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

Victor Silvers was convicted of the premeditated murder of his estranged wife, Brittney Silvers, who was an active member of the United States Army, and was shot and killed at Fort Campbell, Kentucky. Silvers was also found guilty of attempted murder, domestic violence, violation of a protection order, possession of a firearm by a prohibited person, and the use of a firearm during a crime of violence. He was sentenced to life in prison.The United States District Court for the Western District of Kentucky took judicial notice that Fort Campbell was within the United States' special maritime and territorial jurisdiction. Silvers challenged this, arguing that the jury should have determined the jurisdictional status. He also moved to exclude a juror who wore a shirt supporting military veterans and had served in the Navy, claiming potential bias. Additionally, Silvers argued that his mandatory life sentence was unconstitutional under the Eighth Amendment.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the district court did not err in taking judicial notice of the jurisdictional status of Fort Campbell, as it was a legal question rather than a factual one for the jury. The court also found no abuse of discretion in the district court's decision to deny Silvers's motion to exclude the juror, as the juror assured impartiality and the voir dire process was deemed adequate. Finally, the court upheld Silvers's mandatory life sentence, citing binding Supreme Court precedent and the Sixth Circuit's own precedent, which did not find such sentences to be cruel and unusual punishment.The Sixth Circuit affirmed both Silvers's conviction and his sentence. View "United States v. Silvers" on Justia Law

Armani Davis-Malone, while on probation for credit-card fraud, began selling prescription pills in Detroit, Michigan. Law enforcement, alerted by an informant, conducted two controlled buys where Davis-Malone sold oxycodone to an undercover agent. Subsequently, federal agents searched his car, finding a fully automatic handgun, over 100 oxycodone pills, and 200 grams of marijuana. Davis-Malone was charged with possessing a firearm as a felon and pleaded guilty. The district court sentenced him to 60 months, below the guidelines range of 70 to 87 months.The Sentencing Commission later amended the guidelines, reducing Davis-Malone’s range to 57 to 71 months. Davis-Malone sought a sentence reduction under 18 U.S.C. § 3582(c)(2), supported by a probation officer’s report and a joint stipulation from both parties recommending a 57-month sentence. Despite this, the district court denied the reduction, stating that the original 60-month sentence was near the lower end of the amended range.The United States Court of Appeals for the Sixth Circuit reviewed the case. Davis-Malone argued that the district court erred legally by finding him ineligible for a reduction and abused its discretion by not providing a detailed explanation. The Sixth Circuit found that the district court did not commit a legal error, interpreting the order as a discretionary denial rather than a finding of ineligibility. The court also held that the district court did not abuse its discretion, as it had considered the relevant factors and the simple facts of the case justified the use of a form order. The Sixth Circuit affirmed the district court’s decision. View "United States v. Davis-Malone" on Justia Law

George Short was observed by police driving 25 miles per hour over the speed limit and without a car hood. When officers attempted to stop him, he led them on a high-speed chase. Upon his arrest, a rifle was found in his car. Due to his prior felony convictions, Short was charged with being a felon in possession of a firearm and subsequently pled guilty. He was sentenced as an armed career criminal under the Armed Career Criminal Act (ACCA) due to his prior violent felonies.The United States District Court for the Eastern District of Tennessee at Greeneville handled the initial proceedings. Short objected to the ACCA enhancement, arguing that the factual basis for his plea did not include an admission that his prior felonies were committed on separate occasions, as required by the ACCA. The district court overruled his objection, relying on Sixth Circuit precedent that allowed the court to determine whether the prior felonies were committed on different occasions.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the district court did not err in accepting Short’s guilty plea despite the written factual basis not mentioning the separate occasions element. The court found that the indictment, presentence report (PSR), and sentencing hearing provided sufficient evidence that Short’s prior felonies were committed on separate occasions. The court emphasized that Rule 11(b)(3) does not require every element to be included in the written factual basis, and the entire record can be considered to determine if there is a sufficient factual basis for the plea. Consequently, the Sixth Circuit affirmed Short’s ACCA conviction and sentence. View "United States v. Short" on Justia Law

