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

Two African American truck drivers employed by a large transportation company in Nashville alleged that their supervisors subjected them to a racially hostile work environment. The plaintiffs claimed they were assigned longer routes and more hours than their non-African American colleagues for the same pay, denied certain benefits, and given older or more damaged trucks. They also testified that their supervisors, one of whom was also African American, repeatedly called them “monkey” and “monkey ass,” used demeaning language, and threatened or criticized them in ways not directed at white coworkers. The plaintiffs reported this conduct to company liaisons and managers, but the alleged harassment continued. One plaintiff resigned due to the conditions, while the other was terminated for alleged performance issues, which he disputed.The United States District Court for the Middle District of Tennessee granted summary judgment to the employer, finding that the plaintiffs had not provided sufficient evidence of race-based harassment to support a hostile work environment claim. The court reasoned that the terms used by the supervisors were not inherently racist, that the plaintiffs had not shown the terms were used only against African Americans, and that the plaintiffs’ comparative evidence was insufficient because it did not establish the race of the relevant comparators with the required specificity.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the grant of summary judgment de novo. The appellate court held that the plaintiffs’ testimony regarding the use of “monkey” and “monkey ass” by supervisors constituted evidence of race-based harassment, given the well-established history of those terms as racial slurs against African Americans. The court also found that the plaintiffs’ comparative and other evidence was admissible and sufficient to raise genuine issues of material fact regarding the severity and pervasiveness of the harassment and the employer’s liability. The Sixth Circuit reversed the district court’s judgment and remanded the case for further proceedings. View "Smith v. P.A.M. Transport, Inc." on Justia Law

In this case, Christopher C. Brown, through his company Tattooed Millionaire Entertainment (TME), owned a Memphis music studio and insured both the studio and its equipment with Hanover American Insurance Company. John Falls, a musician, leased Studio B and its equipment from Brown and also obtained insurance from Hanover for the equipment and lost business income. In 2015, the studio was damaged by arson, and both Brown and Falls submitted insurance claims. Hanover discovered Brown had forged receipts for equipment purchases and sued to recover advance payments and for a declaratory judgment of no further liability. Brown, Falls, and another lessee counter-sued for breach of contract. After a jury trial in the United States District Court for the Western District of Tennessee, Falls was awarded $2.5 million for equipment loss and $250,000 for business income, while Brown was found to have committed insurance fraud.Hanover moved to set aside the verdict under Rule 50(b), which the district court granted. On appeal, the United States Court of Appeals for the Sixth Circuit reversed, holding Hanover had forfeited its Rule 50(b) motion by failing to make a Rule 50(a) motion as to Falls, and ordered reinstatement of the jury verdict. Subsequent proceedings included a federal interpleader action and a parallel state court action between Falls and TME. The district court enjoined the state action, but the Sixth Circuit reversed the injunction.In the present appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s allocation of the insurance payout, holding that Hanover was precluded by res judicata from challenging Falls’s recovery on grounds that could have been raised earlier. The court found the district court’s error in interpreting the wrong lease was harmless and upheld the allocation of funds based on the value of Falls’s leasehold interest. The court also held that Tennessee public policy barred Brown from recovering his allocated share due to his insurance fraud. The district court’s judgment was affirmed. View "Hanover American Insurance Co. v. Tattooed Millionaire Entertainment" on Justia Law

In this case, the defendant was found in possession of a firearm after having previously been convicted of multiple felonies, including several burglaries. When law enforcement approached his girlfriend’s home, he cooperated and led them to a pistol hidden in the woods, which bore his fingerprints. He was indicted on one count of being a felon in possession of a firearm. The presentence report listed twenty-two prior felony convictions, eleven of which were for burglary, with the offenses occurring over several years and involving different victims.The United States District Court for the Eastern District of Tennessee accepted the defendant’s guilty plea. At sentencing, the court determined, based on the presentence report, that the defendant qualified as an Armed Career Criminal under the Armed Career Criminal Act (ACCA), which mandates a minimum sentence for those with three prior violent felony convictions committed on different occasions. The court imposed a 180-month sentence. The defendant did not object to the factual accuracy of the presentence report but later challenged the application of the ACCA enhancement, arguing that the determination of whether his prior offenses were committed on different occasions should have been made by a jury, as clarified by the Supreme Court in Erlinger v. United States.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the failure to submit the “different occasions” question to a jury was not structural error and that, under harmless error review, no reasonable jury could have found that the defendant’s predicate burglaries occurred on the same occasion, given the significant gaps in time and different victims. The court also rejected the defendant’s double jeopardy argument, finding no plain error. The Sixth Circuit affirmed the enhanced sentence under the ACCA. View "United States v. Ballinger" on Justia Law

