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

Larry Householder, former Speaker of the Ohio House of Representatives, and lobbyist Matthew Borges were convicted of conspiring to solicit and receive nearly $60 million in exchange for passing a billion-dollar bailout for a failing nuclear energy company, FirstEnergy Corp. Householder used the funds to support his bid for the speakership and to recruit candidates who would vote for him. Borges played a role in the conspiracy by attempting to disrupt a referendum campaign against the bailout legislation.The United States District Court for the Southern District of Ohio at Cincinnati found both Householder and Borges guilty after a 26-day trial. Householder was convicted of multiple counts, including public-official bribery, private-citizen bribery, and money laundering. Borges was also found guilty of participating in the conspiracy.The United States Court of Appeals for the Sixth Circuit reviewed the case and found no reversible error, affirming the convictions. The court held that the evidence was sufficient to support the jury's findings that Householder and Borges engaged in a quid pro quo arrangement with FirstEnergy. The court also upheld the jury instructions, finding them consistent with applicable law, and rejected Householder's claims of insufficient evidence, right to counsel violations, and judicial bias. Additionally, the court found that the district court did not abuse its discretion in its evidentiary rulings or in admitting the guilty pleas of co-conspirators.Householder's sentence of twenty years, the statutory maximum under RICO, was deemed procedurally and substantively reasonable. The court emphasized the magnitude and severity of Householder's offense, referring to it as the "biggest corruption case in Ohio's history." Borges's arguments regarding the sufficiency of the evidence and the district court's evidentiary rulings were also rejected, and his conviction was affirmed. View "United States v. Householder" on Justia Law

In 2014, federal law enforcement began investigating a website known as "Playpen," used to distribute child pornography. The Department of Justice obtained a warrant to reveal the IP addresses of Playpen users, leading to the identification of Eric Schuster in Ohio. A search of Schuster's residence uncovered multiple devices containing thousands of images and videos of child pornography. In May 2016, Schuster was indicted on three felony child pornography counts and detained pretrial.The case experienced significant delays in the district court. Initially, Schuster requested several continuances to review discovery and prepare motions. Over the next three years, Schuster's litigation conduct, including filing and withdrawing motions and requesting new counsel, contributed to the delays. In April 2019, Schuster's motions were fully briefed, but the district court took no action for twenty months. In December 2020, Schuster requested a status conference, and the court stayed proceedings for additional discovery. Another eighteen months passed without action on Schuster's motions.Schuster moved to dismiss his indictment in August 2022, arguing the delay violated his Sixth Amendment right to a speedy trial. The district court initially denied the motion but later reconsidered and dismissed the indictment with prejudice, finding the delay attributable to the court and the impact of incarceration during the COVID-19 pandemic.The United States Court of Appeals for the Sixth Circuit reviewed the case and applied the Barker v. Wingo factors. The court found that Schuster was responsible for much of the delay and failed to assert his right to a speedy trial in a timely and consistent manner. Additionally, Schuster did not demonstrate substantial prejudice resulting from the delay. The court concluded that Schuster's Sixth Amendment right was not violated and reversed the district court's decision, allowing the prosecution to proceed. View "United States v. Schuster" on Justia Law

In November 2021, a school shooting occurred at Oxford High School in Michigan, resulting in the deaths of four students and injuries to several others. This event had a profound impact on the local community, leading some families to transfer their children to other schools. Plaintiff C.S., a third-grade student at Robert Kerr Elementary School in Durand, Michigan, wore a hat depicting an AR-15-style rifle and the phrase "COME AND TAKE IT" to school during a "Hat Day" event. School officials, concerned about the potential for disruption given the recent shooting and the presence of transfer students from Oxford, asked C.S. to remove the hat.The United States District Court for the Eastern District of Michigan granted summary judgment in favor of the defendants, the school officials, concluding that their actions were justified under the circumstances. The court found that the school officials reasonably forecasted a substantial disruption due to the hat's imagery and message, particularly considering the recent trauma experienced by some students.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 school officials did not violate C.S.'s First Amendment rights by asking her to remove the hat. The court emphasized the unique context of the recent school shooting and the young age of the students, which justified the school officials' concerns about potential disruption. The court also found that the district court did not abuse its discretion in considering the defendants' untimely motion for summary judgment. View "C.S. v. McCrumb" on Justia Law

