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

Timothy Baker, a registered sex offender, was in a relationship with Shaelyn Fann and expressed sexual interest in Fann’s eleven-year-old daughter, S.H. Over several months, Baker and Fann groomed S.H. for sexual activity, with Fann sending Baker sexually explicit photographs of S.H. at his request. Baker provided detailed instructions to Fann on how to obtain these images and discussed plans to sexually abuse S.H. Law enforcement discovered Baker’s activities while investigating him for another alleged sexual assault involving a minor.A grand jury in the United States District Court for the Western District of Michigan indicted Baker on three counts: conspiracy to sexually exploit a minor, coercion and enticement of a minor, and committing these offenses while required to register as a sex offender. The indictment also alleged that Baker had two prior convictions for sexually exploiting minors under Michigan law. Before trial, Baker moved to strike the sentencing enhancement based on his prior convictions, arguing they were juvenile adjudications, not convictions. He also sought to sever the count related to his sex offender status and to exclude testimony from two other minors, L.H. and I.B., who alleged prior sexual assaults by Baker. The district court denied all these motions, admitted the testimony under Federal Rule of Evidence 413, and the jury convicted Baker on all counts. The court imposed a total sentence of 600 months’ imprisonment.On appeal, the United States Court of Appeals for the Sixth Circuit held that Baker’s prior Michigan offenses constituted convictions under federal law, supporting the enhanced sentence. The court also found that cumulative punishments under 18 U.S.C. §§ 2251(e) and 2260A did not violate the Double Jeopardy Clause, as Congress clearly intended such cumulative sentences. Finally, the court concluded that the district court did not abuse its discretion in admitting the testimony of L.H. and I.B. The Sixth Circuit affirmed the district court’s judgment. View "United States v. Baker" on Justia Law

Christina Henry, a Licensed Practical Nurse at Southern Ohio Medical Center (SOMC), refused to comply with SOMC’s COVID-19 policy requiring either vaccination or weekly nasopharyngeal testing, citing religious objections. SOMC granted her a religious exemption from vaccination but denied her request for an exemption from all forms of COVID testing. Henry maintained that her religious beliefs prohibited her from undergoing any COVID test, including non-invasive methods, and proposed self-screening as an alternative. After continued refusal to test or vaccinate, SOMC placed her on unpaid leave. Henry did not request alternative testing methods during her leave and later declined to return to SOMC after the testing requirement was lifted.The United States District Court for the Southern District of Ohio granted summary judgment in favor of SOMC. The court found that Henry’s communications to SOMC indicated she sought exemption from all COVID testing, not just nasopharyngeal testing. It held that accommodating her request would impose an undue hardship on SOMC by endangering vulnerable patient populations. The court also determined that even if Henry had requested saliva testing, this would still constitute an undue hardship due to delays in obtaining test results and reduced effectiveness. Additionally, the court found that Henry failed to show SOMC’s stated reasons for placing her on unpaid leave were pretextual.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The Sixth Circuit held that Henry did not provide sufficient notice to SOMC of a limited objection to only certain types of testing and that either exempting her from all testing or providing saliva testing would impose an undue hardship on SOMC. The court also held that Henry failed to establish pretext in her retaliation claim. View "Henry v. Southern Ohio Medical Center" on Justia Law

