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

Federal and local law enforcement investigated an individual as part of a drug trafficking organization operating in Tennessee. Over ten months, agents used various investigative techniques, including wiretaps, confidential informants, controlled narcotics buys, and electronic surveillance. Based on the evidence, a grand jury indicted the defendant on multiple counts, including conspiracy to distribute cocaine and heroin, drug distribution, money laundering, and related offenses. The defendant was arrested at his home, questioned by agents, and, after receiving Miranda warnings, confessed to involvement in drug trafficking. Agents also seized and searched his cellphones with his verbal and written consent.Before trial in the United States District Court for the Middle District of Tennessee, the defendant filed motions to suppress his post-arrest statements and evidence from the cellphone searches, arguing violations of his Fifth, Sixth, and Fourth Amendment rights. The district court denied these motions after evidentiary hearings. At trial, a jury convicted the defendant on all counts, and the district court imposed a prison sentence and supervised release.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the denial of the suppression motions. The appellate court held that the defendant’s post-Miranda confession was not coerced, the warnings given reasonably conveyed his rights, and even if there were deficiencies, any error was harmless due to overwhelming other evidence of guilt. The court further found that the defendant voluntarily consented to the cellphone searches, and there was no Fourth Amendment violation. The court noted that no evidence from the cellphones was introduced at trial. Accordingly, the Sixth Circuit affirmed the district court’s denial of the suppression motions and upheld the convictions. View "United States v. Magallon Guerrero" on Justia Law

The defendant was previously convicted under Florida law for lewd and lascivious battery and transmission of harmful materials to a minor. After relocating from Florida to Tennessee in 2023, she knowingly failed to register as a sex offender in Tennessee and to notify Florida of her move, as required by federal law. She pleaded guilty to failure to register as a sex offender under 18 U.S.C. § 2250(a). The probation office classified her as a Tier II sex offender under the Sex Offender Registration and Notification Act (SORNA), which affected her sentencing guidelines.The United States District Court for the Eastern District of Tennessee overruled her objection to the Tier II classification and sentenced her to 24 months of imprisonment followed by twenty years of supervised release. The calculated guidelines range for supervised release was five years, but the district court imposed a sentence significantly above this recommendation. The defendant subsequently appealed the classification and the length of her supervised release.The United States Court of Appeals for the Sixth Circuit reviewed the case. It held that the district court erred in classifying the defendant as a Tier II sex offender. Applying the categorical approach, the appellate court determined that Florida’s lewd and lascivious battery statute does not require knowledge of the victim’s age, while the federal comparator offense under 18 U.S.C. § 2422(b) does require such knowledge. Therefore, the state offense was not “comparable to or more severe than” the Tier II offense, and the defendant should have been classified as a Tier I offender. The appellate court also found that the district court procedurally erred in imposing a twenty-year term of supervised release based on a misunderstanding of the applicable guidelines. As a result, the Sixth Circuit reversed the SORNA classification ruling, vacated the supervised release sentence, and remanded for resentencing. View "United States v. Buddi" on Justia Law

In March 2022, a police officer detained a man outside a community center after he was involved in a physical altercation following an argument with his ex-wife. The officer, acting on information from witnesses and the ex-wife about possible domestic violence, handcuffed the man and, during the escort to a police vehicle, applied pain compliance techniques. The man claimed the officer twisted his wrist, resulting in injury that required surgery. After reviewing available body camera footage and conflicting testimony, no criminal charges were filed against the man.The United States District Court for the Western District of Kentucky granted summary judgment to the officer. The court found the officer’s use of force reasonable under the circumstances, holding that qualified immunity shielded him from the federal excessive force claim under 42 U.S.C. § 1983, and that state law also provided qualified immunity on the battery claim. The court dismissed the plaintiff’s negligence claim as incompatible with his excessive force claim. The plaintiff appealed these rulings.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The appellate court concluded that, while the officer was justified in using some degree of force due to the potential for violence, there were genuine disputes of material fact concerning whether the amount of force used was reasonable, particularly given the obscured video evidence and conflicting testimony about the events. The court held that, if the plaintiff’s version was credited, the officer’s actions could constitute excessive and gratuitous force, violating clearly established law. The Sixth Circuit affirmed the dismissal of the negligence claim but reversed the grant of summary judgment on the federal excessive force and state law battery claims, remanding those claims for further proceedings. View "Franke v. Janes" on Justia Law

Scott Williams was elected to serve on the Addison Community School Board for a six-year term and was chosen by his fellow board members to act as president for one year. During his presidency, Williams had a dispute with a staff member, leading to allegations that he harassed staff and improperly requested confidential information. Following an investigation and resolution drafted by board members, the Board voted to censure Williams and remove him from the presidency. Williams was not informed of the allegations against him before the meeting where his removal was voted upon.Williams filed suit in the United States District Court for the Eastern District of Michigan, alleging, among other claims, a violation of the Fair and Just Treatment clause of the Michigan Constitution and asserting that the school district was liable under respondeat superior. The district court granted summary judgment to the defendants on all claims, including the federal constitutional claims, and denied Williams’s motion for partial summary judgment on his Fair and Just Treatment claim. The district court chose to exercise supplemental jurisdiction over the state law claims after dismissing the federal claims.The United States Court of Appeals for the Sixth Circuit reviewed the case and determined that the district court abused its discretion by retaining supplemental jurisdiction over Williams’s Fair and Just Treatment claim. The appellate court found that the state law claim presented a novel and complex issue under Michigan law, particularly because Michigan courts have not yet determined whether a private right of action exists under the Fair and Just Treatment clause. The court held that, given the dismissal of all federal claims and the complexity of the remaining state constitutional issue, the district court should have declined to exercise supplemental jurisdiction. As a result, the Sixth Circuit vacated the district court’s judgment on the Fair and Just Treatment claim and remanded with instructions to dismiss this claim without prejudice. View "Williams v. Addison Community Schools" on Justia Law

