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

A train operated by Norfolk Southern carrying hazardous materials derailed near East Palestine, Ohio, in February 2023. The cleanup released toxic chemicals into the surrounding area, prompting affected residents and businesses to file suit against the railroad and other parties in federal court. These cases were consolidated into a master class action, and after extensive discovery and mediation, Norfolk Southern agreed to a $600 million settlement for the class. The district court for the Northern District of Ohio approved the settlement in September 2024. Five class members objected and appealed, but the district court required them to post an $850,000 appeal bond by January 30, 2025, to cover administrative and taxable costs. The objectors did not pay the bond or offer a lesser amount.After the bond order, the objectors filed a motion in the United States Court of Appeals for the Sixth Circuit to eliminate or reduce the bond, but did not seek a stay. The Sixth Circuit motions panel explained that, absent a separate notice of appeal, it could only address the bond on a motion to stay, which the objectors expressly disclaimed. The objectors then moved in the district court to extend the time to appeal the bond order, but did so one day after the deadline set by Federal Rule of Appellate Procedure 4(a)(5)(A). The district court denied the motion as untimely, finding it lacked jurisdiction to grant an extension.The United States Court of Appeals for the Sixth Circuit held that the deadlines for appealing and requesting extensions are jurisdictional and cannot be equitably extended. The court dismissed the objectors’ appeal of the motion to extend for lack of jurisdiction and granted the plaintiffs’ motion to dismiss the objectors’ appeals of the settlement for failure to pay the required bond. View "In re E. Palestine Train Derailment" on Justia Law

After pleading guilty to federal drug-distribution conspiracy charges in 2012, the defendant was sentenced to ten years in prison followed by eight years of supervised release. He began his supervised release in 2019. In 2022, while still under supervision, he shot and killed a man outside a convenience store, an act captured on security video. He subsequently pled guilty to murder in state court. This new criminal conduct constituted a violation of the conditions of his federal supervised release.Following the murder conviction, the United States District Court for the Eastern District of Michigan revoked the defendant’s supervised release. At the revocation hearing, the court considered the advisory Sentencing Guidelines, which recommended a range of 51 to 63 months, but imposed the statutory maximum of 60 months’ imprisonment. The court ordered this sentence to run consecutively to the defendant’s state sentence. The defendant objected to both the length of the federal sentence and the decision to run it consecutively, but did not object to the court’s consideration of the seriousness of the supervised-release violation.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the procedural and substantive reasonableness of the sentence. Applying plain-error review to the procedural challenge, the court held that the district court did not treat the seriousness of the supervised-release violation as a mandatory factor, but permissibly considered it as a breach of trust. The court also found no abuse of discretion in the substantive reasonableness of the sentence, noting that the district court considered multiple relevant factors and imposed a within-Guidelines sentence. The Sixth Circuit affirmed the district court’s judgment. View "United States v. Patterson" on Justia Law

A police dispatcher who worked for a Michigan city alleged that she and other female dispatchers were required to conduct searches of female arrestees, even when female officers were available, exposing them to health and safety risks. The department did not have a similar policy for male dispatchers. In 2020, the dispatcher and several colleagues filed a lawsuit alleging sex discrimination. Eleven days after filing, the dispatcher became the subject of an Internal Affairs investigation, which ultimately led to her termination for violating department policy by using a case-management system for personal reasons. She later settled with the department, resulting in her reinstatement with a demotion, suspension, and loss of promotion eligibility.Following these events, the dispatcher filed a second lawsuit in the United States District Court for the Eastern District of Michigan, claiming that the city and its police commissioner retaliated against her for exercising her First Amendment rights by filing the original lawsuit. She also brought a claim under Michigan’s Elliott-Larsen Civil Rights Act. The district court granted summary judgment to the city on the retaliation claim, finding no municipal liability, but denied summary judgment to the commissioner in his individual capacity, holding that there was a genuine issue of material fact regarding causation. The commissioner appealed, asserting qualified immunity.The United States Court of Appeals for the Sixth Circuit reviewed the denial of qualified immunity. The court held that the dispatcher alleged legally cognizable adverse actions and that her right to be free from retaliation for protected speech was clearly established. The court affirmed the district court’s denial of qualified immunity to the commissioner and dismissed the remainder of the appeal for lack of appellate jurisdiction over factual disputes. The court declined to exercise pendent appellate jurisdiction over the state-law claims. View "DeVooght v. City of Warren" on Justia Law

