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

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

The case centers on an individual who immigrated to the United States and became involved in a transnational drug trafficking and money laundering conspiracy. His role was to travel across the country collecting large sums of drug proceeds, which he then laundered through a business that purchased used cell phones. These phones were sent to a contact in China as payment for precursor chemicals vital to the drug operation. During one such trip, law enforcement observed him receiving nearly $200,000 in cash and, upon stopping his vehicle, discovered an unloaded firearm and loaded magazine in the van. He admitted to bringing the gun for protection due to the large sums of money he was transporting.He was convicted of money laundering and conspiracy to launder money in the United States District Court for the Eastern District of Kentucky, receiving a 90-month prison sentence and three years of supervised release. His conviction and sentence were affirmed on appeal. While his appeal was pending, the U.S. Sentencing Commission amended the Guidelines to allow certain first-time offenders a two-level reduction in offense level, with exceptions including possession of a firearm “in connection with” the offense. He moved for a sentence reduction under the new provision, but the district court denied the request, finding his possession of the firearm during the offense made him ineligible.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial. The appellate court held that the “in connection with” language should be interpreted broadly and that the close proximity of the firearm to the drug proceeds, along with the defendant’s own admission that the gun was for protection during his criminal activity, established the necessary nexus. The court affirmed the district court’s decision, finding no error in deeming him ineligible for the reduced sentence. View "United States v. Tajwar" on Justia Law

The defendant, a native and citizen of Jamaica, repeatedly entered the United States unlawfully after being removed several times due to criminal convictions, including firearms and drug offenses. In May 2023, he was apprehended at the Ambassador Bridge in Detroit and charged with unauthorized reentry following his removal subsequent to conviction for an aggravated felony, violating 8 U.S.C. § 1326. This constituted his eleventh felony conviction and fifth felony immigration conviction under § 1326.After being indicted in the United States District Court for the Eastern District of Michigan, the defendant moved to dismiss the charge, arguing that § 1326 violates the Fifth Amendment’s equal protection guarantee by discriminating against Mexican and other Latino immigrants. The district court rejected his motion, finding that he failed to link the legislative history and intent of the 1929 Act and its predecessors to the 1952 Immigration and Nationality Act, which codified § 1326. The court also determined that he did not provide evidence of disparate impact or invidious discriminatory purpose regarding § 1326’s enforcement, and adopted the analysis from United States v. Carrillo-Lopez, 68 F.4th 1133 (9th Cir. 2023). The district court sentenced him to 51 months’ imprisonment and he timely appealed.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s refusal to dismiss the indictment de novo and its factual findings for clear error. The appellate court held that the defendant failed to establish discriminatory intent or disparate impact under the Arlington Heights framework. The court emphasized that the legislative history of the 1929 Act is not controlling for § 1326, and Congress is not required to purge previous discriminatory intent when enacting new legislation. The Sixth Circuit affirmed the district court’s judgment. View "United States v. Myrie" on Justia Law

The defendant participated in the robbery of a business known as Cash Express, which offers check cashing, short-term loans, and related financial services. With assistance from his then-girlfriend, the defendant orchestrated the robbery, during which he physically restrained the clerk, brandished a firearm, and escaped with $2,680. Shortly after his arrest, the defendant pleaded guilty to Hobbs Act robbery as part of a plea agreement. Eleven days after signing the agreement, an image implying retaliation against informants was posted on his Facebook profile, which became relevant at sentencing.The United States District Court for the Eastern District of Tennessee sentenced the defendant. The court applied several sentence enhancements: it determined Cash Express was a "financial institution" under the Sentencing Guidelines, imposed a leadership role enhancement, and declined to grant a reduction for acceptance of responsibility due to the defendant's conduct after the plea. The court rejected certain enhancements related to obstruction of justice and reckless endangerment, resulting in a Guidelines range of 151 to 188 months, and sentenced the defendant to 188 months' imprisonment. The defendant appealed, challenging the application of the financial institution and leadership enhancements, the denial of the acceptance of responsibility reduction, and the reasonableness of his sentence.The United States Court of Appeals for the Sixth Circuit reviewed the case. It held that Cash Express qualifies as a "financial institution" under the plain meaning of the term in the Guidelines, affirmed the district court's finding that the defendant acted in a leadership role, and upheld the denial of the acceptance of responsibility reduction due to conduct inconsistent with remorse. The court also found that the sentence was procedurally and substantively reasonable and that the government did not breach the plea agreement. The judgment of the district court was affirmed. View "United States v. Glover" on Justia Law