Several individuals and organizations challenged a 2018 regulation issued by the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) that classified rifles equipped with bump stocks as illegal machineguns. This rule departed from ATF’s previous position and was prompted by the 2017 Las Vegas shooting, where bump stocks were used to inflict mass casualties. The ATF’s rule gave owners 90 days to destroy or surrender such devices, threatening criminal penalties for noncompliance.In the United States District Court for the Western District of Michigan, the plaintiffs sought to enjoin enforcement of the rule. The district court denied a preliminary injunction, finding the statutory definition of “machinegun” ambiguous and deferring to the ATF’s interpretation under Chevron USA, Inc. v. Natural Resources Defense Council, Inc. On appeal, a Sixth Circuit panel disagreed, finding Chevron inapplicable to statutes with criminal penalties and holding the statutory definition unambiguously excluded bump stocks. However, after en banc review, the Sixth Circuit split evenly, resulting in an affirmation of the district court’s denial. Meanwhile, other circuits reached conflicting outcomes, and the Supreme Court ultimately held in Garland v. Cargill that the statutory definition of “machinegun” does not cover bump stocks.Following the Supreme Court’s decision, the district court declared the ATF’s rule unlawful but denied the plaintiffs’ request for attorney’s fees under the Equal Access to Justice Act, finding the government’s position “substantially justified” due to significant judicial disagreement.The United States Court of Appeals for the Sixth Circuit reviewed this denial and affirmed the district court’s decision. It held that, while the government’s position was ultimately rejected, it was “substantially justified” given the novel statutory question, the division among courts, and the existence of reasonable arguments supporting the ATF’s interpretation. Thus, attorney’s fees were not awarded. View "Gun Owners of America, Inc. v. Bondi" on Justia Law

The plaintiff, a magistrate in the domestic-relations division of a county court, declared her candidacy for a judicial seat alongside a fellow magistrate, who was also a court administrator. During her campaign, the plaintiff distributed literature that criticized her opponent’s work schedule and duties, suggesting that the opponent performed trivial administrative tasks and questioning her competence based on personal circumstances. These campaign materials were perceived by the administrative judge as undermining the integrity of the court and casting both the court and its staff in an unfavorable light. After the plaintiff lost the primary election, the administrative judge terminated her employment as a magistrate.Prior to this appeal, the United States District Court for the Southern District of Ohio dismissed the plaintiff’s suit brought under 42 U.S.C. § 1983, which alleged a violation of her First Amendment free-speech rights. The district court ruled that the court itself was not a legally cognizable entity subject to suit, that sovereign immunity barred claims for money damages against the administrative judge in her official capacity, and that the plaintiff failed to state a plausible free-speech claim against the administrative judge. The plaintiff appealed only the dismissal of her free-speech claim.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s dismissal de novo. It held that, because the plaintiff occupied a confidential or policymaking position and her campaign speech addressed matters related to court policy and politics in a manner that undermined the loyalty and efficient functioning required by her employer, her termination did not violate the First Amendment. The court affirmed the district court’s judgment, finding that the balancing test usually applied to public employee speech was unnecessary under these circumstances. The court also rejected the plaintiff’s arguments regarding insubordination, the scope of judicial candidate speech protections, and the applicability of strict scrutiny. View "Gaines v. Cross" on Justia Law

Dr. Lawrence Sherman, a physician, was employed one day per week at Tranquility Wellness Center in Southeastern Michigan, a clinic operated by individuals later convicted for their roles in an illegal prescription scheme. The clinic accepted only cash, did not bill insurance, and routinely provided opioid prescriptions, often based on questionable or fake medical records. Dr. Sherman prescribed large quantities of Schedule II controlled substances, sometimes without adequate patient evaluation or verification of medical histories, and was paid per prescription. After an investigation, Sherman was indicted for conspiracy to possess with intent to distribute and to distribute controlled substances, along with multiple counts of unlawful distribution.In the United States District Court for the Eastern District of Michigan, Sherman went to trial while his co-defendants pleaded guilty and testified against him. The jury found Sherman guilty on all counts, and he was sentenced to 144 months in prison. Sherman subsequently moved for a judgment of acquittal and a new trial, both of which the district court denied.The United States Court of Appeals for the Sixth Circuit reviewed Sherman’s conviction and the denial of his post-trial motions. The court held that sufficient evidence supported the convictions, as a rational jury could find Sherman knowingly issued unauthorized prescriptions based on circumstantial evidence, including expert testimony on deviations from standard medical practice. The appellate court also found no reversible error in the district court’s jury instructions, evidentiary rulings, admission of summary charts, or handling of alleged judicial bias. Any errors identified were deemed harmless in light of overwhelming evidence. The court affirmed both Sherman’s conviction and the denial of his motion for a new trial. View "United States v. Sherman" on Justia Law

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