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

KCP, the plaintiff, had hoped to act as a middleman in a potential distribution deal for a novel cleaning product and targeted Henkel, a large consumer products company as a potential distributor. KCP and Henkel entered into a non-disclosure agreement (NDA) to aid in the negotiations of a distribution deal. KCP provided Henkel with confidential information about the product. Following a year of exchanging information and engaging in negotiations, the NDA lapsed, and no deal was consummated. KCP asserts that Henkel’s parent company, Henkel KGaA, used confidential information it acquired through the NDA to develop the product on its own and also interfered with the potential distribution deal. The district court granted summary judgment in favor of KGaA. As to a breach of contract claim, the court found that KGaA was not a party to the NDA and could not be liable for its breach. As to a tortious interference claim, the court found that KGaA is the parent company of Henkel, so the parent-subsidiary privilege immunizes it from a tortious interference claim involving its subsidiary; the court found that the narrow “improper motive” exception to that privilege did not apply. The Sixth Circuit affirmed summary judgment in favor of KGaA, KCP has not presented sufficient evidence of any improper motive or means to pierce the parent-subsidiary privilege. View "Knight Capital Partners Corp. v. Henkel AG & Co." on Justia Law

A jury determined that four Muslim Michigan inmates collectively suffered $900 ($150 for each Ramadan the prison officials disrupted) in damages when prison officials did not provide them with adequate meals during Ramadan to accommodate their fasting. The Sixth Circuit affirmed, rejecting the inmates’ claim that the jury ignored the spiritual harms they suffered. The jury found that the inmates suffered spiritual injuries but, unlike economic injuries, spiritual injuries are hard to quantify. The jury heard the inmates’ testimony and saw their medical records, then weighed all the evidence and concluded that each inmate suffered $150 worth of harm for each Ramadan the prison officials disrupted. The district court did not downplay the inmates’ spiritual injuries nor did it require that the inmates submit medical records to substantiate those injuries; the court merely noted that objective evidence (like medical records) might have helped the jury reach a higher damages calculation. Without such concrete, objective evidence, the district court had no room to disagree with the value that the jury assigned to the inmates’ spiritual damages. View "Heard v. Finco" on Justia Law

In operating his companies, Rankin failed to remit to the IRS employees’ withholding taxes and inaccurately reported his own earnings as royalties (26 U.S.C. 7202, 7206, 7212). Rankin interfered with and delayed IRS investigations, filing amended returns containing false information and falsely claiming that fire had destroyed his records. Rankin bragged about his efforts to beat the IRS at its own game. He was convicted of 17 tax-related counts, sentenced to 60 months in prison, and required to pay restitution. The Sixth Circuit affirmed his conviction and sentence, modifying his judgment to reflect that he need not pay restitution until his term of supervised release commences. The court rejected a challenge to Count 17, which alleged that during the relevant time, Rankin had “willfully misl[ed] agents of the IRS by making false and misleading statements to those agents and by concealing information sought by those agents who he well knew were attempting to ascertain income, expenses and taxes for [Rankin] and his various business entities and interests.” The indictment contains the elements of the charged offense and does more than merely track the language of the statute. It alleges a nexus between Rankin’s misleading conduct and the agents’ attempts “to ascertain [his] income, expenses and taxes,” an investigation that went beyond the “routine, day-to-day work carried out in the ordinary course by the IRS.” The indictment reflects that the investigation was pending and that Rankin was aware of it. View "United States v. Rankin" on Justia Law

Knox-Bender suffered injuries from a car accident. She sought medical treatment at Methodist Healthcare. Methodist billed her $8,000 for the treatment. Payments to Methodist were made on Knox-Bender’s behalf by her employer-sponsored healthcare plan, her automobile insurance plan, and her husband’s healthcare plan. Knox-Bender says that the insurance plans had already agreed with Methodist on the price of her care. She claims that, despite this agreement, Methodist overcharged her and that this was common practice for Methodist. She and a putative class of other patients, sued in Tennessee state court. During discovery, Methodist learned that Knox-Bender’s husband’s healthcare plan was an ERISA plan, 29 U.S.C.1001(b) that covered $100 of her $8,000 bill. Methodist removed the case to federal court claiming complete preemption under ERISA. The district court denied Knox-Bender’s motion to remand and entered judgment in favor of Methodist. The Sixth Circuit reversed. The complete preemption of state law claims under ERISA is “a narrow exception to the well-pleaded complaint rule.” Methodist has not met its burden to show that Knox-Bender’s complaint fits within that narrow exception. Since Knox-Bender has not alleged a denial of benefits under her husband’s ERISA plan, ERISA does not completely preempt her claim. Even if Methodist had shown that Knox-Bender alleged a denial of benefits, it would also have show that Knox-Bender complained only of duties breached under ERISA, not any independent legal duty. View "K.B. v. Methodist Healthcare - Memphis Hospitals" on Justia Law

In 2009, Brumbach was arrested for pointing a gun at a man and was charged as a felon in possession of a firearm, 18 U.S.C. 922(g)(1). He pleaded guilty and agreed that because he had at least three previous convictions for violent felonies and possessed a gun, he qualified as an armed career criminal under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e)(1). The PSR explained that Brumbach had 12 prior convictions for aggravated burglary under Tennessee law. The court imposed the mandatory minimum sentence of 180 months’ imprisonment. After the Supreme Court struck down ACCA's residual clause in "Johnson" (2015), Brumbach filed a 28 U.S.C. 2255 motion to vacate or correct his sentence, arguing that his convictions for aggravated burglary could no longer count as violent felonies under the ACCA. In another case, Stitt, the Sixth Circuit held that a conviction under Tennessee’s aggravated burglary statute did not constitute a violent felony under the ACCA. The district court granted Brumbach’s habeas petition and imposed a new sentence of time served, which equated to 105 months in prison. In December 2018, the Supreme Court reversed Stitt, finding that the language of the Tennessee statute falls within the scope of generic burglary’s definition. The Sixth Circuit then reversed the grant of habeas relief and reinstated Brumbach’s original sentence. View "United States v. Brumbach" on Justia Law

