U.S. Court of Appeals for the Sixth Circuit - Justia Case Law Summaries

Nelson v. MillerKnoll, Inc.

2026-07-07T13:00:38-08:00

The plaintiffs, including the son and estate of designer George Nelson, brought claims against MillerKnoll, Inc. (formerly Herman Miller, Inc.), arguing that MillerKnoll had wrongfully obtained and used intellectual property rights related to the iconic “Bubble Lamp” design. The key facts center on a series of agreements: George Nelson originally had a royalty arrangement with the company, and after his death, his widow Jacqueline Nelson continued this relationship, entering into a 2006 Royalty Agreement. In 2013, Jacqueline assigned her IP rights to the George Nelson Foundation (GNF). After a separate company, Modernica, registered trademarks related to Bubble Lamps, GNF and Modernica settled a lawsuit in 2015, resulting in MillerKnoll acquiring the Bubble Lamp trademarks. Around this time, the Nelsons executed a 2015 Addendum to the Royalty Agreement, adding lamp products to its scope. The plaintiffs first filed suit in the Southern District of New York, raising claims of fraud, conspiracy, unjust enrichment, trademark infringement under the Lanham Act, state law trademark infringement, and seeking cancellation of the Bubble Lamp trademarks. The case was transferred to the United States District Court for the Western District of Michigan due to a forum selection clause. After initial motions were denied, the district court granted summary judgment to MillerKnoll on all claims, finding that the agreements authorized MillerKnoll’s use and ownership of the Bubble Lamp IP and that plaintiffs had ratified this by accepting royalty payments. The United States Court of Appeals for the Sixth Circuit reviewed the case de novo and affirmed the district court’s decision. The Sixth Circuit held that the 2006 Royalty Agreement, as amended by the 2015 Addendum, unambiguously authorized MillerKnoll’s ownership and use of the Bubble Lamp intellectual property, defeating all infringement and tort claims. The court also found that the plaintiffs had ratified any alleged misconduct by accepting royalties, and that there was insufficient evidence to support cancellation of the trademarks. Judgment for MillerKnoll was affirmed. View "Nelson v. MillerKnoll, Inc." on Justia Law

United States v. Harrell

2026-07-02T11:00:46-08:00

The defendant served in the military and received disability-related unemployability benefits from the Department of Veterans Affairs, which required recipients to notify the VA if they became employable. After founding a nonprofit in 2019 and working full-time, the defendant did not report his employment to the VA and continued receiving benefits. He was indicted for theft of government funds under 18 U.S.C. § 641, with a jury later convicting him. The indictment included notice of possible criminal forfeiture. In the United States District Court for the Eastern District of Kentucky, the government moved for a preliminary order of forfeiture before sentencing, but the court did not address it. At sentencing, the court imposed prison time, supervised release, and restitution, but did not orally address forfeiture. The court allowed the defendant to file supplemental briefing after sentencing. Following the hearing, the district court issued several written judgments and amended judgments, none of which initially included forfeiture. The government repeatedly moved to amend the judgment to include forfeiture. Eventually, the district court issued an order imposing forfeiture and amended the judgment to reflect this, several months after sentencing. The defendant appealed, arguing errors in the handling of forfeiture under Federal Rule of Criminal Procedure 32.2 and violations of his right to presence under Rule 43(a) and the Due Process Clause. The United States Court of Appeals for the Sixth Circuit held that, although the district court violated Rule 32.2(b)(4)(B) by failing to impose forfeiture at sentencing and to include it in the judgment, this rule is a time-related directive subject to harmless-error review. The error was harmless because the defendant had notice and opportunity to contest forfeiture. The court also found no violation of the defendant’s due process right to presence, and although Rule 43(a) was violated, it did not affect substantial rights. The oral sentence and written judgment were not in conflict. The court affirmed the district court’s judgment. View "United States v. Harrell" on Justia Law

United States v. Shelton

2026-07-01T13:00:39-08:00

A Michigan physician was charged with twenty-one counts of unlawfully distributing controlled substances to his patients. Over several years, he prescribed large quantities of medications to individuals who exhibited signs of drug-seeking behavior, failed drug screens, engaged in doctor shopping, and requested specific highly abused drugs. The physician often ignored red flags such as patients’ substance abuse histories and failed to perform required physical examinations. His practices led to at least one patient’s overdose death. Evidence at trial included expert testimony that his prescribing was inappropriate and outside the usual course of professional practice. The case was first tried in the United States District Court for the Eastern District of Michigan, but the initial trial ended in a mistrial. A retrial was delayed and declared a mistrial due to the COVID-19 pandemic. The third trial proceeded in March 2023, with the district court requiring witnesses to wear masks while testifying. After a 13-day trial, a jury convicted the physician on all counts. Post-trial motions for acquittal or a new trial were denied, and the physician was sentenced to twenty years on the count involving death, with concurrent sentences on the remaining counts. He appealed, challenging the sufficiency of the evidence, the authority of the Attorney General to regulate prescribing, the jury instructions, and the mask mandate’s constitutionality. The United States Court of Appeals for the Sixth Circuit reviewed the appeal. It held that sufficient evidence supported the convictions, the jury instructions accurately reflected the law and were not misleading or confusing, and the district court’s mask mandate did not constitute reversible error under the Confrontation Clause. The court found no plain error in the regulatory and constitutional challenges and affirmed the district court’s judgment in its entirety. View "United States v. Shelton" on Justia Law

J.M. Smucker Co. v. Ace American Insurance Co.

