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

In this case, a prisoner, Kyle Brandon Richards, appealed a district court's decision to dismiss his civil rights suit under 42 U.S.C. § 1983. The lawsuit was dismissed because Richards reportedly failed to exhaust his administrative remedies. The plaintiff alleged sexual harassment, retaliation, and destruction of property by Resident Unit Manager Thomas Perttu. Specifically, Richards claimed that Perttu prevented him from filing grievances related to the alleged abuse by destroying or ripping them up.The defendant, Perttu, moved for summary judgment, arguing that Richards had failed to exhaust his administrative remedies as required by the Prison Litigation Reform Act (PLRA), 42 U.S.C. § 1997e(a). The district court denied the motion due to questions of fact. After an evidentiary hearing, a magistrate judge recommended that the district court find that Richards had failed to exhaust his administrative remedies. Richards appealed, alleging errors by the district court, bias by the magistrate judge, and the need for a free transcript of the evidentiary hearing.The United States Court of Appeals for the Sixth Circuit addressed whether the district court should have ordered an evidentiary hearing to decide the disputed questions of fact intertwined with the exhaustion issue. The Court of Appeals found that the Seventh Amendment required a jury trial when the resolution of the exhaustion issue under the PLRA would also resolve a genuine dispute of material fact regarding the merits of the plaintiff’s substantive case. Therefore, the Court of Appeals reversed the judgment of the district court and remanded the case for further proceedings. View "Richards v. Perttu" on Justia Law

The plaintiff, Tillman Transportation, LLC, and the defendant, MI Business, Inc. (operating as affiliate companies RDT and RDF) entered into three trucking contracts, each of which included arbitration clauses. After the contracts were terminated, disputes arose between the parties, leading to this lawsuit and a separate ongoing arbitration. The defendants moved to compel arbitration, arguing that the Federal Arbitration Act (FAA) requires enforcement of the arbitration clauses. Tillman contended that it was exempt from compulsory arbitration under Section 1 of the FAA.The district court granted the defendants’ motion to compel arbitration, ruling that Section 1 of the FAA, which exempts "contracts of employment of seamen, railroad employees, or any other class of workers engaged in foreign or interstate commerce" from the FAA's general policy favoring arbitration, did not apply to the arbitration clauses in the contracts because Tillman, as a limited liability company in contract with another corporate entity, did not qualify for the Section 1 exemption.Tillman appealed this decision. The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The Sixth Circuit held that the Section 1 exemption did not apply to an agreement between two corporate entities. Thus, the exemption did not apply to Tillman, a limited liability company. The court also noted that Tillman had waived certain arguments by failing to raise them in its initial brief on appeal. View "Tillman Transp., LLC v. MI Bus. Inc." on Justia Law

The plaintiff, Ilya Kovalchuk, was driving his vehicle when off-duty police officer Matthew Ward began driving erratically behind him, ordered him to pull over, and held Kovalchuk at gunpoint without any justification. Kovalchuk filed a lawsuit against Ward and the City of Decherd, Tennessee, alleging that Ward violated his Fourth Amendment rights and that the City’s failure to investigate Ward’s background before hiring him led to Kovalchuk’s injuries. The district court dismissed the claims against the City, finding that Kovalchuk failed to adequately plead allegations supporting municipal liability.The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court determined that in order to survive a motion to dismiss, a plaintiff must allege facts that, if accepted as true, are sufficient to state a claim to relief that is plausible on its face. The court found that Kovalchuk did not plausibly allege that the City of Decherd was deliberately indifferent to a known or obvious consequence of its decision to hire Ward. According to the court, Kovalchuk's allegations of "issues," "concerns about [Ward’s] demeanor and professionalism," and his "fail[ure] to complete [a] training program" were insufficient to establish a causal link between Ward's hiring and Kovalchuk's injury. The court further stated that a plaintiff cannot use discovery to bridge the gap between a deficient pleading and the possibility that a claim might survive upon further investigation. Therefore, the court affirmed the district court's dismissal of Kovalchuk's claims against the City of Decherd. View "Kovalchuk v. City of Decherd" on Justia Law

