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

The defendant pled guilty in 2016 to conspiracy to possess with intent to distribute controlled substances, receiving a sentence of 160 months based on his criminal history and offense level. In 2023, a retroactive amendment to the Sentencing Guidelines reduced his criminal history category, lowering his guideline range. The defendant, through appointed counsel, and the government stipulated to a new recommended sentence of 144 months, which the district court imposed.After resentencing, the defendant filed a pro se motion for reconsideration, asserting that his counsel had agreed to the stipulation without his knowledge or consent and that he wished to argue for a lower sentence. The United States District Court for the Eastern District of Michigan denied the motion, reasoning that because the defendant was represented by counsel, his pro se filing constituted improper hybrid representation. The court instructed that any motion for reconsideration should be filed through counsel.On appeal, the United States Court of Appeals for the Sixth Circuit held that when a defendant raises a specific and serious allegation that counsel acted without his knowledge or against his wishes on a fundamental matter, the district court is obligated to inquire into the nature of the attorney-client relationship, regardless of whether the defendant used “magic words” or filed through counsel. The Sixth Circuit found that the district court erred by denying the motion solely on the basis of hybrid representation without conducting such an inquiry. The court vacated the district court’s judgment on the motion for reconsideration and remanded for further proceedings, instructing the district court to determine whether the defendant wishes to dismiss his counsel and whether he is entitled to do so, and then to address the merits of his motion. View "United States v. Riley" on Justia Law

A group of Black farmers and their association, along with several individual members, sought to file claims with the U.S. Department of Agriculture (USDA) for financial assistance under a program created by the Inflation Reduction Act of 2022. They wished to submit applications on behalf of deceased relatives who had allegedly experienced discrimination in USDA farm lending programs. The USDA, however, had a policy that excluded applications reporting only discrimination against individuals who were deceased at the time of application, making such claims ineligible for the program.The plaintiffs filed suit in the United States District Court for the Western District of Tennessee, seeking an injunction to require the USDA to accept these “legacy claims.” The district court denied their motion for a preliminary injunction and granted the government’s motion to dismiss under Rule 12(b)(6), holding that the relevant statute only authorized financial assistance to living farmers. The plaintiffs appealed this decision to the United States Court of Appeals for the Sixth Circuit and also sought an emergency injunction pending appeal, which was denied.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s dismissal de novo. The appellate court held that the statutory language of § 22007(e) of the Inflation Reduction Act required the USDA to provide “assistance” to farmers who experienced discrimination, and that “assistance” was forward-looking and could not be provided to deceased individuals. The court found that the statute did not authorize compensation for past harm to deceased farmers, distinguishing “assistance” from “compensation.” The court affirmed the district court’s judgment and denied the motion for an injunction pending appeal as moot, holding that the USDA was required to reject applications filed on behalf of deceased farmers. View "Black Farmers & Agriculturalists Ass'n v. Rollins" on Justia Law

A billboard company sought to erect a sign in a Michigan township, but its application was denied because the proposed billboard did not comply with local height and size restrictions. Instead of appealing the denial or seeking a variance, the company filed a federal lawsuit challenging the township’s sign ordinance on First Amendment grounds, including claims that the ordinance imposed content-based restrictions, constituted an unconstitutional prior restraint, and was unconstitutionally vague. The company did not challenge the height and size restrictions themselves. The township’s ordinance only allowed billboards in certain industrial zones adjacent to interstate freeways, but, according to the company, no such zones existed in the township.The United States District Court for the Eastern District of Michigan granted summary judgment to the township, finding the company lacked standing because its alleged injuries were not caused by the challenged provisions and would not be redressed by a favorable decision. The United States Court of Appeals for the Sixth Circuit affirmed, holding that the company failed to meet the requirements for standing on any of its claims.Subsequently, the company filed a new lawsuit in the same district court, again alleging that the ordinance was a prior restraint on speech. The district court dismissed the suit, holding that res judicata (claim preclusion) barred the action. On appeal, the United States Court of Appeals for the Sixth Circuit held that issue preclusion, not claim preclusion, applied. The court concluded that issue preclusion barred the company from relitigating its prior-restraint claim based on its earlier application, but did not bar claims based on new facts—specifically, the company’s allegation that it was self-censoring and not applying for any billboards due to the ordinance’s discretionary variance process. The Sixth Circuit affirmed in part, vacated in part, and remanded for further proceedings on the new factual allegations. View "Outdoor One Communications LLC v. Charter Twp. of Canton, Mich." on Justia Law

