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

Donald Sims was serving a term of supervised release after a prior federal conviction for being a felon in possession of a firearm, following an earlier similar conviction. After his release from prison in 2021, Sims initially showed signs of improvement, including negative drug tests and stable employment. However, he later admitted to drug use and, in 2024, was found by police to be in possession of cocaine and drug paraphernalia during a traffic stop. Sims pleaded guilty in state court to felony cocaine possession and received a nine-month sentence. His probation officer then cited him for violating his supervised release by unauthorized drug use, cocaine possession, and failure to report police contact.The United States District Court for the Northern District of Ohio conducted a revocation hearing. Sims admitted violating his supervised release but denied ownership of the cocaine. The district court found his denial not credible, citing his guilty plea and the circumstances of the stop. Although the advisory Sentencing Guidelines range was seven to thirteen months, the court imposed an 18-month sentence to run consecutive to his state sentence, citing Sims’s pattern of violations and the need for deterrence. Defense counsel objected to the upward variance.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed whether the sentence was procedurally and substantively reasonable. The Sixth Circuit held that the district court did not commit procedural error by considering Sims’s state sentence or by finding that his conduct amounted to trafficking based on the evidence. The court also found that the district court adequately explained its reasons for an above-Guidelines sentence and properly weighed the relevant sentencing factors. The Sixth Circuit affirmed the district court’s judgment, holding that the 18-month consecutive sentence was both procedurally and substantively reasonable. View "United States v. Sims" on Justia Law

A native and citizen of Honduras fled to the United States in 2016 after members of the MS gang targeted him and his brother, allegedly due to their refusal to join the gang. After suffering threats, extortion, and a kidnapping in Honduras, he relocated within the country but continued to receive threats. Fearing for his safety, he eventually left for the United States, where his family later joined him. He expressed fear that returning to Honduras would result in serious harm or death at the hands of the gang.Removal proceedings were initiated against him by the Department of Homeland Security, and an Immigration Judge (IJ) found him removable. He applied for asylum, withholding of removal, and protection under the Convention Against Torture (CAT), but his asylum application was filed about fourteen months late. At his merits hearing, the IJ found his testimony credible but determined that he had not demonstrated exceptional circumstances justifying the late filing. The IJ denied his asylum application as untimely and also denied his applications for withholding of removal and CAT protection, finding that the harm he suffered was not severe enough to constitute persecution and that he failed to show a nexus between the harm and the proposed social groups. The IJ further noted he did not demonstrate the Honduran government was unable or unwilling to protect him.The Board of Immigration Appeals (BIA) affirmed the IJ’s decision, determining that he had not established extraordinary circumstances for the asylum application’s untimeliness, and that he had waived his CAT claim and the issue of government protection by failing to meaningfully challenge these findings before the Board.On review, the United States Court of Appeals for the Sixth Circuit held that it lacked jurisdiction to review the BIA’s discretionary determination regarding extraordinary circumstances under 8 U.S.C. § 1158(a)(2)(D) and found that the petitioner had forfeited the necessary government protection element for withholding of removal. The court denied the petition in part and dismissed in part. View "Osabas-Rivera v. Bondi" on Justia Law

Federal agents, while investigating a drug conspiracy in 2019, intercepted two parcels containing nearly five kilograms of methamphetamine addressed to the defendant’s residence. An undercover agent delivered these parcels, which the defendant accepted. Postal records indicated she had received seven similar parcels over several months. The defendant was arrested and indicted along with others involved in the conspiracy. Her admitted role was accepting the drug parcels and turning them over to co-conspirators.The defendant pled guilty to conspiracy to distribute controlled substances. At her sentencing in the United States District Court for the Middle District of Tennessee, the judge considered her difficult background, resilience, and family responsibilities, ultimately imposing a sentence of 12 months, well below the guideline range of 57 to 71 months. The court granted her a delayed prison report date, but she failed to report as ordered. After her failure to surrender, she was charged with criminal contempt under 18 U.S.C. § 401(3), pled guilty, and was sentenced to 11 months for contempt, to run consecutively to her prior sentence.The United States Court of Appeals for the Sixth Circuit reviewed the procedural and substantive reasonableness of the contempt sentence. The court held that to determine whether contempt is a felony for sentencing purposes, the conduct underlying the contempt must be compared to analogous federal offenses. Here, the defendant’s conduct—failing to surrender for service of sentence—was identical to the felony described in 18 U.S.C. § 3146, and thus, the district court properly applied the felony guideline §2J1.6. The appellate court also found the district court’s analysis of the sentencing factors thorough and appropriate. The judgment of the district court was affirmed. View "United States v. Owens" on Justia Law

