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

Federal law enforcement investigated crystal-methamphetamine trafficking in rural eastern Tennessee in July 2019, leading them to Derrick Mitchell in Knoxville. In October 2020, authorities executed a search warrant at Mitchell’s home, finding drugs, firearms, ammunition, and cash. Mitchell pleaded guilty to conspiring to distribute methamphetamine and to commit money laundering. He waived his right to appeal unless the district court imposed an above-Guidelines sentence. The district court accepted his plea and imposed a below-Guidelines sentence.The United States District Court for the Eastern District of Tennessee accepted Mitchell’s plea agreement, which included a stipulation that no other upward enhancements would apply apart from a two-level increase for money laundering. However, the probation office recommended additional enhancements, including one for possessing a firearm in connection with a drug-trafficking offense. Mitchell’s counsel did not initially object to the presentence report, and the district court adopted it in full. Later, Mitchell’s counsel raised the issue of the firearm enhancement, but the court explained that the stipulations in the plea agreement were not binding.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Mitchell’s appeal must be dismissed because he waived his right to appeal under the plea agreement, which was voluntarily accepted. The court found no plain error in the district court’s acceptance of Mitchell’s plea, as the court had adequately informed him of the consequences, and Mitchell understood the nature of his plea. The court also determined that the government did not breach the plea agreement, as it had not promised that only one enhancement would apply and had not objected to the probation office’s recommendation. The appeal was dismissed in accordance with the plea agreement’s appellate waiver provision. View "United States v. Mitchell" on Justia Law

Jeremy Mooney, a former deputy in the Pike County Sheriff’s Office, was convicted of two counts of depriving an inmate, Thomas Friend, of his civil rights under color of law, in violation of 18 U.S.C. § 242. The incidents occurred on November 17-18, 2019, when Mooney pepper sprayed and punched Friend multiple times while Friend was restrained in a chair. Surveillance footage captured these events. Mooney claimed his actions were in response to Friend spitting on him and that he was instructed by his supervisor to use pepper spray.The United States District Court for the Southern District of Ohio denied Mooney’s motion to dismiss the indictment, which argued that the government destroyed exculpatory video evidence in bad faith. The court found no bad faith or exculpatory value in the lost footage. At trial, the jury found Mooney guilty on both counts. The court also excluded evidence of Friend’s Hepatitis C, ruling it irrelevant and potentially prejudicial. Mooney was sentenced to 100 months in prison, with an enhancement for obstruction of justice based on allegedly false trial testimony.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed Mooney’s conviction, finding sufficient evidence that Mooney acted willfully to deprive Friend of his constitutional rights. The court also upheld the district court’s evidentiary rulings, including the exclusion of the Hepatitis C evidence and the admission of testimony from Deputy Jonathan Chandler about police training.However, the Sixth Circuit vacated Mooney’s sentence and remanded the case for further proceedings regarding the obstruction of justice enhancement. The court found that the district court failed to make specific findings necessary to establish perjury, as required for the enhancement. The case was sent back to the district court to either resentence Mooney or make the required factual findings. View "United States v. Mooney" on Justia Law

Police stopped Prince Irell Seuell in Van Buren County, Michigan, in November 2023, discovering drugs, a semiautomatic pistol, and an outstanding warrant. Seuell pleaded guilty to possessing a firearm as a felon, and the government dropped the drug distribution charge. The presentence report calculated a Guidelines range of 70 to 87 months, and the district court sentenced Seuell to 70 months.Seuell challenged his conviction and sentence. He argued that the felon-in-possession statute violated the Second Amendment as applied to him, but he waived this argument at sentencing. The district court offered to appoint new counsel to file a motion challenging the statute, but Seuell chose to proceed with sentencing without raising the motion. The court found this waiver binding.Seuell also contested the base offense level set by the presentence report, arguing that he did not know his pistol could carry a large capacity magazine. The United States Court of Appeals for the Sixth Circuit held that the relevant Guideline does not contain a state-of-mind requirement and applies whenever the firearm qualifies. The court noted that the Sentencing Commission knew how to add a state-of-mind requirement when it wished to do so and rejected Seuell's argument.Additionally, Seuell challenged the district court’s enhancement for using a firearm in connection with another offense. The Sixth Circuit found no clear error in the district court’s finding that Seuell committed another felony offense and connected his pistol to drug trafficking. The court noted that the drugs and drug paraphernalia were found in close proximity to the loaded pistol, supporting the enhancement.The United States Court of Appeals for the Sixth Circuit affirmed Seuell’s conviction and sentence. View "United States v. Seuell" on Justia Law

