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

The case involves Dr. John Stanton, who served as the medical director for a pain clinic in Tennessee. The federal government alleged that the clinic operated as a pill mill, and charged Dr. Stanton with conspiring to violate federal drug laws. Despite numerous red flags indicating the clinic's operation as a pill mill, Dr. Stanton continued to sign off on state compliance reports and prescribe narcotics to patients who failed drug screens. The government indicted Dr. Stanton, along with the clinic's owner and two patient sponsors, for conspiring to distribute controlled substances without a legitimate medical purpose.The case was first heard in the United States District Court for the Eastern District of Kentucky, where Dr. Stanton was found guilty by a jury. At sentencing, the court concluded that Dr. Stanton had prescribed a converted drug weight of at least 21,524 kilograms, leading to a recommended minimum sentence of 188 months. The trial court, however, varied downward to 120 months.Upon appeal to the United States Court of Appeals for the Sixth Circuit, Dr. Stanton challenged the sufficiency of the evidence supporting the jury’s verdict and several rulings by the trial court. The appellate court affirmed the lower court's decision. The court found that there was sufficient evidence to support the jury's finding that Dr. Stanton knowingly agreed to help the clinic and its owner illegally distribute controlled substances. The court also found no abuse of discretion in the trial court's decisions, including the allowance of a new expert witness for the government, the instruction to the jury on deliberate ignorance, and the response to the jury’s questions about the jury instructions. The court also upheld the drug weight calculation at sentencing. View "United States v. Stanton" on Justia Law

Jeffrey Capen, a former employee of Saginaw County, Michigan, sued the county and Robert V. Belleman, the county's Controller and Chief Administrative Officer, under 42 U.S.C. § 1983. Capen claimed that his procedural due process rights under the Fourteenth Amendment were violated when he was scheduled for two fitness-for-duty evaluations. The evaluations were ordered after a co-worker reported that Capen had threatened to kill other employees. Capen was subsequently placed on paid administrative leave and later terminated for failing to participate in an "interactive process" meeting to identify potential reasonable accommodations for his work, as required by the Americans with Disabilities Act.The United States District Court for the Eastern District of Michigan granted summary judgment in favor of the defendants. The court concluded that Capen lacked a constitutionally protected interest, that he received the process he was due, and that Belleman was entitled to qualified immunity.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The appellate court found that Capen's ability to refuse his fitness-for-duty evaluations did not constitute a protected interest under the Due Process Clause. The court noted that while the evaluations were stressful and deeply personal for Capen, he failed to demonstrate that his constitutional rights were violated. The court also observed that compelling circumstances justified the county's decision to require the evaluations, given the reported threats of violence. View "Capen v. Saginaw County, Michigan" on Justia Law

The case involves Oakland Tactical Supply, LLC and five Michigan residents who sued Howell Township, Michigan, alleging that the township's zoning restrictions, which prevented Oakland Tactical from constructing and operating a commercial shooting range, violated the Second Amendment. The district court granted the township's motion for judgment on the pleadings, concluding that the zoning restrictions did not violate the Second Amendment. The plaintiffs appealed this decision.The district court's decision was made before the Supreme Court announced a new framework for deciding Second Amendment challenges in New York State Rifle & Pistol Ass'n, Inc. v. Bruen. The Court of Appeals for the Sixth Circuit remanded the case for reconsideration in light of Bruen, and the district court again granted judgment for the township.The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court found that while the Second Amendment protects the right to engage in commercial firearms training as necessary to protect the right to effectively bear arms in case of confrontation, it does not extend to training in a particular location or at the extremely long distances Oakland Tactical seeks to provide. The court concluded that the plaintiffs' proposed conduct—commercial training in a particular location and long-distance commercial training—was not protected by the plain text of the Second Amendment. Therefore, the township's zoning restrictions did not violate the Second Amendment. View "Oakland Tactical Supply, LLC v. Howell Township" on Justia Law

