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

A Michigan State Trooper conducted a traffic stop after observing a vehicle with expired registration. The passenger, Adam Santos, was identified as a convicted felon, currently on probation, and flagged in police databases as possibly armed and dangerous. During the stop, the trooper noticed Santos acting nervously and avoiding searching a cross-body bag when asked for identification. After obtaining the driver’s consent to search the vehicle, the trooper removed both occupants from the car for safety. While frisking Santos, the trooper felt a weight in the bag consistent with a firearm. A struggle ensued when the trooper attempted to open the bag, and a gun was recovered. Santos was indicted for unlawful possession of a firearm by a felon.The United States District Court for the Western District of Michigan denied Santos’s motion to suppress the gun, finding that the officer’s actions were justified by concerns for safety and that the driver voluntarily consented to the vehicle search. The court also found the frisk of Santos and the subsequent search of the bag permissible, given the reasonable suspicion and probable cause developed during the stop.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s legal conclusions de novo and its factual findings for clear error. The appellate court held that the trooper did not violate Santos’s Fourth Amendment rights. The stop was lawfully initiated, and the questions and actions taken by the officer, including the removal of both occupants and the frisk of Santos, were justified by safety concerns based on specific, articulable facts. The court affirmed the district court’s denial of the suppression motion, holding that neither the duration nor the scope of the stop nor the search of Santos’s bag was unconstitutional. View "United States v. Santos" on Justia Law

The plaintiff claimed that Michigan had taken custody of between $200 and $600 in unclaimed property belonging to her. She alleged that, under Michigan’s Uniform Unclaimed Property Act, the state would return her property if she requested it but would not pay her any interest earned while the property was in the state’s custody, unless the property was originally interest bearing. Without first submitting a claim to reclaim her property, she brought a suit under 42 U.S.C. § 1983 against officials responsible for Michigan’s unclaimed property program, arguing that the state’s failure to pay interest amounted to an unconstitutional taking in violation of the Fifth Amendment. She sought declaratory and injunctive relief on behalf of herself and a putative class.The United States District Court for the Eastern District of Michigan dismissed her case, concluding that she lacked Article III standing because Michigan law did not grant her a property right to interest earned on her unclaimed property. The district court reasoned that, without such a property right, she could not demonstrate an injury from the state’s retention of interest.On appeal, the United States Court of Appeals for the Sixth Circuit found that the plaintiff had standing, as her complaint alleged a concrete financial injury: the state’s withholding of interest that she claimed was rightfully hers. The court held that the district court improperly conflated the merits of whether she was entitled to interest with the standing inquiry. The Sixth Circuit reversed the district court’s dismissal for lack of standing and remanded for further proceedings, emphasizing that the record was insufficient to resolve the merits of the takings claim at this stage. View "Hendershot v. Stanton" on Justia Law

TwinSpires, an Oregon-based electronic wagering platform, facilitates interstate betting on horseraces. Under the federal Interstate Horseracing Act (IHA), such betting is lawful if the operator obtains consent from both the state where the bet is accepted and the state where the race occurs, as well as the relevant racetrack. Michigan, however, enacted a law requiring additional state-specific licensing for platforms like TwinSpires to accept bets from Michigan residents. After TwinSpires partnered with Michigan’s only racetrack and obtained the requisite license, its license was suspended when the racetrack temporarily lost its own license. Even after the racetrack’s license was restored, Michigan maintained the suspension of TwinSpires’ license, prompting the company to sue, arguing that Michigan’s requirements conflicted with the IHA.The United States District Court for the Western District of Michigan granted a preliminary injunction, preventing Michigan from enforcing its licensing requirements against TwinSpires. The district court found that the IHA preempted Michigan’s additional licensing regime, concluding that TwinSpires was likely to succeed on the merits of its preemption claim and that other injunction factors favored TwinSpires.The United States Court of Appeals for the Sixth Circuit reviewed the preliminary injunction for abuse of discretion, applying de novo review to legal conclusions and clear error review to factual findings. The Sixth Circuit affirmed the district court’s order, holding that the IHA conflict-preempts Michigan’s licensing requirement for interstate wagering platforms. The court concluded that Michigan’s law imposed an additional regulatory hurdle beyond what the IHA requires, interfering with the federal scheme and frustrating Congress’s intended objectives. The court also found that the remaining factors for a preliminary injunction—irreparable harm, balance of equities, and public interest—favored TwinSpires. View "Churchill Downs Tech. Initiatives Co. v. Mich. Gaming Control Bd." on Justia Law