The case concerns two decisions made by the Environmental Protection Agency (EPA) regarding air quality standards in the Detroit area under the Clean Air Act (CAA). Michigan sought to redesignate the Detroit area from nonattainment to attainment for the 2015 ozone National Ambient Air Quality Standards (NAAQS), relying on air quality data from 2019–2021. However, in June 2022, the area recorded exceedances attributed to wildfire smoke from Canada. Michigan requested the EPA to exclude these exceptional-event data points. Meanwhile, Detroit missed its attainment deadline and was reclassified from Marginal to Moderate nonattainment, triggering additional requirements for Reasonably Available Control Technology (RACT) implementation.After Detroit missed its attainment deadline, the EPA finalized its determination of nonattainment and reclassified the area as Moderate nonattainment, setting deadlines for Michigan to submit RACT revisions. Michigan submitted its redesignation request before these RACT requirements became effective. The EPA later approved Michigan’s exceptional-events request and redesignated Detroit to attainment, despite Michigan not having implemented the newly required RACT measures for Moderate nonattainment areas. Sierra Club challenged both the EPA’s approval of the exceptional-event exclusion and the subsequent redesignation.The United States Court of Appeals for the Sixth Circuit reviewed both EPA actions. The court held that the EPA’s approval of Michigan’s exceptional-event request was not arbitrary or capricious, finding that the agency had adequately explained its reasoning and considered the relevant data linking wildfire smoke to the ozone exceedances. However, the court vacated the EPA’s redesignation of Detroit to attainment, holding that the CAA requires a state to satisfy all requirements applicable at the time of redesignation, not merely those in effect when the redesignation request was submitted. Because Michigan had not met the RACT requirements by the time of redesignation, the EPA’s action was contrary to law. Thus, the approval of the exceptional-event request was affirmed, and the redesignation was vacated. View "Sierra Club v. Environmental Protection Agency" on Justia Law

Gene Roper, a convicted sex offender, was required to register his location under the Sex Offender Registration Notification Act due to a prior conviction for attempted lewdness with a child under 14. After repeated violations of registration requirements and additional criminal conduct, including multiple failures to register, resisting arrest, and battery, Roper moved from Nevada to Tennessee without notifying authorities, resulting in his fourth failure-to-register offense. His history also included significant mental health challenges, homelessness, and substance abuse issues.The United States District Court for the Eastern District of Tennessee accepted Roper’s guilty plea to the federal failure-to-register charge. At sentencing, the court imposed a 30-month prison term, which Roper did not appeal. However, the court also ordered a 20-year term of supervised release, exceeding the five-year period recommended by the Sentencing Guidelines but remaining under the statutory maximum of life. The district court justified this decision by referencing Roper’s mental health needs, criminal history, repeated noncompliance with prior supervision, and risk to public safety. The court also ordered conditions such as mental health treatment and substance abuse testing.Roper appealed to the United States Court of Appeals for the Sixth Circuit, arguing that the district court erred procedurally by relying on his mental illness to lengthen his supervised release, and that the sentence was substantively unreasonable. The Sixth Circuit held that it was permissible for the district court to consider mental health issues as one factor among several when determining the length of supervised release. The appellate court found no abuse of discretion in the district court’s justification and affirmed the 20-year term, concluding that it was reasonable under the circumstances and did not violate statutory or constitutional limits. View "United States v. Roper" on Justia Law

