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

Broadgate, Inc. employed an H-1B visa holder who filed a complaint with the Department of Labor’s Wage and Hour Division in February 2018, alleging that Broadgate had not paid him the full wages required by the Immigration and Nationality Act. The Division’s investigation substantiated the claim and found additional violations, including failure to post required workplace notices. Consequently, the Division issued a determination letter in December 2018, finding Broadgate had willfully violated the Act, barring it from the H-1B program for two years, requiring payment of back wages, and assessing a civil penalty.Broadgate sought review before an Administrative Law Judge (ALJ), challenging only the determination regarding the workplace notices. The ALJ agreed with Broadgate, vacating the determination. However, the Department’s Administrative Review Board reversed this decision. On remand, Broadgate argued that the Division exceeded its authority by investigating violations not alleged in the original complaint. The ALJ rejected this argument, and the Review Board and the district court affirmed the Director’s imposition of fines and penalties.The United States Court of Appeals for the Sixth Circuit reviewed the case. Broadgate argued that the District Director lacked authority to issue the determination letter and that the Wage and Hour Division exceeded its authority by investigating the notice violations. The court held that the presumption of regularity applied, meaning the Director’s issuance of the letter was presumptive proof of her authority. The court also found that the Division was entitled to investigate the notice violations discovered during the investigation of the wage complaint. The court affirmed the district court’s judgment, rejecting Broadgate’s arguments. View "Broadgate, Inc v. Su" on Justia Law

During a regulatory inspection on May 9, 2022, Sergeant Jeff Fuller of the Tennessee Highway Patrol stopped a semitrailer. The truck's driver, Euclide Aquino Urraca, exhibited suspicious behavior, and the truck's paperwork and cargo had numerous irregularities. Fuller noticed that the truck's cargo did not match the bill of lading, and the driver and his co-driver were evasive when asked about a heavily taped box found under the bunk. A dog sniff of the truck led to the discovery of 20 kilograms of cocaine.The United States District Court for the Western District of Tennessee held an evidentiary hearing and found that Fuller lacked reasonable suspicion to extend the stop for the dog sniff. The court largely credited Fuller’s testimony but rejected his claim that he believed the box contained narcotics at the time of the search. Consequently, the district court granted Urraca’s motion to suppress the cocaine found in the truck.The United States Court of Appeals for the Sixth Circuit reviewed the case and determined that the objective facts known to Fuller at the time of the dog sniff justified the investigation. The court held that the combination of the drivers' suspicious behavior, the irregularities in the truck's paperwork and cargo, and the evasive responses about the box provided reasonable suspicion to extend the stop. The court concluded that the dog sniff was permissible, and the subsequent search, which uncovered the cocaine, was lawful under the automobile exception. Therefore, the Sixth Circuit reversed the district court's decision to suppress the evidence. View "United States v. Aquino Urraca" on Justia Law

Jaylin Morton was indicted for possessing a firearm as a felon, in violation of 18 U.S.C. § 922(g)(1). Morton moved to dismiss the indictment, arguing that the prosecution violated his Second Amendment rights. The district court denied his motion, and Morton conditionally pleaded guilty, retaining the right to appeal the denial of his motion to dismiss.The United States District Court for the Eastern District of Kentucky denied Morton’s motion to dismiss, reasoning that his prior felonies demonstrated that he was a serious and direct threat to public safety. The court concluded that § 922(g)(1) constitutionally applied to him. Morton then appealed the district court’s decision.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Morton’s criminal history, which included multiple violent offenses such as shooting at his ex-girlfriend and her family, and assaulting his then-girlfriend, demonstrated his dangerousness. The court applied the framework established in United States v. Williams, which allows for disarming individuals who are deemed dangerous based on their criminal history. The court concluded that Morton’s conviction was consistent with the Second Amendment as interpreted in Williams and affirmed the district court’s denial of Morton’s motion to dismiss the indictment. View "United States v. Morton" on Justia Law