The case involved Ricardo Alvarado, who was convicted of possessing a firearm as a felon under 18 U.S.C. § 922(g)(1). His crime was reported by officers who responded to a call that a man was carrying what appeared to be a machine gun in a mobile home park. Alvarado was found with a Ruger AR-556 semi-automatic rifle, and upon investigation, officers discovered that he had two prior felony convictions. He was sentenced to 104 months' imprisonment, including a four-level sentencing enhancement for reckless endangerment.Alvarado appealed his conviction and sentence. He contended that his conviction violated the Second Amendment based on the standard articulated in New York State Rifle & Pistol Ass’n v. Bruen, an issue he raised for the first time on appeal. He also argued that the evidence did not support a sentencing enhancement for reckless endangerment.The United States Court of Appeals for the Sixth Circuit affirmed Alvarado’s conviction but vacated his sentence and remanded the case to the district court for resentencing. The court found that the constitutionality of § 922(g)(1) under Bruen was subject to reasonable dispute and would not disturb Alvarado’s conviction on plain error review. However, the court found that the district court erred in applying a sentencing enhancement for reckless endangerment. Without record evidence of anyone in proximity to Alvarado’s line of fire, or otherwise facing an imminent risk of harm, the Government could not satisfy Tennessee’s zone of danger requirement. Consequently, Alvarado's sentence was vacated. View "United States v. Alvarado" on Justia Law

Gloris Sarai Vasquez-Rivera, a native and citizen of El Salvador, entered the United States without authorization in 2014, at the age of nine. She was served with a notice to appear in removal proceedings and charged as a noncitizen present in the country without being admitted or paroled after inspection by an immigration officer. Vasquez-Rivera applied for asylum, withholding of removal, and protection under the Convention Against Torture, citing fear of gang violence in El Salvador.Vasquez-Rivera proposed four social groups for her asylum and withholding of removal claims: Salvadoran women and girls whose parents live outside the country; her family; family members of persons targeted for gang recruitment whose family is threatened when they refuse to join the gangs; and young Salvadoran women considered to be property of the gangs. Both the Immigration Judge (IJ) and the Board of Immigration Appeals (BIA) found that three of these groups were not cognizable under federal immigration law. As for her family, the BIA assumed it constituted a distinct social group but agreed with the IJ that Vasquez-Rivera did not establish a nexus between this group and the harm she experienced and fears.The United States Court of Appeals for the Sixth Circuit decided to grant in part and deny in part the petition for review. It found that the BIA's conclusions regarding the nexus required for the family-as-a-particular-social-group claim lacked support in the record and amounted to improper de novo factfinding. The case was remanded to the BIA for further proceedings, applying circuit nexus precedent to Vasquez-Rivera’s asylum claim and claim for withholding of removal based on her membership in her family. The court upheld the BIA’s determination that Vasquez-Rivera had failed to establish eligibility for Convention Against Torture protection. View "Vasquez-Rivera v. Garland" on Justia Law

The case revolves around an appeal by Karnail Singh, who was charged with using a fraudulently procured passport and making false statements to immigration officials. Singh pleaded guilty to using a fraudulently procured passport in exchange for a lower sentencing range and the dismissal of the false-statement count. After his plea, the government initiated proceedings to revoke his citizenship. In response, Singh petitioned for a writ of coram nobis, requesting the district court to set aside his conviction, arguing he would not have pled guilty had he known his plea could affect his citizenship. The district court denied his petition, leading to this appeal.The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court ruled that Singh's plea was knowing and satisfied due process, regardless of whether he understood it could impact his citizenship. They found that the district court complied with Rule 11 of the Federal Rules of Criminal Procedure, which requires the court to inform the defendant that a conviction may have immigration-related consequences.Singh also claimed ineffective assistance of counsel, arguing his attorney incorrectly informed him that his plea would only affect his citizenship if he committed another crime. The court rejected this claim, citing lack of evidence that Singh would have chosen to go to trial if he had received different advice from his counsel.Finally, the court rejected Singh's argument that the district court should have held a hearing before ruling on his coram nobis petition, stating that the record clearly showed Singh was not entitled to coram nobis relief. View "United States v. Singh" on Justia Law

