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

This case concerns Ana Sanchez Sebastian-Sebastian, a native and citizen of Guatemala, who appealed the denial of her application for asylum, withholding of removal, and protection under the Convention Against Torture (CAT) by the Board of Immigration Appeals (BIA). The United States Court of Appeals for the Sixth Circuit found that the BIA did not fully consider whether Sebastian-Sebastian was persecuted due to her membership in certain social groups, including "Guatemalan Chuj Women in domestic relationships who are unable to leave" and "Guatemalan Chuj Women who are viewed as property by virtue of their positions within a domestic relationship." The court noted that the BIA ended its analysis prematurely, failing to consider the possibility that Sebastian-Sebastian's persecutors may have had mixed motives for their persecution. The BIA also failed to consider whether her husband's motives were intertwined with her particular social groups. As a result, the court granted Sebastian-Sebastian's petition for review in part, vacated the BIA's denial of her application for asylum and withholding of removal, and remanded the case to the BIA for reconsideration. However, the court denied Sebastian-Sebastian's petition for review regarding her CAT claim and dismissed her due process claim, finding that her right to due process was not violated. View "Sebastian-Sebastian v. Garland" on Justia Law

In this case heard by the United States Court of Appeals for the Sixth Circuit, the plaintiff, Rudolph Betancourt, a disabled individual, filed a lawsuit against Indian Hills Plaza LLC, the owner of a shopping plaza, citing violations of the Americans with Disabilities Act (ADA). The plaintiff experienced difficulties accessing the shopping plaza due to his disability. The parties agreed that the defendant had violated the ADA in 17 aspects, and Indian Hills Plaza LLC undertook remediation measures. The district court awarded Betancourt $12,000 in attorney's fees and costs. However, Betancourt appealed this decision, believing he was entitled to more.The main issue on appeal was the challenge to the district court's award of attorney’s fees and costs. The Court of Appeals affirmed the District Court's decision, finding no abuse of discretion. The court explained that the district court properly calculated the lodestar amount (reasonable hourly rate multiplied by the reasonable number of hours worked), which serves as a baseline for attorney's fees. It reduced the hourly rate considering the quality of the performance of Betancourt’s attorney and reduced the number of hours billed by 20% due to excessive billing. The court further reduced the attorney’s fees award based on deficiencies in the actions by Betancourt’s counsel during the litigation. The district court also deemed the requested expert costs as unreasonable and reduced them.Therefore, the holding of the case is that the district court did not abuse its discretion in awarding $12,000 in attorney’s fees and costs to the plaintiff, and that the court properly calculated the lodestar amount and adjusted it based on relevant considerations. The court also held that the plaintiff's attorney's premature fee motions, not the defendant's opposition to those motions, caused the excessive fees. View "Betancourt v. Indian Hills Plaza LLC" on Justia Law

Bradley Peterson, a former professor at Ohio State University, claimed his procedural-due-process rights were violated when the university stripped him of his emeritus status without adequate process. Following a sexual harassment complaint against him, the university conducted an investigation, concluded that Peterson violated the university's Sexual Misconduct Policy, and subsequently revoked his emeritus status. Peterson argued that he had a property interest in his emeritus status and its related benefits. The United States Court of Appeals for the Sixth Circuit, however, affirmed the district court's decision to dismiss Peterson's complaint. The court held that Peterson failed to establish a constitutionally protected property interest in his emeritus status. The court noted that emeritus status was an honorific title, and Peterson did not show that he lost pay or tangible benefits from Ohio State when his emeritus status was revoked. The court also noted that Peterson's claim of harm to his professional reputation was akin to a liberty interest claim, and he did not request a name-clearing hearing, which was a prerequisite for asserting such a claim. View "Peterson v. Johnson" on Justia Law

