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

In the summer of 2020, Adam Fox and Barry Croft, Jr. planned to kidnap Michigan Governor Gretchen Whitmer. They were convicted by a federal jury on all charges, with Fox receiving a 192-month sentence and Croft a 235-month sentence. On appeal, they argued insufficient evidence for their convictions, errors by the district court in not conducting a "Remmer" hearing for a biased juror, limiting cross-examination time, and restricting the admissibility of certain informant statements.The United States District Court for the Western District of Michigan initially tried the case, resulting in a hung jury for Fox and Croft, while co-defendants Harris and Caserta were acquitted. Upon retrial, Fox and Croft were found guilty. They appealed to the United States Court of Appeals for the Sixth Circuit.The Sixth Circuit reviewed the sufficiency of the evidence de novo and found ample evidence supporting the convictions. The court noted that Fox and Croft's actions, including reconnaissance missions and detailed planning, demonstrated a clear agreement to kidnap Governor Whitmer. The court also found sufficient evidence for Croft's possession of an unregistered destructive device and rejected the entrapment defense, citing substantial predisposition to commit the crimes.Regarding the "Remmer" hearing, the Sixth Circuit held that the district court did not abuse its discretion, as the allegations of juror bias were not credible. The court also found no abuse of discretion in limiting cross-examination time, as defense counsel had ample warning and opportunity to question witnesses effectively. Lastly, the court ruled that the exclusion of certain informant statements was harmless error, as the evidence of guilt was overwhelming.The Sixth Circuit affirmed the convictions of Fox and Croft on all counts. View "United States v. Croft" on Justia Law

Fitzgerald Truck Parts & Sales, LLC built and sold highway tractors by installing old engines and transmissions from salvage yards into new tractor kits. The IRS assessed unpaid excise taxes, penalties, and interest totaling $268 million, arguing that Fitzgerald's sales were subject to a 12% excise tax under 26 U.S.C. §§ 4051(a)(1) and 4052(a)(1). Fitzgerald claimed an exemption under 26 U.S.C. § 4052(f)(1), which provides a safe harbor if the cost of repairs or modifications does not exceed 75% of the retail price of a comparable new tractor. Fitzgerald won before a jury, and the government appealed.The United States District Court for the Middle District of Tennessee ruled in favor of Fitzgerald, rejecting the government's arguments that Fitzgerald's operations did not qualify for the safe harbor and that the tractors were not taxable when new under 26 U.S.C. § 4052(f)(2). The government then appealed to the United States Court of Appeals for the Sixth Circuit.The Sixth Circuit agreed with Fitzgerald that § 4052(f)(1) poses a bright-line, 75% test without any further qualitative inquiry, meaning Fitzgerald's vehicles constructed with used engines and transmissions could qualify for the safe harbor. However, the court found that § 4052(f)(2) forecloses this exemption for tractors that never triggered the excise tax when they were new. The court noted that Fitzgerald had not met its burden of proving that the tractors were taxable when new, as evidence suggested that some vehicles were first sold in tax-exempt transactions to entities abroad or state or local governments.The Sixth Circuit reversed the district court's judgment and remanded the case for further proceedings to determine whether each refurbished tractor, when new, incurred the excise tax under § 4051. View "Fitzgerald Truck Parts & Sales LLC v. United States" on Justia Law

Tyler Ross, a manager and co-CEO of ROCO Real Estate LLC and ROCO Management LLC, pleaded guilty to one count of conspiracy to commit an offense against the United States. Ross was involved in a scheme to provide mortgage lenders with inflated income information about properties owned by his real-estate-investment firm. The scheme involved submitting false financial documents to mortgage lending businesses to make underperforming properties appear more profitable than they were, thereby obtaining favorable mortgage valuations and refinancing terms.The United States District Court for the Eastern District of Michigan applied a sentencing enhancement for defendants who derived more than $1,000,000 in gross receipts from one or more financial institutions as a result of their offense. The district court found that Ross's conduct met the enhancement's requirements, as he received over $2 million from a property sale financed by a loan from JPMorgan Chase Bank, which relied on falsified financial documents provided by Ross. The district court sentenced Ross to 12 months and one day of imprisonment, granting a downward variance from the guideline range of 46-57 months.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's judgment. The court held that the gross-receipts enhancement was correctly applied because Ross's offense targeted financial institutions, and he derived gross receipts from a financial institution as a result of his offense. The court rejected Ross's arguments that the enhancement should only apply when a defendant causes loss to a financial institution and that his receipts were derived from a real-estate firm rather than a financial institution. The court emphasized that the enhancement applies to gross receipts obtained directly or indirectly from a financial institution as a result of the offense. View "United States v. Ross" on Justia Law

