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

The case involves the Mackinac Center for Public Policy and the Cato Institute (Plaintiffs) who sued the U.S. Department of Education and its officials (Defendants) over a one-time account adjustment announced by the Department. The adjustment was intended to count months or years that student-loan borrowers spent in excessive forbearance status towards debt forgiveness. The Plaintiffs, being nonprofit, tax-exempt organizations and qualified public service employers under the Public Service Loan Forgiveness (PSLF) program, argued that this adjustment would harm their ability to recruit and retain employees.The case was initially heard in the United States District Court for the Eastern District of Michigan, where the court dismissed the Plaintiffs' complaint for lack of subject-matter jurisdiction, concluding that the Plaintiffs lacked standing. The Plaintiffs appealed this decision.The United States Court of Appeals for the Sixth Circuit affirmed the lower court's decision. The court held that the Plaintiffs failed to demonstrate that they suffered an injury in fact, a requirement for establishing standing. The court rejected the Plaintiffs' arguments that they had competitor standing and that they were deprived of a procedural right. The court found that the Plaintiffs' claims were speculative and unsupported by specific facts. Consequently, the court affirmed the dismissal of the Plaintiffs' complaint for lack of subject-matter jurisdiction. View "Mackinac Center for Public Policy v. Cardona" on Justia Law

Eight men convicted of sexual offenses between 1982 and 1994 challenged the constitutionality of the 2004 Tennessee Sexual Offender and Violent Sexual Offender Registration, Verification, and Tracking Act (“the Act”) and its subsequent amendments. The Act required them to comply with various reporting requirements and geographical restrictions imposed on all sex offenders. The plaintiffs argued that the laws violated the Constitution’s Ex Post Facto Clause.The United States District Court for the Middle District of Tennessee agreed with the plaintiffs and issued an injunction prohibiting Governor Lee and Director Rausch from enforcing the entire Tennessee code against the plaintiffs. The court also issued a declaratory judgment against unnamed parties who might also enforce the Act.The case was appealed to the United States Court of Appeals for the Sixth Circuit. The appellate court disagreed with the district court's decision. The court found that the plaintiffs lacked standing to sue Governor Lee and ordered the lower court to dismiss him from the suit. The court also found that the district court's injunction was overly broad and unjustified. The appellate court reversed in part the district court’s judgment that the Act violates the Ex Post Facto Clause and remanded the case with orders to vacate the declaratory judgment, dissolve the injunction against Governor Lee, dismiss Governor Lee from the suit based on a lack of standing, and to modify the injunction against Director Rausch consistent with its opinion. View "John Doe #1 v. Lee" on Justia Law

The case involves Lance Tobias, who ran an operation shipping and receiving drugs and cash for dealers and their customers. He pleaded guilty to crimes involving the possession and distribution of fentanyl. The district court denied Tobias “safety-valve” relief, an offense-level reduction for defendants who make full disclosures to the government, citing Tobias’s failure to disclose any information regarding his customers. As a result, Tobias qualified for a ten-year mandatory minimum under 21 U.S.C. § 841(b)(1)(B). The court imposed the mandatory minimum and a $100,000 fine without calculating Tobias’s sentencing range under the United States Sentencing Guidelines. Tobias appealed the district court’s denial of safety-valve relief and his sentence.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s decision. The court found that the district court’s denial of safety-valve relief was supported by the record. The court also found that any sentencing error survives plain-error review. The court held that Tobias failed to provide the government with enough information to warrant safety-valve relief. The court also found that the district court’s failure to calculate Tobias’s Guidelines range before imposing the statutorily mandated minimum term of imprisonment and a $100,000 fine did not affect Tobias’s substantial rights. View "United States v. Tobias" on Justia Law

