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

Arsen Sarkisov, an alien unlawfully present in the United States, was issued a final deportation order by an immigration judge. Over six years later, Sarkisov moved to reopen his case, but the immigration judge denied the motion. Sarkisov then appealed to the Board of Immigration Appeals, which also rejected his claim. In 2023, Sarkisov appealed the Board’s decision to the United States Court of Appeals for the Sixth Circuit and requested a stay of the deportation order during the appeal. The United States did not oppose the stay request, and the case was paused for almost a year while Sarkisov attempted to negotiate with the government. When negotiations failed, the litigation resumed, and Sarkisov's motion for a stay was considered.The immigration judge initially denied Sarkisov's motion to reopen his case, and the Board of Immigration Appeals upheld this decision. Sarkisov then appealed to the Sixth Circuit, seeking a stay of removal during the appeal process. The United States did not oppose the stay request, but the case was paused for nearly a year due to ongoing negotiations, which ultimately failed.The United States Court of Appeals for the Sixth Circuit reviewed Sarkisov's motion for a stay of removal. The court applied the traditional test for a stay, as outlined in Nken v. Holder, which requires the applicant to show a likelihood of success on the merits and irreparable harm without a stay. Sarkisov failed to address the merits of his appeal or provide reasons for irreparable harm, leading the court to deny his motion. The court emphasized that the burden of removal alone does not constitute irreparable injury and that the public interest favors prompt execution of removal orders. Consequently, the motion for a stay of removal was denied. View "Sarkisov v. Bondi" on Justia Law

In this case, Kelli Prather was convicted by a jury of bank fraud, wire fraud, aggravated identity theft, and making a false statement on a loan application. The charges stemmed from her fraudulent applications for Paycheck Protection Program (PPP) and Economic Injury Disaster Loan (EIDL) funds under the CARES Act, which were intended to provide financial relief during the COVID-19 pandemic. Prather submitted multiple fraudulent loan applications for non-operational businesses and used the identity of her mentally disabled nephew, D.P., to apply for additional loans.The United States District Court for the Southern District of Ohio sentenced Prather to 84 months in prison. Prather appealed her conviction and sentence, arguing insufficient evidence for her aggravated identity theft conviction, improper admission of certain testimonies, and errors in the jury instructions and sentencing enhancements.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found that there was ample evidence to support Prather's aggravated identity theft conviction, including testimony that D.P. did not understand the loan application process and that Prather used his identity without lawful authority. The court also determined that the testimonies of Special Agent Reier and Prather's ex-fiancé, Darrell Willis, did not constitute plain error and were cumulative of other evidence presented at trial.Regarding the jury instructions, the court held that the district court correctly informed the jury that Prather did not need to know the interstate nature of her acts to be convicted of wire fraud. Finally, the court upheld the district court's application of the vulnerable victim enhancement, finding that D.P. was indeed a victim of Prather's fraudulent scheme.The Sixth Circuit affirmed Prather's conviction and sentence, concluding that there were no reversible errors in the district court's proceedings. View "United States v. Prather" on Justia Law

A group of parents sued their local public school district and the State of Michigan, alleging that their children were denied essential special-education services. The parents claimed that the school district failed to provide promised services, such as full-time aides and speech therapy, and that the State failed to supervise the district adequately. The parents sought damages under the Americans with Disabilities Act (ADA) and the Rehabilitation Act, and injunctive relief under the Individuals with Disabilities Education Act (IDEA), ADA, and Rehabilitation Act.The United States District Court for the Eastern District of Michigan denied the State's motion to dismiss, holding that the ADA abrogated the State's sovereign immunity under the Fourteenth Amendment. The State then filed an interlocutory appeal.The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court's decision. The Sixth Circuit held that the parents failed to state a claim against the State under Title II of the ADA. The court explained that Title II allows lawsuits against a public entity for its own actions, not for the actions of another government entity. In this case, the school district, not the State, was responsible for the alleged denial of services. The court also noted that the State had already taken corrective actions against the school district and that the parents' claims of the State's failure to supervise were too conclusory to proceed. Therefore, the State was entitled to sovereign immunity, and the parents' ADA claim against the State was dismissed. View "Y.A. v. Hamtramck Public Schools" on Justia Law

