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

In this consolidated appeal involving two cases from the Western District of Michigan and the Southern District of Ohio, the United States Court of Appeals for the Sixth Circuit ruled on how pizza-delivery drivers should be reimbursed for the cost of using their vehicles for work. The main dispute lay in the reimbursement method: the Michigan court sided with the drivers, stating they should be reimbursed based on a mileage rate published by the IRS, while the Ohio court agreed with the employers, stating a "reasonable approximation" of the drivers' costs suffices. The Sixth Circuit disagreed with both courts and vacated their decisions.The central issue involved the Fair Labor Standards Act (FLSA) requirement that employers pay each employee at least a minimum wage. The court found that if an employer required a minimum-wage employee to provide his own "tools" for work (in this case, their own vehicles), the employer must reimburse them for 100% of the cost of doing so. The court emphasized that the FLSA mandates that each employee be paid at least the specified minimum wage, not a "reasonable approximation".The court also disagreed with the plaintiffs’ argument that they should be reimbursed using the IRS's standard-mileage rate for business deductions, as it is a nationwide average and does not consider the individual costs of each driver. The court emphasized that the statute entitles a minimum-wage employee to reimbursement of actual costs incurred on the employer's behalf, neither more nor less. The case was remanded back to the lower courts for further proceedings. View "Parker v. Battle Creek Pizza, Inc." on Justia Law

In this case adjudicated by the United States Court of Appeals for the Sixth Circuit, Fred Golson, Jr. had pleaded guilty to two counts of being a felon in possession of a firearm and ammunition. The district court added a two-level enhancement to Golson's sentencing guidelines range, based on the assessment that his flight from law enforcement during one of the underlying incidents amounted to reckless endangerment. Golson challenged this enhancement, arguing that he wasn't the driver of the vehicle during the incident.The appellate court affirmed the district court's decision. It found that, despite Golson not being the driver, the undisputed facts of the case created a reasonable inference that he was an active participant in the reckless flight from police. The court considered Golson's active participation in the crime, his extensive criminal record, his immediate flight from the crashed vehicle, and his subsequent involvement in another shooting and immediate flight from that scene as indicators of his active participation in the reckless flight. Consequently, the court found no error, plain or otherwise, in the district court's application of the two-level enhancement. View "United States v. Golson" on Justia Law

This case concerns a dispute involving the Producers Service Corporation (PSC), an oilfield services company, and several of its current and former employees. The employees alleged that PSC failed to pay them a lawful overtime premium for all hours worked over forty per week. PSC argued that it paid its employees in accordance with a Belo plan, a statutory exception to the Fair Labor Standards Act (FLSA) that allows employers to pay a fixed salary to employees who work fluctuating hours. The district court found that PSC could not establish one of the prerequisites to a valid Belo plan because its employees worked irregular schedules not by necessity, but due to factors within PSC’s control, and therefore granted summary judgment in favor of the employees.On appeal, the United States Court of Appeals for the Sixth Circuit reversed the district court's decision, holding that PSC presented evidence creating a genuine dispute of fact as to the reason behind the employees' irregular schedules. Not all irregular schedules were due to scheduled time off, and PSC provided a plausible explanation for the weeks that employees worked fewer than forty hours despite taking no time off: swings in demand for its services. As such, the matter was remanded back to the district court for further proceedings. View "Jones v. Producers Service Corp." on Justia Law

In the case before the United States Court of Appeals for the Sixth Circuit, State Farm Mutual Automobile Insurance Company ("State Farm") brought a lawsuit against Michael Angelo, alleging violations of the Racketeer Influenced and Corrupt Organizations Act ("RICO"). The lawsuit claimed that Angelo submitted fraudulent bills to the insurance company. Angelo later filed a separate action against State Farm under the False Claims Act ("FCA"), alleging that the insurance company wrongfully avoided paying medical benefits. This action was unknown to State Farm at the time because FCA complaints are required to be filed under seal.The two parties entered into a settlement agreement in February 2021, resolving the RICO action. As part of the agreement, Angelo agreed to take all necessary steps to dismiss certain claims against State Farm. After the settlement agreement was signed, the FCA complaint was unsealed and served on State Farm. State Farm then sought to enforce the settlement agreement, arguing that it required Angelo to dismiss the FCA action as well.Angelo argued that the settlement agreement did not apply to the FCA action because the FCA claims were unrelated to the settled RICO claims. However, the district court disagreed and ordered Angelo to seek the government's consent to dismiss his FCA claims against State Farm. Angelo appealed this decision, claiming it violated his First Amendment rights and the FCA.The Court of Appeals affirmed the district court's decision, stating that the settlement agreement clearly encompassed the FCA action. The court also held that the district court had not erred in requiring Angelo to seek the government's consent to dismiss his FCA claims. Angelo's First Amendment claim was deemed forfeited as it was raised for the first time in a motion for reconsideration and was thus untimely. View "State Farm Mutual Automobile Insurance Co. v. Angelo" on Justia Law

