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

The case involves Carl Hubbard, who was convicted of first-degree murder in Michigan state court in 1992. Over two decades later, Hubbard filed a petition for a writ of habeas corpus in the United States District Court for the Eastern District of Michigan, arguing that he is entitled to an equitable exception to the Antiterrorism and Effective Death Penalty Act of 1996’s (AEDPA) time bar based on a credible showing of actual innocence. The district court dismissed the petition as untimely.The district court's decision was appealed to the United States Court of Appeals for the Sixth Circuit. Hubbard argued that he had new evidence that impeached the State’s case against him, but he failed to present evidence affirmatively demonstrating his actual innocence. The court held that AEDPA does not permit him to file an untimely habeas petition. The court affirmed the district court's decision, stating that Hubbard's new evidence did not meet the burden of showing that the State had imprisoned an innocent person. Therefore, Hubbard must comply with the same law with which all other habeas petitioners must comply. View "Hubbard v. Rewerts" on Justia Law

Travis Lester, a convicted felon, was arrested and charged with possession of a firearm after law enforcement officers found a stolen .40 caliber pistol in his motel room. The arrest occurred after Lester violated the terms of his supervised release from a previous conviction for possessing ammunition as a felon. During the arrest, officers found a baggie of crack cocaine and $869 in cash on Lester's person. Lester admitted to having marijuana in his motel room. Based on this information, officers obtained a search warrant for the room, where they found the pistol, a digital scale, and a small bag of marijuana.Prior to his trial, Lester filed a motion to suppress the evidence obtained from the officers' protective sweep of his motel room and his admission about the marijuana, arguing that these violated his Fourth Amendment and Miranda rights. The district court denied this motion, finding that the officers had not violated Lester's rights. At trial, the jury convicted Lester, and the district court sentenced him to 120 months in prison. The court also imposed an additional seventeen-month prison sentence to be served consecutively due to Lester's violation of the supervised-release conditions from his earlier conviction.On appeal to the United States Court of Appeals for the Sixth Circuit, Lester argued that his Miranda and Fourth Amendment rights were violated, that there were evidentiary errors, and that there were mistakes in his sentencing. The appellate court disagreed with Lester's claims and affirmed the district court's decision. The court held that the officer's question during Lester's arrest was not an interrogation under Miranda, and that the protective sweep of Lester's motel room did not violate his Fourth Amendment rights. The court also found no error in the district court's evidentiary rulings or in its sentencing of Lester. View "United States v. Lester" on Justia Law

The case involves Kamel Chaney-Snell, who was arrested by Deputy Andrew Young and Officer Andrew Teichow during a search of his girlfriend's house. Chaney-Snell claimed that after he peacefully surrendered, Young punched him in the face, and one of the officers kneed him in the back and dragged him across the floor. He sued Young and Teichow under 42 U.S.C. § 1983, alleging excessive force and failure to intervene. The district court denied qualified immunity to both officers.The officers' appeals raised three questions. First, whether the court must accept Chaney-Snell’s claim that Young gratuitously punched him despite Chaney-Snell’s guilty plea for attempting to resist arrest. The Sixth Circuit found that it lacked jurisdiction over Young’s Heck claim, and his judicial-estoppel claim failed on the merits.Second, whether the Fourth Amendment allows officers to use unnecessary force on arrestees if the force qualifies as “de minimis”. The court held that gratuitous force violates the Fourth Amendment even if the force is minor and causes no serious injury.Finally, whether Chaney-Snell established a “failure to intervene” theory of liability. The court found that qualified immunity protects the officers from Chaney-Snell’s failure-to-intervene claims.The Sixth Circuit affirmed in part, reversed in part, and dismissed in part for lack of jurisdiction. View "Chaney-Snell v. Young" on Justia Law

The case involves Hattie Tanner, who was convicted of murder and served seventeen years in prison before her conviction was set aside due to insufficient evidentiary support. After her release, Tanner filed a lawsuit against David Walters, a retired police detective, alleging that he violated her constitutional rights by falsifying investigation reports and providing false testimony, leading to her wrongful conviction. Walters sought summary judgment based on qualified immunity, which the district court partially granted and partially denied. The court allowed Tanner's claims for fabrication of evidence and malicious prosecution to proceed to trial. Walters appealed this decision.Previously, the district court found that Tanner's claims for fabrication of evidence and malicious prosecution should proceed to trial. Walters appealed this decision, arguing that he was entitled to qualified immunity.The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court found that a reasonable jury could conclude that Walters knowingly fabricated evidence against Tanner, and thus he was not entitled to qualified immunity on Tanner's fabrication-of-evidence claim. The court also found that a reasonable jury could find that Walters's false statements influenced the decision to charge Tanner, and that without these false statements, there would not have been probable cause to prosecute Tanner. Therefore, Walters was not entitled to qualified immunity on Tanner's malicious prosecution claim. View "Tanner v. Walters" on Justia Law

