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

A man walking along the shoulder of a Nashville interstate was approached by a state trooper, who intended to pat him down and offer a ride. During the encounter, the man produced a box cutter, failed to comply with repeated police commands, and a standoff ensued involving multiple officers from different agencies. After about thirty-five minutes, the man took two quick steps toward the officers, pulled an object from his pocket, and pointed it at them in a manner resembling a firearm. In response, nine officers fired approximately thirty-three shots, twelve of which struck and killed him. Notably, after the man had fallen to the ground and appeared incapacitated, one officer fired two additional shots.The decedent’s wife filed suit in the United States District Court for the Middle District of Tennessee against the involved cities and officers, alleging excessive force in violation of the Fourth Amendment. The officers moved to dismiss the complaint on the basis of qualified immunity. The district court denied the motions, finding that the complaint plausibly alleged a constitutional violation and that the right at issue was clearly established. The court also determined that video evidence did not blatantly contradict the plaintiff’s allegations regarding the officers’ conduct after the man was incapacitated.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the denial of qualified immunity de novo. The court held that eight of the nine officers were entitled to qualified immunity because their initial use of deadly force was objectively reasonable under the circumstances. However, the court found that the officer who fired two shots after the man was incapacitated was not entitled to qualified immunity at this stage, as the complaint plausibly alleged a violation of clearly established law prohibiting the use of force against a neutralized suspect. The court affirmed in part and reversed in part. View "Eastep v. City of Nashville" on Justia Law

Officers investigating a drug trafficking ring observed Devin Long engaging in several suspected drug transactions, including controlled buys involving other individuals. Surveillance revealed Long’s repeated visits to known stash houses and his own registered residence, where officers witnessed activity consistent with drug dealing. Based on these observations and information from a confidential source, officers obtained a warrant to search Long’s home. The search uncovered illegal drugs, firearms, and related paraphernalia, leading to Long’s indictment on federal drug and firearm charges.The United States District Court for the Northern District of Ohio reviewed Long’s motion to suppress the evidence seized from his home, which argued that the affidavit supporting the search warrant failed to establish a sufficient nexus between his alleged criminal activity and the residence. The district court denied the motion, finding that the affidavit provided probable cause for the search. Long subsequently pleaded guilty to four charges but preserved his right to appeal the suppression ruling.On appeal, the United States Court of Appeals for the Sixth Circuit considered whether the search warrant for Long’s home was supported by probable cause. Applying a deferential standard to the issuing magistrate judge’s determination, the Sixth Circuit held that the affidavit established both that Long’s home was his residence and that he was engaged in ongoing drug trafficking. The court further found that even a single drug transaction observed outside Long’s home provided an independent basis for probable cause. The court affirmed the district court’s denial of Long’s motion to suppress, concluding that the warrant was properly issued under the Fourth Amendment. View "United States v. Long" on Justia Law

A former correctional officer with the Michigan Department of Corrections was terminated after a coworker accused him of making harassing and inappropriate comments. The officer, after being served with a misconduct charge and attending a disciplinary conference with his union representative, was formally terminated in July 2019. He challenged his termination through arbitration, which concluded in December 2020 with a decision upholding his dismissal. Nearly three years later, he filed a federal lawsuit against two department officials, alleging violations of his constitutional rights under 42 U.S.C. § 1983, specifically focusing on procedural due process.The United States District Court for the Western District of Michigan initially dismissed the officer’s first complaint without prejudice for lack of prosecution after he failed to respond to a motion to dismiss. When he refiled a similar complaint, the district court dismissed it again, this time on the grounds that the claim was untimely under Michigan’s three-year statute of limitations for personal injury actions and that, except for his procedural due process claim, he had forfeited his other constitutional arguments. The court also found that his procedural due process claim failed to state a claim upon which relief could be granted.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the dismissal de novo. The court held that the officer’s procedural due process claim accrued, at the latest, on the date of his post-termination arbitration hearing in December 2020, making his June 2024 complaint untimely. The court further held that Michigan law does not permit equitable tolling of the statute of limitations in this context and that the officer failed to plausibly allege inadequate process either before or after his termination. The Sixth Circuit affirmed the district court’s dismissal. View "Bozzo v. Nanasy" on Justia Law