Ulysses Feagin was involved in a police encounter after driving erratically, nearly causing a collision with a marked police cruiser, and subsequently leading officers on a brief pursuit. Upon stopping in a parking lot, Feagin ignored repeated commands to exit his vehicle, rolled up the windows, and appeared to reach toward the center console. When officers attempted to remove him, bullets fell from his pocket, and he physically resisted their efforts. Officer Moore deployed a taser to subdue Feagin, who was then handcuffed and placed in a police cruiser. While detained, Feagin continued to resist by kicking the cruiser’s window, prompting Moore to use pepper spray. A subsequent search of Feagin’s vehicle revealed drugs and firearms, leading to his conviction on multiple charges.The United States District Court for the Northern District of Ohio granted summary judgment to the defendants on most claims but denied it on two: Feagin’s excessive force claim related to the use of a taser and his deliberate indifference claim regarding medical care after being pepper sprayed. The district court found a genuine dispute over whether Feagin’s resistance was active or passive at the time of the tasing, but granted summary judgment on the pepper spray claim, citing Feagin’s continued resistance. The deliberate indifference claim was set for trial because defendants had not moved for summary judgment on that issue.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision de novo. The Sixth Circuit reversed the denial of qualified immunity for the excessive force claim, holding that Officer Moore’s use of a taser was reasonable under the circumstances and did not violate clearly established law. The court dismissed the appeal regarding the deliberate indifference claim for lack of jurisdiction, as the issue had not been raised below, and remanded the case for further proceedings. View "Feagin v. Mansfield Police Dep't" on Justia Law

The founder and former CEO of a national pizza company brought suit against a public relations firm that had previously provided services to the company. The dispute arose after the plaintiff alleged that the firm leaked confidential and damaging information about him to the press, in violation of a nondisclosure agreement (NDA) that included an arbitration clause. The NDA was executed after the company requested the firm sign it, anticipating close work with the plaintiff during a period of reputational crisis. The relationship between the parties deteriorated following a conference call in which the plaintiff made controversial remarks, which were later reported in the media, leading to his resignation from the company’s board.The case was initially filed in state court and then removed to the United States District Court for the Western District of Kentucky. Over several years, the litigation involved multiple amended complaints, extensive discovery, and dispositive motions. The defendant did not move to compel arbitration until after the district court denied summary judgment on the NDA claim. The district court held a bench trial and found that the NDA was enforceable and contained a binding arbitration provision. However, the court concluded that the defendant had defaulted on its right to arbitrate by actively litigating the case for years before seeking arbitration, and thus denied the motion to compel arbitration.On appeal, the United States Court of Appeals for the Sixth Circuit determined it lacked jurisdiction to review the district court’s contract formation ruling but had jurisdiction to review the default determination. The Sixth Circuit affirmed the district court’s finding that the defendant defaulted on its arbitration rights by seeking a merits resolution in court before moving to compel arbitration. The court dismissed the appeal in part for lack of jurisdiction, otherwise affirmed the district court’s judgment, and denied the plaintiff’s request for sanctions. View "Schnatter v. 247 Group, LLC" on Justia Law

Rockwood Auto Parts, Inc. and Rockwood Towing, Inc., along with their owner, Jacques Poli, had longstanding business relationships with the Monroe County Sheriff’s Office, performing vehicle maintenance and towing services. After Troy Goodnough was elected sheriff in 2020, Monroe County initiated a competitive bidding process for fleet maintenance, ultimately awarding the contract to Gerweck Nissan instead of Rockwood Auto. Goodnough also revised the county’s towing rotation, reducing Rockwood Towing’s share of business. Additionally, Goodnough and Sergeant Michael Preadmore conducted warrantless audits of Rockwood’s premises and Poli’s property to inventory county assets, which led to a state police investigation but no criminal charges.The plaintiffs filed suit in the United States District Court for the Eastern District of Michigan, alleging violations of their Fourth Amendment rights due to the warrantless searches, and asserting equal protection and due process claims under the Fourteenth Amendment related to the loss of contracts and towing business. They also sought to impose municipal liability on Monroe County. The district court granted summary judgment to the defendants on all claims, finding no genuine disputes of material fact and concluding that the searches were consensual, the contract decisions had rational bases, and no protected property interest existed in the bidding process.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s summary judgment de novo. The Sixth Circuit affirmed the district court’s judgment, holding that the searches were conducted with valid consent, the changes to contracts and towing lists were supported by rational bases and did not constitute unconstitutional discrimination, and the plaintiffs lacked a protected property interest in the fleet-maintenance contract. The court also found no basis for municipal liability under Monell, as no underlying constitutional violation was established. View "Rockwood Auto Parts, Inc. v. Monroe County" on Justia Law