Three citizens of El Salvador entered the United States in 2014 and were subsequently placed in removal proceedings by the Department of Homeland Security. They conceded removability but applied for asylum, withholding of removal, and protection under the Convention Against Torture. The immigration judge denied all three forms of relief.The petitioners appealed the immigration judge’s decision to the Board of Immigration Appeals (BIA), indicating their intention to file a supporting brief. Their attorney filed a notice of appearance using a post office box as her address. The BIA granted an extension to file the brief, and on the new deadline, the petitioners submitted their brief, but it listed the attorney’s physical address instead of the post office box. The BIA rejected the brief due to the address discrepancy and instructed the petitioners to file with the correct address. The petitioners re-filed the brief with the post office box address, but the BIA rejected it as untimely and required a motion for late filing. The petitioners complied, but the BIA ultimately denied their motion, finding their rationale insufficient, and later summarily dismissed the appeal because no timely brief had been filed.The United States Court of Appeals for the Sixth Circuit reviewed the BIA’s actions for abuse of discretion. The court held that the BIA abused its discretion by rejecting the timely brief based on an address discrepancy that was not mandated by regulation or the BIA’s published procedures. The court further held that summarily dismissing the appeal for failure to file a brief, when a timely brief had in fact been submitted, was irrational and an unexplained departure from established policies. The Sixth Circuit granted the petition for review and reversed the BIA’s order. View "Pineda-Guerra v. Bondi" on Justia Law

A fire at a property in Washington, D.C. in 2015 resulted in the deaths of two tenants. The parents of the tenants sued both the property’s record owner, Len Salas, and his father, Max Salas, who managed the property, for wrongful death in a D.C. trial court. The jury found both defendants jointly and severally liable and awarded multimillion-dollar verdicts. After the verdict, both Len and Max filed for bankruptcy in different jurisdictions. In Max’s bankruptcy case, the court held he was entitled to an unlimited homestead exemption in the property. Subsequently, in Len’s bankruptcy case in Tennessee, the estate’s interest in certain avoidance and recovery rights under the Bankruptcy Code was sold at auction, with the plaintiffs purchasing those rights.The plaintiffs then filed an adversary proceeding in the United States Bankruptcy Court for the Middle District of Tennessee, seeking to avoid transfers and recover property. The bankruptcy court denied their motion for summary judgment and granted partial summary judgment to Max on the fraudulent conveyance claims. Plaintiffs sought and received leave from the United States District Court for the Middle District of Tennessee to pursue an interlocutory appeal. The district court affirmed the bankruptcy court’s partial grant and denial of summary judgment and remanded the case for further proceedings, but did not certify the order for appeal or designate it as a final order.On appeal, the United States Court of Appeals for the Sixth Circuit found that it lacked jurisdiction. The court determined that because the district court’s order was neither final nor properly certified for interlocutory appeal, it could not exercise appellate jurisdiction under the relevant statutes. As a result, the Sixth Circuit dismissed the appeal for lack of jurisdiction. View "Brekelmans v. Salas" on Justia Law

