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

Randy Wiertella died in the Lake County Adult Detention Facility on December 10, 2018. Dennis Wiertella, as the Administrator of Randy's estate, filed a lawsuit claiming that Randy's constitutional rights under the Eighth and Fourteenth Amendments were violated by Jail staff Diane Snow, RN, and Christina Watson, LPN. Randy had been booked into the Jail without his essential medications for heart disease, diabetes, high blood pressure, and a psychiatric disorder. Despite multiple requests, he did not receive all necessary medications, leading to his death from hypertensive cardiovascular disease.The United States District Court for the Northern District of Ohio denied Snow and Watson's motion for summary judgment, which sought dismissal based on qualified immunity. The court found that there were genuine disputes of material fact regarding whether Snow and Watson were aware of the substantial risk to Randy's health and whether they failed to respond reasonably.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Snow and Watson were not entitled to qualified immunity. The court found that both nurses were aware of Randy's serious medical conditions and the need for continuous medication. Despite this knowledge, they failed to ensure that Randy received his essential medications in a timely manner. The court concluded that their actions were unreasonable and violated Randy's constitutional rights. The court affirmed the district court's decision and remanded the case for further proceedings on the Estate's § 1983 claim. View "Wiertella v. Lake County" on Justia Law

Edwin Tavarez acted as a courier for his brother's illegal cocaine business, delivering cocaine to a restaurant in Lakewood, Ohio. After his brother's death, Tavarez continued the operation until he was arrested in February 2019. Authorities found him in possession of two kilograms of cocaine. In July 2019, Tavarez was charged with conspiracy to possess with intent to distribute cocaine, possession with intent to distribute, and use of a communications facility in furtherance of a drug trafficking crime. He pled guilty to the first two charges, and the third was dismissed. Tavarez was sentenced to 18 months in prison and four years of supervised release, including one year of home detention.The United States District Court for the Northern District of Ohio granted Tavarez's motions for compassionate release in September 2021, reducing his sentence to time served and extending his home detention. In June 2022, the court terminated the special condition of home detention. In June 2023, Tavarez filed a pro se motion for early termination of supervised release, citing good behavior and mishandling of his earned time credit. The district court denied the motion in a summary order and also denied his subsequent motion for access to the underlying documents.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that 18 U.S.C. § 3742(a) does not impede their review of the district court's denial of Tavarez's early termination motion. The court found that the district court abused its discretion by not demonstrating that it considered the relevant § 3553(a) factors when denying the motion. The Sixth Circuit vacated the district court's order denying early termination of supervised release and remanded for further proceedings. However, the court affirmed the district court's denial of Tavarez's motion for access to documents, as there was no obligation to disclose the supervision report or its content. View "United States v. Tavarez" on Justia Law

In late July 2022, an unprecedented flood destroyed numerous homes and properties in Eastern Kentucky. Plaintiffs, who suffered losses, filed a lawsuit against Pine Branch Mining, LLC, alleging that the company violated Kentucky mining regulations in maintaining a surface mine property near their lands, resulting in negligence per se. They claimed that Pine Branch's infractions substantially contributed to the flooding.The United States District Court for the Eastern District of Kentucky excluded the opinion of Plaintiffs' sole causation expert, Scott Simonton, under Federal Rule of Evidence 702 and Federal Rule of Civil Procedure 26(a)(2)(B). The court found that Simonton's report was not based on sufficient facts or data specific to the mining sites in question, lacked reliable principles and methods, and failed to consider alternative causes of the damage. Consequently, the district court granted summary judgment to Pine Branch, concluding that Plaintiffs could not establish a prima facie case of negligence per se without competent expert proof.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that the district court did not abuse its discretion in excluding Simonton's testimony, as it was deficient in reliability and completeness. Without Simonton's expert opinion, Plaintiffs lacked sufficient evidence to prove causation, an essential element of their negligence per se claim. The court held that the remaining evidence was insufficient to create a genuine dispute of material fact, and thus, summary judgment in favor of Pine Branch was appropriate. View "Baker v. Blackhawk Mining, LLC" on Justia Law