A Guatemalan national entered the United States without authorization after fleeing gang violence in his home country. He sought asylum, withholding of removal, and protection under the Convention Against Torture, but an immigration judge denied these requests and ordered his removal. The Board of Immigration Appeals affirmed the removal order. Following the Supreme Court’s decision in Niz-Chavez v. Garland, which clarified the requirements for a valid “notice to appear,” the petitioner moved to reopen his removal proceedings to seek voluntary departure, a form of relief that would allow him to leave the United States without a formal removal order. To qualify, he needed to show, among other things, that he had the means to depart the country, typically by possessing a valid passport.The Board of Immigration Appeals denied his motion to reopen, finding that his affidavit—stating only that he was in the process of renewing his Guatemalan passport—was too conclusory and unsupported by documentary evidence. The Board concluded that he had not sufficiently demonstrated that he would be able to depart the United States if granted voluntary departure.The United States Court of Appeals for the Sixth Circuit reviewed the Board’s denial. The court held that the Board applied the correct legal standard, requiring only a prima facie showing of eligibility for relief at the motion-to-reopen stage, not conclusive proof. The court found that the Board did not err in determining that the petitioner’s unsupported and conclusory statement about his passport application failed to meet even this threshold. The Sixth Circuit therefore denied the petition for review, upholding the Board’s decision. View "Pastor-Hernandez v. Bondi" on Justia Law

Kenneth Evans was observed by police engaging in a hand-to-hand transaction in a vehicle. Upon approaching the vehicle, officers detected the smell of marijuana, searched the car, and found a loaded pistol. Evans admitted to handling the firearm and being on parole. He was subsequently indicted by a federal grand jury for being a felon in possession of a firearm and ammunition, to which he pleaded guilty. Evans had prior felony convictions, including one for aggravated robbery under Ohio law.The United States District Court for the Northern District of Ohio determined that Evans’s prior aggravated robbery conviction qualified as a “crime of violence” under the United States Sentencing Guidelines. This finding increased his advisory sentencing range from 24–30 months to 46–57 months, and the court sentenced him to 57 months’ imprisonment. Evans appealed, arguing that his aggravated robbery conviction should not be considered a crime of violence for sentencing purposes.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s legal determination de novo. The appellate court applied the categorical and modified categorical approaches to compare the elements of Ohio’s aggravated robbery statute, as applied to Evans’s conviction, with the definition of “extortion” in the Sentencing Guidelines. The court concluded that aggravated robbery under Ohio Revised Code § 2911.01(A)(1), when predicated on theft, categorically matches the Guidelines’ definition of extortion and therefore constitutes a crime of violence. The court rejected Evans’s arguments to the contrary and affirmed the district court’s judgment, upholding the increased sentence. The court also granted the government’s motion to take judicial notice. View "United States v. Evans" on Justia Law

Four defendants were members of a Detroit-based gang involved in drug distribution and violent crimes, including homicides, during the 1980s and 1990s. They were indicted in 1995 for conspiracy to distribute cocaine and crack cocaine, intentional killings in furtherance of a continuing criminal enterprise, and firearms offenses. Juries convicted all four on all counts in two separate trials. The district court sentenced each to concurrent life terms for the drug and homicide convictions, plus consecutive terms for the firearms offenses, following the then-mandatory Sentencing Guidelines. Their convictions and sentences were affirmed on appeal.Years later, after Congress enacted the Fair Sentencing Act and the First Step Act, which allowed for reduced sentences for certain crack cocaine offenses, the defendants moved for sentence reductions under the First Step Act. The United States District Court for the Eastern District of Michigan initially denied some motions, reasoning that the homicide convictions were not “covered offenses” under the Act. On appeal, the United States Court of Appeals for the Sixth Circuit vacated the denial as to the drug conspiracy count for one defendant, holding he was eligible for a reduction on that count. On remand, the district court reduced the sentences for both the drug and homicide convictions for all four defendants, concluding it had discretion to do so under the First Step Act and the sentencing-package doctrine.The United States Court of Appeals for the Sixth Circuit held that the First Step Act authorizes a district court to reduce a sentence for a non-covered offense only if it was part of a sentencing package with a covered offense. The court vacated the reduced sentences and remanded for the district court to determine whether the homicide sentences were truly part of such a sentencing package with the covered drug offense, and to proceed accordingly. View "United States v. Dale" on Justia Law

Two middle school students in Michigan wore sweatshirts displaying the phrase “Let’s Go Brandon” to school, intending to express disapproval of then-President Joe Biden. School administrators asked the students to remove the sweatshirts, interpreting the phrase as a euphemism for a vulgar anti-Biden chant. The students complied but, through their mother, later sued the school district and two administrators, alleging a violation of their First Amendment rights.The United States District Court for the Western District of Michigan granted summary judgment to the school district and administrators. The court found that the school’s dress code permitted the prohibition of apparel reasonably interpreted as profane or vulgar, and that the administrators’ interpretation of the phrase as vulgar was reasonable. The court concluded that the students’ constitutional rights were not violated, and dismissed all claims with prejudice.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision de novo. The Sixth Circuit held that school administrators may prohibit student speech that is reasonably understood as vulgar, even if the speech is political in nature and uses euphemism rather than explicit profanity. The court found that the administrators’ interpretation of “Let’s Go Brandon” as vulgar was reasonable given its widely understood meaning. The court further held that, under Supreme Court precedent, the school’s interest in prohibiting vulgar speech outweighs the student’s interest in political expression in this context. The Sixth Circuit affirmed the district court’s judgment in favor of the school district and administrators. View "B. A. v. Tri-County Area Schools" on Justia Law

