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

Plaintiffs, Ohio voters and members of an initiative petition committee, sought to amend the Ohio Constitution through two ballot initiatives. The Ohio Attorney General, David Yost, rejected their proposed summaries eight times, preventing them from collecting signatures. Plaintiffs argued that this violated their First Amendment rights. The district court agreed, issuing a preliminary injunction ordering Yost to certify the summaries. However, the district court stayed the injunction pending appeal.The United States District Court for the Southern District of Ohio initially denied preliminary injunctive relief, but a panel of the Sixth Circuit reversed, finding that the fair-and-truthful review process likely violated Plaintiffs' First Amendment rights. The en banc Sixth Circuit later vacated this decision, deeming the case moot as the targeted election had passed. Plaintiffs then filed an amended complaint and sought a second preliminary injunction, which the district court granted, but stayed pending appeal.The United States Court of Appeals for the Sixth Circuit reviewed the case and agreed with the district court that Plaintiffs' First Amendment rights were likely violated. The court found that the fair-and-truthful certification process allowed the Attorney General to exercise editorial control over the petition summaries, which constituted a severe burden on Plaintiffs' core political speech. The court also determined that the other stay factors did not favor Yost. Consequently, the Sixth Circuit granted Plaintiffs' motion to lift the stay, allowing them to proceed with their petition efforts. View "Brown v. Yost" on Justia Law

Randy Erickson, an inmate at Gogebic County Jail, Michigan, was involved in an incident with Deputy Sheriff Scott Voit. Erickson, who was serving a sentence for operating a vehicle while intoxicated, had an altercation with Voit after making a disrespectful comment. Voit responded by canceling Erickson's family visit, which led Erickson to act out by hitting and kicking the cell door. Voit then handcuffed Erickson and took him to a holding cell, where he threw Erickson to the ground and kneed him in the back. Erickson later sought medical attention for injuries including a fractured rib and back contusions.The United States District Court for the Western District of Michigan denied Voit's motion for summary judgment on qualified-immunity grounds, finding that a reasonable jury could conclude that Voit used excessive force maliciously and sadistically to cause harm. However, the court also found that there was no evidence to suggest that Voit deliberately disregarded Erickson's medical needs, as there was no indication that Voit knew of Erickson's injuries.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court agreed with the district court that a reasonable jury could find that Voit used excessive force in violation of the Eighth Amendment, as the force used was disproportionate to the threat posed by Erickson, who was handcuffed and compliant. The court held that Voit was not entitled to qualified immunity on the excessive force claim because the law clearly established that malicious and sadistic use of force violated the Eighth Amendment.However, the Sixth Circuit disagreed with the district court regarding the claim of deliberate indifference to medical needs. The court found no evidence that Voit knew of Erickson's injuries or that Erickson requested medical care from Voit. Therefore, the court held that Voit did not act with deliberate indifference to Erickson's medical needs.The Sixth Circuit affirmed the district court's decision in part, reversed it in part, and remanded the case for further proceedings. View "Erickson v. Gogebic County" on Justia Law

US Framing International LLC entered into a subcontract with Continental Building Company for framing services on two student-housing projects. Disputes arose, leading US Framing to leave the Knoxville project. Continental then filed an insurance claim alleging US Framing's breach of the subcontract. US Framing sued Continental and its officers, claiming insurance fraud under Tennessee law. The district court dismissed the case, stating US Framing failed to plead any injury directly caused by the alleged fraudulent insurance claim.The United States District Court for the Eastern District of Tennessee initially reviewed the case. The court granted Continental's motion to dismiss, concluding that US Framing did not demonstrate any direct injury resulting from Continental's insurance claim. US Framing then appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's dismissal, holding that US Framing did not plausibly allege any economic damages directly resulting from Continental's alleged insurance fraud. The court also determined that US Framing could not recover attorney's fees or statutory penalties, as it did not establish itself as a prevailing party entitled to such relief. The court's decision was based on the interpretation of Tennessee law, which requires a direct causal link between the alleged fraud and the claimed damages. View "US Framing International LLC v. Continental Building Co." on Justia Law