Luis Martinez Jr. died in February 2021, and his body was taken by the Wayne County Medical Examiner’s Office (WCMEO). Despite identifying his next of kin, the WCMEO did not contact them. The family hired a social worker who located Luis Jr.'s body in April 2021, by which time it was severely decomposed and had to be cremated. The family sued Wayne County and various officials under § 1983 for a Fourteenth Amendment procedural due process violation, a Monell liability claim, and state-law claims.The United States District Court for the Eastern District of Michigan granted the defendants' motion to dismiss. The court found that the alleged conduct did not constitute a clearly established constitutional violation and that the Monell claim failed due to a lack of supporting facts. The court declined to exercise supplemental jurisdiction over the state-law claims, dismissing them without prejudice.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The court held that the defendants' conduct did not violate a clearly established constitutional right, as existing precedent did not address delayed notification leading to natural decomposition. The court also found that the Monell claim failed because the complaint did not allege sufficient facts to show a policy or custom of unconstitutional conduct or a failure to train. The court concluded that without a clearly established constitutional violation, the Monell claim could not succeed. View "Martinez v. Wayne Cnty., Mich." on Justia Law

Robert Carbone, a Connecticut resident, sued two Swiss organizations and several individuals from California, Illinois, and Switzerland for defamation and other tortious conduct. Carbone, a member of the two Swiss organizations, claimed that the defendants used websites to publish defamatory statements about him and facilitate his removal from the organizations. He filed the lawsuit in Ohio, arguing that the defamatory statements passed through servers located in Ohio, which hosted the organizations' websites.The United States District Court for the Southern District of Ohio dismissed Carbone's complaint for lack of personal jurisdiction. The court found that Carbone failed to establish that the defendants had sufficient contacts with Ohio to justify the court's jurisdiction over them. The defendants had not purposefully availed themselves of the privilege of acting in Ohio, as the servers' location in Ohio was chosen by third parties, not the defendants.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the defendants did not purposefully avail themselves of the privilege of acting in Ohio, as their only connection to the state was the location of the servers, which was a decision made by third parties. The court also found that Carbone's claims did not arise from the defendants' activities in Ohio, as the allegedly defamatory statements were not directed at Ohio or its residents. Therefore, the exercise of personal jurisdiction over the defendants in Ohio would not comply with the Due Process Clause. View "Carbone v. Kaal" on Justia Law

In 2017, the Saginaw County Sheriff’s Office seized fourteen firearms during a domestic-violence investigation involving Benjamin Heinrich. Heinrich's uncle, Gerald Novak, and distant cousin, Adam Wenzel, claimed ownership of the firearms and sought their return. Sheriff William Federspiel refused to return the firearms, arguing that Novak and Wenzel had not proven ownership. Novak and Wenzel then sued Federspiel under 42 U.S.C. § 1983 and Michigan law, asserting various federal constitutional and state claims.The United States District Court for the Eastern District of Michigan granted summary judgment to Federspiel on all claims and denied Novak and Wenzel’s motion for partial summary judgment. The court found that qualified immunity protected Federspiel in his personal capacity and that Novak and Wenzel had not established constitutional violations. It also held that Michigan law does not recognize a cause of action to sue municipal officials for constitutional torts and that Novak and Wenzel could not establish the elements of claim and delivery.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court’s grant of summary judgment to Federspiel on the individual-capacity takings claims, procedural-due-process claims, substantive-due-process claims, Fourth Amendment claims, and inverse-condemnation claims. However, it vacated the grant of summary judgment on the official-capacity and injunctive-relief takings claims, official-capacity Second Amendment claims, and the claim-and-delivery action. The court remanded these claims for further proceedings, noting that Novak and Wenzel’s affidavits created a genuine issue of material fact regarding ownership of the firearms, and that the district court should address whether Federspiel’s actions were consistent with historical firearm regulation. View "Novak v. Federspiel" on Justia Law

Daniel Lockridge, a decorated combat Marine, was involved in methamphetamine trafficking after returning to the U.S. in 2009. He initially used methamphetamine to manage his PTSD and later began selling it, eventually becoming a significant supplier in Chattanooga, Tennessee. Lockridge pleaded guilty to aiding and abetting possession with intent to distribute methamphetamine and was sentenced to 210 months in prison followed by three years of supervised release. His supervised release conditions included mandatory mental-health and substance-abuse treatment, as directed by a probation officer.The United States District Court for the Eastern District of Tennessee imposed these conditions, and Lockridge objected, arguing that the court must preauthorize any inpatient treatment and set a frequency for drug testing, rather than delegating these decisions to a probation officer. The district court overruled his objections, leading to Lockridge's appeal.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the district court did not relinquish its authority by not specifying the details of the treatment programs at sentencing. Instead, it retained the discretion to make these decisions closer to the time of Lockridge's supervised release, allowing the probation officer to assess his needs and recommend appropriate treatment. The court emphasized that the ultimate authority to modify or enforce the conditions of supervised release remains with the district court, ensuring compliance with Article III of the U.S. Constitution.The Sixth Circuit affirmed the district court's decision, concluding that the delegation of certain responsibilities to the probation officer did not violate constitutional principles, as the district court retained the final decision-making authority. View "United States v. Lockridge" on Justia Law

