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

In the case before the United States Court of Appeals for the Sixth Circuit, the defendant, Bryce Axline, appealed the 65-month sentence imposed by the district court following his guilty plea to charges of vehicular homicide and vehicular assault on federal lands. Axline argued that the district court imposed a substantively unreasonable sentence by failing to provide sufficiently compelling reasons for varying upward from the Sentencing Guidelines advisory range by approximately 40 percent. The Court of Appeals affirmed the district court's decision, concluding that the sentence was substantively reasonable. The court found that the district court thoroughly assessed the seriousness of Axline's offense, his history with underage substance abuse, and the importance of specific and general deterrence. The court also found that the circumstances of this case fell outside the heartland of similar cases. The court noted that the Guidelines did not necessarily account for the confluence of his underage drinking and extremely reckless driving, nor did they necessarily adequately account for the effect of Axline's actions on multiple victims. Thus, the district court acted within its discretion in varying Axline's sentence above the Guidelines range. View "United States v. Axline" on Justia Law

In a case before the United States Court of Appeals for the Sixth Circuit, Premier Dealer Services, a developer and administrator of automobile dealers’ aftermarket products, sued Allegiance Administrators for infringing its copyright. The issue stemmed from Premier's creation of a Lifetime Powertrain Loyalty Program, which included a loyalty certificate that set out the program's terms and conditions. Premier had registered this certificate for copyright protection. When Allegiance started working with a former Premier client, it used Premier’s Lifetime Powertrain Loyalty Program certificates in its own plan, with minor modifications in the contact information.In the lawsuit, the district court ruled that Allegiance had infringed Premier’s copyright, ordered Allegiance to give up any profits from using the certificates, and awarded Premier attorney’s fees. On appeal, the Sixth Circuit affirmed the decision of the lower court.The appellate court held that Premier's certificate was "original" and thus protected by copyright. The court clarified that originality in copyright law has a low threshold, requiring only that the author independently created a work with some minimal degree of creativity. The court rejected Allegiance's argument that the certificates were scenes a faire—stock or standard phrases that necessarily follow from a common theme or setting, which are not protectable by copyright. The court found that Allegiance had not provided sufficient evidence that industry standards or other external constraints dictated the content of the certificates.Regarding the disgorgement of profits, the court agreed with the lower court's calculations. It noted that Premier had successfully shown a reasonable relationship between Allegiance’s infringement and its gross revenues. The burden then shifted to Allegiance to demonstrate which part of its gross revenues did not result from the infringement, but Allegiance failed to fulfill this burden.Finally, the court upheld the award of attorney’s fees to Premier, finding that the lower court did not abuse its discretion in characterizing Allegiance's arguments as unreasonable and contrary to settled law. View "Premier Dealer Services, Inc. v. Allegiance Administrators, LLC" on Justia Law

In this case, Norfolk Southern Railway Company and Dille Road Recycling, LLC disputed over a narrow parcel of land adjacent to Norfolk’s active rail line in Euclid, Ohio. Although Norfolk owned the land, Dille had been using it for nearly two decades. The parties took the matter to federal court after negotiations failed. Dille sought to claim the parcel through adverse possession or a prescriptive easement, while Norfolk argued that Dille’s property claims were preempted by the Interstate Commerce Commission Termination Act (ICCTA). The district court held that Dille’s prescriptive-easement claim was not preempted and granted Dille the easement.The United States Court of Appeals for the Sixth Circuit reversed the district court's decision, ruling that federal law preempted Dille’s state-law prescriptive-easement claim. The court determined that the easement Dille sought was so exclusive and conflicting that it was essentially adverse possession by another name. The court noted that while Dille claimed the easement was nonexclusive, the reality was that Dille's use of the parcel did not allow for shared use with Norfolk. The court also found that Dille's proposed use of the parcel was much closer to the complete taking of the property, which would unreasonably interfere with rail transportation and therefore was preempted by the ICCTA. The court reasoned that the possession or conflicting use of railroad property can be burdensome even if the railroad is not currently using the contested property. The case was remanded for further proceedings consistent with the opinion. View "Norfolk Southern Railway Co. v. Dille Road Recycling, LLC" on Justia Law