Donald Hunter, a former coal miner, applied for benefits under the Black Lung Benefits Act (BLBA) in 2019, claiming that he was totally disabled due to chronic obstructive pulmonary disease (COPD) caused by his coal mine employment. Southern Ohio Coal Company, his former employer, contested his claim, arguing that Hunter's COPD was caused by his significant history of smoking cigarettes rather than coal mine dust exposure.An Administrative Law Judge (ALJ) reviewed the case and awarded benefits to Hunter, finding that his COPD constituted legal pneumoconiosis and that it was a substantially contributing cause of his total disability. Southern Ohio Coal appealed to the Benefits Review Board (BRB), arguing that the ALJ erred in discrediting its evidence and in crediting Hunter's evidence. The BRB affirmed the ALJ's decision, holding that the ALJ had properly considered and weighed the evidence.The United States Court of Appeals for the Sixth Circuit reviewed the case. Southern Ohio Coal argued that the ALJ erred by relying on a pulmonary function test (PFT) that did not comply with regulatory quality standards and by relieving Hunter of his burden to establish entitlement to benefits. The court found that the ALJ acted within his discretion in determining that the PFT was compliant and supported Hunter's entitlement to benefits. The court also held that the ALJ did not improperly rely on regulatory guidance or flip the burden of proof to Southern Ohio Coal. The ALJ's decision was supported by substantial evidence, including expert opinions and Hunter's testimony.The Sixth Circuit denied the petition for review, affirming the ALJ's decision to award benefits to Hunter. The court held that the ALJ correctly applied the law and that his decision was supported by substantial evidence. View "Southern Ohio Coal Co. v. Office of Workers' Compensation Programs" on Justia Law

In 2018, Alexander Sittenfeld, a Cincinnati city council member, was involved in a scheme where he solicited campaign donations in exchange for promises of official action. Sittenfeld had conversations with Chinedum Ndukwe, a local developer working with the FBI, and undercover agents posing as investors. Sittenfeld solicited donations from Ndukwe and later from an undercover agent, Rob, in exchange for supporting a property development project at 435 Elm Street. Despite the conversations being recorded, the evidence was not overwhelming. However, a jury found that Sittenfeld solicited or accepted campaign donations in exchange for his promise to support the project.The United States District Court for the Southern District of Ohio convicted Sittenfeld of attempted Hobbs Act extortion and federal-program bribery. Sittenfeld moved for a judgment of acquittal and a new trial, arguing insufficient evidence and constructive amendment of the indictment. The district court denied both motions and sentenced Sittenfeld to sixteen months' imprisonment.The United States Court of Appeals for the Sixth Circuit reviewed the case. Sittenfeld argued that the evidence was insufficient to prove an explicit quid pro quo and that the indictment was constructively amended. The court held that the evidence, when viewed in the light most favorable to the prosecution, was sufficient for a rational jury to find Sittenfeld guilty beyond a reasonable doubt. The court also found that the jury instructions, although broader than the indictment, did not result in a constructive amendment. The court affirmed Sittenfeld's conviction, concluding that the evidence supported the jury's verdict and that there was no substantial likelihood that Sittenfeld was convicted of an offense not charged in the indictment. View "United States v. Sittenfeld" on Justia Law

Derek Kramer, the plaintiff, joined American Electric Power Service Corporation (AEP) in 2018 and later participated in the AEP Executive Severance Plan. In 2020, AEP terminated Kramer’s employment due to his executive assistant’s misuse of a company credit card and Kramer’s alleged interference with an investigation into his company-issued cell phone. Kramer applied for severance benefits under the Plan, but AEP denied his claim, citing termination for cause. Kramer appealed the decision, but the Plan’s appeal committee upheld the denial.Kramer then filed an ERISA action in the United States District Court for the Southern District of Ohio, seeking benefits and alleging interference. He also demanded a jury trial. The district court struck his jury demand, limited discovery to procedural claims, and denied his motion to compel the production of documents protected by attorney-client privilege. The court ultimately granted judgment in favor of AEP and the Plan, finding that the denial of benefits was not arbitrary and capricious.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court’s rulings, holding that the Plan was a top-hat plan exempt from ERISA’s fiduciary requirements, thus the fiduciary exception to attorney-client privilege did not apply. The court also upheld the district court’s decision to strike Kramer’s jury demand, citing precedent that ERISA denial-of-benefits claims are equitable in nature and not subject to jury trials. Finally, the court found that the district court correctly applied the arbitrary-and-capricious standard in reviewing the denial of benefits and that the decision was supported by substantial evidence. The Sixth Circuit affirmed the district court’s judgment in favor of AEP and the Plan. View "Kramer v. American Electric Power Service Corp. Executive Severance Plan" on Justia Law

Javi Porter, a lawful permanent resident of the United States and a native of Jamaica, was convicted under Virginia law for possessing with intent to distribute methamphetamine. The Department of Homeland Security (DHS) classified this conviction as an aggravated felony and initiated removal proceedings against him. Porter sought review of the final order of the Board of Immigration Appeals (BIA), which affirmed an immigration judge’s (IJ) denial of his motion to terminate removal proceedings and found him removable as an aggravated felon.The IJ denied Porter’s motion to terminate the removal proceedings, concluding that DHS had proven by clear and convincing evidence that Porter was convicted of an aggravated felony. The IJ sustained the charge of removability and denied Porter’s subsequent motion for reconsideration. The IJ later issued a final summary order finding Porter removable as charged. Porter appealed to the BIA, arguing that the IJ erred in denying his motion to terminate the removal proceedings.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Porter’s Virginia drug-trafficking conviction qualifies as an aggravated felony under the Immigration and Nationality Act (INA). The court found that the Virginia statute under which Porter was convicted is divisible by the identity of the controlled substance and applied the modified categorical approach. The court concluded that possession with intent to distribute any amount of methamphetamine is a federal felony under the Controlled Substances Act (CSA). Therefore, Porter’s conviction under Virginia law is a categorical match to a felony offense under the CSA, rendering him removable under 8 U.S.C. § 1227(a)(2)(A)(iii). The court denied Porter’s petition for review. View "Porter v. Bondi" on Justia Law

