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

The plaintiffs, a group of consumers, filed a lawsuit against General Motors (GM) and Robert Bosch LLC, alleging that the companies misled consumers about the emissions produced by certain Chevrolet Cruze vehicles. They claimed that the vehicles emitted higher levels of nitrogen oxides (NOx) than advertised and that the emissions control systems were manipulated to pass regulatory tests. The plaintiffs sought damages under various state fraud laws and the Racketeer Influenced and Corrupt Organizations (RICO) Act.The United States District Court for the Eastern District of Michigan initially dismissed some of the plaintiffs' claims, ruling that those based on the Environmental Protection Agency (EPA) standards were preempted by the Clean Air Act. The court allowed other claims to proceed, particularly those alleging that GM's advertising misled consumers about the vehicles' emissions. However, after the Sixth Circuit's decision in a similar case (In re Ford Motor Company F-150 and Ranger Truck Fuel Economy Marketing and Sales Practices Litigation), the district court revisited its decision and dismissed the remaining fraud claims, concluding they were preempted by federal law. The court also granted summary judgment to the defendants on the RICO claims.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the district court should determine whether the plaintiffs' remaining claims could proceed without relying on a disagreement with the EPA's determinations. The court remanded the case for the district court to decide if the claims were preempted under the analysis described. The court affirmed the dismissal of the RICO claims and the denial of the plaintiffs' post-judgment motion to vacate the judgment in part and approve a preliminary settlement agreement. The case was remanded for further proceedings consistent with the opinion. View "Counts v. General Motors, LLC" on Justia Law

Detectives from the Metropolitan Nashville Police Department observed Edwin Santiago arriving at a car dealership in a vehicle emitting a strong odor of marijuana. Santiago exited the car, and the detectives noticed a pistol on his waistband. Suspecting Santiago of possessing a firearm while under the influence of marijuana, the detectives detained him. During the detention, they discovered Santiago was a felon, leading to his arrest and subsequent indictment for being a felon in possession of a firearm.The United States District Court for the Middle District of Tennessee held a suppression hearing where the detectives and a witness testified about the marijuana odor. The court found the detectives' testimony credible and ruled that the odor provided reasonable suspicion for the stop and probable cause for the arrest. Consequently, the court denied Santiago's motion to suppress the evidence obtained during the arrest. Santiago, representing himself at trial, was convicted by a jury and sentenced to 56 months' imprisonment.The United States Court of Appeals for the Sixth Circuit reviewed Santiago's appeal, which challenged the denial of his motion to suppress and the substantive reasonableness of his sentence. The court affirmed the district court's decision, holding that the smell of marijuana provided reasonable suspicion for the stop and probable cause for the arrest. The court also found Santiago's within-Guidelines sentence to be substantively reasonable, considering his criminal history and the circumstances of the offense. Santiago's additional pro se claims were not considered, as he was represented by counsel on appeal. View "United States v. Santiago" on Justia Law

Tracey Shaw was indicted in January 2023 for knowingly possessing a firearm as a convicted felon, violating 18 U.S.C. § 922(g)(1). Shaw pleaded guilty and, as part of his plea agreement, waived his right to appeal any sentence within the applicable guideline range. At the sentencing hearing, the district court determined Shaw’s guideline range to be 87 to 108 months and sentenced him to 92 months in prison and three years of supervised release. The court did not make a recommendation about substance-abuse treatment during incarceration but left it to the Bureau of Prisons. For supervised release, the court stated that Shaw might be required to participate in substance-abuse treatment if directed by the probation office.The United States District Court for the Western District of Tennessee issued a written judgment stating that Shaw must participate in substance-abuse testing and treatment as directed by the probation officer. Shaw appealed, arguing that the written judgment conflicted with the oral pronouncement, which he interpreted as delegating the decision to the probation office.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Shaw’s appeal was not barred by his plea agreement’s appeal waiver because he was challenging the written judgment, not the sentence itself. The court found that the oral sentence was ambiguous regarding the substance-abuse treatment condition. The written judgment clarified this ambiguity by specifying that Shaw must participate in substance-abuse treatment as directed by the probation officer. The court concluded that this language met constitutional requirements by mandating treatment while allowing the probation officer to handle the details. Therefore, the Sixth Circuit affirmed the district court’s written judgment. View "United States v. Shaw" on Justia Law

