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

A research scientist who had worked for over a decade at a public university in Ohio coauthored several well-regarded articles during her tenure. After she left the university for a new position, allegations of research misconduct surfaced regarding some of her publications. The university convened an investigative committee, as required by federal regulations due to its receipt of federal funding. The committee found that she had committed research misconduct and recommended barring her from future university employment, retracting or correcting certain articles, and reported its findings to relevant journals and her current employer. The scientist alleged that the committee deviated from standard investigatory procedures, failed to provide exculpatory evidence, and did not require proof of intent or recklessness.The United States District Court for the Southern District of Ohio dismissed her complaint, which had sought equitable relief under federal and state law. The court held that sovereign immunity shielded the university’s Board of Trustees and the officials sued in their official capacities from most claims. It found several claims time-barred and determined that the remaining constitutional claims, including due process and equal protection, failed on the merits. The court declined to exercise supplemental jurisdiction over the state-law claims against individuals in their personal capacities.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s dismissal. The court held that sovereign immunity barred all claims against the Board of Trustees and all state-law claims against the officials in their official capacities. As to the remaining federal due process claims, the court determined that the plaintiff failed to identify a constitutionally protected liberty interest under the stigma-plus doctrine and that the alleged conduct—even if malicious or in violation of confidentiality regulations—did not amount to conscience-shocking behavior under substantive due process standards. View "Pichiorri v. Burghes" on Justia Law

The plaintiff was incarcerated in Tennessee on sentences from multiple convictions. After being granted parole by the Tennessee Board of Parole, he was not released on his effective parole date because county officials filed a detainer warrant, claiming he had not completed his sentence and was required to serve additional time in county jail. The plaintiff remained in custody for over four months beyond his scheduled release date. He and his family attempted to resolve the situation, and he eventually retained counsel, after which the detainer was lifted and he was released.The plaintiff brought suit in the United States District Court for the Western District of Tennessee against the county, several county officials, state officials, and unnamed defendants under 42 U.S.C. § 1983, alleging violations of his rights under the Fourth and Fourteenth Amendments, as well as state law. The county defendants moved to dismiss for failure to state a claim and asserted qualified immunity. The plaintiff voluntarily dismissed his claims against the state defendants. The district court granted the county defendants’ motion to dismiss, holding that there was no liberty interest in release on parole under Tennessee law, that the individual defendants were entitled to qualified immunity, and that no plausible claim was stated against the county under Monell v. Department of Social Services. The court declined to exercise supplemental jurisdiction over the state law claims.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s dismissal de novo. The Sixth Circuit held that Tennessee’s statutory scheme does not create a protected liberty interest in parole or in release following a grant of parole. Without such a liberty interest, the plaintiff’s due process claim failed, and the individual defendants were entitled to qualified immunity. The Monell claim against the county also failed in the absence of an underlying constitutional violation. The appellate court affirmed the district court’s refusal to exercise supplemental jurisdiction over the state law claims. The judgment of the district court was affirmed. View "Hester v. Chester County" on Justia Law

Kevin Clay and his associate founded a pharmaceutical sales company that marketed compounded prescriptions directly to patients, promising them a share of the insurance reimbursements for each prescription filled. The company partnered with a pharmacy willing to pay a portion of the insurance proceeds and recruited employees from a local business whose health plan covered these prescriptions. Patients were directed to a doctor who readily prescribed the creams, resulting in millions of dollars in reimbursements over two years. Clay established a public charity to reduce his tax burden but used its funds for personal expenses and failed to comply with nonprofit requirements.The United States District Court for the Northern District of Ohio oversaw Clay’s trial. A jury convicted him of conspiracy to commit healthcare fraud, healthcare fraud, and making a false statement to the IRS, but acquitted him of a separate tax charge. The court sentenced Clay to 51 months’ imprisonment and ordered restitution totaling nearly $7 million to both Fiat Chrysler and the IRS. Clay appealed his convictions, sentence, and restitution orders.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed Clay’s convictions and rejected his challenges to the jury instructions and evidentiary rulings. However, it found error in the district court’s restitution orders and the application of a sentencing enhancement. Specifically, the Sixth Circuit held that restitution should not include payments for medically necessary prescriptions and that the apportionment of restitution must consider each defendant’s contribution and economic circumstances. The court also determined the restitution order to the IRS was not properly substantiated and included acquitted conduct. Finally, the case was remanded for further proceedings on restitution and for clarification or reconsideration of the leadership sentencing enhancement. View "United States v. Clay" on Justia Law

