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

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

A publicly traded company, CoreCivic, which operates private prisons, faced scrutiny after the Bureau of Prisons raised safety and security concerns about its facilities. Following a report by the Department of Justice's Inspector General highlighting higher rates of violence and other issues in CoreCivic's prisons compared to federal ones, the Deputy Attorney General recommended reducing the use of private prisons. This led to a significant drop in CoreCivic's stock price and a subsequent shareholder class action lawsuit.The United States District Court for the Middle District of Tennessee, early in the litigation, issued a protective order allowing parties to designate discovery materials as "confidential." This led to many documents being filed under seal. The Nashville Banner intervened, seeking to unseal these documents, but the district court largely maintained the seals, including on 24 deposition transcripts, without providing specific reasons for the nondisclosure.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court emphasized the strong presumption of public access to judicial records and the requirement for compelling reasons to justify sealing them. The court found that the district court had not provided specific findings to support the seals and had not narrowly tailored the seals to serve any compelling reasons. The Sixth Circuit vacated the district court's order regarding the deposition transcripts and remanded the case for a prompt decision in accordance with its precedents, requiring the district court to determine if any parts of the transcripts meet the requirements for a seal within 60 days. View "Grae v. Corrections Corp. of Am." on Justia Law

Jay Sadrinia, a dentist, was convicted by a jury for knowingly prescribing a controlled substance without a legitimate medical purpose, resulting in the death of his patient, Cheyenne Witt. Witt died of a morphine overdose after Sadrinia prescribed her morphine twice within three days. The prescriptions were given following a dental procedure that Sadrinia performed on Witt. Witt had a history of drug addiction and mental illness, which she did not disclose to Sadrinia. The morphine dosage prescribed by Sadrinia was significantly higher than what is typically prescribed for dental pain.The United States District Court for the Eastern District of Kentucky admitted testimony from several of Sadrinia’s former employees about his prior bad acts, which were unrelated to the conduct charged in the indictment. The court ruled this testimony as intrinsic evidence of the crimes charged. The jury acquitted Sadrinia on three counts related to earlier prescriptions but convicted him on the counts related to the morphine prescriptions on August 24 and August 26, 2020. Sadrinia was sentenced to 240 months in prison.The United States Court of Appeals for the Sixth Circuit reviewed the case and found that there was sufficient evidence to support Sadrinia’s conviction. However, the court agreed with Sadrinia that the district court improperly admitted testimony about unrelated bad acts as intrinsic evidence. The appellate court held that this testimony was not intrinsic to the charged conduct and should not have been admitted. The court vacated Sadrinia’s convictions and remanded the case for a new trial. The court did not address Sadrinia’s other arguments regarding prosecutorial misconduct and the admission of a toxicology report. View "United States v. Sadrinia" on Justia Law

During a late-night traffic stop, officers found two firearms in Andre Whitlow’s car. As Whitlow was a felon, it was illegal for him to possess the guns. At trial, a jury found him guilty of being a felon in possession. Whitlow appealed, challenging various aspects of the traffic stop and his conviction.The United States District Court for the Northern District of Ohio denied Whitlow’s motion to suppress the firearms found during the search. The court found that Officer Kazimer had probable cause to search the car based on the marijuana observed in the vehicle. After a two-day trial, the jury found Whitlow guilty, and the court sentenced him to 120 months in prison.The United States Court of Appeals for the Sixth Circuit reviewed the case. Whitlow argued that Officer Kazimer lacked probable cause to search his car, the evidence was insufficient to convict him, the district court erroneously admitted various pieces of evidence, allowed improper testimony, and that his sentence was procedurally unreasonable. The Sixth Circuit affirmed the lower court’s decision, holding that Officer Kazimer had probable cause to search the car based on the marijuana observed, and the evidence was sufficient to support the conviction. The court also found that the district court did not err in admitting the Instagram photographs and prior police interaction as evidence, nor in allowing the officer to identify himself as being from the Homicide Unit. Finally, the court upheld the procedural reasonableness of Whitlow’s sentence, including the two-level enhancement for possessing a stolen firearm. View "United States v. Whitlow" on Justia Law

Joseph Ebu, a lawful permanent resident, was involved in concurrent naturalization and removal proceedings. The United States Citizenship and Immigration Services (USCIS) delayed considering his naturalization application due to the pending removal proceedings. When the delay exceeded 120 days after his naturalization examination, Ebu sought judicial intervention to determine his naturalization application and declare him prima facie eligible for naturalization under 8 U.S.C. § 1447(b). The district court dismissed his complaint, citing a provision that prohibits the determination of a naturalization application while removal proceedings are pending, relying on the unpublished opinion in Rahman v. Napolitano.The United States District Court for the Eastern District of Kentucky dismissed Ebu’s complaint, agreeing with USCIS that removal proceedings take priority over naturalization applications. The court followed the precedent set in Rahman, which held that 8 U.S.C. § 1429 precludes district courts from considering naturalization applications under § 1447(b) while removal proceedings are pending.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s dismissal. The court held that § 1429’s prohibition on the Attorney General from considering naturalization applications during pending removal proceedings also applies to district courts. The court emphasized that Congress intended for removal proceedings to take priority over naturalization applications, regardless of the forum. The court also rejected Ebu’s request for a declaratory judgment on his prima facie eligibility for naturalization, stating that such a judgment would be an impermissible advisory opinion. The court concluded that the district court correctly dismissed Ebu’s complaint based on § 1429 without considering the merits of his naturalization application. View "Ebu v. Citizenship and Immigration Services" on Justia Law

