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

Freddie Knipp, Jr. was convicted of two counts of distributing methamphetamine and one count of knowingly selling a firearm to a felon. The convictions stemmed from controlled drug buys and a firearm purchase facilitated by law enforcement, with Knipp selling methamphetamine to Larry Eldridge and purchasing a firearm for him, knowing Eldridge was a felon. Eldridge cooperated with law enforcement, leading to Knipp's arrest and subsequent trial.The United States District Court for the Eastern District of Kentucky denied Knipp's motion to dismiss the firearm charge, which he argued violated the Second Amendment. Knipp was found guilty on all counts by a jury and sentenced to 138 months in prison for the drug charges and 120 months for the firearm charge, to be served concurrently.The United States Court of Appeals for the Sixth Circuit reviewed the case. Knipp challenged the constitutionality of 18 U.S.C. § 922(d)(1), which prohibits selling firearms to felons, arguing it violated the Second Amendment. The court applied the two-step framework from N.Y. State Rifle & Pistol Ass’n, Inc. v. Bruen and found that while the Second Amendment covers the right to acquire firearms, historical precedent supports disarming dangerous individuals, including felons. Thus, the court upheld the statute's constitutionality.Knipp also contested the admission of Eldridge's testimony about prior drug transactions, arguing it was impermissible propensity evidence. The court found any potential error in admitting this evidence to be harmless, given the substantial other evidence of Knipp's guilt.Finally, Knipp argued that the district court erred in calculating his sentence by including drug quantities from prior transactions based on Eldridge's testimony. The appellate court found no clear error in the district court's credibility determination and upheld the sentence.The Sixth Circuit affirmed Knipp's conviction and sentence. View "United States v. Knipp" on Justia Law

Malgum Whiteside, Jr. was charged with being a felon in possession of firearms after police found the weapons during a search of his residence. The search was conducted while officers were looking for evidence related to stalking charges against Whiteside. Whiteside moved to suppress the firearms, arguing that the search warrant was invalid and no warrant exception applied. The district court denied the motion, and Whiteside pleaded guilty while reserving the right to appeal the suppression ruling.The United States District Court for the Western District of Michigan denied Whiteside's motion to suppress, finding that the warrant was valid despite the judge not signing the warrant itself, only the affidavit. The court also found that there was a sufficient nexus between the place to be searched and the evidence sought. Additionally, the court ruled that even if the warrant was invalid, the good-faith exception to the warrant requirement would apply, and the firearms were in plain view.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 the warrant was validly issued despite the lack of a signature on the warrant itself, as there was clear and contemporaneous evidence that the judge made the necessary probable cause determination. The court also found that the warrant affidavit established a sufficient nexus between Whiteside's residence and the evidence of stalking. Furthermore, the court concluded that the plain-view doctrine applied to the seizure of the firearms, as the incriminating character of the firearms was immediately apparent to the officers, who knew Whiteside was a felon. Therefore, the seizure of the firearms was valid, and the district court's denial of the motion to suppress was affirmed. View "United States v. Whiteside" on Justia Law

Holly Lawson, a guidance counselor at Franklin County High School, alleged that her Fourth Amendment rights were violated by her coworkers, Kayla Creely and Lori Franke, and by School Superintendent Mark Kopp, along with the Franklin County, Kentucky Board of Education. Lawson claimed that Creely and Franke searched her bag without her consent, discovering a firearm, and that Kopp unlawfully detained and searched her in connection with this incident.The United States District Court for the Eastern District of Kentucky granted summary judgment in favor of the defendants. The court found that Creely and Franke were acting under color of state law but were entitled to qualified immunity. It also determined that Kopp's actions constituted a lawful investigative stop under Terry v. Ohio and that Lawson consented to the search of her bag.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The appellate court concluded that Creely and Franke did not act under color of state law because their actions were not authorized by any school policy or state authority. The court also agreed that Kopp's interaction with Lawson was a lawful investigative stop supported by reasonable suspicion and that Lawson voluntarily searched her own bag, negating any Fourth Amendment violation. Consequently, the court found no basis for municipal liability under Monell against the Board. View "Lawson v. Creely" on Justia Law

Brandi Goodwin, a part-time nursing assistant at Fisher Titus Hospital, contracted COVID-19 in December 2020, leading to symptoms such as shortness of breath and chest pain. She filed for short-term disability benefits, which Unum Life Insurance Company approved and extended until June 2021. However, when Goodwin applied for long-term disability benefits, Unum denied her claim, citing a pre-existing condition (vertigo) and normal test results that did not support her continued complaints.The United States District Court for the Southern District of Ohio upheld Unum's denial of long-term disability benefits. Goodwin then appealed the decision, arguing that Unum's denial was procedurally and substantively unreasonable.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court assessed whether Unum's decision-making process was procedurally sound and whether the decision was supported by substantial evidence. The court found that Unum considered all relevant evidence, including new medical opinions and test results, and provided rational reasons for changing its benefits determination from short-term to long-term. The court also noted that Unum's reliance on file reviewers over treating physicians was not unreasonable and that Goodwin did not provide concrete evidence of bias affecting Unum's decision.The Sixth Circuit concluded that Unum's decision to deny Goodwin long-term disability benefits was both procedurally and substantively reasonable. Therefore, the court affirmed the district court's judgment in favor of Unum. View "Goodwin v. Unum Life Ins. Co. of Am." on Justia Law

