the dog’s actions did not constitute an unlawful search because the officers did not encourage the dog to intrude into the car’s interior. The court also denied Fellmy’s motion in limine to exclude the drug evidence, ruling that concerns about authentication and chain of custody went to the weight of the evidence, not its admissibility, and could be addressed during cross-examination. The drugs were admitted, and Fellmy was convicted by jury and sentenced to 300 months’ imprisonment.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s rulings. The Sixth Circuit held that ordering Fellmy out of the car after a valid stop was lawful and that the dog’s brief contact with the car did not amount to a Fourth Amendment search under prevailing legal standards. The court also held that the district court did not abuse its discretion in admitting the drug evidence or in denying an evidentiary hearing regarding the chain of custody. The conviction and sentence were affirmed. View "United States v. Fellmy" on Justia Law

Michael Victor was detained overnight in an Otsego County, Michigan jail after being arrested for disorderly conduct and resisting an officer. Victor, who has epilepsy, did not receive his prescribed anti-seizure medication while in custody, despite his mother delivering it to the jail and officers being informed of his medical needs. The jail’s procedures required officers to contact an on-call medical provider from Advanced Correctional Healthcare (ACH) before administering any medication. After his release the next morning, Victor suffered a seizure, resulting in significant injuries.The United States District Court for the Eastern District of Michigan heard Victor’s civil rights suit against ACH and Nurse Kimberly Reynolds. At trial, Victor presented evidence including testimony from officers and medical staff, but no one recalled making or receiving a call to ACH regarding his medication, and no records indicated any such contact. The jury found in favor of Reynolds but against ACH, awarding Victor economic, noneconomic, and punitive damages. ACH moved for judgment as a matter of law or a new trial, arguing insufficient evidence that any officer contacted ACH. The district court granted ACH’s motions, holding there was not enough evidence for a reasonable jury to find that contact occurred, and also denied Victor’s request for sanctions related to alleged discovery violations.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed whether Victor had presented sufficient evidence to allow a reasonable jury to find that an officer had contacted ACH about his medication needs. The court held that the absence of any records and the lack of recollection from all involved witnesses meant Victor had not met his burden. Testimony indicating intent to call, without corroboration, was not enough. The Sixth Circuit affirmed the district court’s judgment as a matter of law for ACH and found no abuse of discretion in denying sanctions. View "Victor v. Reynolds" on Justia Law

A parent enrolled his teenage son, who had a history of serious behavioral and mental health issues, in a residential treatment center after other interventions failed. The family’s health insurer initially approved and paid for the first 21 days of residential treatment, then denied further coverage, asserting that the treatment was no longer medically necessary. The parent appealed this decision through the insurer’s internal process, submitting medical records and opinions from the child’s treating clinicians that supported the need for continued residential care. The insurer upheld its denial after cursory reviews that did not address the treating clinicians’ recommendations or key evidence of the child’s ongoing difficulties.The parent filed suit in the United States District Court for the Western District of Kentucky, alleging that the insurer’s denial was arbitrary and capricious under the Employee Retirement Income Security Act (ERISA) and violated the Mental Health Parity and Addiction Equity Act. The district court granted summary judgment to the insurer on both claims, finding that the decision to deny coverage was not arbitrary and capricious and that there was no evidence of a parity violation.On appeal, the United States Court of Appeals for the Sixth Circuit found that the insurer’s coverage decision was procedurally arbitrary and capricious, as it failed to consider the treating clinicians’ opinions, selectively reviewed the medical record, and did not adequately explain its change from initially approving coverage to denying it. The appellate court vacated the district court’s judgment on the ERISA claim and remanded with instructions to send the matter back to the insurer for a full and fair review. However, it affirmed the district court’s judgment on the Parity Act claim, holding that the parent failed to produce evidence showing that the insurer’s limitations on mental health treatment were more restrictive than those applied to medical or surgical benefits. View "T. E. v. Anthem Blue Cross Blue Shield" on Justia Law