After four years of perpetual delays, Prime obtained a sixth trial date to vindicate its claims that Larson and her late husband had cheated it out of hundreds of thousands of dollars. The scam involved fraudulent agreements to finance insurance premiums. The day before trial, after red-flag warnings that the district court would entertain no further extensions, Larson moved for a continuance. Her last-minute motion came with an unsigned doctor’s note, the letterhead of which did not match its signature block. Larson did not show up for trial the next day. The district court found that her motion fell “within a pattern of delaying tactics,” including exaggerated medical excuses, disputes with her attorneys, and abuse of the bankruptcy process. The court denied Larson’s motion, struck her answer, granted Prime a default judgment, and awarded it $964,530.48. The Sixth Circuit affirmed, noting that due process does not require that the defendant in every civil case actually have a hearing on the merits and it was Larson who, through her conduct during this case, deprived herself of her “day in court.” View "Prime Rate Premium Financial Corp., Inc. v. Larson" on Justia Law

Lopez was charged with possessing a firearm as an alien “illegally or unlawfully in the United States,” 18 U.S.C. 922(g)(5)(A). The district court thought that section 922(g)(5)(A) as applied to Lopez was unconstitutionally vague in light of administrative guidance from the Department of Homeland Security, giving “prosecutorial discretion” as to certain (DACA) aliens who had entered this country without authorization as children. Lopez, along with his family, entered the U.S. without authorization when he was four years old and had obtained deferred action under DACA in 2017. Lopez was arrested for DUI and officers found a 9mm pistol and a 12-gauge shotgun in his vehicle. The Sixth Circuit reversed, rejecting his argument that once he was granted relief under DACA, Lopez was “lawfully present” in the United States. The Secretary’s grant of deferred action under DACA, therefore, did not, and could not, change Lopez’s status as an alien “illegally or unlawfully in the United States” for purposes of section 922(g)(5)(A). That relief represented only the Secretary’s decision temporarily not to prosecute him for that status. View "United States v. Lopez" on Justia Law

The Sixth Circuit affirmed the district court's denial of federal habeas relief to petitioner, who argued that he was entitled to a resentencing hearing, essentially because the guidelines were considered mandatory at the time of his hearing, even though not at the time that his sentence became final. The court held that declining to conduct such a new hearing in this case was not contrary to, nor did it involve an unreasonable application of, clearly established federal law, as determined by the Supreme Court of the United States. Furthermore, there was no constitutional error in the substance of the sentencing court's decision. View "Magnum Reign v. Gidley" on Justia Law

Erickson is the only unionized crane rental company in western Michigan. In 2015, the Local insisted that only members of the Local, not the company’s other unions, perform crane-operator work. The Local threatened to stop referring union members for regular temporary-labor needs and operators began seeking the Local’s help with payroll mix-ups rather than resolving them with Erickson. When the company told employees to “quit talking to Brandon because he’s going to get you in trouble,” the Local filed its first-ever grievance and unfair labor practice charge against Erickson, which eventually agreed to allow workers to seek the Local’s help. In 2016 Erickson discovered that the Local was approaching customers and encouraging them to hire through the Union’s referral process rather than contracting with the company. Erickson fired six members of the Local, 30% of the company’s operators. Erickson told the fired workers about the lack of work for small cranes; the layoffs “could be reversed,” if the workers would “get the Union to back off.” Erickson put six small cranes on the market. The Local filed unfair labor practice charges under 29 U.S.C. 158(a)(1); 158(a)(3). The Sixth Circuit affirmed an NLRB decision in favor of the Local. Even if Erickson exited the small-crane market for unrelated reasons, the need to terminate the operators did not necessarily follow. Erickson had a dramatic increase in temporary hires immediately after the discharges, often for tasks the fired workers performed. The company’s justification was pretextual. View "Erickson Trucking Service, Inc. v. National Labor Relations Board" on Justia Law

Brice, who had been purchasing heroin from defendant “[o]ff and on, for maybe a year and a half,” suffered from hypertension and a mild arrhythmia, tested positive for hepatitis C, and had been an opioid addict for years. In the drug sale in question, Brice purchased half a gram of what he believed to be heroin; it was actually fentanyl. Brice injected approximately a quarter of that half gram intravenously, had a stroke, and entered a coma. He survived with a subarachnoid hemorrhage, anoxic brain injury, liver failure, kidney failure, and heart failure. He recovered his day-to-day functioning after six months of intensive therapy. Defendant pleaded guilty to distributing fentanyl, 21 U.S.C. 841(a)(1). Defendant’s presentence report acknowledged that the district court could increase his sentence above the authorized range based upon USSG 5K2.2, which authorizes departures when “significant physical injury result[s]” from the crime. He objected because the victim had an “extensive and serious history of pre-existing medical conditions." Feola, a doctor of pharmacy, testified that it was possible Brice’s pre-existing health status affected his likelihood of experiencing a drug overdose and that it was possible that his condition could have increased the likelihood of overdose symptoms. The district court increased the defendant’s offense level by six points, which increased his Guidelines range to 51-63 months and sentenced him to 51 months. The Sixth Circuit affirmed, rejecting an argument that the district court failed to consider Brice’s “own choices.” View "United States v. Gillispie" on Justia Law