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

After gallbladder surgery, Tranbarger began suffering from multiple medical conditions, including physical pain and chronic fatigue. At work, Tranbarger continued as an accounts receivable manager, a primarily sedentary position. Her supervisor modified some of her responsibilities to accommodate her reduced capacity. Tranbarger resigned in July 2016, citing pain and fatigue.Through her employer, Tranbarger was enrolled in Lincoln's disability insurance plan. About 14 months after resigning, Tranbarger filed a claim for long-term disability benefits. Tranbarger was entitled to benefits if she could show “total disability” such that she was “unable to perform each of the [m]ain [d]uties” of an accounts receivable manager during a six-month “Elimination Period” following her resignation. Tranbarger presented a Social Security ruling in her favor, doctors’ notes, and statements from individuals otherwise familiar with her condition. Lincoln denied Tranbarger’s claim. She sued under the Employee Retirement Income Security Act (ERISA).The Sixth Circuit affirmed a judgment in favor of Lincoln. Tranbarger did not demonstrate a continuous inability to perform the main duties of an accounts receivable manager during the six months following her resignation. Although she provided diagnoses from the Mayo Clinic and established that she suffered pain and fatigue, there was little evidence about whether Tranbarger could perform her job functions. View "Tranbarger v. Lincoln Life & Annuity Co. of New York" on Justia Law

Michigan State Police Officer Lay, stationed about 35 miles from the Indiana state line, noticed a vehicle driving northbound following closely behind another vehicle—a state law infraction. Lay began following the vehicle and ran its plate through a database, which noted that the car had been in Texas, one day before. Lay pulled the vehicle over and approached. Unprompted, the passenger handed over his driver’s license without making eye contact. The driver produced his driver’s license and a car rental agreement. Returning to her cruiser, Lay ran the information through databases and radioed for assistance. The driver’s name came up clean; the passenger was on probation for a prior crime. Meanwhile, Officer Bierema arrived with his drug-detection K-9. Approximately seven minutes into the stop, Lay exited her cruiser to speak with the passenger about his probation status; he was less than forthcoming. Lay requested consent to search the car, which the driver withheld. She then ordered him to stand back while Bierema’s K-9 conducted a sniff of the vehicle’s exterior. The K-9 alerted to the presence of drugs, prompting the officers to search the car. In the back seat, they found two gym bags containing cocaine and methamphetamine.The Sixth Circuit affirmed the denial of the defendants’ motions to suppress, rejecting arguments that the traffic stop was unconstitutionally overlong and that the driver’s arrest was unsupported by probable cause. View "United States v. Williams" on Justia Law

The Tennessee Department of Transportation (TDOT) contracted with Jones to repair State Route 141. The project involved 68,615 tons of “graded solid rock” for the new road's bottom layer. To obtain graded solid rock, Jones leased land near the roadway, paying the property owner $75,282. Jones prepared the Site and began pattern blasting the limestone to produce appropriately sized rock pieces, using a “shaker” bucket to allow debris to fall away. Appropriately-sized rocks were hauled to the road site. The Site also served as a waste pit for material from the road repair. After several months, a Federal Mine Safety & Health Administration Inspector inspected the Site, determined that Jones had violated several Administration standards, and issued citations and orders.An ALJ ruled that the Site was a mine subject to the Mine Act, not a “borrow pit,” which is not subject to the Administration’s jurisdiction. On remand, the case was assigned to another ALJ, who indicated that she had read the vacated decision. Jone moved for recusal, citing the Sixth Circuit’s command that Jones receive fresh proceedings. The ALJ denied the motion and held that the Site was a mine, not a borrow pit, based on findings that Jones did not only use the Site on a one-time basis or only intermittently; engaged in milling, sizing, and crushing; and did not use the rock more for bulk fill than for its intrinsic qualities. The Sixth Circuit affirmed the decision as supported by substantial evidence. View "Jones Brothers, Inc. v. Secretary of Labor, Mine Safety & Health Administration" on Justia Law