The case involves Brian Dewayne Darden-Mosby, who was convicted of two federal drug-dealing offenses. During the investigation, Drug Enforcement Agency (DEA) agents executed a search warrant for Darden-Mosby’s house and car, discovering an unregistered firearm, a money counter, drug ledgers, marijuana, and a backpack containing cocaine. They also seized $112,690 in cash found in various locations in his bedroom. After the search, police pulled over one of Darden-Mosby’s cocaine suppliers and found Darden-Mosby in the passenger seat with a bank envelope containing $2,500 in cash and two cashier’s checks totaling nearly $150,000.The United States prosecuted Darden-Mosby for various crimes based on the drugs and guns found in his house. As part of the prosecution, the government initiated criminal-forfeiture proceedings against the cash from Darden-Mosby’s bedroom, the two cashier’s checks, and the $2,500 found in Darden-Mosby’s pocket. Darden-Mosby sought to suppress the cashier’s checks and $2,500, arguing the detective’s search violated the Fourth Amendment. The district court denied the motion. The government ultimately opted not to introduce that evidence at trial, and it dismissed the criminal forfeiture claims against the two checks.A jury convicted Darden-Mosby of two drug-dealing offenses. The government declined to prosecute the forfeiture of the $2,500 in cash from the traffic stop any further but continued to pursue criminal forfeiture of the $112,690 from Darden-Mosby’s house. After a hearing and additional briefing, the court concluded the cash was connected to Darden-Mosby’s drug dealing and ordered the criminal forfeiture of the money.Separate from the government’s criminal-forfeiture actions, the DEA commenced administrative-forfeiture proceedings against the two cashier’s checks and the $2,500. These proceedings resulted in the administrative forfeiture of all three assets.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed in part and reversed in part. The court affirmed the district court’s criminal-forfeiture order with respect to the $92,470 found in the safe and shoebox at Darden-Mosby’s house but reversed with respect to the $20,220 found in and on the dresser. The court found that Darden-Mosby offered credible evidence that the $20,220 found on and in the dresser had legal sources and purposes. However, the court found that Darden-Mosby’s evidence was considerably weaker when it came to the $92,470 in the safe and shoebox. View "United States v. Darden-Mosby" on Justia Law

The case revolves around a dispute between Diamond Transportation Logistics (Diamond) and The Kroger Company (Kroger). In 2010, the two companies entered into a transportation agreement, which was renewed in 2016, for Diamond to transport Kroger's goods. The agreement included an indemnity provision, which allowed Kroger to withhold payments from Diamond for claims against Diamond under certain conditions. In December 2015, a subcontractor of Diamond was involved in a fatal accident while transporting Kroger's goods. The family of the deceased sued both Diamond and Kroger for wrongful death, alleging negligence in Kroger's selection, hiring, and retention of Diamond as a shipper. Kroger demanded Diamond to cover its legal expenses based on the indemnity provision in their agreement. However, Diamond failed to reimburse Kroger, leading Kroger to withhold nearly $1.8 million in shipping payments from Diamond.The case was first heard in the United States District Court for the Southern District of Ohio, where Kroger filed a counterclaim for breach of the transportation agreement's indemnity provision. The district court ruled in favor of Kroger, awarding it $612,429.45 plus interest. Diamond appealed this decision to the United States Court of Appeals for the Sixth Circuit.The Sixth Circuit Court of Appeals affirmed the district court's decision. The main issue was whether the indemnity provision's exception for "liability...caused by the sole negligence or willful misconduct of Kroger" relieved Diamond of its obligation. The court held that the exception did not apply in this case because Kroger's liability for the family's negligent selection, hiring, and retention claim was not caused by its "sole negligence." The court reasoned that Diamond's negligence also played a part in Kroger's liability, and therefore, Diamond was required to cover Kroger's costs in settling the family's claim. View "Diamond Transp. Logistics, Inc. v. Kroger Co." on Justia Law

The case involves Tommy Kirtdoll, who was under investigation by a multijurisdictional task force in southwest Michigan for leading a drug-trafficking organization. After several undercover drug deals, the task force obtained a search warrant for Kirtdoll's house, which was described in detail in the warrant application. Upon executing the warrant, officers found drugs and distribution equipment, leading to Kirtdoll's indictment on multiple drug offenses.Kirtdoll challenged the validity of the search warrant, citing three errors: the address listed was not his, the tax identification number was incorrect, and the property owner's name was not his. He argued that these mistakes rendered the warrant unconstitutional due to lack of particularity, as required by the Fourth Amendment. The district court denied Kirtdoll's motion, ruling that the warrant's other accurate descriptors were particular enough to satisfy the Fourth Amendment. Kirtdoll pleaded guilty but reserved the right to appeal the district court's decision.The United States Court of Appeals for the Sixth Circuit reviewed the warrant's particularity de novo. The court held that the Fourth Amendment does not require perfection in search warrants, but rather enough detail for the executing officer to identify the intended place with reasonable effort. The court found that despite the errors, the warrant contained three descriptors that indisputably applied only to Kirtdoll's house and clearly identified it as the premises to be searched. These included the house's geographic location, a detailed description of the house, and a unique identifier - a red star affixed to its west side. The court concluded that the warrant for Kirtdoll's house was specific enough to meet the Fourth Amendment's particularity requirement, and thus, the district court properly denied Kirtdoll's motion to suppress. The court affirmed the district court's decision. View "United States v. Kirtdoll" on Justia Law

