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

Joshua Steeb was severely injured after intervening to save his friend, Teresa Fitzgerald, from a violent dog attack at the home of Linda Motter, Fitzgerald’s relative. The dog, known for its aggressive history and previously quarantined by local authorities, was reported to animal control for removal. Officer Mike Ehart, aware of the dog’s past behavior, arrived on the scene but instead of personally handling the dog, he instructed Fitzgerald to retrieve and secure the animal in his truck. Despite Fitzgerald’s apprehension and knowledge of the dog’s dangerous tendencies, she attempted the task and was attacked. Steeb’s attempt to rescue her resulted in the dog mauling him, causing permanent injuries.The United States District Court for the Western District of Michigan reviewed Steeb’s claims under 42 U.S.C. § 1983, which were based on the “state-created-danger” theory of substantive due process. Steeb argued that Officer Ehart’s conduct created or increased the risk that led to the attack and that the City of Battle Creek failed to properly train and equip Ehart. The district court dismissed all federal claims, finding that Steeb had not alleged a plausible constitutional violation. As a result, the court declined to exercise jurisdiction over the related state law claims, dismissing them without prejudice.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s decision. The appellate court held that Steeb failed to plausibly allege that Officer Ehart took an “affirmative act” sufficient to invoke the state-created-danger doctrine, primarily because Fitzgerald voluntarily assumed the risk of handling the dangerous dog. Without a constitutional violation, the municipal liability claim against the City of Battle Creek also failed. The appellate court thus affirmed the dismissal of Steeb’s claims. View "Steeb v. Ehart" on Justia Law

An individual seeking to refinance his mortgage visited a website that offers mortgage information and referrals to affiliated lenders. During three separate visits, he entered personal information and clicked buttons labeled “Calculate” or “Calculate your FREE results.” Immediately below these buttons, the website displayed language in small font stating that clicking would constitute consent to the site’s Terms of Use, which included a mandatory arbitration provision and permission to be contacted by the site or affiliates. The Terms of Use were accessible via a hyperlinked phrase. After using the site, the individual was matched with a particular lender but did not pursue refinancing. Later, he received multiple unwanted calls from the lender and filed a class-action lawsuit under the Telephone Consumer Protection Act, alleging violations such as calling numbers on the Do Not Call registry.The United States District Court for the Eastern District of Michigan initially dismissed the complaint on the merits and denied the lender’s motion to compel arbitration as moot. Upon realizing the arbitration issue should have been decided first, the court reopened the case but found no enforceable agreement to arbitrate existed, denying the motion to compel arbitration. The court also denied reconsideration and allowed the plaintiff to amend his complaint. The lender appealed the denial of arbitration.The United States Court of Appeals for the Sixth Circuit reviewed the denial de novo. It held that, under California law, the website provided reasonably conspicuous notice that clicking the buttons would signify assent to the Terms of Use, including arbitration. The court found that the plaintiff’s conduct objectively manifested acceptance of the offer, forming a binding arbitration agreement. The court also concluded that the agreement was not invalid due to unspecified procedural details and that questions of arbitrability were delegated to the arbitrator. The Sixth Circuit reversed the district court’s decision and remanded for further proceedings. View "Dahdah v. Rocket Mortgage, LLC" on Justia Law