Between 1994 and 2018, the defendant sexually abused three boys, beginning with C.C. in 1994, followed by B.A. around 2005–06, and J.G. in 2017. The abuse included interstate travel with C.C., during which the defendant filmed some of the acts, and the creation of sexually explicit images and videos of all three victims. In 2021, law enforcement recovered thumb drives containing thousands of images of child pornography, including depictions of the three boys. The defendant was indicted on five federal counts: transportation of a minor for criminal sexual activity, two counts of child exploitation, possession of child pornography, and committing sexual exploitation while a registered sex offender.The United States District Court for the Eastern District of Tennessee denied the defendant’s pretrial motion to dismiss the first three counts, rejecting arguments that Count One was time-barred and that the indictment was insufficient. After the defendant waived his right to a jury trial, the court convicted him on all counts and sentenced him to life plus ten years’ imprisonment. The defendant appealed, challenging the statute of limitations, the sufficiency of the indictment, the sufficiency of the evidence, and the application of a sentencing enhancement based on prior convictions.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s judgment. The court held that the extended statute of limitations in 18 U.S.C. § 3283 applied to Count One, making the prosecution timely. It found the indictment sufficient for all challenged counts, concluded that the evidence was sufficient to support each conviction, and upheld the sentencing enhancement, determining that the defendant’s prior Tennessee convictions related to the sexual exploitation of children as required by federal law. The court affirmed the conviction and sentence in all respects. View "United States v. Deakins" on Justia Law

The case concerns an individual who was sentenced in 2006 to a term of imprisonment and supervised release for drug trafficking offenses. After his initial release, his supervised release was revoked due to a new drug offense, resulting in additional imprisonment and a new term of supervised release. While incarcerated, he sought to earn and apply time credits under the First Step Act, arguing that the Bureau of Prisons (BOP) unlawfully denied him these credits despite his eligibility.The United States District Court for the Northern District of Ohio reviewed his habeas corpus petition under 28 U.S.C. § 2241. The warden moved to dismiss, contending that the petitioner had not exhausted administrative remedies and was ineligible for time credits due to a disqualifying offense. The district court agreed, finding both a failure to exhaust and statutory ineligibility, and denied the petition. The petitioner appealed to the United States Court of Appeals for the Sixth Circuit. While the appeal was pending, he was released from BOP custody and began serving his supervised release.The United States Court of Appeals for the Sixth Circuit addressed whether First Step Act time credits could be used to reduce a term of supervised release, as opposed to only reducing a term of imprisonment. The court held that such credits may only be applied to reduce a prison term, not a supervised-release term. Because the petitioner was no longer incarcerated and the credits could not affect his supervised release, the court determined that the case was moot and dismissed the appeal. The court did not address other arguments regarding exhaustion or the merits of the underlying claim. View "Hargrove v. Healy" on Justia Law

Samantha Graf worked as a Certified Nursing Assistant Technician at Morristown-Hamblen Hospital Association (MHHA). She alleged that during a lunch break on hospital grounds, a security guard employed by a third-party firm raped her. Graf reported the incident to hospital human resources, but after a limited investigation, HR concluded the sexual encounter was consensual. MHHA terminated Graf for violating hospital policy by having intercourse while on the clock and in an unauthorized area. Graf continued to communicate with the security guard after the incident, and both parties disputed the nature of their relationship and the encounter.Graf filed suit in the United States District Court for the Eastern District of Tennessee, asserting claims under Title VII and the Tennessee Human Rights Act (THRA), as well as state tort claims. The district court dismissed several claims and one defendant, Shield and Buckler Security, Inc., on statute of limitations grounds. After summary judgment, only Graf’s retaliation claims under Title VII and THRA, and her negligent infliction of emotional distress claim, proceeded to trial. Before trial, the district court ruled on the admissibility of evidence regarding Graf’s sexual history, allowing some communications with the security guard but excluding other evidence under Federal Rule of Evidence 412. The jury found in favor of MHHA on all counts, and judgment was entered against Graf.On appeal to the United States Court of Appeals for the Sixth Circuit, Graf argued that the district court erred in requiring her to prove she did not consent to the alleged rape for her Title VII retaliation claim, and in admitting evidence of her sexual history. The Sixth Circuit held that a Title VII retaliation plaintiff must demonstrate a reasonable and good-faith belief that the conduct opposed was unlawful, and that evidence regarding consent was relevant to this inquiry. The court also found no abuse of discretion in the district court’s evidentiary rulings. The judgment was affirmed. View "Graf v. Morristown-Hamblen Hospital" on Justia Law