In November 2018, Marlon Johnson was arrested after a vehicle he was driving crashed during a police pursuit. The police found over 1,000 grams of pure methamphetamine and a loaded semiautomatic pistol in the vehicle. A jury convicted Johnson of firearm and drug trafficking offenses, and he was sentenced to 300 months’ imprisonment. Johnson appealed his convictions and sentence on four grounds.The United States Court of Appeals for the Sixth Circuit affirmed Johnson's convictions and sentence. Firstly, the court rejected Johnson's claim that his jury was not drawn from a fair cross-section of the community, in violation of the Sixth Amendment and the Jury Selection and Services Act. The court found that Johnson failed to show that the underrepresentation of African Americans in the jury pool was due to systematic exclusion.Secondly, the court dismissed Johnson's claim that his felon-in-possession conviction violated the Second Amendment. The court noted that there was no precedent explicitly holding that the law under which Johnson was convicted, 18 U.S.C. § 922(g)(1), was unconstitutional.Thirdly, the court upheld the district court's decision to admit testimony about Johnson's prior drug sales as "res gestae" evidence. This type of evidence is considered to be part of the story of the charged offense and is not subject to Rule 404(b), which generally prohibits the admission of evidence of a defendant’s prior bad acts.Finally, the court found that Johnson's sentence of 300 months’ imprisonment was not substantively unreasonable. Johnson had argued that the district court erred in using a 10:1 weight ratio between methamphetamine mixtures and actual methamphetamine to determine the offense level. The court noted that a district court’s use of the 10:1 ratio is a discretionary decision and cannot, by itself, render a criminal sentence invalid. View "United States v. Johnson" on Justia Law

The case revolves around a plaintiff, Jorden Brown, who was tasered by Officer Samuel Giles while fleeing from police, resulting in injuries to Brown. Brown sued Officer Giles, the police chief, and the municipality he was arrested in under 42 U.S.C. § 1983, alleging excessive use of force and violation of his Fourth Amendment rights. He also claimed that department policies or customs enabled these violations. The defendants moved to dismiss the case, and the district court granted the dismissal on the grounds that Brown failed to allege a violation of clearly established law. Brown appealed this decision.The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court ruled that Brown failed to show that it was clearly established that tasing him in this particular context was excessive. They referred to previous cases where it was deemed reasonable for officers to tase fleeing suspects. The court further dismissed Brown's claim that the taser hit his head, arguing that during a chase, it is unrealistic to expect an officer to aim precisely to avoid the head.The court also rejected Brown's claim that Officer Giles continued to tase him after he was incapacitated. Brown had provided video footage of the incident which, according to the court, showed that Officer Giles tased Brown only once. The court therefore ruled that Officer Giles was entitled to qualified immunity. As Brown's claims against Officer Giles failed, his claims against the police chief and the municipality were also dismissed. View "Brown v. Giles" on Justia Law

A former restaurant owner from Mexico, Alma Reyes Galeana, and her three daughters sought asylum and withholding of removal in the United States after fleeing violent threats from gangs in Mexico. Reyes Galeana claimed that, as a Mexican business owner, she was a member of a "particular social group" that deserved protection from deportation under federal law. However, both the Immigration Judge and the Board of Immigration Appeals rejected this argument, asserting that "Mexican business owners" do not constitute a specific social group.The United States Court of Appeals for the Sixth Circuit reviewed the Board's decision and agreed with the lower courts' rulings. The court ruled that Reyes Galeana's proposed social group of "Mexican business owners" failed on grounds of particularity and social distinction. The court held that this group was neither specifically defined nor perceived as socially distinct in Mexican society. Furthermore, the court maintained that being a target for extortion, a common threat faced by business owners, does not establish membership in a particular social group. The court also found that Reyes Galeana failed to provide evidence that Mexican society perceives business owners as a distinct class of persons subject to persecution.Consequently, the court denied her petition for review, affirming the Board's decision that Reyes Galeana does not qualify for asylum or withholding of removal as a member of a particular social group. View "Galeana v. Garland" on Justia Law