2026-07-01T13:00:38-08:00

A food manufacturing company purchased commercial general liability insurance policies from an insurer, with each policy providing coverage against bodily injuries from bacterial contamination. The policies defined “occurrence” as “an accident, including continuous or repeated exposure to substantially the same general harmful conditions,” and required the company to pay a $250,000 retained limit per occurrence before coverage would be triggered. In 2022, the company recalled certain peanut butter products due to potential salmonella contamination, resulting in thousands of consumer claims for bodily injury and property damage. The insurer denied coverage, asserting that each claimant’s exposure counted as a separate occurrence, but aggregated these exposures by production “lot,” meaning the company would need to pay the retained limit for each lot before the insurer’s obligation began. The United States District Court for the Northern District of Ohio reviewed cross-motions for summary judgment. The district court sided with the company, finding that the salmonella contamination constituted a single occurrence and deeming the Lot Endorsement ambiguous. The court granted summary judgment for the company and denied the insurer’s motion, then certified its order for interlocutory appeal and stayed the case. The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision de novo. The court held that, under the insurance policies’ definition of occurrence and Ohio’s “cause” test, the salmonella contamination was the single occurrence. It also determined that the Lot Endorsement did not clearly create multiple occurrences and was ambiguous, requiring interpretation in favor of the insured. The court affirmed the district court’s judgment in favor of the company, holding that only one retained limit applied for all claims arising from the salmonella contamination. View "J.M. Smucker Co. v. Ace American Insurance Co." on Justia Law

Bender v. Village of Mariemont

2026-06-30T12:30:38-08:00

A woman was the primary caregiver for her friend, residing in her friend’s condominium for several years. After the friend passed away, ownership of the condo transferred to a living trust, and the caregiver became trustee. She continued living in the condo for a month to recover from illness and remove her belongings. The friend’s nephew contacted local police, claiming the right to evict her, and presented officers with a superseded will listing him as a beneficiary but not mentioning the condo. The officers accompanied the nephew to the condo, told the caregiver she had ten minutes to leave, threatened her with arrest, pushed her out, and took her key. The United States District Court for the Southern District of Ohio reviewed the case after the caregiver sued various parties, alleging Fourth Amendment violations. The court granted summary judgment to some defendants but denied it for the officers, reasoning that the caregiver, as trustee, held a possessory interest in the condo, and the officers’ actions constituted active participation in an eviction without proper legal authority. The court relied on Sixth Circuit precedent to find the seizure unreasonable and the right clearly established. The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial of qualified immunity. The appellate court held that the caregiver had a possessory interest in the condo at the time of the eviction, the officers actively participated in the eviction, and their conduct was unreasonable under the Fourth Amendment because there was no court order or exigent circumstances justifying the seizure. The court further held that existing precedent clearly established the unlawfulness of the officers’ actions. The Sixth Circuit affirmed the district court’s denial of summary judgment, leaving the officers subject to further proceedings. View "Bender v. Village of Mariemont" on Justia Law

Bridges v. Maxum Indemnity Company

2026-06-29T12:00:47-08:00

The case centers on a legal-malpractice insurance dispute arising from a failed medical-malpractice lawsuit. Lauren Bridges, acting as guardian for her minor daughter, initially filed suit in Alaska state court, alleging negligence by healthcare providers that resulted in her child’s disabilities. The case was dismissed when Bridges’s attorney, McKeen & Associates, failed to respond to summary judgment motions. Bridges subsequently brought a legal-malpractice claim against McKeen. At the relevant times, McKeen held legal-malpractice policies from Maxum Indemnity Company, StarStone Specialty Insurance Company, and Landmark American Insurance Company. All insurers declined to defend or indemnify McKeen. McKeen settled with Bridges, assigning her its rights under the policies. Bridges filed suit in the United States District Court for the Eastern District of Michigan against all three insurers, seeking a declaratory judgment and damages for breach of contract. Maxum and Landmark moved to dismiss, and the district court granted their motions, finding the policies unambiguously excluded coverage. The district court also denied Bridges’s motion to amend her complaint to add bad-faith claims and, after Bridges and StarStone stipulated to dismissal, entered final judgment regarding Maxum and Landmark. Bridges appealed only the dismissal of her claims against Maxum and Landmark. The United States Court of Appeals for the Sixth Circuit reviewed the district court’s dismissal de novo. The court held that Maxum’s policy unambiguously required notification of potential malpractice claims during the policy period, which McKeen failed to do, precluding coverage. As to Landmark, the court found that the relevant “wrongful act” occurred before the retroactive date specified in the follow-form policy, excluding coverage. Bridges’s arguments regarding policy ambiguity and procedural fairness were rejected. The Sixth Circuit affirmed the district court’s dismissal of Bridges’s claims against both Maxum and Landmark. View "Bridges v. Maxum Indemnity Company" on Justia Law

Washington v. First Nat'l Bank of Penn.