EOG Resources, Inc. holds drilling rights to oil and gas beneath property owned by Lucky Land Management, LLC in Ohio. The dispute arose over whether EOG's drilling rights included the right to drill horizontally from Lucky Land's surface to adjacent properties. EOG sought a preliminary injunction to access the land, cut down trees, and start constructing drills. The district court granted the injunction, finding that EOG would likely succeed on the merits.The United States District Court for the Southern District of Ohio granted EOG's request for a preliminary injunction, allowing EOG to access the land and begin drilling operations. The court found that EOG was likely to succeed on the merits of its claim and that the balance of equities and public interest favored granting the injunction. Lucky Land Management appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case and disagreed with the district court's findings. The appellate court held that Lucky Land had the better interpretation of oil-and-gas law, which generally does not allow a lessee to use the surface of one property to drill into neighboring lands without explicit permission. The court also found that EOG would not suffer irreparable harm if it had to wait for the litigation to proceed, as any potential losses could be compensated with monetary damages. The court emphasized that preliminary injunctions are meant to prevent irreparable injuries and preserve the court's ability to issue meaningful final relief, not to serve as shortcuts to the merits. Consequently, the Sixth Circuit reversed the district court's decision to grant the preliminary injunction. View "EOG Resources, Inc. v. Lucky Land Management, LLC" on Justia Law

Allen Walker pleaded guilty to conspiracy with intent to distribute and dispense controlled substances and was sentenced to 96 months in prison on August 20, 2015. He did not appeal, making the judgment final on September 3, 2015. Walker had until September 3, 2016, to file a habeas motion under 28 U.S.C. § 2255. In August 2016, Walker sent a letter to the district court requesting more time to file his motion and for the appointment of counsel, citing ineffective assistance of counsel. The district court denied his request on jurisdictional grounds but provided a form for filing a § 2255 motion. Walker filed his motion pro se on August 17, 2017, almost a year after the deadline.The United States District Court for the Middle District of Tennessee denied Walker's motion as untimely, despite the government not raising the statute of limitations defense. Walker appealed, and the case was remanded to determine if the government's failure to raise the defense constituted forfeiture or waiver. The district court concluded it was forfeiture and again denied Walker's motion as time-barred.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the government waived the statute of limitations defense by not raising it despite being aware of the timeliness issue. The court noted that the government had multiple opportunities to address the statute of limitations but chose to focus on the merits of Walker's claim instead. Consequently, the district court erred in considering the timeliness issue sua sponte. The Sixth Circuit reversed the district court's decision and remanded the case for further proceedings on the merits of Walker's § 2255 motion. View "Walker v. United States" on Justia Law

Patrick Reed was convicted of drug trafficking, drug possession, firearm possession, and evidence tampering. The police, with the help of confidential informants, conducted controlled drug purchases from Reed near a house on Larchmont Drive in Sandusky, Ohio. A search warrant for the house led to the discovery of firearms, ammunition, cash, drug paraphernalia, and drugs. Evidence linking Reed to the house was also found. During the trial, a detective testified about the investigation and the search, including information from a confidential informant about where Reed hid drugs. The trial court instructed the jury to consider the informant's tip only to explain the detective's actions, not for the truth of the matter asserted.Reed appealed, arguing that his Confrontation Clause rights were violated because the informant did not testify, preventing cross-examination. The Ohio Court of Appeals rejected this claim, stating that the trial court's instructions to the jury were sufficient. The Ohio Supreme Court declined to hear Reed's appeal. Reed then filed a habeas corpus petition in federal court, which was dismissed. The district court certified one question for review: whether the Ohio trial court properly admitted the detective's testimony about the informant's tip.The United States Court of Appeals for the Sixth Circuit reviewed the case under the Antiterrorism and Effective Death Penalty Act (AEDPA). The court held that the Confrontation Clause does not apply to non-hearsay statements, and the informant's tip was admitted for a non-hearsay purpose—to explain the detective's actions. The court found that the Ohio courts' decision was not contrary to or an unreasonable application of clearly established federal law. The court affirmed the district court's denial of Reed's habeas petition. View "Reed v. May" on Justia Law