Dwayne Robinson was convicted by a jury for unlawfully possessing a firearm as a felon. The district court imposed the Armed Career Criminal Act’s (ACCA) minimum punishment, finding that Robinson had three prior qualifying offenses committed on different occasions. Robinson appealed, raising four claims: a Sixth Amendment violation due to the district court responding to a jury note without his counsel’s input, the court’s failure to grant a mistrial after detectives implied he had shot at someone, incorrect jury instructions regarding gun ownership and possession, and the district court’s application of the ACCA without a jury determination on whether his prior offenses occurred on different occasions.The United States District Court for the Middle District of Tennessee at Nashville initially reviewed the case. Robinson did not properly object to the court’s response to the jury note, the failure to grant a mistrial, or the jury instructions, leading to a review for plain error. The district court found Robinson’s three prior offenses occurred on different occasions, thus applying the ACCA’s mandatory minimum sentence.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Robinson’s failure to object to the jury note response, mistrial denial, and jury instructions meant these issues were reviewed for plain error. The court found no obvious mistakes in these areas. Regarding the ACCA application, the court acknowledged intervening Supreme Court precedent requiring a jury to determine if prior offenses occurred on different occasions. However, the court found this error harmless because the record clearly showed Robinson’s offenses were separated by many years. Thus, the Sixth Circuit affirmed the district court’s judgment. View "United States v. Robinson" on Justia Law

Plaintiffs, thirty-eight current and former engineers employed by FCA US LLC (FCA), were transferred from the Chrysler Technical Center to the Trenton Engine Complex in 2011. They alleged that this transfer violated the collective bargaining agreement (CBA) and filed grievances with the International Union, United Automobile, Aerospace and Agricultural Implement Workers of America (UAW). These grievances were denied, and Plaintiffs later discovered a bribery scheme between FCA and UAW officials, which they claimed influenced the handling of their grievances.The United States District Court for the Eastern District of Michigan denied Plaintiffs' motion to remand their state-law claims to state court, finding that the claims were completely preempted by Section 301 of the Labor Management Relations Act (LMRA). The court held that the claims required interpretation of the CBA and were thus preempted. Plaintiffs then stipulated to the dismissal of their complaint but reserved the right to appeal the remand decision.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that Plaintiffs' state-law claims for fraud, breach of fiduciary duty, and civil conspiracy were completely preempted by Section 301 of the LMRA. The court reasoned that the claims were based on rights created by the CBA and required interpretation of its terms. Consequently, the claims had to be heard in federal court. The court also rejected Plaintiffs' arguments for remand based on Michigan criminal laws and Section 9(a) of the National Labor Relations Act (NLRA). View "Baltrusaitis v. UAW" on Justia Law

Tennessee Gas Pipeline Company (TGP) proposed constructing a 32-mile natural gas pipeline across several Tennessee counties, which would involve crossing numerous waterbodies. TGP applied for a § 404 permit from the United States Army Corps of Engineers (the Corps), a § 401 water quality certification from the Tennessee Department of Environment and Conservation (TDEC), and a certificate of public convenience and necessity from the Federal Energy Regulatory Commission (FERC). The Corps issued the § 404 permit, allowing TGP to discharge materials into waterbodies during construction.The Corps issued public notices and received comments on TGP’s application. TGP responded to these comments, explaining its assessment of alternative routes and crossing methods. FERC issued a Final Environmental Impact Statement, concluding that the Pipeline would not result in significant environmental impacts. TDEC issued a § 401 water quality certification, and FERC issued a certificate of public convenience and necessity. The Corps then issued the § 404 permit with special conditions, including requirements for TGP to use the least impactful trenching techniques and obtain approval before using blasting methods.The United States Court of Appeals for the Sixth Circuit reviewed the Corps' decision. The court held that the Corps did not act arbitrarily or capriciously in issuing the § 404 permit. The Corps properly assessed practicable alternatives to open-cut trenching, determined that TGP’s proposed rock-removal methods were the least environmentally damaging practicable alternatives, and correctly relied on TDEC’s § 401 water quality certification. The court also found that the Corps provided sufficient support for its conclusions regarding suspended particulates and turbidity and adequately assessed the cumulative effects of the Pipeline’s construction. The court denied the petition for review. View "Appalachian Voices v. Army Corps of Engineers" on Justia Law

The case involves a dispute over the Tennessee Department of Environment and Conservation’s (TDEC) issuance of a water quality certification to Tennessee Gas Pipeline Company (TGP) for the construction and operation of a 32-mile natural gas pipeline in Tennessee. The pipeline would cross over one hundred bodies of water and require drilling across rocky terrain. Environmental groups Sierra Club and Appalachian Voices argue that TDEC failed to properly assess TGP’s application and ensure that the pipeline would not cause significant environmental damage.The lower court, TDEC, issued the water quality certification to TGP, authorizing temporary and permanent impacts to various water bodies and wetlands. TDEC imposed several conditions on TGP to minimize environmental disruption, including selecting the least impactful trenching techniques and obtaining written authorization before using controlled blasting. Petitioners filed a timely Petition for Review in the United States Court of Appeals for the Sixth Circuit, arguing that TDEC’s issuance of the certification violated the Administrative Procedure Act (APA).The United States Court of Appeals for the Sixth Circuit reviewed the case and found that TDEC did not violate the APA. The court held that TDEC adequately evaluated the water quality certification application and reasonably explained its decision-making process regarding waterbody crossings, rock removal methodology, downstream sedimentation, trench excavation, and baseline conditions of waterbodies. The court concluded that TDEC’s actions were not arbitrary, capricious, or inconsistent with its regulations. Consequently, the court denied the Petition for Review. View "Sierra Club v. Tennessee Department of Environment and Conservation" on Justia Law