Five University of Kentucky football players attended a fraternity party where they were subjected to racial slurs and, in some cases, physical assault by attendees. After the incident, a fraternity member called the police and accused the players of assault and burglary, claiming they brandished weapons. Detective Cory Vinlove led the investigation and, despite evidence suggesting the players were victims, allegedly fabricated information to support criminal charges against them. The university cleared the players of wrongdoing, but Vinlove proceeded with charges, and a police press release publicized the allegations. Ultimately, a grand jury declined to indict the players, but the negative publicity had already damaged their reputations and careers.The players filed lawsuits in the United States District Court for the Eastern District of Kentucky against Vinlove, Sergeant Donnell Gordon, Police Chief Lawrence Weathers, and the Lexington-Fayette Urban County Government, asserting federal claims under 42 U.S.C. § 1983 (including malicious prosecution and fabrication of evidence) and various state-law claims. The district court consolidated the cases and granted the defendants’ motion to dismiss all claims except a state-law malicious prosecution claim against Vinlove. The court found that the plaintiffs had not alleged a deprivation of liberty under the Fourth Amendment, as required for their federal claims, and that the state-law claims were inadequately pled. The court later dismissed the remaining state-law claim for lack of subject matter jurisdiction.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s decision. The Sixth Circuit held that the plaintiffs failed to allege a deprivation of liberty under the Fourth Amendment, as they were not arrested, detained, or subject to pretrial restrictions. The court also held that the press release was absolutely privileged under Kentucky law, defeating the defamation claim, and that the plaintiffs did not sufficiently allege that Gordon or Weathers initiated or continued the prosecution, defeating the state-law malicious prosecution claim. View "Adams v. Lexington-Fayette Urban County Gov't" on Justia Law

A company that supplies allergy testing materials and personnel to primary-care physicians in Tennessee alleged that several insurers and a dominant allergy-care medical group conspired to drive it and its contracting physicians out of the market. The company provided technicians and supplies to physicians, who then billed insurers for allergy services. The company claimed that the insurers and the medical group coordinated audits, denied claims, and set restrictive reimbursement policies, which led physicians to stop using its services and caused it financial harm.The United States District Court for the Eastern District of Tennessee dismissed the company’s federal antitrust claims at the pleading stage, finding it lacked standing to sue under the antitrust laws, and later granted summary judgment to the defendants on the company’s state-law tort claims. The company appealed both the dismissal of its antitrust claims and the grant of summary judgment on its tort claims.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s decisions. The Sixth Circuit clarified that, under federal antitrust law, a plaintiff must show both antitrust injury and proximate causation. The court held that the company’s injuries were only indirect, as they resulted from harms inflicted on the physicians, who were the direct victims of the alleged anticompetitive conduct. Applying the Supreme Court’s rule from Illinois Brick Co. v. Illinois, the court found that indirect sellers—those two or more steps removed in the distribution chain—may not sue for antitrust violations. The court also affirmed summary judgment on the state-law claims, concluding that the company failed to show either malice or causation as required for tortious interference, and that its civil conspiracy claim could not survive without an underlying tort. View "Academy of Allergy & Asthma in Primary Care v. Amerigroup Tennessee, Inc." on Justia Law

The petitioner, who was previously sentenced to death in Ohio, obtained a conditional writ of habeas corpus from the United States Court of Appeals for the Sixth Circuit, which required the State of Ohio to conduct a new penalty-phase proceeding within 180 days or have the death sentence vacated. The state failed to meet this deadline, even after receiving several extensions due to complications such as judicial recusals, defense preparations, and questions regarding the petitioner’s competency. As a result, the United States District Court for the Northern District of Ohio converted the conditional writ into an unconditional writ, ordering the state to vacate the death sentence and release the petitioner within five business days. The state did not fully comply until nearly three months later, when the state court formally vacated the sentence.After the state’s delayed compliance, the petitioner moved for relief from the unconditional writ, seeking as a sanction an order barring the state from reprosecuting the death penalty. The district court denied this request, finding that although there were significant delays, many were attributable to the petitioner, and the state’s conduct did not rise to the level of bad faith or substantial inequitable conduct that would justify barring reprosecution.On appeal, the United States Court of Appeals for the Sixth Circuit held that it had jurisdiction to review both the unconditional writ and the denial of the Rule 60(b) motion for sanctions, even after the state’s eventual compliance. The court affirmed the district court’s judgment, holding that the delays and procedural complications did not constitute extraordinary circumstances or substantial inequitable conduct warranting a bar on reprosecution of the death penalty. The court also found no abuse of discretion in the district court’s denial of further relief under Rule 60(b). View "Allah-U-Akbar v. Bradshaw" on Justia Law