A woman from Honduras entered the United States without inspection in 2005 and was served with a Notice to Appear (NTA) for removal proceedings, which included the time, date, and location of her initial hearing, as well as instructions to update her address. She failed to appear at her first scheduled hearing, which was dismissed because the Department of Homeland Security (DHS) had not filed the NTA with the immigration court. After DHS filed the NTA and moved to recalendar, subsequent hearing notices sent to her listed address were returned as undeliverable. She did not appear at the rescheduled hearing in November 2009, and the immigration judge (IJ) ordered her removal in absentia.She later filed three motions to reopen her removal proceedings, arguing each time that she had not received notice of her hearing. The first motion was denied by the IJ, who found she had constructive notice and was at fault for not updating her address; the Board of Immigration Appeals (BIA) affirmed. Her second motion was denied by the BIA as repetitive. In her third motion, she cited new Supreme Court decisions (Pereira v. Sessions and Niz-Chavez v. Garland) and raised a new jurisdictional argument, but the BIA found the motion untimely and numerically barred, declined to exercise its sua sponte authority, and rejected her legal arguments.The United States Court of Appeals for the Sixth Circuit reviewed the BIA’s denial under an abuse-of-discretion standard. The court held that even if multiple motions to reopen based on lack of notice were permitted, the petitioner’s arguments lacked merit because she received an NTA that satisfied statutory notice requirements and failed to fulfill her obligation to update her address. The court also held that the immigration court had jurisdiction and that it lacked authority to review the BIA’s discretionary decision not to reopen proceedings sua sponte. The petition for review was denied. View "Vargas-Rodriguez v. Bondi" on Justia Law

A sheriff’s deputy responded to a 911 call reporting a domestic dispute at a residence, with allegations that the homeowner had threatened a woman with a gun and grabbed her by the neck. Upon arrival, the deputy encountered three women and a small child outside or in the garage; none appeared injured or in distress. The homeowner stood in the garage doorway, raised his hands when ordered, and denied wrongdoing. When the deputy attempted to handcuff him, the homeowner retreated into his house, resisted being handcuffed, and a physical altercation ensued, during which the deputy punched the homeowner. The deputy ceased his efforts after being told that no gun threat had occurred.The homeowner filed suit under 42 U.S.C. § 1983 in the United States District Court for the Middle District of Tennessee, alleging unlawful entry and excessive force in violation of the Fourth Amendment. Both parties moved for summary judgment. The district court denied summary judgment to the deputy on the unlawful entry and excessive force claims, finding that material factual disputes existed as to whether exigent circumstances justified the warrantless entry and whether the force used was reasonable. The deputy appealed, asserting entitlement to qualified immunity.The United States Court of Appeals for the Sixth Circuit reviewed the denial of qualified immunity de novo. The court held that, viewing the facts in the light most favorable to the plaintiff, a reasonable jury could find that the deputy lacked an objectively reasonable basis for believing exigent circumstances existed to justify a warrantless entry. The court further held that the right to be free from such entry and from force used to effectuate it was clearly established. Because the deputy failed to argue that his use of force was reasonable even if the entry was unlawful, the court affirmed the district court’s denial of summary judgment on both claims. View "Hoover v. Due" on Justia Law

A Mexican citizen entered the United States without authorization in 2005. In 2018, the Department of Homeland Security began removal proceedings against him, initially serving him with a Notice to Appear (NTA) that did not specify the date and time of his hearing. He later received a subsequent notice with the specific date, time, and location of his hearing, which also warned of the consequences of failing to appear. Neither he nor his attorney appeared at the scheduled hearing, resulting in an in absentia removal order.He first moved to reopen the proceedings, alleging ineffective assistance of counsel, but the Immigration Judge, the Board of Immigration Appeals (BIA), and the United States Court of Appeals for the Sixth Circuit all denied relief. While his appeal was still pending, he filed a second motion to reopen, arguing that the initial NTA was deficient and that, under recent Supreme Court precedent, he was entitled to rescission of the removal order and eligibility for cancellation of removal. He also requested that the BIA reopen his case on its own motion (sua sponte). The BIA denied all requested relief, finding that he had received proper notice under the law, was ineligible for cancellation of removal, and declining to exercise its sua sponte authority.The United States Court of Appeals for the Sixth Circuit reviewed the BIA’s decision. The court held that the petitioner was not entitled to rescission of the in absentia removal order because, although the initial NTA was deficient, he received a subsequent notice that satisfied statutory requirements. The court also held that he forfeited his argument for cancellation of removal by failing to adequately develop it. Finally, the court dismissed for lack of jurisdiction his claim regarding the BIA’s refusal to reopen the case sua sponte. The petition was denied in part and dismissed in part. View "Guzman-Torralva v. Bondi" on Justia Law

A journalist sought access to meetings of the Tennessee Judicial Advisory Commission, which advises the Tennessee Supreme Court on rules of practice and procedure. The Commission’s meetings had been open to the public until 2018, when they were closed following a disruption by a member of the public. The journalist argued that closing these meetings violated his First Amendment rights by denying him access to government proceedings.The United States District Court for the Middle District of Tennessee initially granted the journalist a preliminary injunction, allowing public access to the meetings. However, after discovery, the district court granted summary judgment in favor of the defendant, the Director of the Tennessee Administrative Office of the Courts, and dissolved the injunction. The journalist appealed this decision.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court held that the First Amendment does not provide a general right of access to government information or proceedings. It explained that the “experience-and-logic” test, derived from Press-Enterprise Co. v. Superior Court of California for Riverside County, applies only to adjudicatory proceedings, such as criminal trials or formal administrative hearings. The court found that the Commission’s meetings are purely advisory and not adjudicatory in nature, as they do not involve adversarial proceedings or have binding legal effect. Therefore, the experience-and-logic test was inapplicable, and the journalist’s First Amendment claim failed. The Sixth Circuit affirmed the district court’s grant of summary judgment to the defendant. View "McCaleb v. Long" on Justia Law