Rutherford County, Tennessee law enforcement officers raided 23 stores selling cannabidiol (CBD) products because they falsely believed that such products were illegal under state law. The charges were dropped; the products were legal under both state and federal law. The shop owners sued the responsible law enforcement agencies, asserting violations of their constitutional rights and conspiracy to violate those rights. All but one of the shop owners ultimately settled. The district court then granted summary judgment to the County and Sheriff Fitzhugh.On interlocutory appeal, the Sixth Circuit reversed. The plaintiff presented evidence to support a claim of 42 U.S.C. 1983 civil conspiracy. Fitzhugh’s alleged behavior reflects interdependent decision-making with the Smyrna Police Department (SPD) and the DA’s office through the planning and execution of the raids, calculated to achieve an unconstitutional outcome. Although SPD’s raid of the plaintiff’s business was the overt act that directly caused the plaintiff’s alleged injury, holding the county defendants liable for their alleged involvement in the overall plan that led to that raid is the kind of conspiratorial behavior at the heart of section 1983 civil conspiracy claims. A jury could reasonably conclude that there was a “single plan” in which Fitzhugh participated. View "Rieves v. Smyrna, Tennessee" on Justia Law

DayCab designs, manufactures, and sells conversion kits that convert a sleeper tractor cab into a tractor that does not have a sleeper unit (a daycab). DayCab’s founder, Wagers, started his conversion kit business in 1997 and created the first Peterbilt extended-cab conversion kits on the market, the “Fat Albert” models. Wagers stated that he “carefully selected” the “angles, curves, tapers, lines, profile and appearance” of the DayCab conversion kit “with the aim of making a very distinctive and attractive kit,” but “any number of other angles, curves, tapers, lines, profile and appearance” would have also served as a Peterbilt conversion product.Osman began making conversion kits in 1998 and obtained a utility patent for a panel used to convert a sleeper truck cab into a day cab. Each kit is manufactured and sold with an identification card with Osman’s company’s logo embedded in the fiberglass. Those companies named their conversion-kit products: “Cousin Albert,” “Uncle Albert,” and “Fat Boy.”DayCab sued, asserting claims under the Lanham Act, 15 U.S.C. 1125(a), for trade dress infringement. The district court entered summary judgment for the defendants. The Sixth Circuit reversed. Genuine issues of material fact remain regarding the non-functionality element of DayCab’s trade dress claim as well as on the elements of secondary meaning and the likelihood of confusion. View "DayCab Co, Inc. v. Prairie Technology, LLC" on Justia Law

Nashville passed a “sidewalk ordinance.” To obtain a building permit, an owner must grant an easement across their land and agree to build a sidewalk on the easement or pay an “in-lieu” fee that Nashville will use to build sidewalks elsewhere.In a challenge to the ordinance under the Fifth Amendment’s Takings Clause, the landowner plaintiffs asked the court to apply the “unconstitutional-conditions” test that the Supreme Court adopted in 1987 to assess conditions on building permits (Nollan v. California Coastal Commission). Nashville argued that the Court has applied Nollan’s test only to ad hoc administrative conditions that zoning officials impose on specific permit applicants—not generally applicable legislative conditions that city councils impose on all permit applicants. For legislative conditions, Nashville argued in favor of the application of the deferential “balancing” test that the Court adopted to assess zoning restrictions in “Penn Central” (1978). The district court granted Nashville summary judgment.The Sixth Circuit reversed, agreeing with the landowners. Nothing in the relevant constitutional text, history, or precedent supports Nashville’s distinction between administrative and legislative conditions. Nollan’s test should apply to both types, including those imposed by the sidewalk ordinance. View "Knight v. e Metropolitan Government of Nashville and Davidson County" on Justia Law