Jaime Norris applied for social security disability benefits and supplemental security income in October 2020, claiming disability due to various mental and physical disorders. The Social Security Administration denied his claim, leading Norris to request a hearing before an administrative law judge (ALJ). During the hearing, both Norris and a vocational expert testified. The ALJ concluded that Norris was not disabled under the Social Security Act, determining that he could adjust to other jobs existing in significant numbers in the national economy. Norris appealed to the Appeals Council, which denied his request for review, finalizing the ALJ's decision.Norris then sought judicial review in the United States District Court for the Northern District of Ohio. The district court affirmed the ALJ's decision, finding that substantial evidence supported the ALJ's conclusion. Norris subsequently appealed to the United States Court of Appeals for the Sixth Circuit.The Sixth Circuit reviewed whether the ALJ applied the correct legal standards and whether the findings were supported by substantial evidence. The court affirmed the ALJ's decision, holding that the vocational expert's testimony about the number of jobs available in the national economy constituted substantial evidence. The court rejected Norris's arguments that the ALJ erred in determining the number of significant jobs and that the district court improperly shifted the burden of proof. The court concluded that the ALJ's findings were reasonably drawn from the record and supported by substantial evidence, even if the evidence could support a contrary decision. View "Norris v. Commissioner of Social Security" on Justia Law

A high school student, Eszter Pryor, trained and competed with the Ohio State Diving Club at The Ohio State University (OSU). In the summer of 2014, when she was sixteen, her diving coach, William Bohonyi, sexually abused her. Pryor alleged that OSU was aware of the abuse by August 2014, as they fired Bohonyi following an internal investigation. Pryor filed a Title IX lawsuit against OSU in January 2022, claiming the university was deliberately indifferent to a sexually hostile culture and her abuse.The United States District Court for the Southern District of Ohio dismissed Pryor's claim, ruling it was time-barred by the statute of limitations. OSU had argued that the applicable statute of limitations was two years, as per Ohio Revised Code § 2305.10(A), and the district court agreed, granting summary judgment in favor of OSU based on the expiration of the limitations period.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's decision, holding that the correct statute of limitations for Title IX claims in Ohio is the two-year period for personal injury actions under Ohio Revised Code § 2305.10(A). The court rejected Pryor's argument that a twelve-year limitations period for child sex-abuse claims under Ohio Revised Code § 2305.111(C) should apply. The court emphasized the importance of uniformity and predictability in applying the statute of limitations and noted that Pryor's claim accrued when she turned eighteen in July 2015, giving her until July 2017 to file her lawsuit. Since she filed in January 2022, her claim was indeed time-barred. View "Pryor v. The Ohio State University" on Justia Law

Fire-Dex, a manufacturer of personal protective equipment for firefighters, faced lawsuits from firefighters and their spouses alleging exposure to carcinogens from Fire-Dex's products. These lawsuits were consolidated in multidistrict litigation in South Carolina. Fire-Dex had general commercial liability insurance policies with Admiral Insurance Company and requested Admiral to defend and indemnify it against the lawsuits. Admiral refused, leading to a declaratory judgment action in federal court in Ohio, where the district court declined to exercise jurisdiction.The United States District Court for the Northern District of Ohio initially had diversity jurisdiction over Admiral's declaratory judgment action but chose to abstain from exercising it, a decision affirmed by the Sixth Circuit. Subsequently, Fire-Dex filed a lawsuit in Ohio state court seeking a declaration that Admiral must defend and indemnify it, along with compensatory and punitive damages for breach of contract and bad faith. Admiral removed the case to federal court and filed counterclaims for declaratory judgment. Fire-Dex moved to remand the case to state court.The United States Court of Appeals for the Sixth Circuit reviewed the district court's decision to remand the declaratory claims and stay the damages claims. The Sixth Circuit held that the district court erred in abstaining from the declaratory claims under Thibodaux abstention, as the case did not involve unsettled questions of state law intimately involved with state sovereignty. The court also found that abstaining from the declaratory claims was an abuse of discretion because the declaratory and damages claims were closely intertwined, and no traditional abstention doctrine applied to the damages claims. The Sixth Circuit vacated the district court's order and remanded for further proceedings. View "Fire-Dex, LLC v. Admiral Insurance Co." on Justia Law

Leonel Hinojosa was originally sentenced to 240 months in prison for shooting a man during a robbery. The sentence was vacated by the United States Court of Appeals for the Sixth Circuit because it was unclear whether the district court properly used one of Hinojosa’s prior convictions to calculate his guidelines range. The court could only rely on this prior conviction if it resulted in Hinojosa’s incarceration during any time in the 15 years before he committed his current offenses.On remand, the government presented additional evidence about Hinojosa’s criminal history. The district court found that the prior conviction met the guideline’s standards for inclusion in the criminal history score. This resulted in a guidelines range of 120 to 150 months for his robbery and felon-in-possession offenses, plus a consecutive 120-month minimum sentence for discharging a firearm during a crime of violence. The district court reimposed the same 240-month sentence.The United States Court of Appeals for the Sixth Circuit reviewed the case and held that the “but for” causal connection between the prior conviction and the extra incarceration satisfied the guideline’s “resulted in” language. The court also found that the district court reasonably sentenced Hinojosa to 240 months due to his history of violence. The Sixth Circuit affirmed the sentence, rejecting Hinojosa’s procedural and substantive challenges. The court concluded that the district court properly calculated the guidelines range and reasonably balanced the sentencing factors, including the seriousness of the offense and Hinojosa’s history of violent behavior. View "United States v. Hinojosa" on Justia Law