Jermaine Kimbrough pleaded guilty in 2022 to four criminal offenses related to carjacking and firearms. At sentencing, the district court determined that Kimbrough had three prior violent felonies committed on different occasions, making him subject to an enhanced sentence under the Armed Career Criminal Act (ACCA). This enhancement increased his statutory penalty range for being a felon in possession of a firearm from a maximum of 10 years to a minimum of 15 years.The district court, following then-controlling Sixth Circuit precedent, decided that Kimbrough's two 2016 aggravated burglary offenses occurred on different occasions, thus applying the ACCA enhancement. Kimbrough objected, arguing that a jury should make this determination. The district court overruled his objection and sentenced him to 148 months for Counts One, Two, and Four, to be served concurrently, and 84 months for Count Three, to be served consecutively.The United States Court of Appeals for the Sixth Circuit reviewed the case. The Supreme Court's decision in Erlinger v. United States established that it is an error for a judge, rather than a jury, to determine whether prior offenses occurred on different occasions for ACCA purposes. The Sixth Circuit found that this error was not harmless in Kimbrough's case. The court noted that a reasonable jury could find that Kimbrough's two 2016 burglaries were part of a single criminal event, given their close proximity and similar nature.The Sixth Circuit vacated Kimbrough's sentence on Counts One, Two, and Four and remanded for further proceedings consistent with its opinion. The court also noted that the sentence for Count One exceeded the statutory maximum and must be corrected on remand. Additionally, the court left Kimbrough's Double Jeopardy argument for the district court to address if the government seeks an ACCA-enhanced sentence on remand. View "United States v. Kimbrough" on Justia Law

Tiara Yachts, Inc. hired Blue Cross Blue Shield of Michigan (BCBSM) to administer its self-funded healthcare benefits plan. Tiara Yachts alleges that BCBSM systematically overpaid certain claims, thereby squandering plan assets, and then profited from these overpayments through a program that clawed back the overpayments and kept a portion of the recovered funds. Tiara Yachts sued BCBSM under the Employee Retirement Income Security Act (ERISA), claiming breaches of fiduciary duty and self-dealing.The United States District Court for the Western District of Michigan granted BCBSM's motion to dismiss, holding that Tiara Yachts had not plausibly alleged that BCBSM acted as an ERISA fiduciary. The court also held that ERISA’s remedial provisions could not provide the relief Tiara Yachts sought.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 Tiara Yachts plausibly alleged that BCBSM acted as an ERISA fiduciary by exercising control over plan assets when it overpaid claims and by exercising discretion over its compensation through the Shared Savings Program (SSP). The court found that BCBSM’s control over the claims-processing apparatus and its ability to profit from overpayments through the SSP indicated fiduciary status.The Sixth Circuit also held that Tiara Yachts could seek recovery on behalf of the plan under 29 U.S.C. § 1132(a)(2) and could seek equitable relief, such as restitution and disgorgement, under 29 U.S.C. § 1132(a)(3). The court concluded that Tiara Yachts’ claims for restitution and disgorgement were equitable in nature and that the complaint plausibly alleged that BCBSM retained specific funds from the SSP, satisfying the traceability requirement for equitable relief. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Tiara Yachts, Inc. v. Blue Cross Blue Shield of Michigan" on Justia Law

Federal and local law enforcement officers in Toledo, Ohio, uncovered a large-scale drug distribution scheme involving cocaine, cocaine base, and fentanyl. Christopher Simpson, Marquise Figures, and Antuan Wynn were charged with various federal crimes related to this scheme. They were tried together, and the jury found them guilty on all charges except one against Wynn.The United States District Court for the Northern District of Ohio sentenced Simpson to 300 months, Wynn to 224 months, and Figures to 70 months. All three defendants appealed their convictions and sentences.The United States Court of Appeals for the Sixth Circuit reviewed the case. Simpson challenged the seizure and search of a vehicle, arguing Fourth Amendment violations, but the court found the actions lawful. Simpson also contested his sentence, particularly the drug quantity calculation and an obstruction of justice enhancement, but the court upheld the district court's findings.Figures argued that evidence from a traffic stop was improperly admitted and that there was insufficient evidence for his conspiracy conviction. The court found the evidence intrinsic to the charged conspiracy and sufficient to support the conviction. Figures also challenged his sentence, but the court found no error in the drug quantity calculation or the denial of a minor participant reduction.Wynn contended there was a variance between the indictment and the trial evidence, but the court found no prejudicial variance. He also challenged a jury instruction and the admission of pre-conspiracy evidence, but the court found no error. Wynn's sentence challenges, including the drug quantity calculation and enhancements for firearm possession and maintaining a drug premises, were also rejected.The Sixth Circuit affirmed the judgments of the district court for all three defendants. View "United States v. Simpson" on Justia Law