A group of Ohio voters sought to amend the Ohio Constitution through a ballot initiative. To do so, they had to submit their proposed amendment, a summary of the amendment, and one thousand supporting signatures to the Ohio Attorney General, who then had to certify that the summary was a fair and truthful statement of the proposed amendment. The Attorney General, David Yost, declined to certify the plaintiffs' summary on at least six occasions. After the most recent denial, the plaintiffs sought review from the Supreme Court of Ohio, which declined to grant expedited review. The plaintiffs then filed a complaint in federal district court, alleging that the Attorney General's enforcement of the certification requirement violated their First and Fourteenth Amendment rights by creating an unconstitutional obstacle to their ballot access and their ability to advocate for their proposed amendment. The district court denied the plaintiffs' motion for preliminary injunctive relief.On appeal, the United States Court of Appeals for the Sixth Circuit reversed the district court's decision. The appellate court found that the plaintiffs had standing to bring their claims and were not barred by sovereign immunity. The court also determined that the certification requirement imposed a severe burden on the plaintiffs' core political speech, and that the state had not shown that the requirement was narrowly tailored to its interests. The court therefore concluded that the plaintiffs were likely to succeed on the merits of their First Amendment claim. The court also found that the remaining factors for granting a preliminary injunction weighed in the plaintiffs' favor. The court therefore granted the plaintiffs' motion for preliminary injunctive relief, enjoining the Attorney General from enforcing the certification requirement against the plaintiffs. View "Brown v. Yost" on Justia Law

The case revolves around Roy Christopher West, who is serving a life sentence without parole for a conviction that the district judge has attributed to a sentencing error. West was indicted in 2010 on a charge of conspiracy to use interstate commerce facilities in the commission of murder for hire. He was tried twice, and during the second trial, he was convicted and sentenced to life imprisonment without parole. However, the indictment did not include any allegation that personal injury or death resulted from the conspiracy, and the jury was not instructed that death was an element of West's offense. The district court sentenced West under the federal murder-for-hire statute, which imposes a life sentence in cases where "death results." The court concluded that sentencing West to life imprisonment under these circumstances violated West's constitutional rights.West initially moved to vacate his sentence under 28 U.S.C. § 2255, arguing that his trial counsel was ineffective for failing to investigate a causation defense. The district court denied that motion. West then moved for compassionate release, arguing that his unconstitutionally imposed life sentence, combined with his rehabilitation while incarcerated, created an extraordinary and compelling circumstance that warranted a sentence reduction. The district court agreed and reduced his sentence to time served. However, the Government appealed, and the appellate court reversed, holding that compassionate release could not be used as a vehicle for second or successive § 2255 motions.West then sought relief from judgment under Federal Rule of Civil Procedure 60(b). The district court construed West's motion as a second or successive § 2255 motion and transferred it. West opposed the transfer and asked the appellate court to remand to the district court for a ruling on the merits of his Rule 60(b) motion. The appellate court vacated the district court's order construing West's motion as a second or successive § 2255 motion and remanded the motion to the district court to consider under Rule 60(b). View "In re: West" on Justia Law

The case revolves around Yvonne Craddock, an African American woman who was terminated from her employment at FedEx Corporate Services following a workplace altercation. Craddock alleged that her termination was racially motivated, in violation of Title VII of the Civil Rights Act of 1964. The case was presented to a jury, which concluded that FedEx's reason for termination was pretextual, but that Craddock had failed to demonstrate that FedEx intentionally discriminated against her because of her race. Craddock appealed, arguing that the district court had made several errors, including forcing her to bifurcate the liability and damages portions of her trial and excluding testimony and evidence pertaining to events post-termination.The district court had granted FedEx’s motion to dismiss Craddock’s libel claim, Family Medical Leave Act claim, 42 U.S.C. § 1981 claim, and spoliation claim, but denied dismissal of her Title VII claims. After discovery, the court granted FedEx’s motion for summary judgment on Craddock’s Title VII claims. The case was then taken to the United States Court of Appeals for the Sixth Circuit.The Court of Appeals held that the district court did not abuse its discretion regarding the claims raised by Craddock, and affirmed the jury’s verdict. The court found that the district court's decision to bifurcate the trial was not an abuse of discretion, and that the court's exclusion of testimony and exhibits postdating the termination was not erroneous. The court also found no error in the district court's trial rulings and case management decisions, and concluded that the jury verdict form was not plainly erroneous. The court further held that the cumulative effect of the alleged errors did not deprive Craddock of a trial consistent with constitutional guarantees of due process. View "Craddock v. FedEx Corporate Services, Inc." on Justia Law

