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

Art Iron, Inc. faced a lawsuit from the Board of Trustees of the Shopmen’s Local 499 Pension Plan seeking over one million dollars in withdrawal liability under ERISA. The key issue was whether Robert Schlatter, Art Iron’s sole shareholder, and his wife, Mary Schlatter, were personally liable for this withdrawal liability due to their operation of businesses allegedly under common control with Art Iron.The United States District Court for the Northern District of Ohio granted summary judgment in favor of the Board, finding both Robert and Mary Schlatter personally liable. The court determined that Robert’s consulting business and Mary’s jewelry-making activities were trades or businesses under common control with Art Iron, thus making them jointly and severally liable for the withdrawal liability.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court’s judgment regarding Robert Schlatter, agreeing that his consulting business was a trade or business under common control with Art Iron. The court applied the Groetzinger test, which considers whether the activity is continuous and regular and primarily for income or profit, and found that Robert’s consulting business met these criteria.However, the court reversed the district court’s judgment regarding Mary Schlatter. It found that her jewelry-making activities did not constitute a trade or business under the Groetzinger test, as her activities lacked the necessary continuity and regularity in 2017, the year of Art Iron’s withdrawal from the Plan. Consequently, Mary Schlatter was not personally liable for the withdrawal liability.The Sixth Circuit thus affirmed the district court’s judgment as to Robert Schlatter and reversed and remanded the judgment as to Mary Schlatter. View "Shopmen’s Local No 499, Bd of Trustees v. Art Iron, Inc." on Justia Law

The case involves Robert Holman, who challenged a debt-relief program under the American Rescue Plan Act that provided benefits to "socially disadvantaged" farmers and ranchers based on racial categories. Holman, a farmer, argued that he was excluded from the program solely due to his race and sought a preliminary injunction to halt the program. The district court granted the preliminary injunction, finding that the program did not meet the strict scrutiny standard required for racial classifications under the Fifth Amendment. However, before a final judgment was reached, Congress repealed the program, leading Holman to seek attorney's fees under the Equal Access to Justice Act (EAJA).The United States District Court for the Western District of Tennessee denied Holman's request for fees, ruling that he was not a "prevailing party" under the EAJA because the preliminary injunction did not provide him with lasting relief. The court also noted that the injunction was temporary and revocable, and thus did not materially alter the legal relationship between the parties.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The appellate court did not definitively rule on whether Holman was a "prevailing party" but found that the Government's position during the litigation was "substantially justified" under the EAJA. The court noted that the Government had presented substantial evidence to defend the program's constitutionality, including historical discrimination against minority farmers by the USDA. The court concluded that a reasonable person could find the Government's position justified, thereby precluding Holman's entitlement to attorney's fees and expenses. View "Holman v. Vilsack" on Justia Law

A police officer with over thirty-three years of experience, including seventeen years with the Blue Ash Police Department, was terminated at age sixty-one. The officer alleged that his performance record was nearly perfect until a new police chief took over, after which he faced increased scrutiny and discipline. The officer was assigned a traffic study, typically not given to patrol officers, and disciplined multiple times for minor infractions, including failing to turn on his microphone during traffic stops and not responding promptly to a noise complaint. The final incident leading to his termination involved a delayed response to a medical emergency, which led to an investigation uncovering multiple policy violations, including untruthfulness.The United States District Court for the Southern District of Ohio granted summary judgment to the defendants on all claims. The court concluded that the officer failed to provide sufficient evidence that his termination was due to age discrimination. The court also found that the officer abandoned his other claims by not addressing them in his brief opposing summary judgment.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's decision regarding the age discrimination claim, holding that the officer could not show that age was the "but-for" reason for his termination. However, the court reversed the district court's decision on the hostile work environment claim. The appellate court found that the officer presented enough evidence to create a genuine dispute of material fact regarding whether he was subjected to a hostile work environment based on age. The court noted that the officer's allegations of increased scrutiny, disproportionate discipline, and demeaning assignments could support a hostile work environment claim. The case was remanded for further proceedings on this claim against the City of Blue Ash. View "McNeal v. City of Blue Ash" on Justia Law

