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

The case involves a dispute between a family and a school district regarding the provision of special education services under the Individuals with Disabilities Education Act (IDEA). The student, Jeremy Holland, who suffers from various learning impediments, had an individualized education plan developed by the Kenton County School District. This plan included special education teachers accompanying Jeremy to some of his classes at his high school and providing him with behavioral instruction at the end of the school day. For his senior year, Jeremy's family decided to enroll him full-time at a local community college and argued that the IDEA required the school district to provide the same level of support and special education services at the college. The school district disagreed, contending that the IDEA did not impose such an obligation.The United States Court of Appeals for the Sixth Circuit held in favor of the school district. The court determined that the IDEA does not require a school district to provide special education services at the post-secondary level after a student graduates from high school, nor does it require the school district to provide the same services to high school students when they enroll in dual-credit courses offered at post-secondary institutions. The court found that Jeremy's education at the community college was post-secondary, not secondary, and therefore the IDEA did not apply. Additionally, the court found that the school district did not violate the terms of Jeremy's individualized education plan, as the plan did not indicate that Jeremy would receive services at any place other than his high school. The court affirmed the district court's granting of summary judgment in favor of the school district. View "Holland v. Kenton Cnty. Public Schs." on Justia Law

In the case involving a high school student, Jacob Bradley, and his parents, the United States Court of Appeals for the Sixth Circuit concluded that the Individuals with Disabilities Education Act (IDEA) does not require states to provide special education services to students participating in dual-credit or dual-enrollment programs offered at postsecondary institutions.Jacob Bradley, a gifted student with several physical and cognitive conditions, was enrolled in the Craft Academy for Excellence in Science and Mathematics, a state-run dual-credit program located at Morehead State University. His parents sought reimbursement for special education support accommodations provided at Craft under IDEA. However, the district court ruled that IDEA, which offers federal funds to states to provide free appropriate public education to students with disabilities, does not apply to Craft because its dual-credit classes provide postsecondary rather than secondary school education.The Court of Appeals affirmed this decision, holding that the IDEA’s obligation to provide a "free appropriate public education" applies to "secondary," not postsecondary, education. The court also noted that, under Kentucky law, Craft is considered a postsecondary school because it delivers a college-level course of study on a college campus.The court also concluded that the state and federal agencies' interpretation of the IDEA and the state law, which excluded dual-credit courses at postsecondary institutions from IDEA’s mandate, was correct. The court emphasized that the IDEA is a spending clause legislation that operates as a contract between the federal government and states, and states need to comply only with clearly written terms in the Act, not uncertain or ambiguous ones.Additionally, the court affirmed the dismissal of the Bradleys' claims under the Americans with Disabilities Act and Section 504 of the Rehabilitation Act, as they failed to demonstrate how the Commonwealth separately violated the provisions of these distinct Acts.In conclusion, the court held that the IDEA does not obligate Kentucky school districts to provide special education services to a student participating in dual-credit classes offered at a postsecondary institution. The court also affirmed the dismissal of the Bradleys' claims under the Americans with Disabilities Act and Section 504 of the Rehabilitation Act. View "Bradley v. Jefferson Cnty. Public Schs." on Justia Law

In this case heard before the United States Court of Appeals for the Sixth Circuit, the plaintiff, Christina Littler, a bus driver for a school district, appealed a grant of summary judgment in favor of the defendant, Ohio Association of Public School Employees (OAPSE), a union she had joined. Littler had filed a 42 U.S.C. § 1983 action alleging the wrongful deduction and retention of union dues. She claimed that she had withdrawn her union membership and therefore her dues deduction authorization too, but OAPSE had continued to deduct dues from her paycheck. On remand from an earlier appeal, the district court held that Littler had failed to show that OAPSE was a state actor under § 1983, and thus granted OAPSE summary judgment on Littler’s § 1983 claim.The Sixth Circuit affirmed the district court’s judgment. It held that Littler had failed the first prong of the "state action" test under § 1983, as she could not show that the alleged deprivation was caused by any governmental policy or decision. Instead, the conduct she complained about was inconsistent with the collective bargaining agreement and violated her agreement with OAPSE. This conduct was attributed to a private actor—OAPSE—acting contrary to any rule of conduct imposed by the state, and therefore could not be attributed to the state. The court also rejected Littler's argument that the deprivation was caused by the terms of the collective bargaining agreement and the school district’s compliance with the union’s request to withhold dues from her paycheck. Instead, the court held that the specific conduct complained about was OAPSE’s failure to process Littler’s withdrawal pursuant to the membership application and remove her name from the deduction list. This was not governed by a state-imposed rule of conduct but rather by a private individual or organization’s policy. Thus, the court concluded that the challenged conduct could not be fairly attributable to the state. View "Littler v. Ohio Ass'n of Pub. Sch. Emps." on Justia Law