In this case, Whitney Hodges, representing the estate of her late daughter Honestie Hodges, alleges that on December 6, 2017, Grand Rapids Police Department officers detained Honestie, an eleven-year-old African American girl, at gunpoint, handcuffed her, and placed her in a police car. The officers were searching for a stabbing suspect who did not match Honestie’s description. Honestie was not armed, did not pose a threat, and did not attempt to flee. The complaint asserts that the officers lacked probable cause or reasonable suspicion to detain Honestie and used excessive force in doing so.The United States District Court for the Western District of Michigan partially denied the officers' motion to dismiss on qualified-immunity grounds. The district court found that the complaint plausibly alleged violations of Honestie’s Fourth Amendment rights, including unreasonable search and seizure, false imprisonment, and excessive force. The court declined to consider video evidence and police reports provided by the officers, determining that these materials did not blatantly contradict the complaint’s allegations and were subject to reasonable dispute.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision. The court affirmed the district court’s order, agreeing that the complaint plausibly alleged that the officers violated Honestie’s clearly established rights. The Sixth Circuit held that the officers’ actions, as alleged, lacked reasonable suspicion or probable cause and involved excessive force. The court dismissed the officers' appeal to the extent it sought to resolve disputed factual issues, emphasizing that such issues should be addressed after discovery. View "Hodges v. City of Grand Rapids, Mich." on Justia Law

Belinda Fitzpatrick owns two adjacent homes in Lansing, Michigan. In September 2021, Ingham County Animal Control received a complaint about Fitzpatrick harboring up to 30 chickens in unsanitary conditions. Officer Kyle Hanney from Animal Control investigated and observed severe unsanitary conditions, including a strong odor of ammonia and chicken feces throughout the house. Hanney obtained a warrant to search both homes for evidence of animal neglect and cruelty. He invited Matthew Simon, a local housing-code official, to join the search. Simon concluded that both homes were unfit for human occupancy and placed red tags on them, prohibiting entry until cleaned.Fitzpatrick sued Officer Hanney, Simon, and the City of Lansing, alleging violations of her Fourth and Fourteenth Amendment rights. Simon moved to dismiss based on qualified immunity. The United States District Court for the Western District of Michigan denied Simon’s motion, concluding that Simon had plausibly violated Fitzpatrick’s clearly established constitutional rights. Simon then filed an interlocutory appeal.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Simon was entitled to qualified immunity on Fitzpatrick’s Fourth Amendment claims because it was not clearly established that Simon needed a separate warrant for housing-code violations when he was searching for the same conditions as authorized by Hanney’s warrant. The court also held that Simon was entitled to qualified immunity on Fitzpatrick’s Fourteenth Amendment claims, as the unsanitary conditions in her homes constituted exigent circumstances justifying immediate eviction without prior notice. The court reversed the district court’s decision and remanded with instructions to dismiss the claims against Simon. View "Fitzpatrick v. Hanney" on Justia Law

Michael Molson was arrested by Kent County officers during a search warrant execution for crack cocaine. Molson attempted to swallow a bag of drugs, which officers forced him to expel. Despite being asked multiple times, Molson denied swallowing any more drugs. He showed no symptoms of drug ingestion and was taken to jail, where he underwent two medical evaluations and continued to deny swallowing drugs. The next day, Molson was found unresponsive and later died from acute cocaine toxicity, with an autopsy revealing a bag of cocaine in his stomach.The United States District Court for the Western District of Michigan denied the officers' motions for summary judgment based on qualified immunity, finding that there was a genuine issue of material fact regarding whether the officers were deliberately indifferent to Molson's serious medical needs. The court concluded that Molson's need for medical attention was clearly established at the time of his arrest.The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court's denial of qualified immunity. The Sixth Circuit held that Molson's medical need was not sufficiently serious or obvious to the officers, as he showed no symptoms and repeatedly denied swallowing drugs. The court found that the officers acted reasonably by taking Molson to jail, where he received medical evaluations that did not indicate any immediate health risk. Consequently, the officers were entitled to qualified immunity, and the case was remanded for entry of judgment in favor of the defendants. View "Hodges v. Abram" on Justia Law