Jin Yin Zhou, a Chinese citizen, married a U.S. citizen in 1996 and entered the United States as a conditional permanent resident in 1997. However, she never lived with her husband and instead lived with her boyfriend in Kentucky, with whom she had three children. Zhou concealed these facts during her immigration proceedings, including when she applied for naturalization. Eventually, the United States Citizenship and Immigration Services discovered her marriage fraud, leading to her being placed in removal proceedings. The immigration judge sustained the charge of removability but granted her relief from removal under 8 U.S.C. § 1227(a)(1)(H), considering her long residence, stable employment, and the hardship her children would face if she were removed.The Department of Homeland Security appealed the immigration judge's decision to the Board of Immigration Appeals (BIA). Zhou's counsel failed to file a brief on her behalf, and the BIA reversed the immigration judge's decision, ordering Zhou's removal. Zhou filed an untimely motion to reopen her removal proceedings, requesting equitable tolling of the 90-day deadline due to ineffective assistance of counsel. The BIA denied the motion, stating that Zhou failed to demonstrate the requisite prejudice and due diligence.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that it lacked jurisdiction to review the BIA's determination regarding the lack of prejudice, as this determination was dispositive of the appeal. Consequently, the court dismissed Zhou's petition for review. View "Zhou v. Bondi" on Justia Law

Several hair stylists filed a lawsuit against their employer, Lady Jane’s Haircuts for Men, alleging that they were underpaid due to being misclassified as independent contractors instead of employees. This misclassification, they argued, allowed the employer to avoid the Fair Labor Standards Act’s minimum-wage and overtime-pay requirements. The employer moved to dismiss the lawsuit, citing an arbitration agreement in the Independent Contractor Agreement, which required disputes to be resolved through the American Arbitration Association (AAA) under its Commercial Arbitration Rules.The United States District Court for the Eastern District of Michigan reviewed the case and found the arbitration agreement enforceable but severed the cost-shifting provision, which required the stylists to pay arbitration costs exceeding their yearly income. The court ruled that the arbitration would proceed under the less costly AAA employment rules and dismissed the lawsuit in favor of arbitration.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that the severability clause in the contract allowed the court to remove the cost-shifting provision while enforcing the rest of the arbitration agreement. The court found that the term “provision” in the severability clause referred to individual clauses within the contract, not entire sections. The court also rejected the stylists’ arguments that the district court had impermissibly reformed the contract and that the arbitration agreement should be unenforceable for equitable reasons. The court concluded that the district court correctly severed the cost-shifting provision and enforced the arbitration agreement under the AAA’s employment rules. View "Gavin v. Lady Jane's Haircuts for Men" on Justia Law

Enbridge Energy owns and operates a pipeline that runs from Wisconsin, through Michigan, and into Canada, crossing the Straits of Mackinac under a 1953 easement with the State of Michigan. In 2020, Michigan Governor Gretchen Whitmer informed Enbridge that the State was revoking the easement, alleging that Enbridge had violated it by creating an unreasonable risk of an oil spill. Enbridge responded by filing a federal lawsuit against Governor Whitmer and the Director of the Michigan Department of Natural Resources, seeking declaratory and injunctive relief to prevent the State from interfering with the pipeline's operation.The United States District Court for the Western District of Michigan rejected the defendants' argument that Enbridge’s claims were barred by Eleventh Amendment sovereign immunity. The court held that Enbridge’s lawsuit fell within the Ex parte Young exception to sovereign immunity, which allows federal courts to hear cases seeking prospective relief against state officials for ongoing violations of federal law.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The Sixth Circuit held that Enbridge’s lawsuit was not barred by sovereign immunity because it sought prospective injunctive relief against state officials for alleged violations of federal law, fitting within the Ex parte Young doctrine. The court rejected the defendants' arguments that the suit was equivalent to a quiet title action or a request for specific performance of a state contract, finding that the relief sought would not divest the State of ownership or regulatory control over the land. Thus, the court concluded that Enbridge’s claims could proceed in federal court. View "Enbridge Energy, LP v. Whitmer" on Justia Law

Three federal prisoners, Jason Bricker, Ellis McHenry, and Lois Orta, sought compassionate release under 18 U.S.C. § 3582(c)(1)(A), citing a new policy statement by the Sentencing Commission, U.S.S.G. § 1B1.13(b)(6). This policy allows for sentence reductions based on nonretroactive changes in the law if certain conditions are met, including serving at least 10 years of an "unusually long sentence" and a "gross disparity" between the actual and hypothetical sentences under current law.In the Northern District of Ohio, the district court granted Bricker's motion for compassionate release, finding that his sentence would be significantly shorter under current law. The court acknowledged a Sixth Circuit precedent, United States v. McCall, which held that nonretroactive changes in the law are not "extraordinary and compelling reasons" for sentence reduction, but asserted that the Sentencing Commission had overruled this precedent. The government appealed this decision.In McHenry's case, the district court denied his motion for compassionate release, stating that applying the new policy would require disregarding the statutory mandatory minimum and the binding precedent set by McCall. Similarly, in Orta's case, the district court denied the motion, relying on McCall to conclude that nonretroactive changes in sentencing law do not constitute "extraordinary and compelling reasons" for release. Both McHenry and Orta appealed these decisions.The United States Court of Appeals for the Sixth Circuit reviewed the consolidated appeals and held that the Sentencing Commission overstepped its authority with U.S.S.G. § 1B1.13(b)(6). The court concluded that the policy statement was invalid as it conflicted with the statute and the separation of powers. Consequently, the Sixth Circuit reversed the district court's decision in Bricker's case and affirmed the denials in McHenry's and Orta's cases, denying compassionate release for all three prisoners. View "United States v. Bricker" on Justia Law