In a dispute involving a power grid operator, PJM Interconnection, L.L.C., and the Federal Energy Regulatory Commission (FERC), the United States Court of Appeals for the Sixth Circuit ruled that the Chairman of FERC exceeded his authority by seeking a remand of a ratemaking challenge without the support of other Commission members.The case originated when PJM filed a request to modify its existing rates for electricity reserves, arguing that the existing rates were unjust and unreasonable. Initially, FERC agreed and approved the new rates. However, after a change in FERC's composition and a unilateral decision by the Chairman to request a voluntary remand from the D.C. Circuit for reconsideration, FERC reversed its decision and found PJM's evidence insufficient.The Sixth Circuit's ruling focused on the procedural irregularity, specifically the Chairman's unilateral decision to seek a remand, which it deemed exceeded his administrative authority. The court stated that a quorum majority must decide the Commission’s policy and dealings with the outside world, and the Chairman acting alone does not meet this requirement. As such, the court vacated the part of FERC's rehearing order that claimed the Chairman had this unilateral authority and remanded the matter back to FERC to address this issue.The court did not address the substantive issue of whether FERC's reversal on the ratemaking decisions was arbitrary and capricious. It noted that any interested party may renew a petition to challenge that decision after FERC resolves the procedural issue. View "PJM Power Providers Grp. v. FERC" on Justia Law

In a case involving the Federal Energy Regulatory Commission (FERC) and the Electric Power Supply Association and PJM Power Providers Group (collectively, PJM), the United States Court of Appeals for the Sixth Circuit had to address two questions. The first was whether the Chairman of FERC exceeded his authority when he moved for a remand of a ratemaking challenge without the support of any other members of the Commission, and the second was whether FERC's underlying ratemaking decisions were arbitrary and capricious.The case arose from PJM's request to FERC to raise the reserve price cap for electricity from $850 to $2,000 per megawatt hour and to replace the flat $300 per megawatt hour cap after Step 1 with a downward sloping price schedule. Initially, FERC agreed with PJM that the existing price cap and stepwise demand curve were unjust and unreasonable. However, after a change in the composition of the FERC, the Commission sought a voluntary remand from the D.C. Circuit to reconsider its prior decisions. The D.C. Circuit granted the unopposed motion for remand. On remand, the Commission reversed its previous decision and found PJM's evidence insufficient to show that the price caps for reserves and stepwise demand curve were unjust and unreasonable.PJM and others sought rehearing before the Commission, citing a procedural irregularity - the Chairman had directed FERC's Solicitor to seek remand without first informing the other Commissioners - and challenging the substance of the agency’s shift in views. The Commission rejected the request for rehearing but issued a modified order, reaching the same result, and reasoning that Chairman Glick had the unilateral authority to make the remand motion.The Court of Appeals for the Sixth Circuit held that the Chairman of FERC exceeded his legal authority when he requested a remand in the name of the Commission on his own. The court vacated part of the Commission’s order claiming the Chairman had this unilateral authority and remanded the case back to the Commission to decide what, if anything, it could or would have done differently in response to this legal mistake. The court did not rule on whether FERC's underlying ratemaking decisions were arbitrary and capricious, leaving it to the Commission to first resolve the legal mistake. View "Electric Power Supply Ass'n v. FERC" on Justia Law

This case concerns an appeal by Edgardo Esteras against the district court’s decision to revoke his supervised release and sentence him to 24 months in prison. Esteras had pleaded guilty to conspiring to distribute and possess with intent to distribute heroin, violating the conditions of his supervised release by committing domestic violence and possessing a firearm.Esteras argued that the district court relied on prohibited factors in sentencing him. He claimed that the court should not have considered three subfactors identified in 18 U.S.C. § 3553(a)(2)(A) when crafting his sentence: “to reflect the seriousness of the offense, to promote respect for the law, and provide just punishment for the offense.”The United States Court of Appeals for the Sixth Circuit rejected his argument, citing the precedent set in United States v. Lewis. The court stated that a district court judge who considers the mentioned factors does not necessarily impose a procedurally unreasonable sentence. The court also noted that the judge could not ignore respect for the law but consider a defendant’s need to respect the terms of supervised release. The court affirmed the district court’s revocation order. View "United States v. Esteras" on Justia Law