Quincy Taylor was convicted by a jury of possession of a controlled substance with intent to distribute, possession of a firearm in furtherance of drug trafficking, and being a felon in possession of a firearm. The charges stemmed from an incident where Taylor was involved in a car accident, and a witness, William Howell, testified that Taylor had a bag containing drugs and a firearm. Howell's testimony was the only evidence linking Taylor to the contraband.The United States District Court for the Eastern District of Kentucky limited Taylor's ability to cross-examine Howell about his criminal history and potential bias. Specifically, the court allowed Taylor to ask if Howell had any felony convictions but prohibited questions about the nature of the conviction, Howell's pending felon-in-possession charge, and any benefits Howell might receive for his cooperation. Taylor argued that these limitations violated his Confrontation Clause rights under the Sixth Amendment.The United States Court of Appeals for the Sixth Circuit reviewed the case and found that the district court's limitations on cross-examination violated Taylor's constitutional right to confront witnesses. The court determined that the jury did not have sufficient information to assess Howell's potential bias and motive for testifying. The court also found that the error was not harmless, as Howell's testimony was crucial to the prosecution's case, and there was no other evidence linking Taylor to the contraband.As a result, the Sixth Circuit reversed Taylor's convictions and remanded the case for a new trial, holding that the district court's limitations on cross-examination violated Taylor's Confrontation Clause rights and that the error was not harmless. View "United States v. Taylor" on Justia Law

Edna Napier, a former cashier and certified nursing assistant, applied for disability insurance benefits due to severe physical conditions and mental impairments, including depression and anxiety. Her initial application was denied by the Social Security Administration (SSA) in 2018. Napier filed a new application in December 2019, claiming she had been unable to work since December 2018. An administrative law judge (ALJ) held an evidentiary hearing and concluded that Napier was not disabled under the Social Security Act, finding that her mental impairments were mild and her physical impairments did not prevent her from performing her past work as a cashier.The United States District Court for the Eastern District of Kentucky affirmed the ALJ's decision. Napier appealed, arguing that the ALJ erred in assessing the severity of her mental impairments and failed to account for them in her residual functional capacity (RFC) analysis.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the ALJ's decision was supported by substantial evidence and complied with proper legal standards. The ALJ had considered Napier's testimony, her limited treatment history for mental impairments, and the opinions of several psychologists. The ALJ found that Napier's mental impairments were not severe and that her physical impairments did not preclude her from performing her past work. The court also found that the ALJ adequately accounted for Napier's mental impairments in the RFC analysis.The Sixth Circuit affirmed the district court's judgment, concluding that the ALJ's findings were supported by substantial evidence and that the ALJ had followed the appropriate procedures in evaluating Napier's claims. View "Napier v. Commissioner of Social Security" on Justia Law

In March 2020, Andrew Cooperrider, owner of Brewed, a coffee shop and bar in Lexington, Kentucky, criticized Governor Beshear’s COVID-19 policies on social media. In November 2020, the Kentucky Department of Alcoholic Beverage Control (DABC) suspended Brewed’s alcohol license, and officially revoked it in March 2022. Cooperrider filed a lawsuit against Governor Beshear, DABC officials, and other state officials, alleging First Amendment retaliation and due-process violations, claiming the license revocation was in retaliation for his critical speech.The United States District Court for the Eastern District of Kentucky dismissed the case, granting the defendants' motions to dismiss. The court found that most of Cooperrider’s claims were barred by absolute, qualified, and sovereign immunity. It also determined that Cooperrider’s remaining substantive-due-process claim did not meet the Rule 12(b)(6) pleading standard.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court’s dismissal of most claims, agreeing that the defendants were protected by absolute, qualified, and sovereign immunity. However, the appellate court found that the district court improperly granted qualified immunity to Governor Beshear, Ray Perry, and Wesley Duke regarding Cooperrider’s First Amendment retaliation claim. The appellate court held that Cooperrider had plausibly alleged that the enforcement action against Brewed was motivated by his protected speech. Consequently, the court reversed the district court’s decision on this point and remanded the case for further proceedings on the First Amendment retaliation claim. View "Cooperrider v. Woods" on Justia Law