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

Kimberly Diei, a pharmacy student at the University of Tennessee Health Science Center, maintained social media accounts under a pseudonym where she posted about song lyrics, fashion, and sexuality. Her posts did not identify her as a student or affiliate her with the university. Despite this, the College of Pharmacy's Professional Conduct Committee investigated her social media activity following anonymous complaints. The Committee found her posts "sexual," "crude," and "vulgar," and ultimately voted to expel her. Diei appealed, and the Dean reversed the expulsion decision.Diei then filed a lawsuit in the United States District Court for the Western District of Tennessee, asserting violations of her First Amendment rights under 42 U.S.C. § 1983. She sought declaratory and injunctive relief, as well as damages for emotional distress. The district court dismissed her complaint, ruling that her claims for injunctive and declaratory relief were moot due to her graduation and that her remaining claims failed to state a claim for relief. The court also held that the defendants were entitled to qualified immunity.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court determined that Diei's claims for injunctive and declaratory relief were moot but found that her claims for damages were still viable. The court held that Diei plausibly alleged a First Amendment violation, as her social media posts were unrelated to her studies, caused no disruption, and were made under a pseudonym. The court also found that the district court improperly relied on documents not properly before it when dismissing Diei's complaint. The Sixth Circuit reversed the district court's dismissal of Diei's claims for damages and remanded the case for further proceedings, holding that Diei's speech was protected by the First Amendment and that the defendants were not entitled to qualified immunity at this stage. View "Diei v. Boyd" on Justia Law

Quickway Transportation, Inc. (Quickway) petitioned the United States Court of Appeals for the Sixth Circuit to review a National Labor Relations Board (NLRB) order in an unfair labor practice proceeding. The NLRB cross-petitioned for enforcement of its order. The case involved Quickway's cessation of operations at its Louisville terminal, which the NLRB found violated the National Labor Relations Act (NLRA). Quickway argued that the NLRB's findings were not supported by substantial evidence and that the Board's remedial order was overly burdensome.The Administrative Law Judge (ALJ) initially found that Quickway violated the NLRA by ceasing operations at the Louisville terminal due to anti-union animus, failing to bargain over the cessation and its effects, and engaging in coercive and retaliatory actions against employees. The NLRB affirmed the ALJ's findings and ordered Quickway to reopen the Louisville terminal, reinstate employees, and compensate them for lost earnings and benefits.The Sixth Circuit reviewed the NLRB's decision under a substantial evidence standard and found that the Board's conclusions were supported by substantial evidence. The court noted that Quickway's decision to close the Louisville terminal was motivated by anti-union animus and aimed at chilling unionization efforts at other terminals. The court also upheld the Board's finding that Quickway failed to bargain in good faith over the decision and its effects.The court affirmed the NLRB's remedial order, including the requirement for Quickway to reopen the Louisville terminal and reinstate employees. The court found that the Board did not abuse its discretion in ordering these remedies and that Quickway failed to demonstrate that the restoration order would be unduly burdensome. The court denied Quickway's petition for review and granted the NLRB's cross-application for enforcement of its order in full. View "Quickway Transp., Inc. v. NLRB" on Justia Law

A psychiatrist employed at a public university's medical school participated in a panel discussion on childhood gender dysphoria, expressing views that were unpopular with his colleagues and supervisors. Following his remarks, he was demoted and his contract was not renewed after over fifteen years of employment. He sued several university officials, alleging First Amendment retaliation.The United States District Court for the Western District of Kentucky denied the defendants' motions for summary judgment, which argued for Eleventh Amendment immunity and qualified immunity. The court found material fact disputes regarding whether the defendants retaliated against the plaintiff for his protected speech.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the plaintiff's speech was protected under the First Amendment as it addressed a matter of public concern and was not made pursuant to his official duties. The court also found that the plaintiff's interest in speaking on the topic outweighed the university's interest in maintaining workplace efficiency. The court determined that the adverse actions taken against the plaintiff, including his demotion and contract nonrenewal, were motivated by his protected speech.The Sixth Circuit affirmed the district court's denial of summary judgment, concluding that the defendants were not entitled to Eleventh Amendment immunity or qualified immunity. The court held that the plaintiff's rights were clearly established and that a reasonable university official would have understood that retaliating against him for his speech was unlawful. The court also denied the plaintiff's motion to dismiss the appeal for lack of jurisdiction as moot. View "Josephson v. Ganzel" on Justia Law

