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

The Sixth Circuit affirmed the order of the district court denying Appellant's motion to suppress, holding that there was no violation of Defendant's Fourth Amendment rights under the circumstances of this case.Defendant entered a conditional plea to being a felon in possession of a firearm. Defendant subsequently brought this appeal challenging the district court's order denying his motion to suppress, arguing that the arresting officer lacked probable cause to initiate the traffic stop leading to the search of his car and unconstitutionally prolonged the stop. The Sixth Circuit affirmed, holding (1) there was sufficient evidence to warrant a prudent person in believing Defendant had violated 4511.431(A); and (2) the officer had probable cause to detain Defendant, investigate the source of a marijuana odor, and continue search the entire vehicle for marijuana. View "United States v. Stevenson" on Justia Law

The Sixth Circuit vacated the judgment of the district court granting summary judgment in favor of Defendant, a Canadian resident, in this lawsuit brought under 28 U.S.C. 1332(a)(2), holding that remand was required for the district court to decide the issue of subject matter jurisdiction in the first place.Plaintiff, Akno 1010 Market Street St. Louis Missouri, LLC, sued Defendant in federal district court, asserting diversity jurisdiction but stating only that it was "organized under the laws of Michigan." Although Plaintiff did not adequately allege its own citizenship the district court decided the case on the merits. The Sixth Circuit vacated the district court's judgment, holding that further fact-finding was required on the issue of whether the district court had subject matter jurisdiction to hear this dispute. View "Akno 1010 Market Street St. Louis Missouri LLC v. Pourtaghi" on Justia Law

The Sixth Circuit reversed the judgment of the district court dismissing this ERISA action for lack of jurisdiction on the grounds that no contract bound the parties, holding that the presence of a live contract goes to the merits of this action, not the district court's jurisdiction to hear it.A group of employee benefits funds sued Defendant in a federal district court alleging breach of contract for late contributions under the Employee Retirement Income Security Act (ERISA). Defendant responded that no contract existed and that the presence of a live contract was a jurisdictional prerequisite to Plaintiffs' ERISA suit, meaning that the claim should have been brought under the National Labor Relations Act and that the National Labor Relations Board had exclusive jurisdiction to hear Plaintiffs' grievances. The district court dismissed the suit without prejudice, holding that it lacked jurisdiction to hear Plaintiffs' claim. The Sixth Circuit reversed, holding that the presence of a live contract is not an essential jurisdictional fact in an action brought under section 515 of ERISA. Rather, the presence of a live contract goes to the merits of Plaintiffs' ERISA claim. View "Operating Engineers' Local 324 Fringe Benefits Funds v. Rieth-Riley Construction Co." on Justia Law

The Sixth Circuit vacated the judgment of the district court vacating an arbitration award to the extent that it applied to Greenhouse Holdings, LLC (Greenhouse), holding that it was disputed whether Greenhouse consented to arbitrate, and therefore, the evidence should be weighed by the district court in the first instance.At issue was whether an arbitrator has the authority to bind someone who hasn't signed the underlying arbitration agreement to an arbitration award. A Union filed a grievance against "Clearview Glass," alleging that it violated the parties' collective bargaining agreement. An arbitrator concluded that Greenhouse was bound by an in violation of the CBA. The district court vacated the award to the extent it applied to Greenhouse because it was unclear whether Greenhouse ever assented to the CBA. The Sixth Circuit vacated the judgment, holding that remand was required for the district court to first decide whether Greenhouse consented to arbitrate the threshold arbitrability question. View "Greenhouse Holdings, LLC v. International Union of Painters" on Justia Law

The Sixth Circuit affirmed in part and reversed in part the judgment of the district court denying Defendant's motion to vacate his convictions under 28 U.S.C. 2255, holding that the district court erred by denying Defendant's request to vacate his 18 U.S.C. 924(j) conviction.Defendant pled guilty to discharging a firearm during a crime of violence that resulted in death, in violation of 18 U.S.C. 924(j), and illegally possessing a firearm as a felon, in violation of 18 U.S.C. 922(g)(1). On appeal, Defendant argued, among other things, that the Court should vacate his crime-of-violence conviction under section 924(j) because of the Supreme Court's decision in Rehaif v. United States, 139 S.Ct. 2191 (2019). The Sixth Circuit agreed and vacated that conviction, holding that, given Davis, Defendant did not violate section 924(j) because his attempted robbery did not qualify as a crime of violence under the constitutional portion of section 924's definition. View "Wallace v. United States" on Justia Law