The plaintiff, Percy Brown, alleged that he was framed by University of Louisville Police Officer Jeffrey Jewell and several Louisville Metro Police Department officers for various crimes, including kidnapping, murder, rape, sodomy, and wanton endangerment, after he refused to cooperate in a check-forging investigation. Over more than ten years, the Commonwealth of Kentucky brought and dismissed numerous charges against Brown, resulting in his spending over seven years in prison. After the final indictment was dismissed, Brown filed a lawsuit.The United States District Court for the Western District of Kentucky dismissed Brown's malicious-prosecution claim related to the murder charge as barred by the statute of limitations. The court found that the claim accrued when the murder charge was dismissed on February 24, 2015, and thus was time-barred. The court also granted Jewell’s motion for judgment on the pleadings regarding Brown’s fabrication-of-evidence claim, finding it insufficiently pleaded.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's dismissal of the malicious-prosecution claim, agreeing that it was time-barred. The court held that the murder charge was separable from the other charges against Brown, which were dismissed later, and thus the statute of limitations for the malicious-prosecution claim related to the murder charge began to run when that charge was dismissed. The court also found that the continuing-violation doctrine did not apply, as the last alleged unlawful act occurred more than a year before Brown filed his lawsuit. Consequently, the Sixth Circuit affirmed the district court's decision. View "Brown v. Louisville-Jefferson County Metro Government" on Justia Law

David Hieber, who led Oakland County’s Equalization Department for nearly twenty years, was terminated after an employee reported him for creating a hostile work environment. Hieber sued Oakland County and his supervisor, Kyle Jen, under 42 U.S.C. § 1983 for deprivation of pretermination and post-termination due process, political-affiliation retaliation, and age discrimination. He also brought state-law claims for defamation and age discrimination. Oakland County and Jen moved for summary judgment, which the district court granted.The United States District Court for the Eastern District of Michigan granted summary judgment in favor of Oakland County and Jen on all claims. Hieber appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court reversed the district court’s grant of summary judgment to Oakland County and Jen, in his official capacity, on Hieber’s pretermination due-process claim, finding that there was a genuine dispute of material fact about whether Hieber received a meaningful opportunity to respond to the charges against him. The court affirmed the district court’s judgment on Hieber’s post-termination due-process claim, political-affiliation retaliation claim, age discrimination claims, and defamation claim. The court also affirmed the district court’s grant of qualified immunity to Jen in his individual capacity on the due-process claims.The main holding of the Sixth Circuit was that Hieber’s pretermination due-process rights may have been violated, warranting further proceedings on that claim. The court found that the investigatory interview and the pretermination hearing may not have provided Hieber with adequate notice of the charges and a meaningful opportunity to respond. The court remanded the case for further proceedings consistent with its opinion. View "Hieber v. Oakland County, Mich." on Justia Law

Amaury Villa participated in two significant burglaries in 2011, stealing $61 million worth of pharmaceuticals from an Eli Lilly warehouse in Connecticut and $1.5 million worth of cigarettes from a warehouse in Kentucky. He was indicted by federal grand juries in Florida, Connecticut, and Kentucky. Villa pled guilty in the Florida and Connecticut cases, receiving concurrent prison terms of 140 and 98 months, respectively. In January 2016, Kentucky prosecutor Joshua Judd emailed Villa’s attorney, Donald Meier, a proposed plea agreement that did not mention concurrent sentencing. Villa later pled guilty without a plea agreement and was sentenced to 77 months, to be served consecutively.Villa moved to set aside his Kentucky sentence under 28 U.S.C. § 2255 in January 2019, claiming ineffective assistance of counsel. He later sought to amend his motion to add a claim that Meier failed to inform him of a potential cooperation agreement. The district court initially denied the motion as untimely. On appeal, the Sixth Circuit remanded for an evidentiary hearing on the timeliness of the claim. The district court found the claim timely but denied it on the merits.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s decision. The court found that Judd’s January 21 email did not constitute a formal plea offer but was an invitation to negotiate. The court also found that Meier had informed Villa of the January 9 plea offer, which was discussed at Villa’s change-of-plea hearing. The court concluded that Meier’s performance was not deficient and that Villa himself impeded further negotiations by refusing to provide additional information about his co-conspirator. The district court’s judgment denying Villa’s motion to vacate, set aside, or correct his sentence was affirmed. View "Villa v. United States" on Justia Law

Sonya Kenette Brown, a City Council member in Albion, Michigan, was prosecuted for allegedly violating a City Charter provision that prohibits council members from directing the appointment or removal of city employees. Brown claimed that her political opponents on the City Council engaged in retaliatory prosecution and arrest, malicious prosecution, and conspiracy to violate her civil rights. She also challenged the constitutionality of the City Charter provision.The United States District Court for the Western District of Michigan dismissed Brown's claims of retaliatory prosecution and arrest, malicious prosecution, and conspiracy, finding that there was probable cause for her prosecution based on her Facebook messages. The court also granted summary judgment to the defendants on Brown's claim that the City Charter provision was unconstitutional.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's dismissal of Brown's claims, agreeing that there was probable cause for her prosecution. The court found that Brown's Facebook messages provided sufficient evidence to believe she had violated the City Charter by directing the removal of a city employee. The court also held that the City Charter provision was not unconstitutionally vague or overbroad, as it provided clear standards and did not prohibit a substantial amount of protected speech.The Sixth Circuit concluded that Brown's claims failed because she could not demonstrate an absence of probable cause, and the City Charter provision was constitutionally valid. The court affirmed the district court's judgment in favor of the defendants. View "Brown v. City of Albion, Mich." on Justia Law