Two sisters from Guatemala fled to the United States in 2015 after gang members threatened to maim and kill them. They entered the U.S. without inspection and were placed in removal proceedings by the Department of Homeland Security (DHS). The sisters applied for asylum and withholding of removal, claiming they were targeted due to their membership in two particular social groups (PSGs): "Guatemalan female children without parental protection" and "the Rodas family."An immigration judge (IJ) denied their applications, finding that the harm they suffered did not rise to the level of persecution, that their proposed PSGs were not cognizable, and that there was no nexus between the harm and their family membership. The Board of Immigration Appeals (BIA) affirmed the IJ's decision, assuming without deciding that the harm constituted persecution but agreeing that the gang members were motivated by financial gain rather than animus toward the family.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found that the Petitioners' arguments regarding due process and the "Guatemalan female children without parental protection" PSG were unreviewable because they were not raised before the BIA. However, the court held that the BIA's no-nexus determination regarding the "Rodas family" PSG was inconsistent with precedents. The court emphasized that persecutors can have mixed motives, and the BIA failed to consider whether the gang members' financial motives were intertwined with the Petitioners' family membership.The Sixth Circuit granted the petition for review in part, dismissed it in part, vacated the BIA's denial of asylum and withholding of removal, and remanded the case for further proceedings consistent with its opinion. The court instructed the BIA to reconsider the nexus between the harm and the Petitioners' family membership and to address whether the Guatemalan government was unable or unwilling to control the persecutors. View "Mazariegos-Rodas v. Garland" on Justia Law

In this case, three plaintiffs—Christian Healthcare Centers, Sacred Heart of Jesus Parish, and St. Joseph Parish St. Johns—challenged aspects of Michigan’s antidiscrimination laws, alleging that these laws violated their First and Fourteenth Amendment rights. The plaintiffs argued that the laws chilled their speech and conduct, particularly regarding their religious beliefs and practices related to gender identity and sexual orientation.The United States District Court for the Western District of Michigan dismissed each case for lack of standing. The court reasoned that none of the plaintiffs had shown that Michigan’s laws arguably proscribed their speech or conduct, nor had they demonstrated a credible threat of enforcement against them. Consequently, the district court granted the defendants' motions to dismiss.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decisions. The appellate court agreed in part, finding that Michigan’s laws arguably forbade several of the plaintiffs’ pleaded activities. The court concluded that Christian Healthcare and Sacred Heart had plausibly established a credible threat of enforcement against them for some of the challenged provisions of Michigan’s laws. However, the court found that St. Joseph Parish had not plausibly established standing, as it failed to show a credible threat of enforcement.The Sixth Circuit affirmed the district court’s dismissal of the claims related to the Equal Accommodations Act (EAA) but reversed the dismissal of the claims related to the Elliot-Larsen Civil Rights Act (ELCRA) for Christian Healthcare and Sacred Heart. The court remanded the cases to the district court to evaluate the plaintiffs’ requests for injunctive relief. The district court’s decisions were thus affirmed in part, reversed in part, and remanded for further proceedings. View "Christian Healthcare Centers v. Nessel" on Justia Law

Kimberly Diei, a pharmacy student at the University of Tennessee Health Science Center, maintained social media accounts under a pseudonym where she posted about song lyrics, fashion, and sexuality. Her posts did not identify her as a student or affiliate her with the university. Despite this, the College of Pharmacy's Professional Conduct Committee investigated her social media activity following anonymous complaints. The Committee found her posts "sexual," "crude," and "vulgar," and ultimately voted to expel her. Diei appealed, and the Dean reversed the expulsion decision.Diei then filed a lawsuit in the United States District Court for the Western District of Tennessee, asserting violations of her First Amendment rights under 42 U.S.C. § 1983. She sought declaratory and injunctive relief, as well as damages for emotional distress. The district court dismissed her complaint, ruling that her claims for injunctive and declaratory relief were moot due to her graduation and that her remaining claims failed to state a claim for relief. The court also held that the defendants were entitled to qualified immunity.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court determined that Diei's claims for injunctive and declaratory relief were moot but found that her claims for damages were still viable. The court held that Diei plausibly alleged a First Amendment violation, as her social media posts were unrelated to her studies, caused no disruption, and were made under a pseudonym. The court also found that the district court improperly relied on documents not properly before it when dismissing Diei's complaint. The Sixth Circuit reversed the district court's dismissal of Diei's claims for damages and remanded the case for further proceedings, holding that Diei's speech was protected by the First Amendment and that the defendants were not entitled to qualified immunity at this stage. View "Diei v. Boyd" on Justia Law

Quickway Transportation, Inc. (Quickway) petitioned the United States Court of Appeals for the Sixth Circuit to review a National Labor Relations Board (NLRB) order in an unfair labor practice proceeding. The NLRB cross-petitioned for enforcement of its order. The case involved Quickway's cessation of operations at its Louisville terminal, which the NLRB found violated the National Labor Relations Act (NLRA). Quickway argued that the NLRB's findings were not supported by substantial evidence and that the Board's remedial order was overly burdensome.The Administrative Law Judge (ALJ) initially found that Quickway violated the NLRA by ceasing operations at the Louisville terminal due to anti-union animus, failing to bargain over the cessation and its effects, and engaging in coercive and retaliatory actions against employees. The NLRB affirmed the ALJ's findings and ordered Quickway to reopen the Louisville terminal, reinstate employees, and compensate them for lost earnings and benefits.The Sixth Circuit reviewed the NLRB's decision under a substantial evidence standard and found that the Board's conclusions were supported by substantial evidence. The court noted that Quickway's decision to close the Louisville terminal was motivated by anti-union animus and aimed at chilling unionization efforts at other terminals. The court also upheld the Board's finding that Quickway failed to bargain in good faith over the decision and its effects.The court affirmed the NLRB's remedial order, including the requirement for Quickway to reopen the Louisville terminal and reinstate employees. The court found that the Board did not abuse its discretion in ordering these remedies and that Quickway failed to demonstrate that the restoration order would be unduly burdensome. The court denied Quickway's petition for review and granted the NLRB's cross-application for enforcement of its order in full. View "Quickway Transp., Inc. v. NLRB" on Justia Law