Federal authorities investigated a man in Michigan after receiving a tip that he was distributing methamphetamine sourced from Las Vegas. Over several months, law enforcement gathered evidence, including intercepting a package containing nearly seven pounds of methamphetamine sent to his uncle’s home. Upon executing search warrants, officers seized drugs, cash, and firearms from both the uncle’s residence and the defendant’s home. The defendant admitted his involvement during a post-arrest interview. After serving a short state sentence for probation violations, he moved to Atlanta, where he was employed and had no further criminal incidents for about a year. In 2023, a federal grand jury indicted him for drug and firearm offenses. He was arrested in Michigan several months later, and while out on bond, he violated conditions and was re-arrested. While in jail, he attempted to smuggle synthetic drugs and was caught with contraband.The United States District Court for the Western District of Michigan denied the defendant a reduction for acceptance of responsibility, citing his continued drug-related conduct and false denials during the presentence investigation. The court also denied his request for a downward variance based on his period of lawful behavior in Atlanta, but did grant a downward variance due to his lack of youthful guidance, sentencing him to 300 months, below the guideline range. Defense counsel did not object to the court’s handling of non-frivolous arguments at sentencing.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial of the acceptance-of-responsibility reduction for clear error and affirmed, holding that post-offense drug activity and false denials were relevant to assessing acceptance of responsibility under U.S.S.G. § 3E1.1(a). The appellate court also declined to review the procedural reasonableness of the sentence, finding that the defendant had either waived or invited any error by affirming that all arguments had been addressed. The judgment of the district court was affirmed. View "United States v. Jett" on Justia Law

Diego Pavia, a college football player, sought to play for Vanderbilt University during the 2025 season. After a successful 2024 season, Pavia faced ineligibility under National Collegiate Athletic Association (NCAA) rules, which limit athletes to four seasons of intercollegiate competition, including seasons played at junior colleges. Pavia’s path included time at a junior college, New Mexico State University, and Vanderbilt. The NCAA counted his 2021 junior college season toward his eligibility, effectively barring him from playing in 2025. Pavia argued that this rule violated the Sherman Act and sought injunctive relief to allow him to play in the 2025 and 2026 seasons.The United States District Court for the Middle District of Tennessee granted Pavia a preliminary injunction, preventing the NCAA from enforcing the rule against him for the 2025 season and from applying its restitution rule to Vanderbilt or Pavia based on his participation. The NCAA appealed this decision to the United States Court of Appeals for the Sixth Circuit.While the appeal was pending, the NCAA issued a waiver allowing all similarly situated athletes, including Pavia, to play in the 2025 season. The NCAA confirmed that this waiver would remain in effect regardless of the outcome of the appeal. The United States Court of Appeals for the Sixth Circuit determined that, because Pavia had already received the relief he sought at the preliminary injunction stage, the appeal was moot. The court held that it could not grant any further effectual relief and dismissed the appeal for lack of jurisdiction. The court also declined to vacate the preliminary injunction, finding that the NCAA’s own actions had caused the case to become moot. View "Pavia v. NCAA" on Justia Law

Daniel Jackson was stopped by sheriff’s deputies in Kentucky after they observed his truck with an obscured license plate and learned he was driving without a valid license or registration. After arresting Jackson, deputies searched his truck and found methamphetamine, marijuana, syringes, and digital scales. A subsequent search of the police cruiser’s back seat, where Jackson had been placed, revealed a bag containing fentanyl. Jackson was charged with possession of fentanyl and methamphetamine with intent to distribute.The United States District Court for the Eastern District of Kentucky presided over Jackson’s trial. At trial, Jackson testified that he had been framed by a deputy who allegedly planted the drugs in both his truck and the police cruiser. The jury rejected Jackson’s account and convicted him. At sentencing, the district court found that Jackson’s testimony constituted perjury and applied a two-level obstruction-of-justice enhancement under the Sentencing Guidelines. The court also imposed a five-year term of supervised release, including a condition permitting searches of Jackson’s electronic devices by the probation office. Jackson did not object to this condition at sentencing.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed Jackson’s challenges to both the obstruction-of-justice enhancement and the supervised-release search condition. The court held that the district court’s findings of perjury—falsity, willfulness, and materiality—were not clearly erroneous and that the enhancement was mandatory under the Guidelines. The appellate court also found no plain error in the imposition or explanation of the electronic-device search condition, given the district court’s stated concerns about officer safety and recidivism. Accordingly, the Sixth Circuit affirmed the judgment of the district court. View "United States v. Jackson" on Justia Law

A prisoner at a Michigan correctional facility was involved in a physical altercation with another inmate, after which he was subdued and handcuffed by corrections officers. Two officers then escorted him through a hallway and into a prison yard. Upon entering the yard, the officers performed a takedown maneuver, throwing the prisoner to the ground and fracturing his foot. The prisoner claimed he did not resist or act aggressively before the takedown, while the officers asserted that he had lunged away, prompting their response. Surveillance footage captured much of the incident, but some key moments were obscured or unclear. The prisoner suffered significant injury as a result of the takedown.Following the incident, a prison misconduct hearing was held, and the hearing officer found the prisoner guilty of assaulting staff, relying heavily on the video evidence, which the prisoner was not permitted to view. The prisoner did not seek judicial review of this administrative finding. He then filed a lawsuit in the United States District Court for the Eastern District of Michigan under 42 U.S.C. § 1983, alleging excessive force in violation of the Eighth Amendment. The district court granted summary judgment to the officers, holding they were entitled to qualified immunity. The court reasoned that the hearing officer’s factual findings should have preclusive effect and that the video evidence clearly contradicted the prisoner’s account.The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court’s decision. The appellate court held that the hearing officer’s findings should not have preclusive effect because the prisoner lacked a full and fair opportunity to litigate the facts, particularly due to his inability to access crucial evidence. The court also found that the video evidence did not so clearly contradict the prisoner’s version as to warrant summary judgment. The court concluded that there was a genuine dispute of material fact regarding whether the officers used excessive force, and that the officers had forfeited the “clearly established” prong of their qualified immunity defense. The case was remanded for further proceedings. View "Nash v. Bryce" on Justia Law