The Sixth Circuit affirmed the order of the district court vacating its previous judgment, in which it granted Defendant's 28 U.S.C. 2255 motion and vacated his sentence, and reinstating Defendant's original sentence, holding that the district court did not enjoy the discretion to resentence Defendant de novo.More than a decade ago, Defendant pleaded guilty to possessing a firearm as a felon. In part because Defendant had prior Tennessee convictions for aggravated burglary the district court designated sentenced Defendant under the Armed Career Criminal Act. Defendant later moved to vacate his sentence under section 2255, arguing that his prior Tennessee convictions for aggravated burglary did not constitute violent felonies given recent developments in Armed Career Criminal Act jurisprudence. The district court granted the motion and vacated Defendant's sentence. Due to intervening Supreme Court caselaw decided before resentencing, the district court vacated the order granting Defendant's section 2255 motion, denied the motion, and reinstated the original sentence. The Seventh Circuit affirmed, holding that Defendant lacked any viable section 2255 claim. View "Mitchell v. United States" on Justia Law

The Sixth Circuit affirmed the judgment of the district court denying Appellant's 28 U.S.C. 2255 motion for relief from his first-degree murder conviction, holding that there was no merit to any of Appellant's claims on appeal.In his section 2255 petition, Appellant claimed that he was deprived of the effective assistance of trial counsel (IAC). The Sixth Circuit granted a certificate of appealability on Appellant's IAC claim concerning an alleged conflict of interest, a Brady claim, an IAC claim regarding the investigation at the guilt stage, and a final IAC claim regarding the presentation of mitigation evidence at the penalty phase. The district court denied the petition. The Sixth Circuit affirmed, holding that Appellant was not entitled to relief on any of his claims of error. View "Gabrion, II v. United States" on Justia Law

The Sixth Circuit affirmed in part, reversed in part and vacated in part the district court's denial of Appellant's petition for a writ of habeas corpus, holding that, in Tennessee, ineffective assistance of post-conviction counsel can establish cause to excuse a defendant's procedural default of a substantive claim of ineffective assistance at the motion-for-a-new-trial stage of the proceedings.Appellant was convicted of first-degree premeditated murder, first-degree felony murder, aggravated kidnapping, rape of a child, and criminal impersonation. The jury sentenced Appellant to death. The Tennessee Supreme Court affirmed. Appellant later filed a habeas petition, which the district court denied. The Sixth Circuit (1) affirmed the district court with respect to the guilt phase of Defendant's trial; (2) held that Appellant's counsel rendered ineffective assistance at the sentencing phase, requiring remand with instructions to grant habeas on this claim as to the penalty phase; and (3) vacated the district court's findings that Appellant failed to overcome his procedural default on certain claims; and (4) reversed the court's finding that the Martinez-Trevino exception to procedural default cannot excuse a procedural default when the underlying ineffective assistance occurred in a motion for a new trial. View "Rogers v. Mays" on Justia Law

The Sixth Circuit reversed the judgment of the district court denying the government's motion to admit records documenting a terrorist group's organizational structure, logistics, and activities as statements of co-conspirators under Fed. R. Evid. 801(d)(2)(E), holding that the district court erred.A grant jury indicted Defendant for his ISIS-related activities. Before trial, the government identified certain exhibits recovered from various ISIS facilities and moved to admit the documents as statements of co-conspirators admissible under Fed. R. Evid. 801(d)(2)(E). The district court denied the government's motion. The Sixth Circuit reversed, holding that the government adequately defined the scope of the conspiracy that it claimed existed, and the district court clearly erred in ruling otherwise. View "United States v. Musaibli" on Justia Law

The Sixth Circuit affirmed the order of the district court granting summary judgment in favor of the City of Powell, Ohio and dismissing Golf Village North LLC's claims brought under 28 U.S.C. 1983 for violating its procedural and substantive due process rights, holding that there was no error.Golf Village, a developer, sought to build a "residential hotel" on its property in Powell, Ohio but never filed the required zoning application. Instead, Golf Village requested that the City confirm the residential hotel was a permitted use of the property. The City directed Golf Village to file an appropriate application for "zoning Certificate approval" to receive an answer. Rather than reply, Golf Village sued the City. The district court granted summary judgment for the City. The Sixth Circuit affirmed, holding that Golf Village's procedural due process and substantive due process rights were not violated in this case. View "Golf Village North, LLC v. City of Powell, Ohio" on Justia Law