A woman from Guatemala entered the United States without inspection in 1994 and later applied for asylum, using the address of a man she believed to be an immigration attorney. She was served a Notice to Appear at that address for a removal hearing in 1997 but did not attend, resulting in her removal in absentia. Over a decade later, in 2010, she moved to reopen her removal proceedings, arguing she never received notice of the hearing. The immigration judge (IJ) requested more evidence, but she did not respond, and her motion was denied. She did not appeal that denial.In 2020, she filed a second motion to reopen, again claiming lack of notice. The IJ found this motion was barred because only one such motion is permitted and she did not qualify for any exception. She appealed to the Board of Immigration Appeals (Board), raising arguments about notice and extraordinary circumstances but did not specifically challenge the IJ’s finding that her motion was numerically barred or argue for equitable tolling of the limit. The Board dismissed her appeal, deeming those issues waived, and declined to reopen her case sua sponte, citing her long delay and lack of due diligence.The United States Court of Appeals for the Sixth Circuit reviewed her petition. The court held that, because she failed to exhaust her administrative remedies by not contesting the number-bar ruling before the Board, review of that issue was denied. The court further held that it lacked jurisdiction to review the Board’s discretionary refusal to reopen proceedings sua sponte. Finally, the court rejected her due process claim, finding the Board’s explanation sufficient. Accordingly, the petition was denied in part and dismissed in part. View "Herrera v. Bondi" on Justia Law

Milder Escobar-Temal, a Guatemalan national, unlawfully entered the United States in 2012, living and working in Nashville, Tennessee. In October 2022, Nashville police responding to a domestic incident found three firearms at his residence. He was charged with unlawful possession of a firearm under 18 U.S.C. § 922(g)(5)(A), which prohibits possession of firearms by individuals unlawfully present in the United States. Escobar-Temal had no prior criminal convictions except a dismissed charge for driving without a license.The United States District Court for the Middle District of Tennessee denied Escobar-Temal’s motion to dismiss the indictment, in which he argued that § 922(g)(5)(A) violated the Second Amendment both facially and as applied. The district court reasoned that, while the Second Amendment’s protections may extend to unlawfully present persons, historical tradition supported disarming those who had not sworn allegiance to the state. After denying the motion, Escobar-Temal pleaded guilty but reserved the right to appeal the constitutional issue.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s judgment. The Sixth Circuit held that the Second Amendment does protect individuals unlawfully present in the United States if they have developed sufficient connections to the national community. However, it further held that there is a longstanding historical tradition of disarming groups lacking a formal relationship with the government, such as unlawfully present noncitizens, due to regulatory difficulties rather than inherent dangerousness. Therefore, the court concluded that § 922(g)(5)(A) does not violate the Second Amendment, either on its face or as applied to Escobar-Temal, and affirmed his conviction and sentence. View "United States v. Escobar-Temal" on Justia Law

Troy Williams pleaded guilty to various federal offenses, including drug trafficking, firearm possession by a felon, and money laundering, and was sentenced to 198 months in prison, which was below the applicable sentencing guideline range. Williams has a history of serious medical conditions—thrombophilia and recurrent deep vein thrombosis—that require ongoing management, including regular blood testing and medication. Nearly ten years into his sentence, Williams sought compassionate release, asserting that inadequate medical care at his current facility placed him at risk of severe health complications or death.After Williams filed his pro se motion for compassionate release in the United States District Court for the Northern District of Ohio, counsel was appointed to supplement his arguments. Williams claimed the Bureau of Prisons was not providing sufficient medical care, particularly after his transfer to FCI Coleman, where he alleged infrequent blood testing and interruptions in medication. He also argued the sentencing factors under 18 U.S.C. § 3553(a) favored his release. The district court reviewed his medical records and expert testimony from the prison’s clinical director, ultimately finding that Williams’s care was not so deficient as to amount to extraordinary and compelling circumstances. The district court further concluded that, even if such circumstances were present, the sentencing factors did not support early release. Williams timely appealed.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial for abuse of discretion, considering legal questions de novo and factual findings for clear error. The Sixth Circuit held that the district court did not clearly err in finding that Williams’s medical care was adequate and that his situation did not present extraordinary and compelling circumstances under the relevant Sentencing Commission policy statement. Accordingly, the Sixth Circuit affirmed the denial of Williams’s motion for compassionate release. View "United States v. Williams" on Justia Law

Joseph Hehrer was detained in the Clinton County Jail in Michigan following charges related to operating a vehicle under the influence and a probation violation. While in custody, Hehrer began to exhibit symptoms of illness, including vomiting and abdominal pain. Over four days, jail medical staff evaluated him multiple times but failed to diagnose his underlying diabetes. Despite continued deterioration, corrections officers deferred to the medical professionals’ judgment and followed their instructions. Hehrer’s condition worsened until he was transported to a hospital, where he died from diabetic ketoacidosis.The United States District Court for the Western District of Michigan reviewed the estate’s claims, which included federal claims under 42 U.S.C. § 1983 against the county and its officers for deliberate indifference to medical needs, as well as a Monell claim for failure to train. The estate also brought state-law claims against the contracted medical provider and its staff. A magistrate judge recommended granting summary judgment to the county and its officials on the federal claims, finding no deliberate indifference or Monell liability, and advised declining supplemental jurisdiction over the state-law claims. The district court adopted these recommendations and entered final judgment for the defendants.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s decision. The Sixth Circuit held that the corrections officers acted reasonably by deferring to medical staff and did not act with deliberate indifference under the applicable Fourteenth Amendment standard. The court further held that the estate failed to show a pattern or obvious need for additional training to support Monell liability. Finally, the Sixth Circuit found no abuse of discretion in declining supplemental jurisdiction over the state-law claims after dismissing the federal claims. View "Hehrer v. County of Clinton" on Justia Law