A sixth-grade student with behavioral disabilities, X.M., attended Mount Pleasant Public Schools under an Individualized Education Plan that allowed him to use a breakroom to manage stress. In the fall of 2021, after a student reported that X.M. had brought a gun to school, school officials, including special-education teacher Jason Russell, searched X.M.’s locker and questioned him, but found nothing. The next day, after X.M. made a comment about not having his gun at school, officials again searched his belongings. According to X.M., Russell then ordered him to pull down his trousers and lift his shirt in a search for a gun. Days later, after X.M. was suspended for violence, he claimed Russell locked him in the breakroom for over 20 minutes.Cheyenne Johnson, X.M.’s mother, sued Russell, the school district, and other officials, alleging violations of X.M.’s constitutional rights. The United States District Court for the Eastern District of Michigan granted summary judgment to all defendants except Russell, denying him qualified immunity on the Fourth Amendment claims. The district court found that disputed facts—specifically, whether Russell conducted a strip search and locked X.M. in the breakroom—required a jury’s determination.The United States Court of Appeals for the Sixth Circuit reviewed the case on interlocutory appeal. The court held that, even accepting X.M.’s version of events, Russell did not violate clearly established Fourth Amendment rights. The court found that Russell’s search was justified at its inception and not clearly excessive in scope given the suspicion of a gun. It also concluded that it was not clearly established that locking a student in a breakroom for 20 minutes under these circumstances constituted an unreasonable seizure. The Sixth Circuit reversed the district court’s denial of qualified immunity and remanded with instructions to dismiss the Fourth Amendment claims against Russell. View "Johnson v. Mount Pleasant Public Schools" on Justia Law

A married couple, both employees of UT-Battelle, objected to their employer’s COVID-19 vaccine mandate on religious grounds, specifically because of their belief that the vaccines’ development involved the use of fetal cell lines from abortions, which conflicted with their Christian faith. UT-Battelle required employees seeking religious exemptions to undergo a panel interview and read a “fact sheet” presenting religious leaders’ support for vaccination. Employees granted religious accommodations were placed on unpaid leave, while those with medical accommodations were not. Mrs. Bilyeu ultimately received a medical exemption before the policy took effect and did not lose pay or work time. Mr. Bilyeu, however, was placed on unpaid leave after exhausting his vacation days, returning to work only after the policy was rescinded.The United States District Court for the Eastern District of Tennessee granted summary judgment to UT-Battelle on all claims except Mrs. Bilyeu’s retaliation claim, which was later settled. The court found that Mrs. Bilyeu lacked standing and that Mr. Bilyeu had not suffered a materially adverse employment action under Title VII.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment as to Mrs. Bilyeu, holding she lacked Article III standing because she suffered no cognizable injury after receiving her medical accommodation. For Mr. Bilyeu, the Sixth Circuit vacated the summary judgment on his disparate treatment and failure-to-accommodate claims, instructing the district court to reconsider them in light of the Supreme Court’s decision in Muldrow v. City of St. Louis, which eliminated the “materially adverse” requirement for adverse employment actions under Title VII. The court reversed the summary judgment on Mr. Bilyeu’s retaliation claim, finding sufficient evidence for a reasonable jury to conclude that the interview process could dissuade a reasonable worker from seeking a religious accommodation, and remanded for further proceedings. View "Bilyeu v. UT-Battelle, LLC" on Justia Law

After being released from federal prison, an individual began a term of supervised release that required him to comply with several conditions, including avoiding new criminal conduct, truthfully answering his probation officer’s questions, and participating in mental health and substance abuse treatment programs. Within two months, the probation office alleged that he violated four conditions: failing to enroll in required treatment, lying to his probation officer about receiving services, missing a scheduled drug test, and committing a new state misdemeanor offense involving assault and stalking.The United States District Court for the Eastern District of Tennessee held a revocation hearing. The individual admitted to three of the violations—lying to his probation officer, failing to enroll in treatment, and missing the drug test—and contested only the allegation that he committed a new state crime. After hearing testimony and reviewing evidence, the district court found by a preponderance of the evidence that he had committed the misdemeanor, in addition to the three admitted violations. The court revoked his supervised release and imposed a 14-month prison sentence, at the top of the applicable guidelines range. The individual appealed, challenging only the finding that he committed the new state offense.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s factual findings for clear error. The appellate court concluded that even if the district court erred in finding the new state offense, any such error was harmless because the three uncontested violations independently justified revocation and the sentence imposed. The court held that a single violation is sufficient to support revocation, and the guidelines range and sentence would have been the same regardless of the contested finding. Accordingly, the Sixth Circuit affirmed the district court’s judgment. View "United States v. Kidd" on Justia Law