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

John Hale pleaded guilty to aggravated sexual battery by unlawful sexual contact in 2010 and was sentenced to eight years of imprisonment and lifetime supervision in Tennessee state court. He was required to register as a sex offender. In 2011, Hale was indicted in the Middle District of Tennessee for traveling out of state and failing to update his sex-offender registration, violating the federal Sex Offender Registration and Notification Act (SORNA). He pleaded guilty and was sentenced to fifteen months’ imprisonment, consecutive to his state sentence, and ten years of supervised release with special conditions. Hale began his supervised release in June 2018 and violated a condition in January 2020 by consuming alcohol.Hale moved for early termination of his supervised release after serving four years and four months of his ten-year term, citing his compliance with supervision conditions, sex-offender treatment, and support letters. His federal probation officer could not recommend early termination due to office policy, but the United States did not oppose the motion. The district court denied Hale’s motion, commending his behavior but finding it insufficiently exceptional to warrant early termination. Hale appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial under the abuse-of-discretion standard. The appellate court found that the district court had relied on an incorrect legal standard by requiring “exceptionally good behavior” for early termination of supervised release. The correct standard under 18 U.S.C. § 3583(e)(1) does not mandate such a threshold. Consequently, the Sixth Circuit vacated the district court’s order and remanded the case for reconsideration under the proper legal standard. The appellate court did not address Hale’s argument regarding the district court’s factual findings about his state supervision terms. View "United States v. Hale" on Justia Law

Lamont Heard, a Michigan prisoner, claimed that prison officials retaliated against him for his litigation activities by transferring him to a different housing unit. He sought to sue the officials under 42 U.S.C. § 1983 for allegedly violating his First Amendment rights. Heard was transferred on January 10, 2017, and filed a grievance the next day. After exhausting his administrative remedies, he filed a lawsuit on January 19, 2021, four years and nine days after the transfer.The United States District Court for the Eastern District of Michigan dismissed Heard's claim for failure to exhaust administrative remedies. Heard then exhausted his remedies and refiled his lawsuit. The district court dismissed the refiled claim as untimely, reasoning that Michigan's tolling provision, which pauses the statute of limitations while a claim is pending in court, conflicted with the Prison Litigation Reform Act (PLRA).The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Michigan's tolling provision does not conflict with the PLRA's exhaustion requirement. The PLRA requires prisoners to exhaust administrative remedies before filing a federal lawsuit but does not address tolling. The court emphasized that federal courts have historically borrowed state statutes of limitations and tolling provisions for § 1983 suits. The court found that Michigan's tolling rule, which pauses the statute of limitations during a prior suit, is consistent with the PLRA and does not undermine its purposes. Consequently, the Sixth Circuit reversed the district court's judgment, allowing Heard's claim to proceed. View "Heard v. Strange" on Justia Law

Nashaun Drake pleaded guilty to several drug offenses after police found significant quantities of fentanyl, cocaine, methamphetamine, and drug trafficking tools in his apartment. He was charged with five counts of possessing illegal drugs with intent to distribute. At sentencing, the district court classified Drake as a "career offender" based on a prior marijuana conviction, resulting in a 200-month prison sentence.The United States District Court for the Northern District of Ohio determined that Drake's prior marijuana conviction qualified as a predicate offense for the career-offender enhancement under the Sentencing Guidelines. This classification led to a sentencing range of 188 to 235 months, and the court imposed a 200-month sentence.The United States Court of Appeals for the Sixth Circuit reviewed the case. Drake argued that his prior marijuana conviction should not have triggered the career-offender enhancement and that his sentence was unreasonable. The court held that binding precedent required the use of a time-of-conviction approach to determine whether a prior offense qualifies as a "controlled substance offense" under the Sentencing Guidelines. Since hemp was included in the drug schedules at the time of Drake's 2016 conviction, his marijuana offense qualified as a controlled substance offense. The court also found that the district court did not abuse its discretion in imposing a 200-month sentence, considering Drake's extensive criminal history and the need for deterrence and public protection.The Sixth Circuit affirmed the district court's decision, upholding both the career-offender enhancement and the 200-month sentence. View "United States v. Drake" on Justia Law