A partnership purchased a historic eleven-story building in downtown Cleveland for $6 million in 2015 and later redeveloped it into residential apartments, utilizing state and federal historic preservation tax credits. In 2016, the partnership donated a conservation easement on the building’s façade and development rights to a local charity, claiming a $22 million charitable deduction—substantially more than the purchase price. The Internal Revenue Service (IRS) disallowed the deduction, citing that it was claimed in the wrong tax year, was grossly overvalued, and lacked proper documentation for related expenses. The IRS also imposed significant penalties for negligence and overvaluation.The partnership and its tax matters partner challenged the IRS’s determinations in the United States Tax Court. After a trial, the Tax Court found that the deduction was improperly claimed by the partnership for a period when it was not a taxable entity, as it had only one partner at the time of the donation. The court also concluded that the easement’s valuation was speculative and unsupported, rejecting the $22 million figure in favor of the IRS’s much lower estimate. Additionally, the Tax Court determined that the partnership failed to adequately document its claimed expenses and upheld the IRS’s penalties.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the Tax Court’s decision. The Sixth Circuit held that the partnership could not claim the deduction for a period when it was not a taxable partnership, that the valuation of the easement was grossly overstated and speculative, and that the partnership failed to substantiate its claimed expenses. The court also upheld the imposition of negligence and gross valuation misstatement penalties, finding no clear error in the Tax Court’s factual determinations. View "Corning Place Ohio, LLC v. Commissioner of Internal Revenue" on Justia Law

The defendant, a long-time drug trafficker, was convicted for conspiring to distribute oxycodone in rural Appalachian communities. His criminal history included two prior drug distribution convictions, and he was previously sentenced as a career offender, resulting in a lengthy prison term, supervised release, and a fine. After a series of unsuccessful post-trial motions and appeals, a change in Sixth Circuit law regarding the definition of a “career offender” under the Sentencing Guidelines made him eligible for resentencing. At resentencing, the defendant presented evidence of rehabilitation and mitigating personal history, and requested a sentence within the recalculated, lower Guidelines range.Previously, the United States District Court for the Eastern District of Kentucky had sentenced the defendant above the Guidelines range, citing his recidivism and lack of remorse. The United States Court of Appeals for the Sixth Circuit affirmed both the conviction and sentence. However, after the Sixth Circuit’s en banc decision in United States v. Havis, which narrowed the definition of a “controlled substance offense,” the defendant successfully moved for relief under 28 U.S.C. § 2255, leading to resentencing without the career offender enhancement. At resentencing, the district court imposed a sentence at the top of the new Guidelines range, reduced the term of supervised release, and reimposed the fine.On appeal, the United States Court of Appeals for the Sixth Circuit held that the district court did not err in denying a reduction for acceptance of responsibility, in its consideration of sentencing disparities, or in its treatment of mitigating evidence. The appellate court also found no plain error in the imposition of supervised release conditions. The sentence was affirmed, but the case was remanded to the district court for consideration of a retroactive sentencing amendment (Amendment 821). The request for reassignment to a different judge was denied. View "United States v. Coleman" on Justia Law

Eskender Getachew, a medical doctor in Columbus, Ohio, operated a clinic treating patients with opioid addiction. The government alleged that Dr. Getachew unlawfully prescribed controlled substances, particularly Subutex, at rates far exceeding medical norms, often without verifying patients’ claimed allergies to naloxone. Evidence at trial included testimony from an undercover officer, clinic staff, and an expert who identified repeated deviations from accepted medical practice, such as prescribing drugs without documented need and ignoring signs of drug diversion. The jury found Dr. Getachew guilty on eleven counts of unlawful distribution of controlled substances and not guilty on four counts.The United States District Court for the Southern District of Ohio presided over the trial. After conviction, Dr. Getachew was sentenced to concurrent six-month terms and three years of supervised release. He moved for a new trial, arguing ineffective assistance of counsel during plea negotiations and requested an evidentiary hearing, which the district court denied. Dr. Getachew appealed, challenging the sufficiency of the evidence, the deliberate-ignorance jury instruction, the content of that instruction, his absence at the return of the verdict, and the denial of an evidentiary hearing.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the evidence was sufficient to support the jury’s finding that Dr. Getachew knowingly issued unauthorized prescriptions. It found no plain error in the deliberate-ignorance instruction or its content. The court determined that Dr. Getachew’s absence at the verdict’s return did not affect his substantial rights and that the district court did not abuse its discretion in denying an evidentiary hearing on the new trial motion. The Sixth Circuit affirmed the district court’s judgment. View "United States v. Getachew" on Justia Law

Benjamin Carpenter was accused of providing translation and related services to ISIS, a designated foreign terrorist organization. He founded Ahlud-Tawhid Publications (ATP), which translated and published ISIS propaganda in multiple languages. Carpenter personally translated ISIS materials into English, wrote original content, and managed an ATP group on Telegram, where he coordinated translation projects. An undercover FBI agent, posing as an ISIS affiliate, joined the group and interacted with Carpenter, who recommended and facilitated the translation of ISIS propaganda videos at the agent’s request. Carpenter was arrested before completing a second translation assignment.The United States District Court for the Eastern District of Tennessee charged Carpenter with attempting to provide material support to a foreign terrorist organization under 18 U.S.C. § 2339B. After a five-day trial, a jury convicted him, and the district court sentenced him to 240 months in prison. Carpenter appealed, challenging the statute’s application to his conduct, evidentiary rulings, a protective order allowing an FBI agent to use a pseudonym, jury instructions, and the reasonableness of his sentence.The United States Court of Appeals for the Sixth Circuit reviewed Carpenter’s arguments and affirmed the district court’s judgment. The court held that translation services constitute “material support” as a “service” under the statute, consistent with Supreme Court precedent. The court found no abuse of discretion in the district court’s evidentiary rulings, including the admission of evidence related to Carpenter’s involvement with ATP and ISIS, the use of a pseudonym for the FBI agent, and the denial of Carpenter’s proposed jury instructions. The court also upheld the application of the terrorism sentencing enhancement and found the sentence both procedurally and substantively reasonable. The conviction and sentence were affirmed. View "United States v. Carpenter" on Justia Law