Sean Hart and Tiffany Guzman filed a lawsuit against the City of Grand Rapids and three police officers, alleging excessive force during a 2020 Black Lives Matter demonstration. Hart and Guzman claimed that the officers used excessive force and that the City ratified this conduct. The officers sought summary judgment based on qualified immunity, and the City argued that the plaintiffs failed to establish municipal liability.The United States District Court for the Western District of Michigan granted summary judgment in favor of the City and the officers, dismissing the federal claims with prejudice and declining jurisdiction over the state claims. The plaintiffs appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's grant of summary judgment based on qualified immunity for Officer Johnson and Sergeant Bush, finding that the plaintiffs did not show that the officers violated clearly established rights. However, the court reversed the grant of summary judgment for Officer Reinink, determining that a reasonable jury could find that he used excessive force when he fired a Spede-Heat canister at Hart at close range, which could be considered deadly force. The court remanded the case for further proceedings on this claim.The court also affirmed the grant of summary judgment in favor of the City, concluding that the plaintiffs did not provide sufficient evidence to support their claim of municipal liability based on ratification of unconstitutional conduct. The plaintiffs' evidence, a spreadsheet of excessive force complaints, lacked qualitative specifics to show a pattern of inadequate investigations by the City. View "Hart v. City of Grand Rapids, Mich." on Justia Law

Georgia-Pacific Consumer Products LP and other plaintiffs incurred cleanup costs at a site on the Kalamazoo River in Michigan due to pollution from paper mills. In 1995, Georgia-Pacific and other companies formed the Kalamazoo River Study Group (KRSG) and sought a declaration of shared liability for cleanup costs under CERCLA § 107. In 1998, the district court declared KRSG members, including Georgia-Pacific, liable for the entire cost of response activities at the site. Subsequent judgments in 2000 and 2003 confirmed this liability.In 2010, Georgia-Pacific filed a lawsuit against NCR Corporation, International Paper Company, and Weyerhaeuser Company, asserting claims under both CERCLA § 107(a) and § 113(f) for cleanup costs. The district court found NCR and International Paper liable and apportioned liability among the parties. However, the Sixth Circuit Court of Appeals held that Georgia-Pacific’s § 113(f) claims were time-barred and that Georgia-Pacific could not pursue § 107(a) claims for costs within the scope of the 1998 judgment.On remand, the district court vacated its judgment under § 113(f) but re-entered a declaratory judgment under § 107, declaring Georgia-Pacific, International Paper, and Weyerhaeuser liable for future response costs. International Paper and Weyerhaeuser appealed this decision.The United States Court of Appeals for the Sixth Circuit reviewed the case and vacated the district court’s declaratory judgment under § 107. The court held that Georgia-Pacific could not pursue a § 107(a) claim for costs within the scope of the 1998 judgment, as those costs were recoverable only under § 113(f). The court remanded the case for further proceedings to determine the scope of the 1998 judgment and allowed Georgia-Pacific to bring § 107(a) claims for costs outside that scope. View "Georgia-Pacific Consumer Products LP v. NCR Corp." on Justia Law

Michael Poffenbarger, a First Lieutenant in the Air Force Reserve, filed a lawsuit challenging the Air Force’s COVID-19 vaccine mandate, claiming it violated the Religious Freedom Restoration Act (RFRA) and the First Amendment. He sought a religious exemption, which was denied, and subsequently refused the vaccine. As a result, he received a letter of reprimand and was placed on inactive status, losing pay and retirement points. Poffenbarger sought declaratory and injunctive relief, including restoration of lost pay and points.The United States District Court for the Southern District of Ohio initially granted a preliminary injunction preventing the Air Force from taking further punitive action against Poffenbarger. In a related case, Doster v. Kendall, the same court certified a class of affected service members and issued similar injunctions. The Sixth Circuit affirmed these injunctions, but the Supreme Court later vacated the decision on mootness grounds after Congress directed the rescission of the vaccine mandate. The district court then dismissed Poffenbarger's case as moot.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s dismissal de novo. The court held that Poffenbarger’s claim for lost drill pay and retirement points was barred by federal sovereign immunity. The court explained that RFRA’s waiver of sovereign immunity does not unequivocally include claims for money damages against the federal government. Since Poffenbarger’s claim sought retrospective compensation for a previous legal wrong, it constituted money damages, which are not covered by RFRA’s waiver. Consequently, the Sixth Circuit affirmed the district court’s dismissal of the case. View "Poffenbarger v. Kendall" on Justia Law