Tina McPherson purchased a car from Suburban Ann Arbor, a Michigan car dealership, in July 2020. She was misled into believing she had been approved for financing, paid a $2,000 down payment, and drove the car home. Later, she was informed that the financing had fallen through and was given the option to sign a new contract with worse terms or return the car. McPherson refused the new terms, and Suburban repossessed the car and kept her down payment and fees. McPherson sued Suburban, alleging violations of state and federal consumer protection laws.A federal jury found Suburban liable for statutory conversion under Michigan law and violations of the Michigan Regulation of Collection Practices Act, among other claims. The jury awarded McPherson $15,000 in actual damages, $23,000 for the value of the converted property, and $350,000 in punitive damages. The district court denied McPherson's request for treble damages but awarded her $418,995 in attorney’s fees, $11,212.61 in costs, and $6,433.65 in prejudgment interest, totaling $824,641.26. McPherson appealed the denial of treble damages and the amount of attorney’s fees awarded, while Suburban cross-appealed the fee award as excessive.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the district court did not abuse its discretion in denying treble damages, as the $350,000 punitive damages already served to punish and deter Suburban's conduct. The court also found that the district court properly calculated the attorney’s fees, considering the market rates and the skill of McPherson’s attorneys. The court affirmed the district court’s judgment in all respects. View "McPherson v. Suburban Ann Arbor, LLC" on Justia Law

Wehr Constructors, Inc. (Wehr) entered into a contract with St. Claire Medical Center (St. Claire) to build an addition to the hospital. Wehr's performance was allegedly deficient, leading to significant construction defects. St. Claire terminated the contract and sought damages from Wehr's performance-bond carrier, Travelers Casualty and Surety Company (Travelers Surety). Travelers Surety then involved Wehr in the litigation. Wehr sought defense coverage from its insurers: Phoenix Insurance Company (Phoenix), St. Paul Surplus Lines Insurance Company (St. Paul), and Travelers Property Casualty Company of America (Travelers Property).The United States District Court for the Eastern District of Kentucky ruled that none of Wehr’s insurers had a duty to defend Wehr in the lawsuit initiated by St. Claire. The court held that Phoenix’s duty to defend was not triggered because St. Claire did not assert claims directly against Wehr. It also found that St. Paul had no duty to defend because Wehr did not specifically agree to perform as a construction manager, a requirement under the St. Paul policy. Although Wehr did not seek summary judgment against Travelers Property, the court noted that Travelers Property also had no duty to defend for the same reasons as Phoenix.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court’s decision regarding St. Paul, agreeing that Wehr did not specifically agree to serve as a construction manager. However, it reversed the decision regarding Phoenix, holding that Phoenix had a duty to defend Wehr because the damages alleged by St. Claire potentially fell within the policy coverage, and Wehr was a party to the suit. The court vacated the decision regarding Travelers Property and remanded for further proceedings to determine whether Travelers Property had a duty to defend, given the ambiguity in the district court’s ruling and the stipulation by the parties. View "Phoenix Insurance Co. v. Wehr Constructors, Inc." on Justia Law

Kassandra Memmer sued her former employer, United Wholesale Mortgage (UWM), alleging discrimination and sexual harassment during her employment. UWM moved to dismiss the lawsuit and compel arbitration based on the employment agreement. Memmer argued that the arbitration agreement was invalid and that she had the right to go to court under the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 (EFAA).The United States District Court for the Eastern District of Michigan granted UWM's motion to dismiss and compel arbitration, concluding that the parties had a valid arbitration agreement. The court did not address Memmer's argument regarding the applicability of EFAA. Memmer appealed the decision, asserting that EFAA should apply to her case.The United States Court of Appeals for the Sixth Circuit reviewed the case and concluded that EFAA applies to claims that accrue after its enactment date and to disputes that arise after that date. The court determined that the district court had not applied the correct interpretation of EFAA. The Sixth Circuit reversed the district court's decision and remanded the case for further proceedings to determine when the dispute between Memmer and UWM arose and whether EFAA applies to her claims. View "Memmer v. United Wholesale Mortgage, LLC" on Justia Law