The United States Court of Appeals for the Sixth Circuit affirmed the decision of the United States District Court for the Northern District of Ohio, which denied Clarence Mack's petition for a writ of habeas corpus. Mack was convicted of aggravated murder in relation to a 1991 carjacking and was sentenced to death. His habeas petition alleged that prosecutors suppressed material evidence, introduced false testimony, and that his trial counsel was ineffective. The appellate court found that Mack had not demonstrated any violation of his constitutional rights. Material evidence was either disclosed, non-existent, not favorable, or immaterial. Mack failed to show that the prosecutor knowingly used a false, material statement to obtain the conviction. His ineffective assistance of counsel claim was procedurally defaulted, and he failed to establish his actual innocence to excuse the default. Lastly, the court found that the exclusion of certain testimony did not render Mack’s trial fundamentally unfair. Therefore, the court denied all claims raised by Mack and affirmed the lower court's decision. View "Mack v. Bradshaw" on Justia Law

In this case, Da’Rell Winters, a convicted petitioner, sought to appeal the district court's denial of his habeas relief application. However, due to the delayed receipt of the district court's decision, he did not file his appeal in time. When he finally filed the appeal notice, he explained his delay but did not formally request to reopen the appeal period. The United States Court of Appeals for the Sixth Circuit ruled that his explanation was sufficient for the district court to consider his appeal notice as a motion to reopen, thus deeming his appeal timely.The case's facts reveal that in 2014, Winters was convicted for armed robbery. After exhausting his appeals in Michigan state courts, he applied for habeas relief in a federal court in 2018. He represented himself and raised various claims, including insufficiency of evidence and errors in jury instructions and sentencing.The federal district court denied Winters's habeas application and a certificate of appealability on March 10, 2021. Due to a mailing error, Winters received the court's decision only on May 18, 2021. He filed a notice of appeal on June 1, 2021, which was after the 30-day deadline for filing an appeal. The Sixth Circuit dismissed his appeal as untimely.Winters later moved the district court to reopen the appeal period, which the court granted. It retroactively construed his June 1 notice of appeal as a motion to reopen, making his appeal timely. The Sixth Circuit agreed with this interpretation, concluding that Winters's appeal was timely and directing the Clerk's Office to set a briefing schedule for considering whether to grant a certificate of appealability in this appeal. View "Winters v. Taskila" on Justia Law

In this case, a prisoner named Lyle Heyward filed a complaint alleging that prison officials frustrated his attempts to celebrate Ramadan, a holy month for Muslims, in violation of the First and Fourteenth Amendments and the Religious Land Use and Institutionalized Persons Act (“RLUIPA”). He also alleges that officials retaliated against him for filing grievances in violation of the First Amendment. The United States Court of Appeals for the Sixth Circuit affirmed the dismissal of Heyward’s Religious Land Use and Institutionalized Persons Act (RLUIPA) claim, as RLUIPA does not permit money damages claims against state prison officials in their individual capacities, and his requests for injunctive relief were mooted by his transfer to a different prison facility.However, the court reversed the dismissal of Heyward’s First Amendment retaliation claim against Defendant Guise, finding that Heyward had adequately pleaded a retaliation claim. Specifically, Heyward alleged that after he filed a grievance against Guise, she threatened members of the Cultural Awareness Inmate Group to kick Heyward out of the organization or else the organization would be shut down. The court found these allegations sufficient to suggest that Guise's action was motivated at least in part by Heyward’s grievance-filing.The court also reversed the dismissal of Heyward’s Equal Protection Clause claim against Defendants Cooper, Smith, Davis, and Factor. Heyward alleged these officials treated members of other faith traditions differently than they treated Muslims. The court found that Heyward’s allegations of a facially discriminatory distinction between different religious groups sufficiently alleged an equal-protection violation.The case was remanded for further proceedings. View "Heyward v. Cooper" on Justia Law

The United States Court of Appeals for the Sixth Circuit affirmed the ruling of the United States District Court for the Northern District of Ohio, which had denied Adam Carson's motion to vacate his sentence under 28 U.S.C. § 2255. Carson had been convicted of robbing a bank and tampering with a witness, and was sentenced to 20 years in prison. In his motion, Carson argued that his trial attorney had provided ineffective assistance by failing to initiate plea negotiations and by committing several mistakes during the trial. He also claimed that he did not knowingly waive his right to testify. The Court of Appeals held that Carson's ineffective-assistance claims failed because they lacked grounds for prejudice. The court ruled there was no reasonable probability that the outcome of Carson's case would have been different if his attorney had acted differently. The court also held that Carson had not demonstrated that he was deprived of his right to testify, as he did not object on the record to his attorney's statement that he did not want to testify. View "Carson v. United States" on Justia Law