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

Two Ohio homeowners discovered that their personal information, including their names, addresses, and property details, appeared in paid reports on a real estate research website operated by a company. The website allows users to search for property information by address or owner name and provides one free report per user, with additional reports available for purchase. The homeowners, without having consented to the use of their information, filed a class action lawsuit on behalf of similarly situated individuals, alleging that the company violated their rights of publicity under both Ohio statute and common law by using their identities for commercial gain.The United States District Court for the Northern District of Ohio reviewed the case after the company moved to dismiss for failure to state a claim. The district court granted the motion and dismissed the complaint with prejudice, finding that the plaintiffs had not adequately alleged that their identities possessed independent commercial value—a necessary element of a right of publicity claim under Ohio law.On appeal, the United States Court of Appeals for the Sixth Circuit conducted a de novo review. It affirmed the district court's dismissal, holding that the plaintiffs failed to plead facts showing that their names or identities had any commercial value, as required by both Ohio’s statutory and common law right of publicity. The court reasoned that simply being used in a commercial context does not satisfy the commercial value requirement, relying on both prior circuit precedent and Ohio state court decisions. The court also declined to certify a question of law to the Ohio Supreme Court, concluding that Ohio law on this issue was sufficiently settled. The judgment of the district court was affirmed. View "LaFleur v. Yardi Systems, Inc." on Justia Law

The plaintiff was employed as a legal assistant and later a paralegal in a law firm’s Liquor Group, initially at one firm and then at another firm, Adams and Reese, LLP, after her group switched employers. She alleged that a supervisor, who moved with the group, persistently directed sexualized comments and jokes at her in the workplace, which included derogatory remarks, inappropriate suggestions, and comments about her appearance and personal life. She also claimed that after her employer changed her work schedule, she experienced difficulties related to her disabilities and was subsequently terminated when she was unable to comply with the new attendance requirements. She brought claims of sexual harassment and violations of the Americans with Disabilities Act (ADA).The United States District Court for the Middle District of Tennessee reviewed the employer’s motions to dismiss the sexual harassment claim and to compel arbitration of the ADA claims, based on an arbitration agreement between the parties. The district court denied both motions, holding that the plaintiff sufficiently stated a plausible sexual harassment claim under applicable standards and that the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 (EFAA) barred enforcement of the arbitration agreement as to her entire case, not just the sexual harassment claim.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s decision. The court held that the plaintiff’s complaint plausibly alleged pervasive sexual harassment sufficient to survive a motion to dismiss. It further determined that the EFAA renders predispute arbitration agreements unenforceable with respect to an entire “case” relating to a sexual harassment dispute, not just the specific sexual harassment claim. Therefore, the arbitration agreement could not be enforced as to any of the plaintiff’s claims in this action. The disposition was to affirm and remand for further proceedings. View "Bruce v. Adams & Reese, LLP" on Justia Law

In this case, a police officer obtained a search warrant for a Detroit home based on information from a confidential informant and the officer’s own surveillance, which allegedly observed suspected drug transactions. The search led to the discovery of a large quantity of cocaine and firearms in a laundry hamper at the residence, along with personal mail addressed to the plaintiff, Darell Chancellor. Chancellor was later arrested and prosecuted for narcotics offenses, resulting in a conviction and a prison sentence of over fourteen years. Several years later, after a review by a Conviction Integrity Unit found the officer’s reported claims uncorroborated or refuted, Chancellor’s conviction was vacated by a state court order, and he was released from prison.Chancellor subsequently filed a federal lawsuit against the officer and the City, alleging violations of his federal and state rights, including claims of false arrest, false imprisonment, malicious prosecution, and a due process claim under Brady v. Maryland for failing to disclose exculpatory evidence. The United States District Court for the Eastern District of Michigan granted summary judgment in favor of the officer, finding qualified immunity applied to the federal claims, no material issue of fact supported the Brady claim, and governmental immunity barred the state law claims.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s decision. The court held that Chancellor had not presented sufficient evidence to show that the officer deliberately or recklessly lied in the search warrant affidavit, as required to overcome qualified immunity. The court also ruled that Chancellor’s due process claim failed because he did not show that the officer suppressed exculpatory evidence. Finally, the court found Chancellor’s state law claims were either inadequately argued or otherwise failed under Michigan law. The disposition by the Sixth Circuit was to affirm the district court’s grant of summary judgment. View "Chancellor v. Geelhood" on Justia Law

A commercial trucking business owner, who is white, learned about a $25,000 grant program administered by two insurance companies in partnership with another company. The program offered grants to ten small businesses to help them purchase commercial vehicles but was limited to black-owned businesses. After receiving an email invitation to apply, the business owner began the online application but stopped and did not submit it upon realizing that only black-owned businesses were eligible. He later alleged that he would have otherwise applied and met all requirements except for the race-based criterion.Following the application deadline, the business owner and his company filed a putative class action in the United States District Court for the Northern District of Ohio, claiming that the grant program’s racial eligibility requirement violated 42 U.S.C. § 1981 by denying them the opportunity to enter into two contracts: one at the application stage and one at the grant award stage. The complaint sought damages and injunctive relief. The district court dismissed the case for lack of subject-matter jurisdiction, concluding that the plaintiffs lacked standing because they had not suffered a cognizable injury caused by the defendants’ conduct.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 the plaintiffs failed the causation requirement for standing because the business owner chose not to submit the application, resulting in any alleged injury being self-inflicted rather than fairly traceable to the defendants’ actions. The court clarified that the judgment was without prejudice and affirmed the district court’s dismissal for lack of subject-matter jurisdiction. View "Roberts v. Progressive Preferred Insurance Co." on Justia Law