The case involves a dispute between Firexo Group Limited (FGL), a British company that manufactures fire extinguishers, and Firexo, Inc., a Florida-based company that was created to sell FGL's products in the United States. Scot Smith, a resident of Ohio, purchased 70% of Firexo, Inc. from FGL under a Joint Venture Agreement (JVA). The JVA included a forum-selection clause designating England or Wales as the exclusive jurisdiction for any disputes arising from the agreement. Firexo, Inc., which was not a signatory to the JVA, later sued FGL in an Ohio court over issues with the fire extinguishers. FGL sought to dismiss the case based on the forum-selection clause in the JVA.The district court granted FGL's motion to dismiss, applying the "closely related" doctrine. This doctrine allows a non-signatory to a contract to be bound by a forum-selection clause if the non-signatory is sufficiently closely related to the contract. The district court found that Firexo, Inc. was closely related to the JVA and therefore subject to the forum-selection clause. Firexo, Inc. appealed this decision, arguing that the district court applied the wrong law and analytical approach in determining the applicability of the contract.The United States Court of Appeals for the Sixth Circuit reversed the district court's decision. The appellate court agreed with Firexo, Inc. that the district court had applied the wrong law. The court held that the "closely related" doctrine, a federal common law rule, should not have been used to interpret the JVA's forum-selection clause. Instead, the court should have applied the law specified in the JVA, which was English law. Under English law, contracts do not apply to non-signatories unless certain exceptions apply, none of which were present in this case. Therefore, the forum-selection clause in the JVA did not apply to Firexo, Inc., and the case was remanded for further proceedings. View "Firexo, Inc. v. Firexo Group Limited" on Justia Law

Sedric Ward, an Army reservist, worked at the Shelby County Jail. In 2015, the County fired Ward but later entered into a settlement agreement in which Ward released “any and all claims whatsoever” related to his termination. Despite this, Ward later sued the County under the Uniformed Services Employment and Reemployment Rights Act (USERRA). The central issue was whether the settlement agreement effectively released Ward’s claim under the Act.The district court ruled in favor of Ward, asserting that the release’s scope—namely, “any and all claims whatsoever”—did not reach his USERRA claim. The case went to trial, and the jury found in Ward’s favor. The district court eventually ordered the County to pay Ward more than $1.5 million.The United States Court of Appeals for the Sixth Circuit disagreed with the district court's reasoning. The appellate court found that the release provision in the settlement agreement clearly encompassed Ward’s USERRA claim. However, the court also noted that USERRA imposes a second requirement for the release of a claim under the Act. Specifically, the Act requires that the agreement “establish” rights that are “more beneficial” for the servicemember than the ones he gives up. The court found that whether a particular settlement agreement provides greater benefits than a USERRA claim is for the servicemember to decide. Given the circumstances, the court concluded that a reasonable jury could find that Ward’s decision to enter into the agreement reflected a considered decision on his part, or instead that it reflected only desperation. The appellate court vacated the district court’s judgment and remanded the case for further proceedings. View "Ward v. Shelby County" on Justia Law

The case involves Walid Abdulahad, an Iraqi national who sought review of the Board of Immigration Appeals' (BIA) denial of his motion to reopen his removal proceedings based on changed country conditions in Iraq. Abdulahad, who had been living in the U.S. since 1997, was ordered removed in absentia in 2006 following a criminal conviction in Aruba. He remained in the U.S. under supervision and filed multiple motions to reopen his case, arguing that he faced a risk of torture if returned to Iraq due to his status as a Chaldean Christian and his ties to the U.S.The BIA denied Abdulahad's latest motion to reopen, finding that his evidence was cumulative of evidence submitted with prior motions, and that he had not established a particularized risk of torture or that each step in his causal-chain claim was more likely than not to occur. Abdulahad petitioned the U.S. Court of Appeals for the Sixth Circuit for review of the BIA's decision.The Sixth Circuit granted the petition, vacated the BIA's decision, and remanded the case back to the BIA. The court found that the BIA had applied the incorrect legal standards when determining whether Abdulahad's evidence was new, cumulative, or material, and had failed to assess Abdulahad's claims in the aggregate. The court also found that the BIA had not sufficiently explained or considered the evidence related to Abdulahad's particularized likelihood of torture. View "Abdulahad v. Garland" on Justia Law