The petitioner, Nayanaben Patel, entered the United States in March 2000 under unclear circumstances. She applied for adjustment of status based on her husband's legal status but lied about her manner of entry. She later admitted to lying but provided conflicting testimonies. The Immigration Judge (IJ) denied her application for adjustment of status and ordered her removal to India, citing factual inconsistencies. The Board of Immigration Appeals (BIA) affirmed the IJ's decision.The IJ's decision was discretionary and protected by statute from judicial review. The petitioner did not raise any colorable constitutional claims that would allow for judicial review. The United States Court of Appeals for the Sixth Circuit reviewed the case and found that the IJ's decision was supported by substantial evidence, including the petitioner's multiple contradictory statements and lack of credible evidence regarding her manner of entry.The Sixth Circuit held that it lacked jurisdiction to review the IJ's discretionary decision under 8 U.S.C. § 1252(a)(2)(B), which bars judicial review of any judgment regarding the granting of relief under sections 1182(i) and 1255. The court also found that the petitioner did not exhaust her administrative remedies regarding her claims of ineffective assistance of counsel and judicial bias, and that her judicial bias claim was not a constitutional issue but rather a factual dispute.The court denied the petition for review, emphasizing that the IJ's decision was within his discretion and supported by the evidence. The court also noted a significant error in the IJ's understanding of the difference between a visa and an I-94 form but concluded that this error did not affect the overall decision. View "Patel v. Garland" on Justia Law

The United States Chamber of Commerce, Business Roundtable, and the Tennessee Chamber of Commerce and Industry sued the Securities and Exchange Commission (SEC) and its Chairman, alleging that the SEC’s partial rescission of a prior regulation did not comply with the Administrative Procedure Act (APA). The regulation in question involved proxy voting advice businesses (PVABs) and their role in the proxy voting process for public companies. The plaintiffs argued that the SEC’s actions were procedurally and substantively deficient under the APA.The United States District Court for the Middle District of Tennessee granted summary judgment in favor of the SEC. The court found that the SEC’s decision to rescind certain conditions of the 2020 Rule was not arbitrary and capricious. The court also held that the SEC had provided a reasonable explanation for its change in policy and had adequately considered the economic consequences of the rescission as required by the Exchange Act. Additionally, the court determined that the 31-day comment period provided by the SEC was legally permissible under the APA.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo and affirmed the district court’s decision. The Sixth Circuit held that the SEC’s 2022 Rescission was not arbitrary and capricious because the SEC had acknowledged its change in position, provided good reasons for the change, and explained why it believed the new rule struck a better policy balance. The court also found that the SEC had adequately assessed the economic implications of the rescission, relying on data from the 2020 Rule and providing a qualitative analysis of the costs and benefits. Finally, the court concluded that the 31-day comment period was sufficient to provide a meaningful opportunity for public comment, as required by the APA. View "Chamber of Commerce v. Securities and Exchange Commission" on Justia Law

Johnathan Holt, just weeks before his eighteenth birthday, shot and killed a drug dealer, Quincy Battle, on behalf of the Short North Posse gang. Holt was later paralyzed from the chest down due to gun violence. A federal jury convicted him of murder in aid of racketeering and murder with a firearm during a drug-trafficking crime. The district court initially sentenced him to life imprisonment, but this was later vacated as it violated the Eighth Amendment under Miller v. Alabama, which prohibits mandatory life sentences for juveniles. Holt was resentenced to 900 months in prison.The United States District Court for the Southern District of Ohio initially sentenced Holt to life imprisonment, which was later vacated due to the Eighth Amendment violation. The district court then resentenced him to 900 months in prison. Holt appealed, arguing that his new sentence still violated the Eighth Amendment and was procedurally and substantively unreasonable.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the district court had adequately considered Holt’s youth, as required by Miller v. Alabama, and that the Eighth Amendment did not require a more lenient sentence based on his medical condition. The court also found that Holt’s procedural claims, including the district court’s handling of the presentence report and his right to allocute, did not demonstrate plain error. Finally, the court held that the 900-month sentence was substantively reasonable given the severity of Holt’s crime and the district court’s consideration of the relevant sentencing factors. The Sixth Circuit affirmed the district court’s decision. View "United States v. Holt" on Justia Law

Plaintiffs, a group of consumers, alleged that Strange Honey Farm, LLC, fraudulently marketed its honey products as "100% raw Tennessee honey." They claimed the honey was not raw, as it was heated during processing, not purely honey, as it was diluted with corn syrup, and not from Tennessee, as it was sourced from Vietnam. Plaintiffs filed a complaint against Strange Honey, its owners, and two supermarket chains that sold the honey, asserting fraudulent misrepresentation and violations of various state consumer protection laws.The United States District Court for the Eastern District of Tennessee dismissed the claims against all defendants except one, citing a lack of specificity required by Federal Rule of Civil Procedure 9(b). The court also denied plaintiffs' motion for leave to amend their complaint. Plaintiffs then voluntarily dismissed the remaining defendant and appealed the district court's decisions.The United States Court of Appeals for the Sixth Circuit reviewed the case and addressed several jurisdictional issues. The court determined that it had jurisdiction to hear the appeal because the district court's eventual entry of final judgment, after the premature notice of appeal, ripened the appellate jurisdiction. On the merits, the Sixth Circuit affirmed the district court's dismissal, finding that the plaintiffs' complaint failed to meet the specificity requirements of Rule 9(b). The court noted that the complaint did not adequately allege why the statements on the honey labels were false or when the statements were made to the plaintiffs. The court also upheld the district court's denial of leave to amend, concluding that the proposed amendments would be futile as they did not cure the deficiencies in the original complaint. View "Greer v. Strange Honey Farm" on Justia Law