Elfido Gonzalez Castillo, a native and citizen of Mexico, illegally entered the United States in 1981 and became a lawful permanent resident in 1989. In 2009, he applied for naturalization but failed to disclose a recent indictment for sexually abusing his niece. He became a naturalized citizen in October 2009 and pleaded guilty to the offense two months later. In 2019, the government sought to revoke his citizenship, and in 2022, a court ordered its cancellation due to his fraudulent procurement. Subsequently, the Department of Homeland Security initiated removal proceedings against him under 8 U.S.C. § 1227(a)(2)(E)(i) for a crime of child abuse.An immigration judge ordered Gonzalez's removal, and the Board of Immigration Appeals upheld this decision. Gonzalez sought review in the Third Circuit, which transferred the case to the Sixth Circuit, determining that venue lay elsewhere.The United States Court of Appeals for the Sixth Circuit reviewed the case and concluded that Gonzalez was not deportable under the child-abuse provision because he was a naturalized citizen at the time of his conviction. The court relied on the precedent set by the Supreme Court in Costello v. INS, which held that deportation provisions do not apply to individuals who were citizens at the time of their conviction. The court noted that the statutory language and the rule of lenity supported this interpretation. Consequently, the Sixth Circuit granted Gonzalez's petition for review, vacated the order of removal, and remanded the case for further proceedings consistent with its opinion. View "Gonzalez Castillo v. Bondi" on Justia Law

A fifty-nine-year-old General Manager (GM) at a Chili’s restaurant in Nashville, Tennessee, was terminated and replaced by a thirty-three-year-old with no managerial experience. The employer, Brinker International, Inc., claimed the termination was due to the GM creating a toxic "culture" and not "living the Chili’s way," despite the restaurant being one of the top performers in the market. The GM alleged that the termination was due to age discrimination, as he was the oldest manager in the region and believed Brinker was systematically replacing older employees with younger ones.The United States District Court for the Middle District of Tennessee granted summary judgment in favor of Brinker, accepting the company's explanation of "culture" as a legitimate, non-discriminatory reason for the termination. The court found that the GM could not sufficiently rebut this explanation to show it was pretext for age discrimination. The court also granted in part and denied in part the GM's motion for sanctions due to Brinker’s spoliation of evidence, awarding fees and costs but not excluding the TMR Report, which documented the termination decision.The United States Court of Appeals for the Sixth Circuit reviewed the case and found that the TMR Report could not be authenticated under Federal Rule of Evidence 901 and was therefore inadmissible. The court vacated the district court’s order on sanctions and instructed it to consider whether additional sanctions beyond fees and costs were appropriate. The appellate court also reversed the district court’s grant of summary judgment for Brinker, finding that the GM had provided sufficient evidence to rebut Brinker’s explanation and create a genuine issue of material fact regarding age discrimination. The court affirmed the district court’s denial of the GM’s motion for summary judgment. View "Kean v. Brinker Int'l, Inc." on Justia Law

From 2016 to 2021, Irene Michelle Fike worked at an accounting firm and later as an independent contractor for a client, J.M., and J.M.'s family. Fike used her access to J.M.'s financial accounts to pay her personal credit card bills and make purchases from online retailers. She concealed her fraud by misrepresenting J.M.'s expenditures in financial reports. Fike defrauded J.M. of $363,657.67 between April 2018 and September 2022.Fike pleaded guilty to wire fraud and aggravated identity theft in 2024. The United States District Court for the Eastern District of Kentucky sentenced her to thirty-six months' imprisonment and three years of supervised release. The court also ordered her to pay $405,867.08 in restitution, which included the principal amount stolen and $42,209.41 in prejudgment interest. Fike appealed, arguing that the Mandatory Victims Restitution Act (MVRA) does not authorize prejudgment interest and that the interest calculation was speculative.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the MVRA allows for prejudgment interest to ensure full compensation for the victim's losses. The court found that the district court did not abuse its discretion in awarding prejudgment interest, as it was necessary to make J.M. whole. The court also determined that the district court had a sufficient basis for calculating the interest, relying on J.M.'s declaration of losses, which was submitted under penalty of perjury and provided a reliable basis for the award. The Sixth Circuit affirmed the district court's decision. View "United States v. Fike" on Justia Law