Faytima Howard failed to pay her property taxes, leading Macomb County, Michigan, to seize and sell her property in 2023. Howard sued, claiming the county violated the Takings Clause of the Fifth Amendment by keeping proceeds exceeding her tax debt. Previously, Michigan's foreclosure regime was found unconstitutional for not compensating property owners for the surplus from foreclosure sales. However, Michigan amended its law in 2020 to allow property owners to claim any surplus value from foreclosed properties. Howard did not utilize this process.The United States District Court for the Eastern District of Michigan dismissed Howard's complaint for failure to state a claim. The court noted that Michigan's amended law provided a procedure for property owners to claim surplus proceeds, which Howard did not follow. The district court concluded that because Howard did not take advantage of the process, her claim was invalid.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The court held that Michigan's procedure for claiming surplus proceeds from foreclosure sales complies with the Takings Clause, as it provides property owners with a reasonable opportunity to claim any surplus. The court distinguished this case from others where no such process was available, emphasizing that Howard's failure to follow the state procedure meant no taking occurred. The court also rejected Howard's arguments that the process was overly burdensome and that the lack of interest and attorney's fees constituted a taking. The court concluded that Michigan's procedures are constitutionally sound and do not violate the Fifth Amendment. View "Howard v. Macomb Cnty., Mich." on Justia Law

Fathiree Ali, a Muslim inmate, requested the Michigan Department of Corrections to provide him with a halal diet, which is required by his religion. The prison chaplain directed him to apply for the vegan meal option, but another official rejected his application after discovering that Ali had purchased over one hundred non-halal items from the prison commissary. Ali then sued the chaplain, the special activities coordinator, the warden, and the Michigan Department of Corrections under the Religious Land Use and Institutionalized Persons Act (RLUIPA), the Free Exercise Clause, and 42 U.S.C. § 1983.The United States District Court for the Western District of Michigan dismissed Ali’s claims against the Department of Corrections and granted summary judgment in favor of the officials. Ali appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case and dismissed Ali’s appeal in part for lack of jurisdiction and affirmed the rest of the district court’s decision. The court held that RLUIPA does not authorize money-damages claims against officials sued in their official or individual capacities. The court also found that Ali’s claims for injunctive relief against the chaplain and warden were moot because they no longer had the power to adjust his meal plan after his transfer to a different prison. Additionally, the court held that Ali’s claim for injunctive relief against the special activities coordinator was moot because the coordinator no longer worked for the Department of Corrections.The court concluded that Ali did not have a cognizable claim for injunctive or declaratory relief under RLUIPA because he had alternatives to access halal meat and could reapply for the vegan meal plan. The court also found that Ali failed to state a claim against the Michigan Department of Corrections as he did not identify a policy that violated RLUIPA. Finally, the court held that the officials were entitled to qualified immunity on Ali’s Free Exercise Clause claims under § 1983. View "Ali v. Adamson" on Justia Law

At the onset of the COVID-19 pandemic, the Governor of Kentucky issued orders prohibiting mass gatherings, including religious services, and closing non-life-sustaining organizations, which included religious organizations. Maryville Baptist Church held an Easter service in defiance of these orders, leading to a lawsuit against the Governor, alleging violations of the First and Fourteenth Amendments.The United States District Court for the Western District of Kentucky initially declined to issue a preliminary injunction. However, the Sixth Circuit Court of Appeals issued a partial stay, allowing outdoor worship. Subsequently, the district court granted a preliminary injunction, permitting both indoor and outdoor worship. The Governor later allowed places of worship to reopen, and the Kentucky General Assembly limited the Governor's authority to issue similar orders in the future. The underlying action was dismissed as moot, and the Church sought attorney’s fees, which the district court denied, ruling that the Church did not prevail.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court referenced the U.S. Supreme Court's decision in Lackey v. Stinnie, which held that a party who receives a preliminary injunction but whose case becomes moot before a final judgment does not qualify as a prevailing party under 42 U.S.C. § 1988. Applying this precedent, the Sixth Circuit affirmed the district court's denial of attorney’s fees, concluding that the Church's preliminary injunction did not constitute enduring judicial relief that materially altered the legal relationship between the parties. View "Maryville Baptist Church v. Beshear" on Justia Law

Aaron Salter spent 15 years in prison for a shooting he did not commit, based on a single eyewitness's testimony. The eyewitness identified Salter from a single mug shot shown by Detective Donald Olsen, who also failed to disclose that the eyewitness had identified another man from a photo array. Salter claims that Olsen's actions led to his wrongful conviction.Salter filed a civil rights lawsuit under 42 U.S.C. § 1983, alleging that Olsen violated his constitutional rights by withholding exculpatory evidence and conducting an unduly suggestive identification process. Olsen moved for summary judgment, claiming qualified immunity, but the United States District Court for the Eastern District of Michigan denied the motion. Olsen appealed.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court dismissed parts of the appeal for lack of interlocutory jurisdiction but affirmed the district court's denial of qualified immunity on the Brady claim and the suggestive identification claim. The court held that there were material disputes of fact regarding whether Olsen withheld evidence and whether the identification process was unduly suggestive and unreliable. The court also found that it was clearly established in 2003 that such actions violated constitutional rights, and thus, Olsen was not entitled to qualified immunity. View "Salter v. City of Detroit" on Justia Law