Three individuals were prosecuted for their roles in a murder-for-hire scheme that resulted in the deaths of Holly Williams and William Lanway in Nashville. After one of the defendants, Maund, was blackmailed by Lanway following an affair with Williams, he hired Peled to address the situation. Peled then recruited Brockway, Carey, and others to surveil the victims, ultimately leading to their murders in March 2020. Substantial evidence was presented at trial, including recorded conversations, testimony from co-conspirators, financial records, and surveillance footage linking the defendants to the crimes.The United States District Court for the Middle District of Tennessee presided over the joint trial. The jury convicted all three defendants on various counts, including murder-for-hire conspiracy, and convicted Brockway and Carey on kidnapping-related charges. After the verdict, the district court discovered a critical error: the jury had received ten unadmitted exhibits—including recordings and transcripts not presented at trial—and had not received three admitted exhibits. Notably, among the unadmitted exhibits were statements concerning Carey’s knowledge of the crimes that had been excluded at trial. Following a post-verdict hearing, the district court concluded that this error was structural and required a new trial for all defendants, reasoning that the effects of the error were too difficult to measure.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s grant of a new trial. The appellate court held that the erroneous jury exposure to unadmitted exhibits was not a structural error and was subject to harmless-error analysis. Applying the strictest harmless-error standard, the court found the error harmless beyond a reasonable doubt given the overwhelming evidence of guilt and the minimal prejudice to the defendants. The Sixth Circuit reversed the district court’s order granting a new trial and remanded for further proceedings. View "United States v. Maund" on Justia Law

A tornado struck Tennessee, damaging two properties owned by a church that held property insurance with an insurer. The church filed a claim, and the insurer made a payment, but the church alleged that the insurer improperly calculated the amount by subtracting depreciation for non-material costs (such as labor) from the "actual cash value" (ACV) payment, leading to a lower payout. The insurance policy did not specify whether labor should be depreciated. The church then brought a putative class action, asserting similar claims under the laws of ten states, seeking class certification for policyholders who received reduced ACV payments because of the insurer’s practice.The United States District Court for the Middle District of Tennessee addressed several motions. It rejected the insurer’s argument that the church lacked Article III standing to assert claims under other states' laws, and denied the insurer’s motion for judgment on the pleadings as to Texas law. When considering class certification, the district court found the plaintiff satisfied Rule 23(a)’s requirements but limited class certification to four states (Arizona, California, Illinois, and Tennessee), citing unsettled law in the remaining six states. The court reasoned that the uncertain nature of laws in Kentucky, Ohio, Missouri, Mississippi, Texas, and Vermont would make a ten-state class action unwieldy, and thus declined to certify a class for those states.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s decisions. It held that the plaintiff had Article III standing to represent the class because the alleged injuries were substantially similar across the proposed class members. The appellate court found that the district court abused its discretion by not conducting an Erie analysis for five of the six excluded states and vacated the class-certification order in part, remanding for further proceedings. However, it affirmed the denial of class certification for Vermont due to insufficient authority on Vermont law. View "Generation Changers Church v. Church Mutual Ins. Co." on Justia Law

The case concerns a life insurance policy that was issued by an insurer to Ewanda Ferguson. After the policy had lapsed for nonpayment, Ewanda applied for reinstatement by submitting an application in which she falsely denied having her driver’s license suspended or being convicted of DUI/DWI in the prior ten years. In reality, Ewanda had two operating-while-impaired convictions and a license revocation within that period. She died in an automobile accident a few months later. The insurer reinstated the policy posthumously and the beneficiary, Elizabeth Ferguson, submitted a claim for the death benefit.Following Ewanda’s death and the submission of the claim, the insurer discovered the misrepresentations in the reinstatement application. Because Ewanda died within the two-year contestability period, the insurer reviewed her application, determined that it would not have reinstated the policy had it known of her true driving history, and rescinded the policy. The insurer then refused to pay the death benefit. Elizabeth Ferguson filed suit in Michigan state court, alleging breach of contract. The insurer removed the case to the United States District Court for the Eastern District of Michigan and counterclaimed to confirm the propriety of rescission. The district court granted summary judgment to the insurer, holding that rescission was proper without balancing the equities, because Ferguson was not an “innocent third party” under Michigan law.On appeal, the United States Court of Appeals for the Sixth Circuit held that, under Michigan law, a life insurance beneficiary who is a third-party beneficiary stands in the shoes of the insured and has no greater rights than the insured would have had. Therefore, the insurer was entitled to rescind the policy based on material misrepresentations made by Ewanda, and the district court was not required to balance the equities before ordering rescission. The Sixth Circuit affirmed the district court’s judgment. View "Ferguson v. MetLife Investors USA Insurance Co." on Justia Law