Kia and Hyundai manufactured millions of vehicles between 2011 and 2021 that lacked engine immobilizers, a standard anti-theft device, and had ignition assemblies that were easily compromised. These design features made the cars especially vulnerable to theft, leading to a surge in thefts nationwide, particularly after a viral social media trend demonstrated how to steal these vehicles. In two separate incidents, teenagers stole such cars and, while driving them, caused accidents that resulted in severe injury to Donald Strench and the death of Matthew Moshi. Strench and Moshi’s estate brought suit against Hyundai and Kia, respectively, alleging that the companies were liable under the Ohio Product Liability Act (OPLA) for design defects that made the cars susceptible to theft and, consequently, to the resulting injuries.The United States District Court for the Southern District of Ohio dismissed the claims, holding that the plaintiffs could not establish proximate causation as a matter of Ohio law. The district court relied on Ohio precedents that generally absolve car owners of liability for injuries caused by thieves who steal their cars, applying the same reasoning to the manufacturers.On appeal, the United States Court of Appeals for the Sixth Circuit held that the Ohio cases concerning car owners’ liability do not control product liability claims against manufacturers. The Sixth Circuit found that, under OPLA and Ohio common law, foreseeability must be assessed from the perspective of a manufacturer, who is expected to have specialized knowledge of risks, including those arising from third-party theft. The court concluded that the plaintiffs plausibly alleged that the manufacturers should have foreseen the risk of theft-related accidents. The Sixth Circuit reversed the district court’s dismissal of the design defect and inadequate warning claims, but affirmed the dismissal of the manufacturing defect and nonconformance to representation claims. The case was remanded for further proceedings on the surviving claims. View "Moshi v. Kia Motors Am., Inc." on Justia Law

A woman experiencing a mental health crisis called 911 and requested that police come to her home to shoot her. Three officers responded and found her holding a bat and a pickaxe. The officers maintained a distance of about fifteen feet and attempted to de-escalate the situation, with one officer assuring her that she would not be harmed. After several minutes, and following an interaction with the woman’s mother, one officer tased her, and another officer shot her multiple times as she moved in the direction of the officers. The woman survived but suffered severe injuries.The plaintiff, acting on the woman’s behalf, filed suit in the United States District Court for the Middle District of Tennessee against the two officers and the Metropolitan Government of Nashville and Davidson County under 42 U.S.C. § 1983, alleging excessive force in violation of the Fourth Amendment, and also brought a negligence claim against the municipality. The officers moved to dismiss the complaint on qualified immunity grounds, and the municipality sought judgment on the pleadings. The district court granted the officers’ motion to dismiss the excessive force claims and the municipality’s motion on the negligence claim, but initially denied the municipality’s motion as to the § 1983 claim. Later, the district court granted the municipality’s motion for judgment on the pleadings on the § 1983 claim as well.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court held that the complaint plausibly alleged that both officers violated the woman’s clearly established Fourth Amendment rights by tasing and shooting her under the circumstances described. The court also held that the district court erred in dismissing the municipal liability claim. Accordingly, the Sixth Circuit reversed the dismissal of the claims against the officers, vacated the judgment for the municipality, and remanded for further proceedings. View "Chrestman v. Metropolitan Government of Nashville and Davidson County" on Justia Law

A tenured English professor at a public university in Ohio, who identifies as transgender, became involved in discussions about leading the university’s Center for the Study of Gender and Sexuality during a period of departmental restructuring. Although the professor expressed interest in directing the Center and was considered a strong candidate, the position was not open as the Center had gone dormant. The professor was offered a partial teaching load reallocation to help develop a new gender-studies major, but after a series of profanity-laden and disparaging social media posts targeting colleagues and administrators, the offer was rescinded. The professor also sought a tenure transfer to the main campus, which was denied by faculty committees after considering collegiality and departmental needs, with no discussion of gender identity.The United States District Court for the Northern District of Ohio granted summary judgment for the university and individual defendants on all claims. The court found no genuine dispute of material fact and concluded that the university’s actions were based on legitimate, nondiscriminatory reasons, including the professor’s unprofessional conduct and the department’s academic requirements. The professor appealed, challenging the district court’s rulings on claims of sex discrimination and retaliation under Title VII, First Amendment retaliation under 42 U.S.C. § 1983, and perceived-disability discrimination under the Rehabilitation Act.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s summary judgment. The court held that there was no direct or circumstantial evidence of discrimination or retaliation, that the professor’s social media posts did not constitute protected speech on matters of public concern under the First Amendment, and that there was insufficient evidence to support a perceived-disability claim. The court clarified that adverse employment actions under Title VII need only cause some harm, but found the university’s reasons for its decisions were not pretextual. View "GPat Patterson v. Kent State University" on Justia Law