Zachariah Histed pleaded guilty to possessing methamphetamine with intent to distribute. The District Court for the Western District of Michigan sentenced him to 300 months' imprisonment. Histed appealed his sentence on both procedural and substantive grounds, arguing that the district court incorrectly calculated the drug quantity, wrongly applied multiple sentencing enhancements, improperly denied him credit for acceptance of responsibility, and imposed a sentence that was too long.The United States Court of Appeals for the Sixth Circuit affirmed in part, vacated Histed’s sentence, and remanded for resentencing. The Court of Appeals held that the district court erred in calculating the quantity of methamphetamine attributable to Histed because it did not adequately explain how it arrived at the drug quantity or articulate any methodology for reaching the offense level of 32. Thus, the Court of Appeals vacated Histed's sentence and remanded the case for resentencing with a more precise determination of the drug quantity attributable to Histed.However, the Court of Appeals affirmed the district court's application of the dangerous-weapon, reckless-endangerment, and obstruction-of-justice enhancements, as well as its denial of an acceptance-of-responsibility reduction. The court found that Histed's possession of an inert grenade during his drug-trafficking offense justified the dangerous-weapon enhancement. It also held that Histed's reckless behavior during his flight from law enforcement warranted the reckless-endangerment enhancement, and his attempts to make others lie to investigators justified the obstruction-of-justice enhancement. Finally, the court held that despite Histed's guilty plea, his lack of full acceptance of responsibility for his actions justified the denial of an acceptance-of-responsibility reduction. View "United States v. Histed" on Justia Law

In this case heard by the United States Court of Appeals for the Sixth Circuit, the plaintiff, Marketing Displays International (MDI), sued the defendant, Brianna Shaw, for allegedly violating her one-year non-compete agreement when she left MDI and began working for another company. The district court granted a preliminary injunction, preventing Shaw from working for her new employer for one year. Shaw appealed this decision in January 2023. However, due to several deadline extensions requested by both parties, the briefing did not finish until January 2024. By that time, the one-year period of the injunction had already expired, rendering the appeal moot.Shaw argued that the appeal was not moot as a ruling would impact her ability to recover any damages, including reputational harm caused by the injunction, and MDI's ability to recover attorney fees. The court disagreed, stating that Shaw could not collect damages until a final judgment is in her favor, and MDI's right to attorney fees did not depend on the validity of the preliminary injunction.Shaw also requested the court to vacate the moot portion of the preliminary injunction. However, the court refused, stating that the injunction would not have any preclusive effect on future litigation and that Shaw contributed to the appeal's mootness by requesting deadline extensions.Therefore, the appeal was dismissed as moot, and the case was remanded back to the lower court for further proceedings. View "Marketing Displays International v. Shaw" on Justia Law

In 2024, the United States Court of Appeals for the Sixth Circuit examined whether a conviction for aggravated robbery with a deadly weapon under Ohio law could be considered a "crime of violence" under the federal Sentencing Guidelines, which would lead to an enhanced sentencing range. The defendant, Alexander Ivy, had pleaded guilty to possession of methamphetamine with intent to distribute and being a felon in possession of a firearm. At sentencing, the district court found that Ivy's prior conviction for aggravated robbery was a "crime of violence," resulting in an increased Guidelines range of 92 to 115 months' imprisonment instead of the likely 46 to 57 months' imprisonment without such a finding. Ivy appealed this decision.The Court of Appeals held that a conviction for aggravated robbery with a deadly weapon under Ohio law without further information that the aggravated-robbery conviction is predicated on a particular underlying theft offense is not a "crime of violence" under the Guidelines. The court found that the Ohio aggravated-robbery statute criminalizes a broader range of conduct than both robbery and extortion, making it not a crime of violence under the Guidelines. Moreover, the court found that Ohio aggravated robbery doesn't require an offender to obtain something of value from another person, making it broader than the definition of extortion under the Guidelines.Therefore, the court vacated Ivy's sentence and remanded the case back to the district court for resentencing, consistent with its opinion. View "United States v. Ivy" on Justia Law

In July 2018, Brian Lawler, a pretrial detainee, committed suicide at a county jail in Hardeman County, Tennessee. Lawler's father, Jerry Lawler, brought a lawsuit under 42 U.S.C. § 1983, alleging that the officers had been deliberately indifferent to the risk that Brian would commit suicide. The United States Court of Appeals for the Sixth Circuit held that the officers were entitled to qualified immunity because the laws in place at the time of the suicide did not clearly establish that the officers’ actions violated the Constitution. The court noted that in 2018, to hold officers liable for failing to prevent a pretrial detainee’s suicide, it was necessary to prove that the officers subjectively believed there was a strong likelihood the inmate would commit suicide. The evidence showed that the officers did not subjectively believe that Lawler was likely to take his life. Therefore, the court reversed the district court’s denial of qualified immunity to the officers. View "Lawler v. Hardeman County" on Justia Law