In 2005, Thomas Clardy was identified by Kent Clouatre as one of the shooters in an incident at Kent's auto-repair shop, which resulted in the death of Kent's brother, Kirk, and injuries to Kent and Kirk's wife, Melissa. Clardy was charged with murder, attempted murder, and reckless endangerment. The primary evidence against Clardy was Kent's eyewitness identification. Clardy's trial counsel did not call an expert on eyewitness identification due to financial constraints and the inability to find an expert willing to work for the fees the state would pay. Clardy was convicted on all counts.Clardy filed a petition for postconviction review in state court, arguing ineffective assistance of counsel for failing to call an eyewitness expert. The state trial court denied the petition, and the Tennessee Court of Criminal Appeals (TCCA) affirmed, concluding that Clardy had not suffered prejudice because the expert could not negate Kent's identification. The TCCA did not evaluate whether counsel's performance was deficient.Clardy then filed a habeas corpus petition in federal court. The United States District Court for the Middle District of Tennessee granted the writ, finding that trial counsel's performance was deficient for not seeking expert funding and that the TCCA unreasonably applied Supreme Court precedent in concluding that Clardy was not prejudiced.The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court's decision. The Sixth Circuit held that Clardy's counsel's performance was not deficient. The court noted that counsel made reasonable efforts to secure an expert and, when unsuccessful, used cross-examination and argument to highlight the weaknesses in the eyewitness identification. The court concluded that these efforts were sufficient to meet the standard of reasonably effective assistance under Strickland v. Washington. The case was remanded for further proceedings consistent with this opinion. View "Clardy v. Pounds" on Justia Law

Timothy Davis accidentally shot himself in the leg with his Sig Sauer P320 X-Carry pistol while getting out of his truck. Davis claimed the gun was fully holstered and that he did not pull the trigger. He alleged that the P320 was defectively designed, making it prone to accidental discharge, and that alternative designs could have prevented his injury. Davis filed a products-liability lawsuit against Sig Sauer under Kentucky law, citing strict liability and negligence.The United States District Court for the Eastern District of Kentucky granted Sig Sauer’s motions to exclude Davis’s expert witnesses and for summary judgment. The court found that Davis’s experts, James Tertin and Dr. William J. Vigilante, Jr., did not investigate the exact circumstances of the shooting and thus could not opine on causation. Without expert testimony, the court held that Davis could not pursue his products-liability claims.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court’s exclusion of the experts’ opinions on causation but reversed the exclusion of their testimonies on design defects and reasonable alternative designs. The appellate court found that the experts’ opinions were admissible to prove that the P320 was defectively designed and that reasonable alternative designs existed. The court held that Davis had demonstrated a genuine issue of material fact regarding whether the P320 was defectively designed and caused his injury. Consequently, the court vacated the district court’s grant of summary judgment and remanded the case for further proceedings. View "Davis v. Sig Sauer, Inc." on Justia Law

Louis Chandler, a Michigan prisoner, was convicted of two counts of first-degree criminal sexual conduct and sentenced to concurrent terms of twenty-five to seventy-five years in prison. Chandler filed a habeas corpus petition, claiming that the trial court infringed his right to present a complete defense. The district court denied the petition, and Chandler appealed.The United States District Court for the Western District of Michigan initially reviewed the case and denied Chandler's habeas corpus petition. Chandler argued that the trial court's refusal to delay the trial, exclusion of key witnesses, and prevention of presenting critical evidence violated his constitutional rights. The Michigan Court of Appeals found that the trial court had abused its discretion by denying Chandler's requests for an adjournment, barring his witnesses, and excluding evidence of the victim's prior false allegations. However, the appellate court affirmed Chandler's conviction, concluding that the errors were not outcome determinative under the state's non-constitutional error standard.The United States Court of Appeals for the Sixth Circuit reviewed the case and found that the trial court's actions significantly undermined Chandler's ability to present a complete defense. The court held that the exclusion of evidence and witnesses critical to Chandler's defense violated his constitutional rights. The court concluded that the errors had a substantial and injurious effect on the jury's verdict, creating grave doubt about the trial's fairness.The Sixth Circuit reversed the district court's decision, conditionally granted Chandler's habeas corpus petition, and remanded the case with instructions to order Chandler's release unless the State of Michigan grants him a new trial within ninety days. View "Chandler v. Brown" on Justia Law

Kevin Lavery, an ophthalmologist, invented a vision screening device and patented it. He entered into an agreement with Pursuant Health, a company developing vision screening kiosks, to transfer his patent in exchange for royalties on the sales of these kiosks. Lavery's patent expired in May 2021, and Pursuant Health ceased paying royalties. Lavery sued Pursuant Health, seeking a declaration that the royalty payments should continue indefinitely, damages for breach of the Contribution Agreement, and damages for unjust enrichment.The United States District Court for the Eastern District of Michigan granted summary judgment in favor of Pursuant Health, ruling that the expiration of Lavery's patent rendered the royalty agreement unenforceable. Lavery appealed the decision, challenging the grant of summary judgment on his breach of contract claim.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the royalty provision in the Contribution Agreement was unenforceable after the expiration of Lavery's patent. The court found that the agreement did not specify any non-patent contributions that would justify continuing the royalty payments beyond the patent's expiration. The court also noted that the royalty was based on the sales of kiosks that incorporated Lavery's patent, and thus, the royalty provision improperly extended beyond the patent's 20-year term. Consequently, the Sixth Circuit affirmed the district court's decision to grant summary judgment in favor of Pursuant Health. View "Lavery v. Pursuant Health, Inc." on Justia Law