In this case heard by the United States Court of Appeals for the Sixth Circuit, the plaintiff, Marlean Ames, alleged that the Ohio Department of Youth Services discriminated against her on the basis of sexual orientation and sex under Title VII of the Civil Rights Act of 1964. Ames, a heterosexual woman, was an employee of the Department and was demoted from her position as Administrator of the Prison Rape Elimination Act, and denied a promotion to Bureau Chief of Quality. She was replaced in her role by a gay man and the Bureau Chief position was filled by a gay woman.The court affirmed the district court's grant of summary judgment in favor of the Department. It found that Ames failed to provide sufficient evidence of "background circumstances" necessary to establish a prima facie case of discrimination based on sexual orientation. The court stated that a plaintiff who is a member of the majority must show suspicion that the defendant is an unusual employer who discriminates against the majority. Ames was unable to provide evidence that the decision-makers who demoted her were part of a minority group (gay people) or that there was a pattern of discrimination against heterosexuals by the Department.As for Ames's sex discrimination claim, the court found that while Ames was replaced by a man, the Department had provided nondiscriminatory reasons for her demotion. The Department cited the need for improved performance and the fact that Ames's evaluations showed she met expectations rather than exceeded them. Ames was unable to show that the Department's reasons were without basis in fact, did not actually motivate the employer's actions, or were insufficient to motivate the employer's actions. Therefore, her claims of pretext were not persuasive. View "Marlean Ames v. Ohio Dep't of Youth Servs." on Justia Law

In the case before the United States Court of Appeals for the Sixth Circuit, Jennings Maynard, a coal miner with severe respiratory issues, filed a claim for benefits under the Black Lung Benefits Act. After his death while the claim was pending, his widow, Elizabeth Maynard, filed a claim for survivor’s benefits. The Administrative Law Judge (ALJ) awarded benefits to Elizabeth Maynard on behalf of her late husband and as his surviving spouse. The Benefits Review Board affirmed this decision. The petitioner, Island Creek Coal Company, sought review of the award.The court denied the petition for review. The court explained that Maynard had worked in the coal mining industry for over forty-three years and had developed severe respiratory issues. Maynard's widow, Elizabeth, filed a claim for survivor's benefits after her husband's death. The ALJ awarded benefits to Elizabeth, both on behalf of her late husband and as his surviving spouse. The Benefits Review Board affirmed this decision.The court held that substantial evidence supported the ALJ's findings that Maynard was totally disabled due to his elevated PCO2 values and that the petitioner failed to provide persuasive contrary evidence. The court also found that substantial evidence supported the ALJ's conclusion that the petitioner failed to rebut the presumption that Maynard's respiratory impairment, which contributed to his total disability, arose out of coal mine employment. The court determined that the ALJ properly discredited the medical opinions offered by the petitioner's experts because these opinions were inconsistent with the regulations of the Black Lung Benefits Act and the Department of Labor's determinations. The court therefore denied the petitioner's request for review. View "Island Creek Coal Co. v. Elizabeth Maynard" on Justia Law

The case involves a man named James Wilder II who was convicted for possession of a firearm as a felon and attempted witness tampering. While on patrol, Officer Meric Whipple observed Wilder walking beside the road with a visible firearm. When Wilder noticed the police car, he ran, dropped the gun, picked it back up, and entered a house. Upon searching the house, the officers found a gun that matched the one Wilder had dropped and arrested him. While in jail, Wilder called a friend and directed her to bribe the residents of the house to falsely claim that they owned the gun. A jury found him guilty of both charges.Wilder appealed his conviction on the grounds that the trial testimony regarding the officer's training and experience was unfairly admitted and that there was insufficient evidence supporting his conviction for attempted witness tampering. The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court held that the officer's training and experience in identifying weapons were relevant to the case, and the testimony did not pose a risk of unfair prejudice. In regards to the second ground, the court found that Wilder's instructions to his friend to bribe the residents of the house to claim the gun was theirs demonstrated a substantial step towards witness tampering and was sufficient evidence for the conviction. View "United States v. Wilder" on Justia Law

In 2021, the Department of Health and Human Services (HHS) issued a final rule governing the Title X program, which makes grants to assist in the establishment and operation of family planning projects. The Rule interpreted section 1008 of Title X, which bars funds appropriated under the Title X grant program from being “used in programs where abortion is a method of family planning.” States challenged the 2021 Rule’s elimination of a prior HHS rule that required grantees to maintain strict physical and financial separation between Title X programs and abortion-related services they might provide and the Rule’s requirement that Title X projects provide referrals for abortion services when requested by the patient.The Supreme Court has held (“Rust,” 1991) that section 1008 is ambiguous as to program integrity and referrals for abortion and that Chevron deference applies. The Sixth Circuit held Ohio is entitled to a preliminary injunction enjoining the government from enforcing the 2021 Rule’s program integrity rules in Ohio in a manner that would affect the allocation of funding in Ohio. While the doctrinal landscape undergirding Rust has shifted significantly since it was decided, Rust, and its application of Chevron, remain binding. The 2021 Rule’s referral requirement is not an impermissible interpretation of section 1008 but the program-integrity requirements do not represent a permissible interpretation. View "State of Ohio v. Becerra" on Justia Law