After a fatal school shooting occurred at a high school in Michigan, H.H., an eighth-grade student at a different school, was reported by several classmates to have made threatening comments about possessing or bringing a gun to campus. The school administration, in response to these reports and heightened safety concerns, questioned H.H. with assistance from law enforcement, searched his person, backpack, and locker, and ultimately found no firearm. Despite this, the administration determined that H.H. had violated the school district’s code of conduct and referred him for an expulsion hearing, which resulted in his expulsion for 180 days.Following the expulsion, H.H.’s parents filed a lawsuit in the United States District Court for the Eastern District of Michigan against the school district and various officials. They raised claims under 42 U.S.C. § 1983 for alleged violations of H.H.’s Fourth Amendment rights (unlawful search and seizure), procedural and substantive due process, and also asserted state law tort claims. The district court granted summary judgment in favor of the defendants on all claims, finding no constitutional violations and determining that the defendants were immune from state law liability.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court held that the search and seizure of H.H. were reasonable under the circumstances, given the nature of the reported threat and school safety concerns. It found that the procedures afforded to H.H. during the expulsion process satisfied due process requirements, and there was no evidence of bias or arbitrary conduct by the school board. The court also concluded that the individual defendants were entitled to qualified immunity, and that governmental immunity barred the state tort claims. The Sixth Circuit affirmed the district court’s judgment in full. View "Halasz v. Cass City Public Schools" on Justia Law

Joe’Veon Penson Willis operated a residence used for drug trafficking with his half-brother. On Christmas Day 2021, the two streamed a Facebook Live video describing their drug business, which drew the attention of federal authorities. Shortly afterward, agents from the ATF and DEA executed a search warrant at their house, discovering significant quantities of methamphetamine and fentanyl, multiple firearms, and drug paraphernalia in various rooms. Further investigation established that Willis had used a straw purchaser to acquire at least some of the firearms.Willis was charged in the United States District Court for the Northern District of Ohio with maintaining a drug premises and two counts of aiding and abetting false statements in the purchase of firearms. He pled guilty without a written plea agreement. At sentencing, Willis objected to a two-level sentencing enhancement for maintaining a drug premises, arguing that it constituted impermissible double-counting because the underlying offense and enhancement addressed the same conduct. He also challenged the attribution of certain drugs found in shared spaces to him. The district court rejected these objections, adopted the presentence report in full, and imposed three concurrent sentences of 135 months, which was below the advisory Guidelines range.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed Willis’s arguments de novo for double-counting and for abuse of discretion regarding substantive reasonableness. The court held that applying the two-level enhancement for maintaining a drug premises, even when the underlying conviction was for that same conduct, was permissible given clear Congressional intent. The court also found the sentence substantively reasonable and adequately supported by the record. Although the court acknowledged a technical error in the length of the firearm-related sentences exceeding statutory maximums, it determined this had no practical effect because all sentences ran concurrently. Accordingly, the Sixth Circuit affirmed the district court’s judgment. View "United States v. Willis" on Justia Law

The plaintiffs in this case are mental health counselors who provide “talk therapy” services, including counseling to minors, guided by their Catholic faith. Their services consist exclusively of spoken words, and they do not use physical or aversive techniques. Some of their clients, including minors with parental consent, seek counseling to address issues related to gender identity or sexual orientation, such as wanting to align their gender identity with their biological sex or to reduce same-sex attraction in accordance with their religious beliefs. The plaintiffs assert an ethical and religious duty to help clients pursue such goals if requested.In 2023, Michigan enacted laws forbidding licensed therapists from engaging in “conversion therapy” with minors, defined as efforts to change an individual’s sexual orientation or gender identity, but specifically permitting counseling that assists with gender transition. The plaintiffs filed suit in the United States District Court for the Western District of Michigan, seeking a preliminary injunction to block enforcement of these laws, arguing that the prohibition restricts their speech based on its content and viewpoint in violation of the First Amendment. The district court denied the motion, reasoning that the counseling in question was conduct, not speech, for constitutional purposes.On appeal, the United States Court of Appeals for the Sixth Circuit found that the plaintiffs had standing and disagreed with the district court’s characterization of the therapy as conduct rather than speech. The court held that the Michigan law is a content- and viewpoint-based restriction on speech and is therefore subject to strict scrutiny under the First Amendment. The court determined that the State did not demonstrate a sufficient justification for the restriction, and that the plaintiffs are likely to succeed on the merits of their claim. The Sixth Circuit reversed the district court’s denial of the preliminary injunction and remanded for prompt entry of an injunction preventing enforcement of the law during the case. View "Catholic Charities of Jackson v. Whitmer" on Justia Law

A fast-casual restaurant chain hired an individual with arthritis in her knees for a cashier/service-team member position. Prior to starting, she requested to be allowed to sit for five minutes after every ten minutes of standing, due to her medical condition. The restaurant required employees in her role to multitask and maintain mobility throughout their shifts, handling various duties such as operating the register, restocking, cleaning, and serving customers. The employer concluded that her requested accommodation would prevent her from performing essential job functions and did not permit her to begin work until the accommodation issue was resolved.The United States District Court for the Eastern District of Kentucky reviewed the case after the employee sued under the Americans with Disabilities Act (ADA) and the Kentucky Civil Rights Act (KCRA), alleging failure to accommodate her disability and failure to engage in the interactive process. The district court granted summary judgment to the employer, holding that the requested accommodation was not reasonable as a matter of law, and that her claim regarding the interactive process could not proceed without a viable accommodation claim.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s grant of summary judgment de novo. The appellate court affirmed, holding that the employee’s proposed accommodation—sitting for five minutes after every ten minutes of standing—was not objectively reasonable because it would fundamentally alter essential functions of the cashier/service-team member position, which required continuous mobility and multitasking. The court further held that, because no reasonable accommodation was shown, the claim arising from the employer’s alleged failure to engage in the interactive process also failed as a matter of law. The judgment of the district court was therefore affirmed. View "Bowles v. SSRG II, LLC" on Justia Law