The case involves Dennis Neate, a former employee of the James B. Oswald Company (Oswald), an insurance firm. Neate left Oswald to work for Hylant Group, Inc., another insurance firm, and some of his clients followed him. Oswald accused Neate of violating his non-solicitation agreement and sued in federal district court. The court issued a preliminary injunction ordering Neate and others to comply with Oswald’s non-solicitation agreement. Neate appealed.Previously, the district court granted a preliminary injunction after an evidentiary hearing. The injunction prohibited Neate and others from violating their agreements with Oswald, retaining or using Oswald's confidential information, and soliciting or accepting business from Oswald's clients. The injunction also required all defendants to return all of Oswald's property.The United States Court of Appeals for the Sixth Circuit vacated and remanded the case. The court found that the district court failed to properly apply Ohio law in determining the reasonableness of the non-solicitation agreement. The court also found that the injunction did not meet the specificity requirements of Federal Rule of Civil Procedure 65(d)(1), as it incorporated the non-solicitation agreement by reference. However, the court agreed with the district court that Oswald had shown a likelihood of success on its trade-secrets claims. View "James B. Oswald Co. v. Neate" on Justia Law

The case revolves around Gregory Rogers, who was convicted of various drug and firearm-related crimes. The evidence leading to his conviction was obtained from his girlfriend's car, where he was found alone in the passenger seat. Rogers claimed that the evidence was collected in violation of his Fourth Amendment rights, arguing that he had a legitimate expectation of privacy in the vehicle.Previously, the trial court had denied Rogers' motion to suppress the evidence. The court ruled that Rogers lacked a legitimate expectation of privacy in the vehicle as he was neither the owner nor the driver of the car and failed to show that he had permission to occupy it. The court also determined that the search was a valid inventory search. After trial, a jury convicted Rogers on all six counts.The United States Court of Appeals for the Sixth Circuit affirmed the trial court's decision. The court agreed with the trial court that Rogers had no legitimate expectation of privacy in the vehicle. The court noted that Rogers had not exhibited a subjective expectation of privacy. He was neither the owner nor the driver of the vehicle, and he had not shown that he had "complete dominion and control" over the car. The court also noted that Rogers had twice informed the police that the car was not his and had loudly disclaimed his authority over the vehicle. Therefore, the court concluded that Rogers could not establish that the police had violated his Fourth Amendment rights. View "United States v. Rogers" on Justia Law

The case revolves around the death of Darius Caraway, who overdosed while serving a murder sentence at Whiteville Correctional Facility in Tennessee, operated by CoreCivic, Inc. Caraway's estate, represented by his mother, sued CoreCivic and three of its officials, alleging that they violated Caraway's Eighth Amendment rights by failing to protect him from overdosing. The estate argued that CoreCivic deliberately understaffed the facility, leading to inadequate screening of prison guard applicants, smuggling of illegal drugs, and lack of supervision, which allowed fentanyl to proliferate at Whiteville. The estate claimed that the defendants knew about this proliferation but did nothing about it, leading to Caraway's death by overdose.The United States District Court for the Western District of Tennessee dismissed the estate’s complaint, stating that the claims were conclusory allegations of unconstitutional conduct devoid of well-pled factual support. The estate appealed this dismissal to the United States Court of Appeals for the Sixth Circuit.The Sixth Circuit affirmed the district court's decision. The court found that the estate failed to adequately allege that Caraway faced an objectively excessive risk of harm from unfettered access to drugs inside Whiteville. The court also found that the estate failed to sufficiently allege that the defendants knew of a drug problem at Whiteville or that they didn't reasonably respond to the alleged risk. The court concluded that the estate failed to meet the requirements of a failure-to-protect claim under the Eighth Amendment. The court also dismissed the estate's procedural claims, stating that the district court properly treated the motion as one to dismiss and that the estate had forfeited its argument about the district court's failure to issue a scheduling order. View "Caraway v. CoreCivic of Tennessee, LLC" on Justia Law