Calvin Caver was sentenced to life imprisonment for conspiring to distribute more than 50 grams of crack cocaine, having committed three prior felony drug offenses. The Fair Sentencing Act of 2010 later increased the amount of crack cocaine required to trigger a life sentence to 280 grams. The First Step Act of 2018 allowed defendants like Caver to seek retroactive relief as if they had committed their crimes after the Fair Sentencing Act. Caver sought a reduced sentence under the First Step Act, but the district court held that the Act gave it no discretion to grant him relief. The court reasoned that Caver's jury had found that his drug crime involved at least 500 grams of crack cocaine, an amount that still exceeded the 280 grams required to trigger a mandatory life sentence after the Fair Sentencing Act.The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court clarified that if the Fair Sentencing Act's changes would still trigger the same mandatory-minimum sentence that a district court originally imposed, a district court lacks discretion to reduce the defendant’s sentence below that minimum under the First Step Act. The court also noted that the First Step Act allows a court to impose a reduced sentence as if the Fair Sentencing Act were in effect at the time the covered offense was committed. The court concluded that no plausible reading of the First Step Act or the caselaw interpreting it permitted the district court to sentence Caver below the mandatory-minimum term that he faced under the Fair Sentencing Act. View "United States v. Caver" on Justia Law

The case involves StarLink Logistics, Inc. ("StarLink") and ACC, LLC ("ACC"). StarLink owns land adjacent to and downstream from ACC's land, where ACC used to operate a landfill for byproducts of aluminum recycling. StarLink alleged that ACC's improperly closed landfill was polluting StarLink’s land. After StarLink initiated its suit, ACC and the Tennessee Department of Environment and Conservation (“Department”) finalized a consent order requiring ACC to abate the landfill’s pollution. The district court dismissed StarLink’s claims for lack of jurisdiction and granted summary judgment to ACC as to its remaining claims.The district court dismissed StarLink’s claims for injunctive and declaratory relief as moot and granted summary judgment to ACC as to StarLink’s claims for civil penalties. The court also dismissed StarLink’s claims for failure to meet the Clean Water Act’s and the Resource Conservation and Recovery Act’s jurisdictional notice requirements.The United States Court of Appeals affirmed in part and reversed in part the district court’s judgment. The court held that StarLink can proceed with Count 2 and to seek remediation of its property for Count 5 of its complaint. As to Counts 1, 3, and 4, the court agreed with the district court’s claim preclusion and notice rulings. The case was remanded for further proceedings consistent with the opinion. View "StarLink Logistics, Inc. v. ACC, LLC" on Justia Law

The case involves the family of Todd Kerchen, who died from a lethal dose of fentanyl. The family filed a complaint against the University of Michigan and Dr. James Woods, alleging violations under 42 U.S.C. § 1983 and Michigan state law. The family claimed that the fentanyl that killed Todd originated from a University of Michigan pharmacology lab where Christian Raphalides, the person who allegedly provided the drug to Todd, worked. The lab was overseen by Dr. Woods. The family argued that the lab's lax policies surrounding the use of controlled substances led to Todd's death.The district court denied the defendants' motion to dismiss and ordered limited discovery on whether the action was barred by the statutes of limitations applicable to the plaintiffs' claims. The defendants appealed this decision.The United States Court of Appeals for the Sixth Circuit reversed the district court's decision. The court found that the University of Michigan and Dr. Woods in his official capacity were entitled to sovereign immunity, barring all claims against them. The court also found that Dr. Woods in his individual capacity was entitled to qualified immunity, barring the § 1983 claim against him. Furthermore, the court found that the wrongful death claim against Dr. Woods in his individual capacity should be dismissed as it was barred by governmental immunity. The court dismissed the remainder of the defendants' appeal for lack of jurisdiction. View "Kerchen v. University of Michigan" on Justia Law

Thabet Mahdi Saleh, an Iraqi refugee, was granted asylum in the United States in 2010. However, after being convicted of crimes under Michigan law, the Department of Homeland Security initiated removal proceedings against him. Saleh sought asylum, withholding of removal, and protection under the Convention Against Torture (CAT), fearing torture if he returned to Iraq due to his work with the U.S. Army and his mixed marriage. The immigration judge denied all forms of relief and ordered Saleh's removal. Saleh did not appeal this decision.In 2018, Saleh moved to reopen his proceedings, seeking deferral of removal under the CAT. He alleged changed country conditions and an increased risk of torture due to his past experiences and criminal convictions in the U.S. The immigration judge granted the motion to reopen but later denied Saleh’s application for relief. Saleh appealed this decision to the Board of Immigration Appeals (BIA), which assumed Saleh’s credibility but found no error in the other decisions, thus denying Saleh’s petition.In the United States Court of Appeals for the Sixth Circuit, Saleh challenged the BIA's decision, arguing that the immigration judge erred by treating a key witness as a fact witness rather than an expert. However, the court found that Saleh's counsel had agreed to this treatment of the witness, and Saleh had not shown that the agency erred by treating the witness as a fact witness only. The court also found that the BIA had properly analyzed Saleh’s probability of torture in the aggregate, considering all the factors together. Therefore, the court denied Saleh's petition for review. View "Mahdi Saleh v. Garland" on Justia Law