Lathfield Investments, LLC, Lathfield Holdings, LLC, and Lathfield Partners, LLC (collectively, "Lathfield") own three commercial buildings in Lathrup Village, Michigan, rented to various commercial tenants. The City of Lathrup Village and its Downtown Development Authority (collectively, the "City") require landlords to obtain a rental license and list each tenant's name and principal business. Lathfield applied for a landlord rental license in July 2020 but did not list the required tenant information, leading to the denial of their application and their tenants' business license applications. Lathfield sued the City, alleging unlawful compulsion to apply for unnecessary licenses and make unnecessary property improvements, bringing eleven claims, nine against the City.The United States District Court for the Eastern District of Michigan granted summary judgment to the City on all nine claims. Lathfield appealed, arguing that the City improperly required site plan approval, violated due process and equal protection rights, and engaged in inverse condemnation, among other claims.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The court held that Lathfield's request for declaratory relief regarding site plan approval was moot since the site plan process was already completed. The court also found that Lathfield was required to obtain a general business license under the City Code and that the City Code's tenant registration requirement applied to Lathfield. The court rejected Lathfield's due process claims, noting that the City’s adoption of the Michigan Building Code was a legislative act not subject to procedural due process requirements. The court also dismissed Lathfield's equal protection claim due to a lack of evidence of differential treatment and found no basis for the Contracts Clause claim under 42 U.S.C. § 1983. Lastly, the court concluded that Lathfield failed to establish an inverse condemnation claim or a civil conspiracy. View "Lathfield Investments, LLC v. City of Lathrup Village, Mich." on Justia Law

Federal law enforcement investigated crystal-methamphetamine trafficking in rural eastern Tennessee in July 2019, leading them to Derrick Mitchell in Knoxville. In October 2020, authorities executed a search warrant at Mitchell’s home, finding drugs, firearms, ammunition, and cash. Mitchell pleaded guilty to conspiring to distribute methamphetamine and to commit money laundering. He waived his right to appeal unless the district court imposed an above-Guidelines sentence. The district court accepted his plea and imposed a below-Guidelines sentence.The United States District Court for the Eastern District of Tennessee accepted Mitchell’s plea agreement, which included a stipulation that no other upward enhancements would apply apart from a two-level increase for money laundering. However, the probation office recommended additional enhancements, including one for possessing a firearm in connection with a drug-trafficking offense. Mitchell’s counsel did not initially object to the presentence report, and the district court adopted it in full. Later, Mitchell’s counsel raised the issue of the firearm enhancement, but the court explained that the stipulations in the plea agreement were not binding.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Mitchell’s appeal must be dismissed because he waived his right to appeal under the plea agreement, which was voluntarily accepted. The court found no plain error in the district court’s acceptance of Mitchell’s plea, as the court had adequately informed him of the consequences, and Mitchell understood the nature of his plea. The court also determined that the government did not breach the plea agreement, as it had not promised that only one enhancement would apply and had not objected to the probation office’s recommendation. The appeal was dismissed in accordance with the plea agreement’s appellate waiver provision. View "United States v. Mitchell" on Justia Law

Jeremy Mooney, a former deputy in the Pike County Sheriff’s Office, was convicted of two counts of depriving an inmate, Thomas Friend, of his civil rights under color of law, in violation of 18 U.S.C. § 242. The incidents occurred on November 17-18, 2019, when Mooney pepper sprayed and punched Friend multiple times while Friend was restrained in a chair. Surveillance footage captured these events. Mooney claimed his actions were in response to Friend spitting on him and that he was instructed by his supervisor to use pepper spray.The United States District Court for the Southern District of Ohio denied Mooney’s motion to dismiss the indictment, which argued that the government destroyed exculpatory video evidence in bad faith. The court found no bad faith or exculpatory value in the lost footage. At trial, the jury found Mooney guilty on both counts. The court also excluded evidence of Friend’s Hepatitis C, ruling it irrelevant and potentially prejudicial. Mooney was sentenced to 100 months in prison, with an enhancement for obstruction of justice based on allegedly false trial testimony.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed Mooney’s conviction, finding sufficient evidence that Mooney acted willfully to deprive Friend of his constitutional rights. The court also upheld the district court’s evidentiary rulings, including the exclusion of the Hepatitis C evidence and the admission of testimony from Deputy Jonathan Chandler about police training.However, the Sixth Circuit vacated Mooney’s sentence and remanded the case for further proceedings regarding the obstruction of justice enhancement. The court found that the district court failed to make specific findings necessary to establish perjury, as required for the enhancement. The case was sent back to the district court to either resentence Mooney or make the required factual findings. View "United States v. Mooney" on Justia Law