The case concerns a defendant who became involved in a drug conspiracy in Cleveland, Ohio, during 2022 and 2023. Law enforcement conducted controlled buys and wiretaps, ultimately finding that the defendant sold significant quantities of fentanyl pills, including to an undercover agent. Upon his arrest in November 2023, authorities found illegal narcotics in his vehicle and other locations. The defendant was charged with conspiracy to distribute controlled substances, and the government alleged he had a prior “serious drug felony” conviction from April 2023, which could enhance his statutory minimum sentence under federal law.Previously, the United States District Court for the Northern District of Ohio found that the defendant’s April 2023 conviction met the criteria for a “serious drug felony.” After holding an evidentiary hearing, the district court overruled the defendant’s objections, rejected his constitutional arguments regarding jury findings, found the prior conviction final before the current offenses, and determined it lacked authority to review the prosecutor’s discretion in seeking the enhancement. The district court also applied a career-offender enhancement based on prior convictions, resulting in a guidelines range of 262 to 327 months, but ultimately varied downward and sentenced the defendant to 160 months. The defendant appealed, renewing his challenges.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s rulings. The appellate court held that any alleged error in not submitting the statutory enhancement facts to a jury was harmless beyond a reasonable doubt, as the defendant had admitted the relevant facts and would have pleaded guilty regardless. The court also held that the prosecution’s decision to seek the statutory enhancement was within its discretion and not arbitrary or vindictive, and that the prior conviction was “final” under existing precedent. Finally, the court rejected the defendant’s challenge to the career-offender enhancement, finding it foreclosed by circuit precedent. The judgment was affirmed. View "United States v. Loines" on Justia Law

Alliance Data Systems, a company based in Columbus, Ohio, faced mounting debt and responded by selling off side businesses, including spinning off its LoyaltyOne division into a standalone company called Loyalty Ventures Inc. Prior to and during the spinoff, executives publicly described LoyaltyOne’s Canadian AIR MILES program as having strong, long-term sponsor relationships. However, in the period leading up to and following the spinoff, AIR MILES lost several major sponsors, including its second largest, Sobeys, which announced its intention to exit the program shortly before the sponsor’s contract allowed. Loyalty’s financial condition deteriorated, leading to its bankruptcy about a year and a half after the spinoff.Investors, specifically two funds managed by Newtyn Management, brought a class action in the United States District Court for the Southern District of Ohio. They alleged that Alliance Data Systems and individual executives committed securities fraud by making misleading statements or omissions about AIR MILES’s sponsor relationships and LoyaltyOne’s financial health, in violation of Section 10(b) of the Exchange Act and Rule 10b-5. The district court dismissed the complaint, finding that Newtyn had not adequately alleged any actionable misrepresentation or omission, nor had it sufficiently pled that the defendants acted with scienter (intent to defraud).On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s dismissal de novo. The Sixth Circuit affirmed, holding that the statements cited by Newtyn were either immaterial puffery, accurate historical statements, or accompanied by sufficient cautionary language such that no reasonable investor would have been misled. The court also determined that Newtyn failed to plead a strong inference of scienter and that its related scheme liability and control person claims could not survive absent a primary violation. The judgment dismissing the complaint was affirmed. View "Newtyn Partners, LP v. Alliance Data Systems Corp." on Justia Law

Between June 2022 and February 2023, two individuals participated in a conspiracy to distribute methamphetamine in Tennessee. One defendant regularly supplied methamphetamine, while the other purchased and resold it. Law enforcement surveilled their activities, conducted searches, and utilized confidential sources to purchase drugs from both parties. Both defendants gave statements to investigators about the extent and nature of their drug transactions.The United States District Court for the Eastern District of Tennessee charged each defendant with multiple counts related to methamphetamine distribution. Both pled guilty to lesser offenses in exchange for dismissal of other charges. The court calculated each defendant’s sentencing range using drug quantity estimates derived from statements and physical evidence. One defendant objected to the amount attributed, arguing that the calculation relied on unreliable statements and overstated her culpability. Despite objections, the court imposed a sentence within the adjusted Guidelines range. The other defendant requested a downward variance based on age, health, and criminal history, but the court denied this, citing insufficient evidence of mitigating circumstances.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed both sentences for procedural and substantive reasonableness under the abuse of discretion standard. The court held that the sentence for the first defendant was procedurally unreasonable because the district court relied on an uncorroborated out-of-court statement to estimate drug quantity, lacking sufficient indicia of reliability. The court reversed her sentence and remanded for resentencing, restricting the government from introducing new evidence. For the second defendant, the court found the sentence both procedurally and substantively reasonable, affirming the district court’s decision. Thus, the appellate court reversed and remanded for one defendant, and affirmed for the other. View "United States v. Crafton" on Justia Law