Luther Poynter was incarcerated at the Barren County Detention Center in Kentucky for contempt of court related to unpaid child support. After a brief period in COVID-19 observation, he was moved to a general-population cell with two other detainees, Scotty Wix and Timothy Guess. Both Wix and Guess had extensive histories of violent behavior and multiple documented assaults against other detainees while in the facility. Shortly after Poynter entered the cell, Guess and Wix attacked him without apparent provocation, causing a traumatic brain injury and lasting physical impairment.The United States District Court for the Western District of Kentucky reviewed the case after Poynter, through his guardian, sued the jailer and Barren County under 42 U.S.C. § 1983, alleging deliberate indifference to his safety in violation of the Due Process Clause of the Fourteenth Amendment. The district court granted summary judgment to the county, concluding there was insufficient evidence of a constitutional violation or municipal liability, and held that Poynter had not shown he was placed at a substantial risk of harm or that reasonable steps were not taken to abate that risk.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision. The appellate court held that Poynter had presented sufficient evidence for a reasonable jury to find that Barren County had a custom of failing to properly classify detainees with violent histories, recklessly disregarded a known risk, and that this failure caused Poynter’s injuries. The Sixth Circuit clarified that municipal liability can attach even without identifying a specific individual as the violator, so long as the unconstitutional harm resulted from a municipal policy or custom. The Court of Appeals reversed the district court’s summary judgment and remanded the case for further proceedings. View "Poynter v. Bennett" on Justia Law

In this case, an individual attended the 2022 Kentucky Derby in Louisville, Kentucky, with a group to engage in expressive activities such as preaching, distributing literature, and displaying signs near the event. The area surrounding Churchill Downs was subject to a special event permit issued by the city government, which allowed Churchill Downs to restrict access to certain public streets and sidewalks to ticket holders and credentialed individuals. The plaintiff and his group entered a fenced-off, restricted area beyond posted “No Trespassing” signs, despite lacking event tickets or credentials. After repeated warnings from private security and law enforcement, the plaintiff was arrested by a Kentucky State Police trooper for criminal trespass.The plaintiff filed suit in the United States District Court for the Western District of Kentucky, asserting claims under 42 U.S.C. § 1983 for violations of his free speech, free exercise, and due process rights, as well as a Monell municipal liability claim against the city government and claims against the arresting officer. The district court granted summary judgment in favor of the defendants on all claims. It found the free speech restriction content-neutral and justified under intermediate scrutiny, concluded the free exercise claim was not properly developed, determined the permitting scheme was not unconstitutionally vague, dismissed the Monell claim for lack of an underlying constitutional violation, and granted qualified immunity to the arresting officer.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The appellate court held that the restricted area was a limited public forum and the ticketing and access restrictions were content-neutral and survived intermediate scrutiny. The court found no evidence of viewpoint discrimination, held that ample alternative channels for communication existed, and determined that the plaintiff failed to preserve his free exercise claim and did not establish a due process violation. The Monell claim failed for lack of a constitutional violation, and qualified immunity was properly granted to the officer. View "Blankenship v. Louisville-Jefferson Cnty. Metro Gov't" on Justia Law

Two individuals worked as delivery drivers for a transportation company for over a decade, primarily out of the company’s New Jersey terminal. Their work mainly involved picking up and delivering goods in New Jersey, with occasional deliveries in neighboring states. Each driver had a contract with the company that included a forum-selection clause requiring any disputes to be litigated in Memphis, Tennessee, and a choice-of-law clause providing that Tennessee law would govern any disputes. The company is incorporated in Delaware, headquartered in Illinois, and has operations nationwide, including in Tennessee, but neither the drivers nor the company’s relevant activities were based in Tennessee.The drivers filed a putative class action in the United States District Court for the District of New Jersey, alleging that the company violated New Jersey wage laws by withholding earnings and failing to pay overtime, among other claims. The case was transferred to the United States District Court for the Western District of Tennessee pursuant to the forum-selection clause. The company then moved to dismiss the complaint, arguing that the Tennessee choice-of-law provision applied and that Tennessee law did not recognize the claims brought under New Jersey statutes. The district court agreed, upheld the choice-of-law provision, and dismissed the case.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the enforceability of the choice-of-law provision under Tennessee’s choice-of-law rules. The court held that the contractual choice-of-law clause was unenforceable because there was no material connection between Tennessee and the transactions or parties. As a result, the Sixth Circuit reversed the district court’s dismissal and remanded the case for further proceedings. The court did not reach the question of whether Tennessee law was contrary to the fundamental policies of New Jersey. View "Andujar v. Hub Group Trucking, Inc." on Justia Law