The plaintiffs, including the National Republican Senatorial Committee, National Republican Congressional Committee, Senator J.D. Vance, and former Representative Steve Chabot, challenged the Federal Election Campaign Act’s limits on coordinated campaign expenditures. They argued that these limits, which restrict political parties from spending money on campaign advertising with input from the candidate, violate the First Amendment. The plaintiffs sought declaratory and injunctive relief to prevent the Federal Election Commission from enforcing these limits, claiming that the restrictions increase costs, create redundancies, and hinder effective communication and spending.The United States District Court for the Southern District of Ohio certified the constitutional question to the United States Court of Appeals for the Sixth Circuit. The district court found that the plaintiffs raised a non-frivolous question and established a factual record before certifying the question. The district court asked whether the limits on coordinated party expenditures in the Federal Election Campaign Act violate the First Amendment, either on their face or as applied to party spending in connection with "party coordinated communications."The United States Court of Appeals for the Sixth Circuit reviewed the case en banc. The court held that the Supreme Court’s 2001 decision in FEC v. Colorado Republican Federal Campaign Committee (Colorado II) remains binding and that the Act’s limits on coordinated party expenditures do not facially violate the First Amendment. The court rejected the plaintiffs' arguments that changes in legal doctrine, statutory amendments, and factual developments since 2001 undermined Colorado II. The court also denied the plaintiffs' as-applied challenge, noting that it was too broad and would effectively nullify Colorado II. The court concluded that the limits on coordinated party expenditures do not violate the First Amendment, either on their face or as applied to party spending in connection with "party coordinated communications." View "National Republican Senatorial Committee v. Federal Election Commission" on Justia Law

Three Kentucky Republican Party county executive committees challenged the Kentucky Registry of Election Finance’s prohibition on expending funds to support a state constitutional amendment on the November general election ballot. The committees sought an advisory opinion from the Registry, which concluded that they could not use funds raised for party nominees to support a constitutional amendment and would need to form a political issues committee for such expenditures. The committees argued that this restriction violated their First Amendment rights.The United States District Court for the Eastern District of Kentucky denied the committees' motion for a preliminary injunction, finding that the requirement to form a political issues committee imposed only a minimal burden on their First Amendment rights, justified by the governmental interest in transparency and disclosure. The court concluded that the Registry’s actions met the standards of strict scrutiny, exacting scrutiny, or rational basis review.The United States Court of Appeals for the Sixth Circuit reviewed the case and granted an injunction pending appeal. The court found that the executive committees were likely to succeed on the merits of their First Amendment claim. It determined that the Registry’s prohibition on spending in support of a constitutional amendment burdened the committees' political speech. The court applied strict scrutiny, concluding that the Registry’s restriction was not narrowly tailored to the asserted interest in disclosure. The court noted that less restrictive alternatives, such as imposing disclosure requirements on executive committees, could achieve the same ends without restricting speech. The Registry was enjoined from enforcing its advisory opinion against the committees, and expedited briefing was ordered for the appeal. View "Boone County Republican Party Executive Committee v. Wallace" on Justia Law

Chadrick Perry was indicted for being a felon in possession of a firearm and ammunition. After pleading not guilty, he was detained pending trial. Concerns about his competency led to evaluations by two forensic psychologists, who reached different conclusions. The district court committed Perry to the custody of the Attorney General for competency restoration. Perry experienced significant delays in being transported to a federal facility for treatment. Eventually, he was deemed competent, pleaded guilty to being a felon in possession of ammunition, and was sentenced to 57 months in prison.The United States District Court for the Western District of Michigan denied Perry's motion to dismiss the indictment based on alleged violations of the Speedy Trial Act. Perry argued that the 152-day delay between his designation for treatment and his arrival at the facility should count against the Act's 70-day clock. The district court ruled that the entire period from when Perry was deemed incompetent until his competency was restored was excludable under the Act.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the entire period of delay resulting from Perry's mental incompetence was excludable under 18 U.S.C. § 3161(h)(4). This exclusion applied even during the transportation delay, thus not violating the Speedy Trial Act. Additionally, the court upheld Perry's sentence, determining that his prior conviction for aggravated domestic violence qualified as a "crime of violence" under U.S.S.G. § 4B1.2(a), justifying the increased Guidelines range. The court affirmed both the conviction and the sentence. View "United States v. Perry" on Justia Law