Banuelos-Jimenez, a native and citizen of Mexico, arrived in the U.S. in 1999. DHS began removal proceedings in 2010. Those proceedings were administratively closed and re-calendared at the Department’s request. In 2017, Arkansas police arrested Banuelos-Jimenez following a “screaming” incident with his wife. He pleaded guilty to, third-degree assault on a family or household member. DHS re-initiated removal proceedings.Banuelos-Jimenez applied for cancellation of removal. An IJ denied his application, concluding that the Arkansas statute was a crime of violence: Banuelos-Jimenez acted at least recklessly and that “crimes of violence” encompass not only crimes that require specific intent but also reckless conduct. The BIA affirmed. Despite the Supreme Court’s 2021 “Borden” holding that a crime of violence does not encompass reckless conduct, the BIA concluded that Banuelos-Jimenez’s conviction was a crime of violence—his conduct was also purposeful and necessarily involved a threat of force capable of causing physical pain or injury. The Sixth Circuit denied a petition for review. The Arkansas conviction is categorically a crime of violence because it involves the “threatened use of force against the person of another,” 18 U.S.C. 16(a). While the statute may not require the perpetrator to intend actual harm, he still intends to threaten harm. View "Banuelos-Jimenez v. Garland" on Justia Law

Former inmate Morgan, a devout Muslim, sued Michigan prison officials for allegedly violating his free exercise rights by failing to provide him with meals consistent with his religion after he was transferred to a prison that lacked the capacity to produce compliant meals. Morgan filed a grievance with the prison five days after he arrived. The district court granted the defendants summary judgment based on Morgan’s failure to exhaust administrative remedies under the Prison Litigation Reform Act of 1995, 42 U.S.C. 1997e, which requires prisoners to follow a prison’s grievance procedures before challenging prison conditions in court. The district court held that Morgan’s grievance only covered the failure to provide meals up until the date of the grievance, so Morgan should have filed further grievances as to the alleged free exercise violation.The Sixth Circuit reversed. Morgan already put the prison officials on notice of unconstitutional conduct; requiring repeat grievances for the same course of conduct would exceed the requirements of the Act. At issue here is Morgan’s free exercise claim, which he raised by prison grievance. The facts Morgan has pled along with this claim, including staff laughing at him, are sufficiently ancillary to require no further exhaustion of his claim. View "Morgan v. Trierweiler" on Justia Law

While on supervised release for a 2012 felon-in-possession conviction, Hinojosa shot a man and robbed the man’s companion of drugs and money. A jury convicted him of Hobbs Act robbery, discharging a firearm during that robbery, and being a felon in possession of ammunition. The district court sentenced him to 240 months of imprisonment. The court separately revoked Hinojosa’s supervised release and imposed a consecutive 24-month sentence for his 2012 offense.The Sixth Circuit affirmed his convictions and the 24-month sentence for his supervised-release violations. A defendant’s arrest for a violation of a supervised-release condition does not trigger the 30-day clock to file an indictment charging new federal offenses even when both involve “the same underlying conduct.” There was sufficient evidence to support the convictions. The court vacated the 240-month sentence. The district court applied the wrong law when calculating Hinojosa’s guidelines range for his new offenses and should make the required factual findings concerning Hinojosa’s prior offenses. View "United States v. Hinojosa" on Justia Law

Turcios-Flores and her husband operated merchant stands in Honduras and were subject to a “war tax” imposed by the MS-13 gang. Turcios-Flores’s husband inherited a farm, where they grew coffee and plantains, careful not to reveal their ownership. A cousin later joined MS-13 and shared Turcios-Flores’s secret landownership. MS-13 demanded additional payment in an amount 100 times greater than what the family had previously paid, threatening to kill her husband. Turcios-Flores’s husband fled to the U.S. alone, hoping that MS-13 would stop threatening his family. The gang then threatened Turcios-Flores herself. Turcios-Flores complied. MS-13 increased their demands, warning Turcios-Flores that her children would be killed if she did not pay. The police only offered her a phone number to call if gang members returned. Turcios-Flores and her children entered the U.S. without the required entry documents. She filed an application for asylum, withholding of removal, and protection under the Convention Against Torture (CAT) on behalf of her and her sons.The BIA affirmed the IJ’s denial of relief. The Sixth Circuit granted a petition for review, in part. The Board correctly denied Turcios-Flores’s application for CAT protection and her asylum application insofar as it relates to her membership in her husband’s family. The decision with respect to two of Turcios-Flores’s additional proposed social groups (rural landowners or farmers, single mothers living without male protection) was not supported by substantial evidence, however, and the withholding-of-removal analysis was flawed. View "Turcios-Flores v. Garland" on Justia Law