Randell Shepherd, a career coal miner, filed a claim for benefits under the Black Lung Benefits Act (BLBA), invoking the Act’s presumption that he was entitled to benefits due to his over fifteen years of mining and total disability from chronic obstructive pulmonary disease (COPD), bronchitis, and emphysema. Incoal, Inc., Shepherd’s most recent employer, contested his entitlement, arguing that his disability was caused by smoking, not mining. An administrative law judge (ALJ) found Incoal’s expert opinions unpersuasive and inconsistent with the Act’s regulations and preamble, which recognize pneumoconiosis as a latent and progressive disease. The ALJ ruled that Incoal failed to rebut the presumption that Shepherd was entitled to benefits. The Benefits Review Board (BRB) affirmed the ALJ’s decision.Incoal petitioned the United States Court of Appeals for the Sixth Circuit for review, arguing that the ALJ improperly relied on the regulatory preamble over their evidence and that the presumption was effectively irrebuttable, violating the Constitution and the Administrative Procedure Act (APA). The court reviewed the case de novo, focusing on whether the ALJ’s decision was supported by substantial evidence and correctly applied the law.The Sixth Circuit held that the ALJ was entitled to reference the preamble to assess the credibility of expert opinions and found that the ALJ’s decision was supported by substantial evidence. The court noted that the BLBA’s rebuttable presumption is constitutional, as it is based on a rational relationship between the length of a miner’s career and the risk of pneumoconiosis. The court concluded that Incoal’s arguments were unpersuasive and that the ALJ applied the correct legal principles. Consequently, the court denied Incoal’s petition for review. View "Incoal, Inc. v. OWCP" on Justia Law

Mark Blackwell criticized the city manager of Wayne, Michigan, leading the manager to complain to the police. Two officers convinced a prosecutor to charge Blackwell with stalking, but a judge acquitted him. Blackwell then sued the manager and officers, alleging they violated his First Amendment rights by inducing the prosecution in retaliation for his political speech. The district court found that Blackwell's complaint had enough facts to rebut the city officials' qualified-immunity defense at the pleading stage.The United States District Court for the Eastern District of Michigan denied the city officials' motion to dismiss, leading them to appeal. The district court refused to consider exhibits attached to the motion to dismiss and held that the complaint stated a plausible First Amendment retaliation claim. The court also found that qualified immunity would not protect the officials if Blackwell could prove his allegations.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court agreed with the district court's decision to exclude the outside-the-complaint exhibits and found that Blackwell's complaint plausibly alleged a lack of probable cause for the stalking charge. The court held that the complaint sufficiently pleaded a First Amendment violation and that the law clearly established this violation. The court affirmed the district court's denial of the motion to dismiss, allowing Blackwell's claims to proceed. View "Blackwell v. Nocerini" on Justia Law

Celestia Chapman, a finance manager at Brentlinger Enterprises, requested leave under the Family and Medical Leave Act (FMLA) to care for her terminally ill sister. Her employer denied the request, stating that the FMLA did not cover leave to care for an adult sibling. When Chapman did not show up for work on a scheduled day, she was terminated. Subsequently, Brentlinger Enterprises falsely informed workers' compensation authorities that Chapman had quit and threatened her with Rule 11 sanctions if she pursued an FMLA lawsuit. Chapman sued, alleging violations of the FMLA, the Americans with Disabilities Act (ADA), and other statutes.The United States District Court for the Southern District of Ohio granted summary judgment to Brentlinger Enterprises on all claims except for the COBRA violation, for which it imposed a statutory penalty. Both parties appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court reversed the district court's grant of summary judgment on Chapman's FMLA interference claim, finding that an in loco parentis relationship could form between adults, including siblings, under the FMLA. The court also reversed the summary judgment on Chapman's FMLA retaliation claims related to her termination and the false statements made to the unemployment agency, as well as her ADA and Ohio law associational disability discrimination claims. The court affirmed the summary judgment on the FMLA retaliation claim related to the Rule 11 sanctions letter and upheld the district court's award of $85 per day in statutory penalties for the COBRA violation. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Chapman v. Brentlinger Enterprises" on Justia Law

The case involves the Environmental Protection Agency (EPA) changing its air-quality standard for ozone under the Clean Air Act, which required states to amend their state plans. The EPA issued guidance memoranda to assist states, suggesting specific modeling and a minimum threshold for interstate emissions. Kentucky proposed a plan based on this guidance, but the EPA delayed action on the plan for two years and then disapproved it using different modeling and a lower threshold than initially recommended. Kentucky petitioned the court to vacate the EPA's disapproval.The EPA's disapproval of Kentucky's plan was challenged in the United States Court of Appeals for the Sixth Circuit. The EPA sought to transfer the case to the D.C. Circuit, arguing that the disapproval was a nationally applicable final action. The Sixth Circuit denied the motion, stating that the EPA's disapproval was not nationally applicable and was based on Kentucky's unique facts. The court also found that the EPA's action violated the Administrative Procedure Act (APA) by acting arbitrarily and inconsistently with its prior guidance.The Sixth Circuit held that the EPA's disapproval of Kentucky's plan was arbitrary and capricious. The court noted that the EPA failed to adequately explain its departure from prior guidance and did not consider Kentucky's reliance on the initial recommendations. The court vacated the EPA's disapproval of Kentucky's plan and remanded the case for further proceedings consistent with its opinion. The court emphasized the importance of consistency and the need for the EPA to justify its actions when changing its approach. View "Kentucky v. Environmental Protection Agency" on Justia Law