A Kentucky citizen who is subject to lifetime sex offender registration due to prior convictions challenged a new state law requiring certain sex offenders to display their full legal names on social media accounts they create or control. The law defines covered offenses as those committed against minors and applies to a wide range of social media platforms, with exceptions for services such as email and search engines. The plaintiff, who uses social media anonymously for personal and political expression, alleged that the law’s disclosure requirement would subject him and his family to harassment and would force him to stop using social media.The United States District Court for the Western District of Kentucky reviewed the case. Initially, it found the plaintiff was likely to succeed on his claim that the law infringed his First Amendment right to post anonymously and was overbroad, granting a preliminary injunction that barred all Kentucky County Attorneys from enforcing the law. The court later denied class certification, concluding the plaintiff lacked standing to represent absent class members against other County Attorneys and failed to meet requirements for class actions. Consequently, the injunction was narrowed to apply only to the named defendant and protect only the plaintiff.On appeal, the United States Court of Appeals for the Sixth Circuit found the district court erred in its facial overbreadth analysis. The Sixth Circuit held that a proper facial challenge under the First Amendment requires a comprehensive review of the law’s scope and its constitutional and unconstitutional applications, as described in Moody v. NetChoice, LLC. The district court had failed to conduct this thorough analysis and focused too narrowly on the plaintiff’s own circumstances. The Sixth Circuit vacated the preliminary injunction and remanded the case for further proceedings consistent with the proper two-step facial overbreadth approach. View "Doe v. Burlew" on Justia Law

Louis Alford was stopped by Cannon County Sheriff’s Deputies outside Woodbury, Tennessee for minor traffic violations. During the stop, Deputy Deffendoll observed a syringe filled with clear liquid inside Alford’s truck. A subsequent search revealed additional empty syringes, powder in a baggie, paper with residue, empty baggies, prescription pills not belonging to either occupant, and digital scales. Alford was arrested and charged with three state drug offenses. He spent time in jail, and his parole was revoked, resulting in over a year in prison. The drug charges were later dismissed. Forensic analysis showed the powder contained methamphetamine, but other items either contained noncontrolled substances or were not tested.Alford filed suit in the United States District Court for the Middle District of Tennessee against Deputies Deffendoll and Smith, and Cannon County, asserting false arrest, malicious prosecution, and Monell liability under 42 U.S.C. § 1983. After discovery, the district court granted summary judgment to the defendants on the federal claims, finding no genuine issue of material fact as to Smith’s involvement, and that Deffendoll had probable cause for arrest and prosecution. The court also rejected the Monell claim, finding no underlying constitutional deprivation. Alford appealed only the federal claims.On review, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s rulings. The court held that Smith was not personally involved in the arrest, and Deffendoll had probable cause to arrest and charge Alford for simple possession and possession of drug paraphernalia. The court applied the proper summary judgment and qualified immunity standards, and clarified that probable cause existed for the charges that led to Alford’s seizure. Without a constitutional violation, Alford’s Monell claim failed. The court affirmed summary judgment for all defendants. View "Alford v. Deffendoll" on Justia Law

After receiving an anonymous tip, law enforcement in Mercer County, Kentucky, stopped Steven Fellmy, who was driving a silver Ford Mustang matching the tip’s description. The stop was based on observed traffic violations, including a non-illuminated license plate and failure to signal a turn. After backup arrived, Fellmy was asked to exit the vehicle. He declined consent for a search, so a trained drug dog was led around the car. The dog briefly jumped up onto the car door and partially sniffed through the open window, ultimately alerting officers to drugs. A subsequent search revealed methamphetamine and heroin, leading to Fellmy’s arrest and charge for possession of methamphetamine with intent to distribute.The United States District Court for the Eastern District of Kentucky reviewed and denied Fellmy’s pretrial motion to suppress the drugs. The court found that officers lawfully ordered Fellmy out of the vehicle after a valid traffic stop and that the dog’s actions did not constitute an unlawful search because the officers did not encourage the dog to intrude into the car’s interior. The court also denied Fellmy’s motion in limine to exclude the drug evidence, ruling that concerns about authentication and chain of custody went to the weight of the evidence, not its admissibility, and could be addressed during cross-examination. The drugs were admitted, and Fellmy was convicted by jury and sentenced to 300 months’ imprisonment.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s rulings. The Sixth Circuit held that ordering Fellmy out of the car after a valid stop was lawful and that the dog’s brief contact with the car did not amount to a Fourth Amendment search under prevailing legal standards. The court also held that the district court did not abuse its discretion in admitting the drug evidence or in denying an evidentiary hearing regarding the chain of custody. The conviction and sentence were affirmed. View "United States v. Fellmy" on Justia Law