Federal and state authorities initially suspected Luz Jiminez of involvement in a drug-trafficking organization based in Phoenix, Arizona. Investigators obtained a wiretap order to intercept communications from Jiminez and her associates. Through intercepted calls, they learned Jiminez planned to pick up luggage for someone named “Rondo,” later identified as Liggins. Using a “check and miss” scheme, Liggins sent a bag containing nearly $37,000 from Detroit to Phoenix, which Jiminez retrieved but abandoned after noticing surveillance. A police dog alerted to drugs, and a warrant led to the discovery of the money. Separately, Detroit authorities arrested DeHaven Murphy, who possessed heroin and later implicated Liggins. Murphy arranged recorded calls with Liggins, but Detroit officers testified their investigation was independent of the Arizona wiretap.The United States District Court for the Eastern District of Michigan presided over Liggins’s trial, where a jury convicted him on drug charges. The United States Court of Appeals for the Sixth Circuit vacated the conviction due to judicial bias and remanded for a new trial. On remand, Liggins moved to suppress evidence derived from the Arizona wiretap, arguing violations of federal wiretap laws. The district court denied the motion, finding Liggins lacked standing as an “aggrieved person” under Title III and that the Detroit evidence was untainted by the Arizona wiretap. Liggins entered a conditional guilty plea to preserve his right to appeal.The United States Court of Appeals for the Sixth Circuit reviewed whether Liggins qualified as an “aggrieved person” entitled to move for suppression under Title III. The court held that regardless of the interpretation, Liggins was not an “aggrieved person”: he did not participate in intercepted calls, the calls did not use his property, and he was not named or targeted in the wiretap application. The court affirmed the district court’s denial of the motion to suppress. View "United States v. Liggins" on Justia Law

The defendant, while on supervised release following a federal conviction for being a felon in possession of a firearm, was arrested in May 2023 for new state charges involving drug trafficking, possession of marijuana and drug paraphernalia, and being a felon in possession of a handgun. These events occurred after violations that led to his second supervised release revocation but before the hearing for those violations, and were not discovered by the federal probation office until several months later. Upon learning of the May 2023 incident, after the defendant had completed his sentence and was again on supervised release, the probation office initiated the proceedings at issue, seeking a third revocation based on the new conduct.The United States District Court for the Eastern District of Kentucky held a hearing to determine if the defendant could knowingly and voluntarily waive his right to counsel in the revocation proceeding, ultimately allowing him to represent himself. After a subsequent hearing, the district court found violations of supervised release, classified the new conduct as a Grade A violation, and imposed a 24-month term of imprisonment, the statutory maximum. The defendant timely appealed, challenging the validity of his waiver of counsel, the sentencing procedure, and the constitutionality of his underlying conviction.The United States Court of Appeals for the Sixth Circuit reviewed the case. It held that the right to counsel in a supervised release revocation is not derived from the Sixth Amendment but is governed by statutory and due process considerations. The court reviewed the waiver of counsel for abuse of discretion and found the district court’s inquiry sufficient under the totality of the circumstances. The court also found no procedural error in sentencing, concluding that the district court did not improperly rely on prohibited factors. Finally, the court declined to consider the challenge to the underlying conviction, holding that such arguments must be raised on direct appeal or collateral review. The Sixth Circuit affirmed the district court’s judgment. View "United States v. Spence" on Justia Law

Two police officers responded to a report of an armed suspect in a Cleveland boarding house. While searching the darkened building, the officers encountered the suspect, leading to a confrontation and retreat down the stairs. One officer, Gannon, fired his weapon twice; the first, intentional shot struck his fellow officer, Kilnapp, causing significant injury. The officers did not identify themselves as police during the incident, and the body camera footage did not clearly depict critical moments. Both sides disputed details such as whether the suspect fired first, but agreed that Gannon’s first shot, meant to stop the suspect, hit Kilnapp as she followed behind him.Kilnapp sued Gannon, the City of Cleveland, and its Chief of Police, alleging excessive force under both the Fourth and Fourteenth Amendments. Gannon sought qualified immunity and dismissal, arguing his actions did not violate clearly established rights. The United States District Court for the Northern District of Ohio denied his motion to dismiss and later his motion for summary judgment on qualified immunity grounds. The Sixth Circuit previously affirmed the denial of the motion to dismiss, but Gannon continued to challenge the denial of summary judgment.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial of summary judgment de novo. The court held that when an officer intentionally fires a weapon in circumstances objectively manifesting an intent to restrain, any person struck is seized under the Fourth Amendment, regardless of whether they were the officer’s specific intended target. However, because the Supreme Court’s decision in Torres v. Madrid (2021) clarified this principle after Kilnapp’s shooting, the law was not clearly established at the time. The Sixth Circuit vacated the district court’s decision and remanded with instructions to grant Gannon qualified immunity on the Fourth Amendment claim and for further proceedings on the Fourteenth Amendment claim. View "Kilnapp v. City of Cleveland" on Justia Law