Glorianna Moore was stopped by Officer Brian Wilson for speeding in Pontiac, Michigan. When Moore refused to show her license and moved her hands towards the center console, Wilson reached into her car, grabbed her arm, and ordered her to shut off the car. Moore resisted by screaming and twisting her body. Wilson restrained her by holding her arm and head until backup arrived. Moore was subsequently handcuffed and placed in Wilson's patrol car. Although an initial test indicated the presence of cocaine in Moore's car, further testing revealed it was not cocaine, leading to the dismissal of all charges against her.Moore filed a § 1983 action against Wilson and other officers, alleging excessive force in violation of her Fourth Amendment rights. The United States District Court for the Eastern District of Michigan granted summary judgment to all defendants except Wilson, who appealed the denial of his motion for summary judgment based on qualified immunity.The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court's decision. The appellate court held that Officer Wilson did not violate clearly established Fourth Amendment principles. The court reasoned that Wilson's actions were reasonable given Moore's refusal to show her license, her movement towards the center console, and her active resistance. The court concluded that no clearly established law indicated that Wilson's use of force was excessive under the circumstances, thus entitling him to qualified immunity. View "Moore v. Oakland County" on Justia Law

Megan Miller was arrested and booked into the City of Troy’s pretrial detention facility, where she informed staff that she had been heavily using heroin and expected to go into withdrawal. Over the next two and a half days, Miller vomited continually. On the third day, she was found unconscious and unresponsive in her cell and was pronounced dead shortly after. Despite her continual vomiting, no jail official sought medical care for her, including Julie Green-Hernandez, who was responsible for monitoring detainees on the day of Miller’s death. Miller’s husband sued Green-Hernandez, claiming she violated Miller’s Fourteenth Amendment right to adequate pretrial medical care and acted with gross negligence under Michigan state law.The United States District Court for the Eastern District of Michigan denied Green-Hernandez’s motion for summary judgment, concluding she was not entitled to qualified immunity on the Fourteenth Amendment claim or state law immunity on the negligence claim. The court found that there were disputes of material fact regarding whether Green-Hernandez was deliberately indifferent to Miller’s serious medical needs and whether her conduct amounted to gross negligence.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court dismissed Green-Hernandez’s appeal regarding qualified immunity due to lack of jurisdiction, as her arguments were based on factual disputes rather than purely legal questions. However, the court reversed the district court’s denial of Michigan governmental immunity. The Sixth Circuit held that while Green-Hernandez’s conduct could be considered grossly negligent, it was not the single most proximate cause of Miller’s death. The court concluded that Miller’s ingestion of fentanyl was the most immediate, efficient, and direct cause of her death, entitling Green-Hernandez to state law immunity. The case was remanded for further proceedings consistent with this opinion. View "Gillman v. City of Troy" on Justia Law

Michael and Rebecca McIntosh owned a mobile home park in Madisonville, Kentucky. In 2020, a tenant complained about mold and mildew in one of the mobile homes. The City of Madisonville inspected the home and found it unsafe, condemning it and giving the McIntoshes 30 days to submit repair plans. The McIntoshes disputed the condemnation, claiming they made necessary repairs and attempted to contact city officials multiple times without success. The City demolished the mobile home a month later.The McIntoshes pursued a § 1983 action, alleging due process violations. The district court granted summary judgment in favor of the City, leading the McIntoshes to appeal.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found that while the City provided adequate notice of the condemnation, it failed to provide the McIntoshes with a pre-demolition hearing, as required by due process. The court noted that the City’s Code promised a hearing before a Local Appeals Board, which did not exist. The court also found that informal opportunities for a hearing were not adequately communicated to the McIntoshes. However, the court upheld the district court’s decision on the substantive due process claim, stating that the City’s actions did not rise to the level of conscience-shocking behavior. The court reversed the district court’s summary judgment on the procedural due process claim and affirmed the decision on the substantive due process claim, remanding the case for further proceedings on the procedural due process claim. View "McIntosh v. City of Madisonville" on Justia Law