In this case, the United States Court of Appeals for the Sixth Circuit was faced with the claims of Cameron Cooper, an employee with Tourette Syndrome, who sued his former employer, Coca-Cola Consolidated, Inc. (CCCI), under the Americans with Disabilities Act (ADA). Cooper's Tourette Syndrome caused him to involuntarily utter racist and profane words. He alleged that CCCI failed to provide him with reasonable accommodations and constructively discharged him by forcing him into an undesirable position.Cooper had been working as a delivery merchandiser for CCCI, a role which required excellent customer service. However, his condition led to complaints from customers due to his use of offensive language. CCCI attempted various accommodations, including having Cooper work alongside another employee and ultimately transferring him to a warehouse position with no customer contact. Cooper claimed that CCCI could have accommodated him by assigning him to a non-customer-facing delivery route.The court held that providing excellent customer service was an essential function of Cooper's job and, given his condition, he could not perform this function without an accommodation. The court further held that Cooper's proposed accommodation (assigning him to a non-customer-facing delivery route) was not objectively reasonable because the suggested delivery route did involve customer contact and there were no other non-customer-facing routes available at the time. Additionally, the court found that the warehouse position offered by CCCI was a reasonable accommodation under the ADA.As to the constructive discharge claim, the court held that Cooper failed to show that CCCI deliberately created intolerable working conditions with the intention of forcing him to quit. The court concluded that CCCI provided Cooper with reasonable accommodations each time he requested, thus, there was no evidence to support a constructive discharge claim.The court affirmed the lower court's decision to grant summary judgment in favor of CCCI. View "Cooper v. Dolgencorp, LLC" on Justia Law

In a case heard before the United States Court of Appeals for the Sixth Circuit, plaintiff Jeffrey Hughes, an inmate in a Tennessee state prison, sued the Tennessee Board of Parole, alleging that the Board's refusal to move up his parole hearing date resulted in his overincarceration. Hughes believed that a recent change in state law entitled him to an earlier parole hearing. The Board refused his request, and he was paroled about three months after the date he believed he became eligible for release. The district court dismissed the case on the ground that the defendants, members of the Board, were absolutely immune from suit for their acts. Hughes then appealed.The Court of Appeals affirmed the district court’s decision, holding that the members of the Tennessee Board of Parole were entitled to absolute immunity from damages suits challenging its decision on when to hold a parole hearing. The court found that the Board's decision to schedule (or not to reschedule) a parole hearing was a judicial act, akin to a judge scheduling a court hearing. As such, the defendants were acting in a quasi-judicial capacity and were entitled to absolute immunity. The court also rejected Hughes's arguments of judicial estoppel and res judicata, stating that the defendants could not have raised their immunity defense in the previous state suit and thus were not barred from raising it in the present federal suit. View "Hughes v. Duncan" on Justia Law

The case involved defendant Antwaun Allen who was found guilty of possessing methamphetamine with the intent to distribute. The defendant had been involved in a police sting operation where he sold methamphetamine to a confidential informant. At sentencing, he requested a downward variance from his Guidelines range, arguing the government's role in his offense, criticizing the Guidelines' treatment of meth purity, and pointing out mitigating offense and character traits. Ultimately, he was sentenced to 108 months, at the bottom of his Guidelines range.On appeal, Allen puts forth three arguments: (1) his sentence is procedurally unreasonable as the district court failed to address the government's provocation of his offense, (2) his sentence is procedurally unreasonable because the district court ceded its sentencing discretion to Congress, and (3) his sentence is substantively unreasonable because the district court relied solely on the meth's weight and purity, neglecting his "whole person."The United States Court of Appeals for the Sixth Circuit rejected all three arguments. The court held that the district court properly addressed all non-frivolous arguments raised by Allen, did not cede its discretion to Congress, and did not abuse its discretion in weighing sentencing factors. The court affirmed Allen's sentence of 108 months. View "United States v. Allen" on Justia Law