A psychiatrist employed at a public university's medical school participated in a panel discussion on childhood gender dysphoria, expressing views that were unpopular with his colleagues and supervisors. Following his remarks, he was demoted and his contract was not renewed after over fifteen years of employment. He sued several university officials, alleging First Amendment retaliation.The United States District Court for the Western District of Kentucky denied the defendants' motions for summary judgment, which argued for Eleventh Amendment immunity and qualified immunity. The court found material fact disputes regarding whether the defendants retaliated against the plaintiff for his protected speech.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the plaintiff's speech was protected under the First Amendment as it addressed a matter of public concern and was not made pursuant to his official duties. The court also found that the plaintiff's interest in speaking on the topic outweighed the university's interest in maintaining workplace efficiency. The court determined that the adverse actions taken against the plaintiff, including his demotion and contract nonrenewal, were motivated by his protected speech.The Sixth Circuit affirmed the district court's denial of summary judgment, concluding that the defendants were not entitled to Eleventh Amendment immunity or qualified immunity. The court held that the plaintiff's rights were clearly established and that a reasonable university official would have understood that retaliating against him for his speech was unlawful. The court also denied the plaintiff's motion to dismiss the appeal for lack of jurisdiction as moot. View "Josephson v. Ganzel" on Justia Law

The petitioner, Nayanaben Patel, entered the United States in March 2000 under unclear circumstances. She applied for adjustment of status based on her husband's legal status but lied about her manner of entry. She later admitted to lying but provided conflicting testimonies. The Immigration Judge (IJ) denied her application for adjustment of status and ordered her removal to India, citing factual inconsistencies. The Board of Immigration Appeals (BIA) affirmed the IJ's decision.The IJ's decision was discretionary and protected by statute from judicial review. The petitioner did not raise any colorable constitutional claims that would allow for judicial review. The United States Court of Appeals for the Sixth Circuit reviewed the case and found that the IJ's decision was supported by substantial evidence, including the petitioner's multiple contradictory statements and lack of credible evidence regarding her manner of entry.The Sixth Circuit held that it lacked jurisdiction to review the IJ's discretionary decision under 8 U.S.C. § 1252(a)(2)(B), which bars judicial review of any judgment regarding the granting of relief under sections 1182(i) and 1255. The court also found that the petitioner did not exhaust her administrative remedies regarding her claims of ineffective assistance of counsel and judicial bias, and that her judicial bias claim was not a constitutional issue but rather a factual dispute.The court denied the petition for review, emphasizing that the IJ's decision was within his discretion and supported by the evidence. The court also noted a significant error in the IJ's understanding of the difference between a visa and an I-94 form but concluded that this error did not affect the overall decision. View "Patel v. Garland" on Justia Law

The United States Chamber of Commerce, Business Roundtable, and the Tennessee Chamber of Commerce and Industry sued the Securities and Exchange Commission (SEC) and its Chairman, alleging that the SEC’s partial rescission of a prior regulation did not comply with the Administrative Procedure Act (APA). The regulation in question involved proxy voting advice businesses (PVABs) and their role in the proxy voting process for public companies. The plaintiffs argued that the SEC’s actions were procedurally and substantively deficient under the APA.The United States District Court for the Middle District of Tennessee granted summary judgment in favor of the SEC. The court found that the SEC’s decision to rescind certain conditions of the 2020 Rule was not arbitrary and capricious. The court also held that the SEC had provided a reasonable explanation for its change in policy and had adequately considered the economic consequences of the rescission as required by the Exchange Act. Additionally, the court determined that the 31-day comment period provided by the SEC was legally permissible under the APA.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo and affirmed the district court’s decision. The Sixth Circuit held that the SEC’s 2022 Rescission was not arbitrary and capricious because the SEC had acknowledged its change in position, provided good reasons for the change, and explained why it believed the new rule struck a better policy balance. The court also found that the SEC had adequately assessed the economic implications of the rescission, relying on data from the 2020 Rule and providing a qualitative analysis of the costs and benefits. Finally, the court concluded that the 31-day comment period was sufficient to provide a meaningful opportunity for public comment, as required by the APA. View "Chamber of Commerce v. Securities and Exchange Commission" on Justia Law