Michael Victor was detained overnight in an Otsego County, Michigan jail after being arrested for disorderly conduct and resisting an officer. Victor, who has epilepsy, did not receive his prescribed anti-seizure medication while in custody, despite his mother delivering it to the jail and officers being informed of his medical needs. The jail’s procedures required officers to contact an on-call medical provider from Advanced Correctional Healthcare (ACH) before administering any medication. After his release the next morning, Victor suffered a seizure, resulting in significant injuries.The United States District Court for the Eastern District of Michigan heard Victor’s civil rights suit against ACH and Nurse Kimberly Reynolds. At trial, Victor presented evidence including testimony from officers and medical staff, but no one recalled making or receiving a call to ACH regarding his medication, and no records indicated any such contact. The jury found in favor of Reynolds but against ACH, awarding Victor economic, noneconomic, and punitive damages. ACH moved for judgment as a matter of law or a new trial, arguing insufficient evidence that any officer contacted ACH. The district court granted ACH’s motions, holding there was not enough evidence for a reasonable jury to find that contact occurred, and also denied Victor’s request for sanctions related to alleged discovery violations.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed whether Victor had presented sufficient evidence to allow a reasonable jury to find that an officer had contacted ACH about his medication needs. The court held that the absence of any records and the lack of recollection from all involved witnesses meant Victor had not met his burden. Testimony indicating intent to call, without corroboration, was not enough. The Sixth Circuit affirmed the district court’s judgment as a matter of law for ACH and found no abuse of discretion in denying sanctions. View "Victor v. Reynolds" on Justia Law

A parent enrolled his teenage son, who had a history of serious behavioral and mental health issues, in a residential treatment center after other interventions failed. The family’s health insurer initially approved and paid for the first 21 days of residential treatment, then denied further coverage, asserting that the treatment was no longer medically necessary. The parent appealed this decision through the insurer’s internal process, submitting medical records and opinions from the child’s treating clinicians that supported the need for continued residential care. The insurer upheld its denial after cursory reviews that did not address the treating clinicians’ recommendations or key evidence of the child’s ongoing difficulties.The parent filed suit in the United States District Court for the Western District of Kentucky, alleging that the insurer’s denial was arbitrary and capricious under the Employee Retirement Income Security Act (ERISA) and violated the Mental Health Parity and Addiction Equity Act. The district court granted summary judgment to the insurer on both claims, finding that the decision to deny coverage was not arbitrary and capricious and that there was no evidence of a parity violation.On appeal, the United States Court of Appeals for the Sixth Circuit found that the insurer’s coverage decision was procedurally arbitrary and capricious, as it failed to consider the treating clinicians’ opinions, selectively reviewed the medical record, and did not adequately explain its change from initially approving coverage to denying it. The appellate court vacated the district court’s judgment on the ERISA claim and remanded with instructions to send the matter back to the insurer for a full and fair review. However, it affirmed the district court’s judgment on the Parity Act claim, holding that the parent failed to produce evidence showing that the insurer’s limitations on mental health treatment were more restrictive than those applied to medical or surgical benefits. View "T. E. v. Anthem Blue Cross Blue Shield" on Justia Law