Tyler Venema, an inmate with a history of mental illness and suicide attempts, committed suicide by asphyxiation with a plastic bag while in the custody of the Michigan Department of Corrections (MDOC) at Woodland Center Correctional Facility (WCC). Venema's estate filed a lawsuit under 42 U.S.C. § 1983 against Jodi DeAngelo, the warden of WCC, alleging that her failure to train and supervise corrections officers led to Venema's death, violating his Eighth Amendment rights. The estate claimed that DeAngelo knew about the risk posed by plastic bags and the officers' failure to remove them from at-risk inmates' cells.The United States District Court for the Eastern District of Michigan denied DeAngelo's motion to dismiss based on qualified immunity, finding that the estate's allegations were sufficient to establish that DeAngelo implicitly authorized or knowingly acquiesced in the unconstitutional conduct of her subordinates. DeAngelo appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court held that the estate plausibly alleged that DeAngelo knowingly acquiesced in the unconstitutional conduct of her subordinates by failing to train and supervise them properly. The court also found a causal connection between DeAngelo's actions and Venema's death, as her failure to enforce policies against providing plastic bags to at-risk inmates could reasonably be expected to result in harm. The court concluded that Venema's Eighth Amendment rights were clearly established at the time of the violation, and thus, DeAngelo was not entitled to qualified immunity. View "Venema v. West" on Justia Law

Michael Salazar filed a class action lawsuit against Paramount Global, alleging a violation of the Video Privacy Protection Act (VPPA). Salazar claimed that he subscribed to a 247Sports e-newsletter and watched videos on 247Sports.com while logged into his Facebook account. He alleged that Paramount had installed Facebook’s tracking Pixel on 247Sports.com, which enabled Paramount to track and disclose his video viewing history to Facebook without his consent.The United States District Court for the Middle District of Tennessee dismissed Salazar’s complaint. The court found that Salazar had standing because the alleged disclosure of his video viewing history to Facebook constituted a concrete injury. However, the court dismissed the complaint for failure to state a claim under the VPPA, concluding that Salazar was not a “consumer” under the Act. The court reasoned that Salazar’s subscription to the 247Sports e-newsletter did not qualify him as a “consumer” because the newsletter was not “audio visual materials.”The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s decision. The Sixth Circuit agreed that Salazar had standing but held that he did not plausibly allege that he was a “consumer” under the VPPA. The court interpreted the term “goods or services” in the context of the VPPA to mean audio-visual materials, and since Salazar’s newsletter subscription did not involve audio-visual materials, he was not a “consumer” under the Act. The court also found that the district court did not abuse its discretion in dismissing the complaint with prejudice, as Salazar had not filed a formal motion to amend his complaint. View "Salazar v. Paramount Global" on Justia Law

Jeffrey Campbell, the owner and lead doctor at Physicians Primary Care (PPC), and Mark Dyer, a nurse practitioner at PPC, were indicted in 2020 on multiple counts related to overprescribing opioids and engaging in a scheme to seek fraudulent reimbursements from health insurance providers. The indictment included charges of unlawfully distributing controlled substances, conspiracy to unlawfully distribute controlled substances, health-care fraud, conspiracy to commit health-care fraud, and money laundering.The case proceeded to trial in the United States District Court for the Western District of Kentucky. The jury found Campbell guilty on several counts, including conspiracy to unlawfully distribute controlled substances, health-care fraud, conspiracy to commit health-care fraud, and money laundering. Dyer was also found guilty on similar counts. The district court sentenced Campbell to 105 months of imprisonment and Dyer to 60 months, followed by three years of supervised release for both. The district court also ordered restitution payments from both defendants.The United States Court of Appeals for the Sixth Circuit reviewed the case. The defendants challenged the jury instructions, sufficiency of the evidence, and the district court’s evidentiary rulings. The appellate court found that the jury instructions, although not fully compliant with the Supreme Court's decision in Ruan v. United States, were adequate under the court's precedents. The court also found sufficient evidence to support the convictions for conspiracy to unlawfully distribute controlled substances, health-care fraud, and money laundering. The court held that the district court did not abuse its discretion in admitting the testimony of government experts and other evidence.The appellate court affirmed the convictions and sentences, concluding that any potential errors in the district court’s intended-loss calculation for sentencing were harmless, as the sentences imposed were well below the applicable Guidelines range. The court also noted that the defendants failed to properly appeal the restitution order, making it outside the scope of the current appeal. View "United States v. Campbell" on Justia Law