In this case before the United States Court of Appeals for the Sixth Circuit, the defendant, Charles O’Neill, appealed the judgment of the district court. O’Neill was charged with sexually exploiting a minor and receiving or distributing child pornography. He pleaded guilty to both charges but reserved the right to appeal the district court’s denial of his motion to suppress evidence obtained from his home and a barn he owned. The evidence included large numbers of photographs of nude and partially nude minor boys on O’Neill’s phone and iPad, and a computer, camcorder, camera, digital storage devices, miscellaneous clothing, and a vibrator found in the barn.The district court found that although the affidavits from the police officers used to obtain search warrants contained false statements and lacked probable cause, the officers had not knowingly or recklessly misled the issuing magistrate, and their reliance on the warrants was objectively reasonable under the good-faith exception in United States v. Leon.On appeal, the Sixth Circuit affirmed the district court's decision, agreeing that none of the exceptions to the good-faith exception applied. The court found that the officers' errors in the affidavits were negligent rather than reckless, the affidavits weren't "bare bones" as they contained more than conclusory claims and were far from devoid of factual support, and the warrants weren't facially deficient. The court noted that the officers' reliance on the search warrants was objectively reasonable, and therefore the fruits of their searches shouldn't be suppressed. The court also noted that even if it shared the dissenting judge's view on the officers' state of mind, it would likely conclude that the district court's denial of the suppression motion was proper because the remaining content of the affidavit would likely establish probable cause. View "United States v. O'Neill" on Justia Law

In this case, DeShawn Anderson-Santos, a juvenile detainee at the Kent County Juvenile Detention Center, claimed he suffered a head injury after being pushed by corrections officer Derek Leshan. Anderson-Santos filed a lawsuit against Leshan under 42 U.S.C. § 1983, the Fourteenth Amendment, and the Eighth Amendment, alleging the use of excessive force. Leshan sought summary judgment arguing qualified immunity. The district court denied Leshan’s motion, finding that there was a genuine dispute of material fact as to whether Leshan had used excessive force, thus violating the Eighth Amendment. The court also found that Leshan was not entitled to qualified immunity at the summary judgment stage. Leshan appealed this decision to the United States Court of Appeals for the Sixth Circuit.The Sixth Circuit dismissed the appeal for lack of jurisdiction. The court noted that while denials of summary judgment are not typically appealable on an interlocutory basis, an exception exists for denials of claims of qualified immunity if the appeal turns on a legal issue. However, the court found that Leshan's appeal ultimately turned on questions of fact rather than an issue of law, divesting the court of jurisdiction. The court explained that a defendant seeking to challenge a denial of qualified immunity based on a genuine dispute of material fact may invoke the court's jurisdiction by conceding the plaintiff's version of the facts. However, the court determined that Leshan did not truly concede Anderson-Santos' version of the facts, thus the court lacked jurisdiction to hear the appeal. View "Anderson-Santos v. Kent County" on Justia Law

Insight Terminal Solutions, LLC ("ITS") appealed against a decision by the Bankruptcy Appellate Panel of the Sixth Circuit. The dispute centered on a claim originally filed by Cecelia Financial Management, LLC ("Cecelia"), and later transferred to Bay Bridge Exports, LLC ("Bay Bridge"), in ITS's chapter 11 bankruptcy. ITS sought to disallow or reduce the claim, recharacterize the debt as an equity contribution, and hold John J. Siegel, Jr., the non-member manager of both ITS and Cecelia, liable for fraud. The Bankruptcy Court allowed the claim, rejecting ITS's arguments. On appeal, ITS argued that the Bankruptcy Court erred in refusing to admit incomplete deposition testimony from Siegel, who died before cross-examination could take place. ITS also contended that the court erred in applying the presumption of validity to the claim and in refusing to recharacterize the claim as equity. The Appellate Panel upheld the Bankruptcy Court's decision, finding no reversible error. It ruled that the Bankruptcy Court was within its discretion to exclude Siegel's incomplete testimony and found no error in the court's decision to allow the claim and refusal to recharacterize it as equity. View "In re Insight Terminal Solutions, LLC" on Justia Law