Freddie Knipp, Jr. was convicted of two counts of distributing methamphetamine and one count of knowingly selling a firearm to a felon. The convictions stemmed from controlled drug buys and a firearm purchase facilitated by law enforcement, with Knipp selling methamphetamine to Larry Eldridge and purchasing a firearm for him, knowing Eldridge was a felon. Eldridge cooperated with law enforcement, leading to Knipp's arrest and subsequent trial.The United States District Court for the Eastern District of Kentucky denied Knipp's motion to dismiss the firearm charge, which he argued violated the Second Amendment. Knipp was found guilty on all counts by a jury and sentenced to 138 months in prison for the drug charges and 120 months for the firearm charge, to be served concurrently.The United States Court of Appeals for the Sixth Circuit reviewed the case. Knipp challenged the constitutionality of 18 U.S.C. § 922(d)(1), which prohibits selling firearms to felons, arguing it violated the Second Amendment. The court applied the two-step framework from N.Y. State Rifle & Pistol Ass’n, Inc. v. Bruen and found that while the Second Amendment covers the right to acquire firearms, historical precedent supports disarming dangerous individuals, including felons. Thus, the court upheld the statute's constitutionality.Knipp also contested the admission of Eldridge's testimony about prior drug transactions, arguing it was impermissible propensity evidence. The court found any potential error in admitting this evidence to be harmless, given the substantial other evidence of Knipp's guilt.Finally, Knipp argued that the district court erred in calculating his sentence by including drug quantities from prior transactions based on Eldridge's testimony. The appellate court found no clear error in the district court's credibility determination and upheld the sentence.The Sixth Circuit affirmed Knipp's conviction and sentence. View "United States v. Knipp" on Justia Law

Malgum Whiteside, Jr. was charged with being a felon in possession of firearms after police found the weapons during a search of his residence. The search was conducted while officers were looking for evidence related to stalking charges against Whiteside. Whiteside moved to suppress the firearms, arguing that the search warrant was invalid and no warrant exception applied. The district court denied the motion, and Whiteside pleaded guilty while reserving the right to appeal the suppression ruling.The United States District Court for the Western District of Michigan denied Whiteside's motion to suppress, finding that the warrant was valid despite the judge not signing the warrant itself, only the affidavit. The court also found that there was a sufficient nexus between the place to be searched and the evidence sought. Additionally, the court ruled that even if the warrant was invalid, the good-faith exception to the warrant requirement would apply, and the firearms were in plain view.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The Sixth Circuit held that the warrant was validly issued despite the lack of a signature on the warrant itself, as there was clear and contemporaneous evidence that the judge made the necessary probable cause determination. The court also found that the warrant affidavit established a sufficient nexus between Whiteside's residence and the evidence of stalking. Furthermore, the court concluded that the plain-view doctrine applied to the seizure of the firearms, as the incriminating character of the firearms was immediately apparent to the officers, who knew Whiteside was a felon. Therefore, the seizure of the firearms was valid, and the district court's denial of the motion to suppress was affirmed. View "United States v. Whiteside" on Justia Law

Holly Lawson, a guidance counselor at Franklin County High School, alleged that her Fourth Amendment rights were violated by her coworkers, Kayla Creely and Lori Franke, and by School Superintendent Mark Kopp, along with the Franklin County, Kentucky Board of Education. Lawson claimed that Creely and Franke searched her bag without her consent, discovering a firearm, and that Kopp unlawfully detained and searched her in connection with this incident.The United States District Court for the Eastern District of Kentucky granted summary judgment in favor of the defendants. The court found that Creely and Franke were acting under color of state law but were entitled to qualified immunity. It also determined that Kopp's actions constituted a lawful investigative stop under Terry v. Ohio and that Lawson consented to the search of her bag.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The appellate court concluded that Creely and Franke did not act under color of state law because their actions were not authorized by any school policy or state authority. The court also agreed that Kopp's interaction with Lawson was a lawful investigative stop supported by reasonable suspicion and that Lawson voluntarily searched her own bag, negating any Fourth Amendment violation. Consequently, the court found no basis for municipal liability under Monell against the Board. View "Lawson v. Creely" on Justia Law

Brandi Goodwin, a part-time nursing assistant at Fisher Titus Hospital, contracted COVID-19 in December 2020, leading to symptoms such as shortness of breath and chest pain. She filed for short-term disability benefits, which Unum Life Insurance Company approved and extended until June 2021. However, when Goodwin applied for long-term disability benefits, Unum denied her claim, citing a pre-existing condition (vertigo) and normal test results that did not support her continued complaints.The United States District Court for the Southern District of Ohio upheld Unum's denial of long-term disability benefits. Goodwin then appealed the decision, arguing that Unum's denial was procedurally and substantively unreasonable.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court assessed whether Unum's decision-making process was procedurally sound and whether the decision was supported by substantial evidence. The court found that Unum considered all relevant evidence, including new medical opinions and test results, and provided rational reasons for changing its benefits determination from short-term to long-term. The court also noted that Unum's reliance on file reviewers over treating physicians was not unreasonable and that Goodwin did not provide concrete evidence of bias affecting Unum's decision.The Sixth Circuit concluded that Unum's decision to deny Goodwin long-term disability benefits was both procedurally and substantively reasonable. Therefore, the court affirmed the district court's judgment in favor of Unum. View "Goodwin v. Unum Life Ins. Co. of Am." on Justia Law