On November 30, 2021, a 15-year-old student, E.C., brought a gun to Oxford High School in Michigan and shot ten students and one teacher, resulting in four student deaths. E.C. pled guilty to first-degree murder and is serving a life sentence. His parents were also convicted of manslaughter. Victims of the shooting filed multiple lawsuits in state court against school and law enforcement officials, alleging various tort claims. The consolidated federal cases here involve claims that school officials violated the plaintiffs' constitutional rights to due process.The United States District Court for the Eastern District of Michigan largely dismissed the plaintiffs' claims, holding that the plaintiffs had not alleged facts sufficient to support an inference that the school officials' actions were so outrageous as to shock the conscience. However, the court allowed one claim to proceed, finding that a statement made by a school counselor, Shawn Hopkins, to E.C.'s parents about contacting Child Protective Services if they did not get counseling for E.C. within 48 hours, could potentially support a constitutional claim.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's dismissal of most claims. The appellate court agreed that the plaintiffs had not plausibly alleged that the school officials' actions were so egregious as to violate due process. The court found that the actions of returning E.C.'s backpack and failing to inform other officials about the risk did not constitute affirmative acts that increased the danger to the plaintiffs. The court also held that Hopkins' statement to E.C.'s parents did not demonstrate reckless or callous indifference. Consequently, the Sixth Circuit reversed the district court's decision to allow the claim based on Hopkins' statement to proceed and remanded the case with instructions to dismiss all claims. View "St. Juliana v. Oxford Community School District" on Justia Law

Lonnie Hubbard, a pharmacist, was convicted of operating an illegal "pill mill" and sentenced to 30 years in prison. The government confiscated his assets, including over $400,000 from his individual retirement account (IRA), as part of the criminal forfeiture. The IRS later claimed that this seizure constituted taxable income for Hubbard, resulting in a tax deficiency notice for over $180,000 in taxes and penalties.The United States Tax Court agreed with the IRS, ruling that the transfer of the IRA funds to the IRS was a taxable event for Hubbard. The court held that the funds qualified as Hubbard's income because they discharged an obligation he owed. Consequently, the court ordered Hubbard to pay the taxes and penalties.The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the Tax Court's decision. The Sixth Circuit held that the forfeiture order granted the IRS ownership of the IRA, meaning the IRS, not Hubbard, was the payee or distributee of the funds. The court concluded that the withdrawal of the IRA funds by the IRS did not constitute taxable income for Hubbard, as he no longer owned or controlled the IRA at the time of the withdrawal. The court emphasized that the tax code requires the payee or distributee of withdrawn IRA funds to pay the taxes, and in this case, the IRS was the payee or distributee. Therefore, Hubbard was not liable for the taxes on the forfeited IRA funds. The court reversed the Tax Court's decision and remanded the case for further proceedings consistent with its opinion. View "Hubbard v. Commissioner of Internal Revenue" on Justia Law

Paula S. Linden applied for Social Security benefits online in September 2014 at the age of 62, which was before her full retirement age of 66. As a result, she received smaller monthly payments than she would have if she had waited until 66. Linden claimed that she applied early based on misinformation from the Social Security Administration (SSA), which allegedly told her that she would receive the same benefits as if she had applied at 66. She sought to have her benefits recalculated as if she had applied at 66.The SSA denied her request, both initially and upon reconsideration. An Administrative Law Judge (ALJ) also ruled against her, stating that the statutory provision she cited, 42 U.S.C. § 402(j)(5), only applied to individuals who failed to apply for benefits due to misinformation. The ALJ also found insufficient evidence that Linden received misinformation from the SSA. The Appeals Council denied her request for review. Linden then filed a complaint in the United States District Court for the Eastern District of Michigan, which granted summary judgment in favor of the SSA and denied Linden’s motion for summary judgment.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the plain text of 42 U.S.C. § 402(j)(5) precluded Linden’s recovery because the statute only applies to individuals who failed to apply for benefits due to misinformation. Since Linden did apply for benefits, she did not meet the statutory requirement. The court also found that the SSA’s regulations supported this interpretation. Additionally, the court noted that even if there was misinformation, it would not change the outcome because Linden did not fail to apply for benefits. Therefore, the court affirmed the district court’s decision. View "Linden v. Comm'r of Soc. Sec." on Justia Law