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

In this case, DEA agents, acting on an anonymous tip, conducted a four-month investigation into Robert Cortez Burrell's alleged drug trafficking activities. They surveilled Burrell, observed suspicious behavior consistent with drug transactions, and corroborated the tip with additional evidence, including Burrell's criminal history and interactions with known drug dealers. Based on this information, they obtained and executed search warrants for four residences associated with Burrell, recovering significant quantities of illegal narcotics, firearms, and drug-manufacturing equipment. Burrell was subsequently convicted by a jury of multiple drug-related offenses and being a felon in possession of firearms and ammunition, resulting in a 180-month prison sentence.The United States District Court for the Eastern District of Michigan denied Burrell's motion to suppress the evidence obtained from the searches, as well as his motion to dismiss the firearms and ammunition charges on Second Amendment grounds. The court found that the search warrants were supported by probable cause and that Burrell's motion to dismiss was untimely. Additionally, the court admitted testimony that Burrell argued violated the Confrontation Clause and the Federal Rules of Evidence.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's judgment. The appellate court held that the search warrants were supported by probable cause, as the DEA agents had sufficiently corroborated the anonymous tip through extensive surveillance and other investigative methods. The court also found that the district court did not abuse its discretion in denying Burrell's motion to dismiss as untimely and that Burrell's constitutional challenges to the firearms and ammunition charges failed under the plain-error standard. Furthermore, the court ruled that the admission of the contested testimony did not violate the Confrontation Clause or the Federal Rules of Evidence, as the statements were not offered for their truth but to explain the DEA's actions. View "United States v. Burrell" on Justia Law

The case involves Joseph Betro, Mohammed Zahoor, Tariq Omar, and Spilios Pappas, who conspired to defraud Medicare by administering medically unnecessary back injections and bribing patients with opioid prescriptions. They fraudulently billed these injections as “facet injections” to receive higher reimbursements. Additionally, they ordered unnecessary urine drug tests and referred patients to ancillary services in exchange for kickbacks. Despite patient complaints about the ineffectiveness and pain of the injections, the defendants continued their fraudulent practices.A jury in the United States District Court for the Eastern District of Michigan convicted the defendants of conspiracy to commit healthcare fraud and wire fraud under 18 U.S.C. § 1349 and healthcare fraud under 18 U.S.C. § 1347. The defendants filed motions for a new trial, which the district court denied. They then appealed their convictions and sentences, raising various challenges related to the prosecution, evidence admission, jury instructions, and sentencing calculations.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s judgments. The court found sufficient evidence to support the jury’s findings that the defendants knowingly participated in the fraudulent scheme. The court also held that the district court did not abuse its discretion in denying the motions for a new trial, admitting evidence, or instructing the jury. The sentences imposed were deemed procedurally and substantively reasonable, with the court noting that the district court had appropriately calculated the loss amounts and applied relevant sentencing enhancements. View "United States v. Betro" on Justia Law

The case involves an unfair labor practice dispute between Rieth-Riley Construction Co., a highway construction contractor in Michigan, and Local 324, International Union of Operating Engineers, AFL-CIO. The dispute centers on subcontracting and employee wages. The last collective-bargaining agreement expired on May 31, 2018, and despite multiple bargaining sessions, no successor agreement has been reached. The Union went on strike on July 31, 2019, and picketing incidents ensued, including an altercation where a striking union member, Michael Feighner, assaulted a truck driver, Karl Grinstern.The National Labor Relations Board (NLRB) General Counsel issued complaints against both parties: against the Union for picketing misconduct and against Rieth-Riley for failing to provide requested subcontracting and employee information. An Administrative Law Judge (ALJ) found that Rieth-Riley violated the National Labor Relations Act (NLRA) by not providing the requested information and that the Union violated the NLRA when Feighner assaulted Grinstern. The ALJ ordered Rieth-Riley to provide the requested information and the Union to cease and desist from such misconduct. The NLRB affirmed the ALJ’s decision with a slight modification.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that President Biden lawfully removed the NLRB General Counsel, and the General Counsel had unreviewable prosecutorial discretion. The court found substantial evidence supporting the ALJ’s conclusions that the requested information was relevant to the Union’s bargaining responsibilities and that Rieth-Riley’s refusal to provide it violated the NLRA. The court also upheld the finding that the Union’s assault on Grinstern was an unfair labor practice. The court denied Rieth-Riley’s petition for review and granted the NLRB’s cross-application for enforcement of its order in full. View "Rieth-Riley Construction Co. v. National Labor Relations Board" on Justia Law