Several female students at a public university alleged that the school violated Title IX by failing to offer varsity-level women’s teams in equestrian, field hockey, and lacrosse. Although the university provided club-level opportunities for these sports, the plaintiffs contended that this did not satisfy the school’s obligation to offer equal athletic opportunities. Over the previous decade, the percentage of female students and female varsity athletes at the university increased, but women still comprised a smaller share of varsity athletes than of the total student body. The university periodically surveyed students to assess interest and ability for new varsity teams and maintained a review committee to monitor athletic opportunities.The United States District Court for the Eastern District of Kentucky held a three-day bench trial, considering testimony from students, coaches, and university staff, as well as survey data regarding student interest and ability in the relevant sports. The district court found that while women were underrepresented relative to the student body, the plaintiffs failed to show there were enough female students with the requisite interest and ability to compete at the Division I varsity level in equestrian, field hockey, or lacrosse. The court concluded the university had sufficiently accommodated the athletic interests and abilities of its female students and denied relief to the plaintiffs.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s factual findings for clear error and its legal conclusions de novo. The appellate court held that the district court did not clearly err in finding insufficient interested and able female students to form viable varsity teams in the disputed sports. The court also upheld the exclusion of an expert witness who lacked relevant survey design expertise. The Sixth Circuit affirmed the judgment in favor of the university, holding that Title IX does not require the creation of new varsity teams in the absence of demonstrated unmet demand and ability. View "Niblock v. University of Kentucky" on Justia Law

An individual who founded a Michigan biomedical research company sold a majority stake in 2019 to four defendants but retained a minority interest, later becoming dissatisfied with the company’s management and moving out of state. The new owners aimed to expand the company but withheld information from the plaintiff about their efforts to secure financing, including discussions with Avista Capital Partners, a venture capital firm that ultimately made a large investment. The plaintiff sold his shares in December 2020 for a price based on an annual valuation, prior to Avista’s capital infusion that significantly increased the company’s value. The plaintiff later sued, alleging violations of federal and state securities laws, breach of fiduciary duty under Michigan law, and various fraud and contract claims based on the defendants’ failure to disclose material facts about the company’s pursuit of equity financing and Avista’s interest.The case was first heard in the United States District Court for the Western District of Michigan. That court denied the defendants’ motion to dismiss but, following discovery, granted summary judgment in favor of the defendants on all counts. The court concluded that the omissions were not material under federal securities law and, applying Delaware law and a federal standard, also found no materiality for the breach of fiduciary duty claim under Michigan law.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s summary judgment as to the federal securities law claims, the Michigan Uniform Securities Act claim, and the contract-based claims, holding that the omissions were not material under the applicable federal standards. However, the Sixth Circuit reversed the summary judgment for the Michigan common-law fiduciary duty and fraud claims, finding the district court had applied an incorrect legal standard and that genuine disputes of material fact remained. The case was remanded for further proceedings on the fiduciary duty and fraud counts. View "Boyd v. Northern Biomedical Research Inc." on Justia Law

Dustin Booth, who had a history of stable employment and no prior mental health issues, began exhibiting signs of severe mental illness in early 2022 after changes in his substance use. His erratic behavior escalated over several days, culminating in a violent incident at home and a lengthy standoff with police after he barricaded himself inside his house. Booth’s wife repeatedly sought police intervention, expressing concerns that he was a danger to himself and others, and noted his access to firearms. After attempts to calm Booth and persuade him to leave his house, he eventually left with a friend, taking a gun with him. Police stopped the vehicle, leading to a confrontation in which Booth brandished the firearm and was fatally shot by officers.The United States District Court for the Southern District of Ohio granted summary judgment to the defendants on all federal claims. The district court held that the proposed accommodation under the Americans with Disabilities Act (ADA)—that officers should have used de-escalation techniques—was unreasonable due to the safety risks posed by Booth. The court further found that the officers’ actions during the traffic stop and subsequent use of force, including the deployment of a police dog and takedown maneuver, were reasonable under the Fourth Amendment. It also declined to exercise supplemental jurisdiction over the state-law claims.Upon review by the United States Court of Appeals for the Sixth Circuit, the appellate court affirmed the district court’s decision. The Sixth Circuit held that, as a matter of law, the ADA did not require officers to accommodate Booth’s disability in the face of objective safety risks. Additionally, the court found the officers had probable cause for a mental-health seizure and acted reasonably under the Fourth Amendment in both the stop and use of force. The judgment in favor of the defendants was affirmed. View "Booth v. Lazzara" on Justia Law