A group consisting of a local chapter of a national organization and two individuals challenged certain rules governing public comment at Wilson County Board of Education meetings in Tennessee. The Board’s policies required speakers to disclose their names and addresses, limited comments to certain topics, and included a restriction on “abusive” comments as read by the Chair at meetings. The plaintiffs alleged that these rules deterred them from fully expressing their views, particularly regarding controversial school policies, and that they feared enforcement of the address-disclosure and abusive-comments rules. One plaintiff was stopped from speaking at a meeting for refusing to provide her address.The plaintiffs filed suit in the United States District Court for the Middle District of Tennessee, seeking to enjoin enforcement of three rules: the public-interest provision, the address-disclosure requirement, and the abusive-comments restriction. After the suit was filed, the Board removed the address-disclosure and abusive-comments rules from its policies and meeting materials. The district court denied the plaintiffs’ motion for a preliminary injunction, finding they had not shown a likelihood of success on the merits regarding the public-interest provision, nor a likelihood of imminent and irreparable harm from the other two rules, since they had been rescinded.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s denial of a preliminary injunction. The court held that the plaintiffs lacked standing to challenge the public-interest provision because they had not shown a credible threat of its enforcement. As to the address-disclosure and abusive-comments rules, the court found that, because the Board had rescinded these rules and committed not to reinstate them during the litigation, the plaintiffs could not show a likelihood of imminent and irreparable harm necessary for preliminary injunctive relief. The case was remanded for further proceedings. View "Moms For Liberty - Wilson County, Tenn. v. Wilson Cnty. Bd. of Educ." on Justia Law

The plaintiff, a long-term employee of a brewery, suffered two work-related back injuries, the second of which led to significant physical restrictions. The brewery accommodated him with light duty work for a period, but when such work was no longer available, he was placed on leave and later participated in a transitional work program. The plaintiff requested the creation of a new position to accommodate his restrictions, which the brewery declined. After his restrictions were lifted, he returned to his original position. During his employment, the plaintiff also applied unsuccessfully for other internal positions and was later suspended following allegations of inappropriate workplace conduct. He was offered a choice between a last chance agreement and a severance package, ultimately declining both and leaving the company.The United States District Court for the Western District of Michigan granted summary judgment to the employer on all claims. The court found that the plaintiff failed to exhaust or timely exhaust administrative remedies for certain claims, and for others, lacked evidence to establish pretext for discrimination or retaliation. The plaintiff appealed, challenging the district court’s findings regarding the adequacy of his EEOC charge and the sufficiency of his evidence for disability and age discrimination, retaliation, and failure to accommodate.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s decision. The appellate court held that the plaintiff failed to properly exhaust his failure-to-accommodate claim under the ADA, as it was neither explicitly included in his EEOC charge nor reasonably related to the facts alleged, and was also untimely. The court further held that the plaintiff failed to establish a prima facie case or pretext for his remaining ADA, state law disability, and age discrimination claims. The court also found that the plaintiff forfeited his Title VII and motion for reconsideration arguments by failing to adequately brief them. The district court’s grant of summary judgment was affirmed in full. View "Pemberton v. Bell's Brewery, Inc." on Justia Law