In 1974, Regina Andrews was found murdered, and her husband, Isaiah Andrews, was convicted of the crime based on circumstantial evidence. After nearly 46 years in prison, Isaiah was granted a new trial in 2020 when it was discovered that exculpatory evidence had been withheld. A new jury acquitted him in 2021. Subsequently, Isaiah filed a § 1983 lawsuit against the City of Cleveland and several officers, alleging violations of his Fourteenth Amendment rights due to the suppression of exculpatory evidence.The United States District Court for the Northern District of Ohio dismissed Isaiah's claims against the estates of the deceased officers, William Hubbard and Ernest Rowell, citing that the claims were filed too late under Ohio law. The court also granted summary judgment in favor of the City of Cleveland, concluding that the police did not withhold exculpatory evidence from the prosecution.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's dismissal of claims against the estates of Hubbard and Rowell, agreeing that Isaiah's claims were untimely under Ohio law. However, the court reversed the summary judgment in favor of the City of Cleveland. The appellate court found that there was a material dispute of fact regarding whether the police had withheld a crucial page of a police report linking another suspect to the crime scene. The court remanded the case to the district court to determine whether a City policy caused the alleged Brady violation. View "Estate of Andrews v. City of Cleveland" on Justia Law

Joseph Fortin applied for disability insurance benefits, but his claim was denied by an Administrative Law Judge (ALJ) from the Social Security Administration (SSA). Fortin argued that the ALJ who denied his claim was improperly appointed because the then-Acting Commissioner of the SSA, Nancy Berryhill, lacked the authority to ratify the ALJ's appointment. Fortin did not challenge the merits of the ALJ's decision but focused on the validity of the ALJ's appointment.The United States District Court for the Eastern District of Michigan granted summary judgment in favor of the Commissioner of Social Security, rejecting Fortin's arguments. The court held that Berryhill's ratification of the ALJ's appointment was valid and that the ALJ did not err in denying Fortin's application for benefits.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The court held that Berryhill, as Acting Commissioner, had the authority to ratify the appointments of SSA ALJs in response to the Supreme Court's decision in Lucia v. Securities and Exchange Commission, which required ALJs to be appointed in accordance with the Appointments Clause. The court also concluded that Berryhill's actions were valid under the Federal Vacancies Reform Act and that she did not need to be reappointed by the sitting President to serve as Acting Commissioner. The court found that Berryhill's ratification of the ALJ's appointment was both constitutionally and statutorily valid, and therefore, Fortin was not entitled to a new hearing before a different ALJ. View "Fortin v. Commissioner of Social Security" on Justia Law

Gregory D. Ralston was found guilty by a jury of distributing and possessing with intent to distribute a fentanyl-containing substance. He was acquitted of causing serious bodily injury by distributing the fentanyl. Ralston challenged the district court’s denial of his motion to suppress evidence without an evidentiary hearing, the limitation of his cross-examination of two government witnesses, and the reasonableness of his 180-month sentence.The United States District Court for the Northern District of Ohio initially scheduled an evidentiary hearing on Ralston’s motion to suppress but later denied the motion without holding the hearing. Ralston proceeded to trial, where the court limited his cross-examination of witnesses regarding potential bias and prior convictions. The jury convicted Ralston on the drug charges but acquitted him of the enhancement for causing serious bodily injury. The district court then imposed a 180-month sentence, significantly above the Guidelines range of 27 to 33 months, citing Ralston’s prior conviction and the seriousness of the current offense.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found no abuse of discretion in the district court’s decision to deny the motion to suppress without an evidentiary hearing, as the issues raised were legal rather than factual. The appellate court also upheld the limitation on cross-examination, noting that Ralston had the opportunity to question the witnesses directly about potential bias. The court found the sentence procedurally reasonable, as the district court adequately explained the upward variance and considered the § 3553(a) factors. The court also found the sentence substantively reasonable, given the district court’s rationale and the evidence supporting the findings.The Sixth Circuit affirmed the district court’s judgment but remanded the case for consideration of a potential sentence reduction under 18 U.S.C. § 3582(c) due to an intervening amendment in the Sentencing Guidelines. View "United States v. Ralston" on Justia Law

In 2022, Condarius Tripplet pleaded guilty to possession with intent to distribute controlled substances. The district court sentenced him to 188 months in prison, applying a drug-premises enhancement. This enhancement adds two levels to the base offense level when a defendant maintains a premises for drug manufacturing or distribution. Tripplet acknowledged maintaining an apartment but disputed that its primary use was for drug distribution, noting he lived there with his girlfriend and her two children.The United States District Court for the Western District of Michigan found that Tripplet had significant quantities of illegal drugs, cash, a firearm, and drug manufacturing tools in the apartment. The court also noted that he regularly distributed drugs from this residence. Based on these findings, the court applied the drug-premises enhancement, resulting in a higher offense level and a longer sentence. Tripplet appealed the application of this enhancement.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the drug-premises enhancement was correctly applied. The court noted that the enhancement does not require drug operations to be the sole purpose of the premises, only that it be one of the primary uses. Given the substantial quantities of drugs, cash, and drug-related tools found in the apartment, along with evidence of regular drug transactions, the court affirmed the district court's decision to apply the enhancement. The court concluded that the totality of the evidence supported the inference that Tripplet maintained the apartment for drug trafficking purposes, justifying the enhancement and the resulting sentence. View "United States v. Tripplet" on Justia Law