An inmate, Timothy Finley, who suffers from severe psychiatric disorders, was placed in a heavily restrictive cell in administrative segregation for approximately three months by prison officials. Finley brought a case against the deputy wardens, Erica Huss and Sarah Schroeder, alleging violations of the Eighth Amendment and his right to procedural due process, as well as disability-discrimination claims under the Americans with Disabilities Act and the Rehabilitation Act.The district court granted summary judgment to Huss and Schroeder on all claims. On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the lower court's decision on Finley’s procedural due process and statutory discrimination claims. However, the court reversed the lower court's decision on Finley’s Eighth Amendment claim, finding that he presented sufficient evidence to find that the deputy wardens violated his clearly established rights. The court remanded the case for further proceedings on the Eighth Amendment claim. View "Finley v. Huss" on Justia Law

Emmanuel Merritt was convicted for being a felon in possession of firearms and was sentenced to 120 months in prison. Prior to his guilty plea, Merritt had spent several months evading authorities, leading the district court to deny him a two-point reduction in his total offense level for not accepting responsibility. Additionally, the district court increased Merritt's criminal history score by three points due to a past state offense that included a total prison sentence of 870 days. Merritt contested both decisions, arguing that his sentence was only 330 days due to credits he received.The United States District Court for the Western District of Michigan disagreed with Merritt's objections. It found that Merritt had not clearly demonstrated acceptance of responsibility and that his criminal history score was calculated correctly. Merritt was sentenced to a within-Guidelines sentence of 120 months in prison.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The appellate court found that the district court did not err in denying the two-point reduction for acceptance of responsibility, given Merritt's history of evading authorities. The court also upheld the district court's calculation of Merritt's criminal history score, ruling that the Guidelines required the addition of three points for Merritt's past state offense. View "United States v. Merritt" on Justia Law

The case involves Douglas Milczak, a long-term employee of General Motors (GM), who alleged that he was subjected to age-based harassment by his managers and subordinates, with the aim of pushing him into early retirement. Milczak claimed that this harassment violated the Age Discrimination in Employment Act. After enduring several years of alleged degradation, he filed an action against GM. GM moved for summary judgment, arguing that the record did not support any of his claims. The district court granted the motion.The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court found that Milczak failed to establish a prima facie case of age discrimination. While the court acknowledged that Milczak had experienced offensive comments from his manager, it found that these comments did not constitute age-based harassment that was severe or pervasive enough to create a hostile work environment. The court also found that Milczak failed to show that GM's personnel actions were based on his age or that similarly situated younger employees were treated more favorably. Finally, the court found that Milczak failed to establish a prima facie case of retaliation, as he could not demonstrate a causal connection between his protected activities and the adverse actions taken by GM. View "Milczak v. General Motors, LLC" on Justia Law

Keita Jerrod Hayden was convicted for violating the terms of his supervised release for the second time. The district court imposed a seven-month term of incarceration followed by an eight-year term of supervised release. Hayden challenged his supervised-release term on two grounds: first, that it is longer than his statute of conviction allows, and second, that the district court violated his right to be present at sentencing by imposing the mandatory and standard conditions by reference.The district court had previously sentenced Hayden to a ten-year prison term and eight years of supervised release for knowingly and intentionally possessing with the intent to distribute a mixture containing cocaine base. Hayden violated the terms of his supervised release twice, first by driving under the influence of alcohol, and second by being intoxicated in a public place. Each time, the district court sentenced him to imprisonment followed by an eight-year supervised-release term.The United States Court of Appeals for the Sixth Circuit affirmed the district court's judgment. The court found that the district court did not exceed the statutory-maximum term of supervised release and provided Hayden with sufficient notice of the conditions to satisfy due process. The court also determined that the district court did not violate Hayden's due-process right by incorporating the standard supervised-release conditions by reference. The court concluded that the district court had followed an appropriate procedure in imposing four special discretionary conditions upon Hayden during his supervised release. View "United States v. Hayden" on Justia Law