The Township solicited bids for the demolition of former hospital buildings. ICC, a Detroit-based minority-owned company, submitted the lowest bid. AAI, a white-owned business submitted the second-lowest bid, with a difference between the bids of almost $1 million. The Township hired a consulting company (F&V) to vet the bidders and manage the project. F&V conducted interviews with both companies and provided a checklist with comments about both companies to the Township. ICC alleges that F&V made several factual errors about both companies, including that AAI had no contracting violations and that ICC had such violations; that ICC had no relevant experience, that AAI had relevant experience, and that AAI was not on a federal contracting exclusion list. F&V recommended that AAI receive the contract. The Township awarded AAI the contract. ICC filed a complaint, alleging violations of the U.S. Constitution, federal statutes, and Michigan law.The district court dismissed the case, finding that ICC failed to state a claim under either 42 U.S.C. 1981 or 42 U.S.C. 1983 by failing to allege the racial composition of its ownership and lacked standing to assert its constitutional claims and that F&V was not a state actor. The Sixth Circuit reversed in part. ICC had standing to bring its claims, and sufficiently pleaded a section 1981 claim against F&V. The other federal claims were properly dismissed. View "Inner City Contracting LLC v. Charter Township of Northville" on Justia Law

Ohio revoked the operating license for Ricci's company, Palms, which operated a substance abuse treatment center. The Department of Justice (DOJ) seized $600,000 from Palms for alleged fraud. Pender was attempting to terminate Palms's building lease. Palms sued Ohio to recover its license, sued the DOJ to recover the $600,000, and filed for Chapter 11 bankruptcy, 11 U.S.C. 1187–95. Its plan for reorganization depended on the success of its pending lawsuits. Concerned that the litigation would consume the estate, the Trustee sought conversion to a proceeding under Chapter 7 for liquidation. Weeks later, the seized assets lawsuit was put on hold while the DOJ pursued a criminal indictment. Palms failed to meet the bankruptcy court's deadline for an accounting of post-petition transactions. Two days before a hearing on the conversion, Palms’s attorney (Vitullo) moved to withdraw, citing a conflict of interest. Minutes before the hearing, Rucci (also a lawyer) filed an objection to the motion to convert. Rucci did not object to Vitullo’s withdrawal.The bankruptcy court granted Vitullo’s motion and converted the proceedings to Chapter 7. Pender successfully evicted Palms. An Ohio court upheld the revocation of its license. A Sixth Circuit panel denied Palms’s petition to return the seized $600,000. The district court and Sixth Circuit affirmed the conversion order as a final, appealable order. Considering the substantial, continuing losses and the unlikelihood of rehabilitation, the court did not abuse its discretion in finding cause to convert. View "In re: California Palms Addiction Recovery Campus, Inc. v." on Justia Law

In five 2008 transactions, Goodwin distributed a total of 71.9 grams of crack cocaine to a confidential informant. He pleaded guilty to a conspiracy to distribute at least 50 grams of crack cocaine, 21 U.S.C. 846. Goodwin had a prior “felony drug offense,” 21 U.S.C. 841(b)(1)(A), and faced a statutory minimum 20-year sentence. The district court found that two of his prior offenses made him a “career offender,” calculated his guidelines range as 262-327 months, and imposed a 262-month sentence. After Goodwin’s sentencing, the 2010 Fair Sentencing Act increased the amount of crack cocaine necessary to subject Goodwin to his 20-year minimum sentence from 50 to 280 grams; the 2018 First Step Act made that change retroactive. Goodwin moved for a reduced sentence under the Act. In 2020, before that motion was resolved, the Bureau of Prisons allowed Goodwin to serve the remainder of his sentence in home confinement because of the COVID-19 pandemic (CARES Act, 134 Stat. 281, 516).Two years later, the district court denied Goodwin’s motion for a reduced sentence primarily because his guidelines range remained the same even after the statutory changes. The Sixth Circuit affirmed, rejecting arguments that the district court committed a procedural error by denying relief in a cursory order and committed a substantive error because Goodwin's rehabilitation efforts (combined with other legal changes) required the court to issue a below-guidelines sentence. View "United States v. Goodwin" on Justia Law