The plaintiffs, who regularly engage in cryptocurrency transactions, challenged amendments to 26 U.S.C. § 6050I, which now require reporting certain cryptocurrency transactions to the federal government. They argued that the law violates their constitutional rights under the Fourth, First, and Fifth Amendments, and exceeds Congress's enumerated powers. The plaintiffs claimed that the law's requirements would force them to disclose private information, incur compliance costs, and potentially expose them to criminal penalties.The United States District Court for the Eastern District of Kentucky dismissed the case, finding that it lacked jurisdiction to consider the merits of the plaintiffs' claims. The court ruled that the claims were either not ripe for adjudication or that the plaintiffs lacked standing. Specifically, the court found that the Fourth Amendment claim was not ripe because the law was not yet effective and the Department of Treasury was still developing rules. The First Amendment claim was dismissed for lack of standing, as the court deemed the plaintiffs' injuries too speculative. The court also found the Fifth Amendment vagueness claim unripe due to pending regulatory action, and the enumerated-powers claim unripe for similar reasons. The Fifth Amendment self-incrimination claim was dismissed as not ripe because the plaintiffs had not yet asserted the privilege.The United States Court of Appeals for the Sixth Circuit reviewed the case and found that the district court erred in dismissing the enumerated-powers, Fourth Amendment, and First Amendment claims. The appellate court held that these claims were ripe for review and that the plaintiffs had standing. The court noted that the plaintiffs, as direct objects of the law, would indeed be subject to the reporting requirements and incur compliance costs, thus suffering an injury in fact. The court affirmed the district court's dismissal of the Fifth Amendment vagueness and self-incrimination claims as not ripe. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Carman v. Yellen" on Justia Law

Marta Lidia Tista-Ruiz De Ajualip, a native of Guatemala, applied for asylum and withholding of removal for herself, her three children, and her grandson after entering the U.S. in 2016. They fled Guatemala due to threats from Marta’s son-in-law, Marvin, who had a history of domestic violence and gang affiliations. Despite credible testimony about the abuse and threats, an immigration judge (IJ) denied their asylum and withholding claims, citing outdated precedent that did not recognize domestic violence victims as a protected group under U.S. asylum laws.The Department of Homeland Security initiated removal proceedings in 2016. In 2019, the IJ denied Marta’s claims, relying on Matter of A-B-, which stated that domestic violence victims generally do not qualify for asylum. The IJ also applied the wrong legal standard for withholding of removal. In 2023, the Board of Immigration Appeals (Board) affirmed the IJ’s decision, despite acknowledging a significant change in precedent that overruled Matter of A-B-. The Board did not remand the case for further review and summarily affirmed the denial of withholding of removal.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found that the Board’s denial of asylum and withholding of removal was inconsistent with current precedent and immigration authority. The court held that the Board failed to consider the record as a whole and did not properly evaluate the evidence regarding the particular social group (PSG) and the Guatemalan government’s inability to protect Marta’s family. The court granted Marta’s petition for review, vacated the Board’s denial, and remanded the case for further proceedings consistent with the updated legal standards. View "Tista-Ruiz de Ajualip v. Garland" on Justia Law

In 2020, Eric Noble, a security guard at the Cincinnati and Hamilton County Public Library, shared an insensitive meme on his personal Facebook page during the Black Lives Matter (BLM) protests. The meme, which was visible only to his Facebook friends, was taken down within 24 hours after his mother advised him to do so. However, some of his colleagues at the Library saw the post and complained. Following an investigation, the Library terminated Noble's employment, citing a violation of its harassment policy and a loss of confidence in his ability to perform his duties impartially.The United States District Court for the Southern District of Ohio granted summary judgment in favor of the defendants, holding that the Library's actions did not violate Noble's First Amendment rights as a public employee. Noble appealed the decision, arguing that his termination was a result of exercising his right to free speech.The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court's decision. The appellate court held that Noble's Facebook post was protected speech under the First Amendment. The court found that Noble spoke on a matter of public concern and that his interest in expressing his views outweighed the Library's interest in maintaining workplace efficiency. The court noted that there was no evidence of public disruption or that Noble's post had a significant impact on Library operations. Consequently, the court remanded the case with instructions to grant summary judgment in favor of Noble on his First Amendment retaliation claim. View "Noble v. Cincinnati & Hamilton County Public Library" on Justia Law