An individual received health insurance through his employer, with the plan administered by a third-party insurer. After being injured in a car accident, he recovered damages from the other driver’s employer and, based on communications from his insurer and its agent, paid $25,000 in reimbursement to the plan. He later learned that the full plan document did not contain a reimbursement obligation, contrary to what was represented in the summary plan description. A similar situation occurred when his wife was injured in a separate accident; litigation in state court ultimately resulted in a declaratory judgment that the plan did not provide for reimbursement, and this was affirmed on appeal.The individual then sued the insurer, its agent, and his employer in federal court under the Employee Retirement Income Security Act of 1974 (ERISA), alleging he was defrauded into paying reimbursement. The United States District Court for the Northern District of Ohio dismissed most claims, but allowed one ERISA claim under § 1132(a)(3) to proceed. While his federal appeal was pending, the plaintiff filed state law claims in state court, which were removed to federal court. The district court held that these state law claims were completely preempted by ERISA and dismissed the action, reasoning that the claims were duplicative of the pending federal lawsuit and arose from the same events.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s dismissal. The appellate court held that the plaintiff’s state law claims were completely preempted by ERISA under the standard articulated in Aetna Health Inc. v. Davila, because the claims sought relief for benefits allegedly due under the terms of an ERISA-governed plan and did not rely on a legal duty independent of ERISA or the plan. The court further concluded that dismissal, rather than remand or amendment, was appropriate due to the duplicative nature of the proceedings. View "Patterson v. UnitedHealth Group, Inc." on Justia Law

A Salvadoran woman and her two daughters entered the United States unlawfully after the woman, who owned a beauty salon in El Salvador, was allegedly threatened by men she believed to be gang members. She claimed that after paying them “rent” for two years, she stopped making payments and was threatened with violence. Fearing for her safety and that of her daughters, she sought asylum, withholding of removal, and protection under the Convention Against Torture (CAT) in the United States, arguing she would be targeted in El Salvador as a Salvadoran woman and as a business owner.An immigration judge denied her applications, finding her not credible and concluding she had not established membership in a legally cognizable particular social group (PSG), nor shown that she could not reasonably relocate within El Salvador to avoid harm. The immigration judge also determined she failed to meet the standards for withholding of removal and CAT protection. The Board of Immigration Appeals affirmed, agreeing that her proposed PSGs—“Salvadoran women,” “single Salvadoran women who are working professionals,” and “salon owners in El Salvador”—were not cognizable and that she could reasonably relocate. The Board also upheld the denial of her CAT claim, finding no particularized threat or evidence of government acquiescence.The United States Court of Appeals for the Sixth Circuit reviewed the case and denied the petition for review. The court held that none of the proposed PSGs were sufficiently particular or socially distinct to qualify under the relevant statutes and precedent. The court further concluded that substantial evidence supported the Board’s finding that the petitioner could reasonably relocate within El Salvador and that she had not demonstrated a likelihood of torture with government acquiescence necessary for CAT relief. View "Cristales-de Linares v. Bondi" on Justia Law

An elected county commissioner was arrested during a public board meeting after she repeatedly interrupted the reading of a letter that criticized her prior statements about alleged inmate mistreatment in the county jail. The commissioner, known for her confrontational stance toward her fellow commissioners and county officials, objected to the letter being read without prior notice and continued to speak over the clerk despite warnings and calls to order from her colleagues. Two sheriff’s deputies present as security arrested her for disrupting a lawful meeting under an Ohio statute. She was processed and released the same day, and the criminal complaint was later dismissed.The United States District Court for the Northern District of Ohio granted partial summary judgment in favor of the commissioner on her federal claims for First Amendment retaliation and Fourth Amendment unlawful seizure, and denied qualified immunity and statutory immunity to the defendants on these claims and related state-law claims for false arrest and civil conspiracy. The defendants, including the deputies, fellow commissioners, and sheriff, appealed the denial of immunity.The United States Court of Appeals for the Sixth Circuit held that the deputies had probable cause to arrest the commissioner for disrupting the meeting, and thus all defendants were entitled to qualified immunity on the Fourth Amendment claim. The court also concluded that only the deputies were personally involved in the arrest for purposes of individual First Amendment liability and that the presence of probable cause generally precluded the First Amendment retaliatory arrest claim, but remanded for the district court to consider whether exceptions to this rule applied. Regarding the state-law claims, the court affirmed the denial of statutory immunity, finding genuine issues of material fact as to whether the defendants acted in bad faith by allegedly conspiring to arrest the commissioner in retaliation for her speech. The case was remanded for further proceedings. View "Frenchko v. Monroe" on Justia Law