Brian Washington, a federal prisoner, pleaded guilty in 2013 to possession of crack cocaine with intent to distribute and using and carrying a firearm in a drug trafficking crime. Due to prior convictions, he was classified as a career offender and sentenced to 280 months in prison. Washington did not appeal his convictions, and his post-conviction relief claims were unsuccessful. He has since filed four motions for compassionate release, all of which were denied by the district court.The United States District Court for the Eastern District of Kentucky denied Washington's fourth motion for compassionate release. Washington appealed, arguing that the disparity between crack and powder cocaine sentences, his declining mental health, age, and rehabilitation efforts constituted extraordinary and compelling reasons for his release. The district court found these arguments unpersuasive and denied the motion.The United States Court of Appeals for the Sixth Circuit reviewed the district court's denial for abuse of discretion. The court held that the disparity between crack and powder cocaine sentences does not constitute an extraordinary and compelling reason for compassionate release. The court also noted that Washington's claims regarding his mental health and age were forfeited as they were not raised in the district court. Additionally, the court found that rehabilitation alone is not an extraordinary and compelling reason for release, as per 28 U.S.C. § 994(t). Consequently, the Sixth Circuit affirmed the district court's denial of Washington's motion for compassionate release. View "United States v. Washington" on Justia Law

In 2005, Delano Hale was sentenced to death by an Ohio court for the murder of Douglas Green. Green was found dead in a motel room, wrapped in plastic bags, and had been shot multiple times. Hale was arrested driving Green's stolen vehicle and later admitted to the shooting, claiming it was in self-defense against Green's sexual advances. Hale was convicted of aggravated murder and other charges, and the jury recommended the death penalty.Hale's conviction and sentence were affirmed by the Ohio Supreme Court and the Ohio Court of Appeals. Hale filed for post-conviction relief, which was denied by the trial court and affirmed by the appellate court. He then sought federal habeas relief, raising multiple claims, including ineffective assistance of counsel and sentencing errors under Blakely v. Washington.The United States Court of Appeals for the Sixth Circuit reviewed Hale's habeas petition. The court denied Hale's claim of ineffective assistance of counsel, finding that his trial counsel's decision not to call a forensic expert was a reasonable strategic choice. The court noted that Hale's counsel had considered hiring an expert but ultimately chose a different strategy, which did not constitute deficient performance under Strickland v. Washington.The court also denied Hale's claim regarding his noncapital sentences, which were enhanced based on judicial factfinding in violation of Blakely. The Ohio Supreme Court had reviewed this claim for plain error and found no prejudice, concluding that a jury would have reached the same sentencing conclusions. The Sixth Circuit found this determination reasonable and upheld the Ohio Supreme Court's decision.The Sixth Circuit affirmed the district court's denial of Hale's habeas petition, concluding that Hale's claims did not warrant relief under the deferential standards of the Antiterrorism and Effective Death Penalty Act (AEDPA). View "Hale v. Cool" on Justia Law

Michael Gardner was convicted of sex trafficking a minor and production of child pornography. He prostituted his 17-year-old girlfriend, B.H., and recorded himself having sex with her. Gardner was sentenced to 240 months in prison. After an unsuccessful appeal, Gardner sought habeas relief under 28 U.S.C. § 2255, claiming ineffective assistance of counsel for not introducing B.H.'s prior advertisements for sex work as evidence and for not seeking an evidentiary hearing.The United States District Court for the Eastern District of Michigan denied Gardner's habeas petition but granted a certificate of appealability on two issues: whether Gardner’s trial counsel was ineffective for failing to introduce the minor victim’s prior advertisements for sex work and whether Gardner was entitled to an evidentiary hearing.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Gardner’s counsel was not ineffective for failing to introduce the prior advertisements because they were irrelevant to the charges and inadmissible under Federal Rule of Evidence 412. The court also found that the advertisements would not have impeached B.H.'s testimony, as her statements were focused on the period after she reconnected with Gardner. Additionally, the court ruled that Gardner was not entitled to an evidentiary hearing because he did not present a factual dispute that would warrant such a hearing.The Sixth Circuit affirmed the district court’s denial of Gardner’s § 2255 petition and the denial of an evidentiary hearing. View "Gardner v. U.S." on Justia Law