In the United States Court of Appeals for the Sixth Circuit, Alison Kareem brought a case against the Ohio Secretary of State, the Cuyahoga County Board of Elections, and the Cuyahoga County Prosecuting Attorney. Kareem challenged two Ohio state election laws, which prohibited her from displaying her marked ballot to others as a violation of her First Amendment rights. Kareem refrained from displaying a photograph of her marked ballot online due to these laws. The district court granted summary judgment to the defendants, arguing that Kareem lacked Article III standing.The Appeals Court, however, reversed the district court's order and remanded it for further proceedings. The court held that Kareem had demonstrated a credible threat of enforcement of the Ohio laws, which constituted an injury in fact, a requirement for Article III standing. The court found that Kareem's fear of enforcement, given the possible criminal punishment, the defendants' public statements that displaying marked ballots was illegal, and past instances of enforcement, was not merely subjective or self-imposed. The court also found that Kareem's alleged violation of her First Amendment rights was fairly traceable to the defendants and that the relief she requested was likely to remedy her alleged injury, thus meeting the causation and redressability requirements of Article III standing. The court did not rule on the merits of Kareem's First Amendment claims, leaving that for the district court to decide. View "Kareem v. Cuyahoga County Board of Elections" on Justia Law

Timothy Jaimez was found guilty of federal drug charges and sentenced to supervised release. Following several violations of the terms of his release, the district court sentenced him to sixty months' imprisonment. Jaimez appealed the decision, arguing that his sentence was both procedurally and substantively unreasonable.The United States Court of Appeals for the Sixth Circuit disagreed with Jaimez's arguments. Jaimez claimed that the court inadequately explained his sentence, improperly considered certain sentencing factors, and incorrectly classified his release violation. The appellate court found that the district court had sufficiently explained the sentence, correctly considered relevant sentencing factors, and accurately classified the release violation.Jaimez also argued that his sentence was substantively unreasonable. He claimed that the court placed too much weight on his conduct underlying the release violation, inflicted "double punishment" by considering conduct for which he had already been punished in Ohio, and imposed a sentence that was too long in light of mitigating evidence. The appellate court disagreed with all of these points, finding that the district court had appropriately weighed Jaimez's conduct and that the sentence did not constitute "double punishment." The court also found that the sentence length was reasonable given the circumstances.The appellate court upheld the district court's sentence of sixty months' imprisonment for Jaimez. The holding of the case is that the district court correctly considered the relevant sentencing factors, accurately classified the release violation, and imposed a reasonable sentence given the circumstances. The court affirmed the district court's decision. View "United States v. Jaimez" on Justia Law

In this case, the United States Court of Appeals for the Sixth Circuit considered an appeal by Herbert Marsh, who was convicted of various charges related to a robbery of a Nashville pawn shop. Marsh and two co-conspirators stole eleven firearms and over $8,000 in cash. Marsh challenged the denial of his motion to suppress evidence obtained from a traffic stop the day after the robbery, arguing the stop was based on a mistaken interpretation of Tennessee traffic law. The court held that the officers' interpretation was objectively reasonable and did not violate the Fourth Amendment, affirming the denial of Marsh's motion to suppress.Marsh also argued that the calculation of his sentence was procedurally unreasonable. The court rejected Marsh's argument that the district court's calculations constituted double counting, finding that the district court’s factual findings fully supported holding Marsh accountable for his co-conspirator’s conduct through the base offense level and the enhancements. The court held that the base offense level and the three firearms enhancements penalized Marsh for distinct harms, so there was no impermissible double counting. Consequently, the court affirmed the judgment of the district court. View "United States v. Marsh" on Justia Law

This case involves two consolidated appeals from the Western District of Michigan and the Southern District of Ohio. The dispute revolves around how pizza delivery drivers should be reimbursed for the cost of using their personal vehicles for work. The delivery drivers argued that they should be reimbursed according to a mileage rate published by the IRS, while the employers contended that a “reasonable approximation” of the drivers’ expenses sufficed.The United States Court of Appeals for the Sixth Circuit disagreed with both parties. The court held that the Fair Labor Standards Act (FLSA) requires employers to pay each employee a wage of not less than $7.25 an hour. If the employer requires an employee to provide tools for work, the employer violates the Act if the cost of these tools cuts into the minimum or overtime wages required to be paid under the Act.Applying these standards, the court rejected the employers' argument that a “reasonable approximation” of a delivery driver’s cost of providing his vehicle is always sufficient reimbursement. Similarly, the court also rejected the drivers' argument that they should be reimbursed using the IRS standard-mileage rate for business deductions, as this rate is a nationwide average and does not accurately reflect an individual employee's actual costs.The court vacated the district courts’ decisions and remanded for further proceedings, suggesting that a potential solution could be a burden-shifting regime similar to those in Title VII cases. View "Bradford v. Team Pizza, Inc." on Justia Law