A nonprofit organization in Detroit, which provides educational and family services to at-risk youth, employed the plaintiff as a full-time case manager after she had previously worked as an independent contractor. The plaintiff’s responsibilities included monitoring students and managing case files, a task that required onsite work due to funding and audit requirements from a key county contract. After a building flood, the plaintiff raised health concerns about mold exposure and requested to work remotely, providing doctor’s notes that did not explicitly require remote work. The employer accommodated her request temporarily by shifting her to part-time remote work, but emphasized that onsite file management was essential. The plaintiff later returned to full-time onsite work. Over the following year, she filed several complaints with state agencies regarding workplace safety, pay, and reimbursement issues. During the COVID-19 pandemic, the organization faced financial difficulties, leading to a restructuring that offered the plaintiff a choice between an independent contractor role with reduced hours and benefits or a severance package. She declined both, ending her employment.The United States District Court for the Eastern District of Michigan granted summary judgment in favor of the employer on all claims, finding insufficient evidence to support the plaintiff’s allegations of discrimination, retaliation, failure to accommodate, and wrongful termination. The court determined that the plaintiff could not perform essential job functions remotely and that the employer’s actions were based on legitimate business reasons.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The Sixth Circuit held that the plaintiff failed to present evidence of a hostile work environment, disability-based discrimination, or retaliation under federal and state law. The court also found that the employer’s restructuring and accommodation decisions were not pretextual and that the plaintiff’s wrongful termination claim was inadequately developed and unsupported by the record. View "Kellar v. The Yunion, Inc." on Justia Law

Donald Roberts and Gun Owners of America challenged the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) after the agency issued a 2020 advisory instructing gun sellers not to accept Michigan concealed-pistol licenses as substitutes for the federally required National Instant Criminal Background Check System (NICS) check. Roberts was denied a gun purchase when he presented his Michigan license, prompting the lawsuit. The plaintiffs sought an injunction against enforcement of the advisory and a declaration that the ATF had exceeded its authority under the Administrative Procedure Act.The United States District Court for the Eastern District of Michigan initially granted summary judgment to the ATF on the merits. On appeal, the United States Court of Appeals for the Sixth Circuit vacated that order and remanded for further consideration of state law requirements. On remand, the district court dismissed the complaint for lack of standing, leading to another appeal.After the district court’s dismissal, the ATF issued a new advisory in May 2025, following a presidential executive order, which recognized Michigan licenses as valid alternatives to NICS checks and superseded the 2020 advisory. The United States Court of Appeals for the Sixth Circuit determined that these developments rendered the case moot, as the challenged policy was no longer in effect and the plaintiffs sought only prospective relief. The court found that neither the voluntary cessation nor the capable-of-repetition exceptions to mootness applied. Accordingly, the Sixth Circuit vacated the district court’s dismissal for lack of standing and remanded with instructions to dismiss the case as moot. View "Gun Owners of America, Inc. v. Dep't of Justice" on Justia Law

Over several months, the defendant participated in four carjackings targeting Lyft drivers in Detroit. In each incident, two assailants, including the defendant, brandished firearms, demanded money and property, and forced the victims to remove their clothing before fleeing in the stolen vehicles. One victim was pistol-whipped and sustained bodily injury. Extensive evidence, including phone records, cell site data, and identification by a victim, linked the defendant to each carjacking. A search of his residence uncovered multiple firearms and stolen vehicles. The defendant pleaded guilty to four counts of carjacking, aiding and abetting, admitting involvement but attempting to minimize his role in some attacks.The United States District Court for the Eastern District of Michigan prepared a presentence report recommending several offense level enhancements under the Sentencing Guidelines, including increases for brandishing and using firearms and for causing bodily injury. The defendant objected, arguing for a mitigating role reduction based on his claimed minor participation. The district court rejected his arguments, found by a preponderance of the evidence that he was a principal in each carjacking, and applied all recommended enhancements. The court imposed an above-Guidelines sentence of 180 months, citing the severity and humiliating nature of the crimes, the defendant’s prior criminal history, and his lack of respect for the law.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the procedural and substantive reasonableness of the sentence. The court held that the district court did not clearly err in its factual findings or in applying the offense level enhancements, nor did it plainly err in denying a mitigating role reduction or in considering the defendant’s age and rehabilitation potential. The appellate court found the upward variance substantively reasonable, given the egregious nature of the offenses and the impact on the victims. The sentence was affirmed. View "United States v. Haile" on Justia Law