Donald Sims was serving a term of supervised release after a prior federal conviction for being a felon in possession of a firearm, following an earlier similar conviction. After his release from prison in 2021, Sims initially showed signs of improvement, including negative drug tests and stable employment. However, he later admitted to drug use and, in 2024, was found by police to be in possession of cocaine and drug paraphernalia during a traffic stop. Sims pleaded guilty in state court to felony cocaine possession and received a nine-month sentence. His probation officer then cited him for violating his supervised release by unauthorized drug use, cocaine possession, and failure to report police contact.The United States District Court for the Northern District of Ohio conducted a revocation hearing. Sims admitted violating his supervised release but denied ownership of the cocaine. The district court found his denial not credible, citing his guilty plea and the circumstances of the stop. Although the advisory Sentencing Guidelines range was seven to thirteen months, the court imposed an 18-month sentence to run consecutive to his state sentence, citing Sims’s pattern of violations and the need for deterrence. Defense counsel objected to the upward variance.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed whether the sentence was procedurally and substantively reasonable. The Sixth Circuit held that the district court did not commit procedural error by considering Sims’s state sentence or by finding that his conduct amounted to trafficking based on the evidence. The court also found that the district court adequately explained its reasons for an above-Guidelines sentence and properly weighed the relevant sentencing factors. The Sixth Circuit affirmed the district court’s judgment, holding that the 18-month consecutive sentence was both procedurally and substantively reasonable. View "United States v. Sims" on Justia Law

A native and citizen of Honduras fled to the United States in 2016 after members of the MS gang targeted him and his brother, allegedly due to their refusal to join the gang. After suffering threats, extortion, and a kidnapping in Honduras, he relocated within the country but continued to receive threats. Fearing for his safety, he eventually left for the United States, where his family later joined him. He expressed fear that returning to Honduras would result in serious harm or death at the hands of the gang.Removal proceedings were initiated against him by the Department of Homeland Security, and an Immigration Judge (IJ) found him removable. He applied for asylum, withholding of removal, and protection under the Convention Against Torture (CAT), but his asylum application was filed about fourteen months late. At his merits hearing, the IJ found his testimony credible but determined that he had not demonstrated exceptional circumstances justifying the late filing. The IJ denied his asylum application as untimely and also denied his applications for withholding of removal and CAT protection, finding that the harm he suffered was not severe enough to constitute persecution and that he failed to show a nexus between the harm and the proposed social groups. The IJ further noted he did not demonstrate the Honduran government was unable or unwilling to protect him.The Board of Immigration Appeals (BIA) affirmed the IJ’s decision, determining that he had not established extraordinary circumstances for the asylum application’s untimeliness, and that he had waived his CAT claim and the issue of government protection by failing to meaningfully challenge these findings before the Board.On review, the United States Court of Appeals for the Sixth Circuit held that it lacked jurisdiction to review the BIA’s discretionary determination regarding extraordinary circumstances under 8 U.S.C. § 1158(a)(2)(D) and found that the petitioner had forfeited the necessary government protection element for withholding of removal. The court denied the petition in part and dismissed in part. View "Osabas-Rivera v. Bondi" on Justia Law

Federal agents, while investigating a drug conspiracy in 2019, intercepted two parcels containing nearly five kilograms of methamphetamine addressed to the defendant’s residence. An undercover agent delivered these parcels, which the defendant accepted. Postal records indicated she had received seven similar parcels over several months. The defendant was arrested and indicted along with others involved in the conspiracy. Her admitted role was accepting the drug parcels and turning them over to co-conspirators.The defendant pled guilty to conspiracy to distribute controlled substances. At her sentencing in the United States District Court for the Middle District of Tennessee, the judge considered her difficult background, resilience, and family responsibilities, ultimately imposing a sentence of 12 months, well below the guideline range of 57 to 71 months. The court granted her a delayed prison report date, but she failed to report as ordered. After her failure to surrender, she was charged with criminal contempt under 18 U.S.C. § 401(3), pled guilty, and was sentenced to 11 months for contempt, to run consecutively to her prior sentence.The United States Court of Appeals for the Sixth Circuit reviewed the procedural and substantive reasonableness of the contempt sentence. The court held that to determine whether contempt is a felony for sentencing purposes, the conduct underlying the contempt must be compared to analogous federal offenses. Here, the defendant’s conduct—failing to surrender for service of sentence—was identical to the felony described in 18 U.S.C. § 3146, and thus, the district court properly applied the felony guideline §2J1.6. The appellate court also found the district court’s analysis of the sentencing factors thorough and appropriate. The judgment of the district court was affirmed. View "United States v. Owens" on Justia Law