John Doe, a convicted sex offender, challenged the enforcement of Tennessee's sex-offender statutes against him, arguing that the requirements imposed by these statutes constituted retroactive punishment in violation of the Constitution’s Ex Post Facto Clause. Tennessee's sex-offender statutes require offenders to register with the Tennessee Bureau of Investigation, update their personal information quarterly, limit where they can live and work, and allow the state to publish information about registrants. Doe committed his offenses before the passage of the 2004 statutes and sought to prevent Tennessee officials from enforcing these laws against him.The United States District Court for the Middle District of Tennessee issued a preliminary injunction barring Tennessee officials from enforcing any of the state’s sex-offender statutes against Doe. This decision was influenced by a related case, Does #1–9 v. Lee, where the district court had issued a similar injunction for nine other convicted sex offenders. After the Sixth Circuit reviewed Does #1–9, it held that the plaintiffs lacked standing to sue the governor and directed the trial court to modify its injunction against the director, stating that the district court had misinterpreted precedent and that only specific provisions of the sex-offender statutes could be enjoined.The United States Court of Appeals for the Sixth Circuit reviewed the district court's refusal to dissolve or modify the preliminary injunction following the Does #1–9 decision. The Sixth Circuit held that the district court abused its discretion by not dissolving or modifying the injunction, as the Does #1–9 decision clarified that the injunction was overly broad. The Sixth Circuit reversed the district court’s order administratively closing the case and remanded for proceedings consistent with the Does #1–9 opinion, instructing the district court to determine which specific provisions of Tennessee’s sex-offender statutes could be enjoined. View "Doe v. Lee" on Justia Law

In 2017, Gratiot County foreclosed on Donald Freed’s home due to unpaid taxes. Freed’s property, valued at $98,800, was sold for $42,000, although he owed just under $1,110. The county kept all proceeds from the sale, as Michigan’s General Property Tax Act (GPTA) did not require returning surplus proceeds to the property owner. Freed sued Gratiot County and its treasurer, Michelle Thomas, under 42 U.S.C. § 1983, claiming a violation of the Fifth and Fourteenth Amendments. Michigan intervened to defend the GPTA’s constitutionality.The United States District Court for the Eastern District of Michigan dismissed Freed’s complaint for lack of subject matter jurisdiction, citing Wayside Church v. Van Buren County. Freed appealed, and the Sixth Circuit reversed the dismissal, recognizing that the Supreme Court’s ruling in Knick v. Township of Scott partially abrogated Wayside Church. On remand, the district court granted partial summary judgment to Freed, affirming that the county had to pay Freed the difference between the foreclosure sale and his debt, but dismissed claims against Thomas due to qualified immunity.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed Freed’s entitlement to attorneys’ fees from Gratiot County and Michigan. However, the court vacated the district court’s fee calculation and remanded for further proceedings. The Sixth Circuit held that Freed prevailed against both Gratiot County and Michigan, and Michigan’s intervention under 28 U.S.C. § 2403(b) subjected it to attorneys’ fee liability. The court found the district court’s explanation for reducing Freed’s hours and rate by 35% insufficient and required a more detailed justification for the fee award calculation. View "Freed v. Thomas" on Justia Law

In September 2020, Jesse Fairley was observed by law enforcement conducting hand-to-hand drug transactions in a convenience store parking lot. When officers approached and searched the vehicle Fairley had been using, they found crack cocaine, marijuana, cash, and two loaded firearms. Fairley was charged and convicted of possessing with intent to distribute crack cocaine, being a felon in possession of firearms, and possessing a firearm in furtherance of a drug trafficking crime. He received a thirty-year sentence and appealed his conviction.The United States District Court for the Northern District of Ohio denied Fairley's motions for acquittal, finding sufficient evidence for the jury to convict him. Fairley raised five issues on appeal, including the sufficiency of the evidence, the jury instructions on third-party guilt, the cumulative effect of evidentiary rulings, alleged improper communications with a defense witness, and improper closing remarks by the prosecution.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the lower court's decision. The court found that there was substantial evidence to support Fairley's convictions, including his proximity to the drugs and firearms, his observed drug transactions, and his evasive behavior. The court also determined that the jury instructions were not misleading, the evidentiary rulings were within the court's discretion, and there was no substantial interference with the witness's decision to testify. Additionally, the court found that the prosecution's closing remarks did not constitute plain error or prosecutorial misconduct. View "United States v. Fairley" on Justia Law