The case concerns a defendant who became involved in a drug conspiracy in Cleveland, Ohio, during 2022 and 2023. Law enforcement conducted controlled buys and wiretaps, ultimately finding that the defendant sold significant quantities of fentanyl pills, including to an undercover agent. Upon his arrest in November 2023, authorities found illegal narcotics in his vehicle and other locations. The defendant was charged with conspiracy to distribute controlled substances, and the government alleged he had a prior “serious drug felony” conviction from April 2023, which could enhance his statutory minimum sentence under federal law.Previously, the United States District Court for the Northern District of Ohio found that the defendant’s April 2023 conviction met the criteria for a “serious drug felony.” After holding an evidentiary hearing, the district court overruled the defendant’s objections, rejected his constitutional arguments regarding jury findings, found the prior conviction final before the current offenses, and determined it lacked authority to review the prosecutor’s discretion in seeking the enhancement. The district court also applied a career-offender enhancement based on prior convictions, resulting in a guidelines range of 262 to 327 months, but ultimately varied downward and sentenced the defendant to 160 months. The defendant appealed, renewing his challenges.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s rulings. The appellate court held that any alleged error in not submitting the statutory enhancement facts to a jury was harmless beyond a reasonable doubt, as the defendant had admitted the relevant facts and would have pleaded guilty regardless. The court also held that the prosecution’s decision to seek the statutory enhancement was within its discretion and not arbitrary or vindictive, and that the prior conviction was “final” under existing precedent. Finally, the court rejected the defendant’s challenge to the career-offender enhancement, finding it foreclosed by circuit precedent. The judgment was affirmed. View "United States v. Loines" on Justia Law

Alliance Data Systems, a company based in Columbus, Ohio, faced mounting debt and responded by selling off side businesses, including spinning off its LoyaltyOne division into a standalone company called Loyalty Ventures Inc. Prior to and during the spinoff, executives publicly described LoyaltyOne’s Canadian AIR MILES program as having strong, long-term sponsor relationships. However, in the period leading up to and following the spinoff, AIR MILES lost several major sponsors, including its second largest, Sobeys, which announced its intention to exit the program shortly before the sponsor’s contract allowed. Loyalty’s financial condition deteriorated, leading to its bankruptcy about a year and a half after the spinoff.Investors, specifically two funds managed by Newtyn Management, brought a class action in the United States District Court for the Southern District of Ohio. They alleged that Alliance Data Systems and individual executives committed securities fraud by making misleading statements or omissions about AIR MILES’s sponsor relationships and LoyaltyOne’s financial health, in violation of Section 10(b) of the Exchange Act and Rule 10b-5. The district court dismissed the complaint, finding that Newtyn had not adequately alleged any actionable misrepresentation or omission, nor had it sufficiently pled that the defendants acted with scienter (intent to defraud).On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s dismissal de novo. The Sixth Circuit affirmed, holding that the statements cited by Newtyn were either immaterial puffery, accurate historical statements, or accompanied by sufficient cautionary language such that no reasonable investor would have been misled. The court also determined that Newtyn failed to plead a strong inference of scienter and that its related scheme liability and control person claims could not survive absent a primary violation. The judgment dismissing the complaint was affirmed. View "Newtyn Partners, LP v. Alliance Data Systems Corp." on Justia Law

Between June 2022 and February 2023, two individuals participated in a conspiracy to distribute methamphetamine in Tennessee. One defendant regularly supplied methamphetamine, while the other purchased and resold it. Law enforcement surveilled their activities, conducted searches, and utilized confidential sources to purchase drugs from both parties. Both defendants gave statements to investigators about the extent and nature of their drug transactions.The United States District Court for the Eastern District of Tennessee charged each defendant with multiple counts related to methamphetamine distribution. Both pled guilty to lesser offenses in exchange for dismissal of other charges. The court calculated each defendant’s sentencing range using drug quantity estimates derived from statements and physical evidence. One defendant objected to the amount attributed, arguing that the calculation relied on unreliable statements and overstated her culpability. Despite objections, the court imposed a sentence within the adjusted Guidelines range. The other defendant requested a downward variance based on age, health, and criminal history, but the court denied this, citing insufficient evidence of mitigating circumstances.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed both sentences for procedural and substantive reasonableness under the abuse of discretion standard. The court held that the sentence for the first defendant was procedurally unreasonable because the district court relied on an uncorroborated out-of-court statement to estimate drug quantity, lacking sufficient indicia of reliability. The court reversed her sentence and remanded for resentencing, restricting the government from introducing new evidence. For the second defendant, the court found the sentence both procedurally and substantively reasonable, affirming the district court’s decision. Thus, the appellate court reversed and remanded for one defendant, and affirmed for the other. View "United States v. Crafton" on Justia Law