2026-06-26T11:30:46-08:00

Two plaintiffs, a married couple of mixed-race background, with one spouse being a disabled veteran, sought a Veterans Administration home loan from a bank. They alleged that, despite promptly providing all required documentation and being assured of eligibility, the bank mishandled their application: providing incorrect and misleading information, making repeated errors, missing crucial deadlines, and ultimately failing to either approve or deny the application. The couple later obtained a loan from a different lender without issue and filed a grievance with the Department of Veterans Affairs regarding the bank’s conduct. They then sued the bank, claiming discrimination based on race and disability under the Fair Housing Act, Ohio law, the Equal Credit Opportunity Act, and the Americans with Disabilities Act. After removal to federal court, the United States District Court for the Northern District of Ohio granted the bank’s motion to dismiss. The court concluded that the complaint did not allege sufficient facts to establish the prima facie elements required for discrimination claims under the Fair Housing Act and Equal Credit Opportunity Act, failed to state a claim under Ohio law, and did not present a cognizable claim under the ADA. On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the dismissal de novo. The court held that the district court erred by requiring the plaintiffs to plead facts establishing a prima facie case of discrimination at the pleading stage; such a requirement is an evidentiary standard relevant to summary judgment or trial, not a pleading standard. Nonetheless, the appellate court found this error harmless because, even applying the correct plausibility pleading standard, the complaint lacked sufficient factual content to plausibly allege that the bank’s actions were motivated by race or disability. The Sixth Circuit affirmed the district court’s dismissal of all claims. View "Washington v. First Nat'l Bank of Penn." on Justia Law

United States v. Lineback

2026-06-26T11:30:46-08:00

A 17-year-old grocery store employee in Tipton County, Tennessee, was approached by a regular customer, Austin Lineback, who took a photo of him and later sent edited pictures depicting the boy’s face superimposed onto female bodies, along with text messages that included compliments and an invitation to Lineback’s house. Concerned by these communications, the minor and his mother contacted law enforcement. Detective Bruno sought and obtained a warrant to search Lineback’s home, citing the photos, texts, and Lineback’s status as a registered sex offender with prior convictions for sexual offenses involving minors. The search uncovered writings and materials expressing sexual interest in minors, a photo album and photographs of apparent minors in provocative poses, and electronic devices. A subsequent search of these devices revealed two verified images of child pornography in a folder labeled “Nude Boys.” At the United States District Court for the Western District of Tennessee, Lineback moved to suppress the evidence, arguing the initial warrant lacked probable cause and that any evidence from the electronic search was tainted as a result. The district court denied both the motion to suppress and a later motion for judgment of acquittal based on sufficiency of the evidence. After a jury trial, Lineback was found guilty on one count of knowingly possessing child pornography. The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decisions de novo and affirmed. The court held that the warrant to search Lineback’s home was supported by probable cause, considering the totality of the circumstances, including his prior convictions and the nature of the communications with the minor. The appellate court also found sufficient evidence for a rational jury to conclude that Lineback knowingly possessed child pornography, given the corroborating circumstantial evidence and the verified images. The conviction was affirmed. View "United States v. Lineback" on Justia Law

Amacher v. City of Tullahoma

2026-06-25T12:30:39-08:00

An elected official in a Tennessee city, after selling her home and residing outside city limits for an extended period, faced a legal challenge to her eligibility to serve based on the city’s residency requirement. The challenge was initiated after a citizen petition, supported by over two hundred signatures, prompted the district attorney to file a quo warranto petition seeking her removal from office. Although she later purchased an unimproved lot in the city and began construction of a new home, questions remained about her intent to return and her actual residency during the contested period. The Tennessee state court found her claims of living on the undeveloped property unconvincing but ultimately determined that her efforts to build a residence demonstrated just enough intent to return, allowing her to retain her office. Following this outcome, the official sued two citizens, the city, the mayor, and the city administrator in the United States District Court for the Eastern District of Tennessee, alleging First Amendment retaliation and conspiracy for their roles in initiating the removal proceedings, along with a state law malicious prosecution claim. The district court granted summary judgment to the defendants on the federal claims, holding that she failed to show a conspiracy or retaliation connected to her protected speech, and declined to exercise jurisdiction over the state law claim. On appeal, the United States Court of Appeals for the Sixth Circuit held that, when a claim of First Amendment retaliation is based on the initiation of a civil action such as a quo warranto petition, the plaintiff must show a lack of probable cause for that action. The court concluded that probable cause existed to support the quo warranto petition, as there were reasonable grounds to doubt the official’s residency. Therefore, the court affirmed summary judgment for the defendants and found no abuse of discretion in the district court’s handling of discovery deadlines. View "Amacher v. City of Tullahoma" on Justia Law

Morris v. Blanche

2026-06-25T12:30:38-08:00

A lawful permanent resident who had fled civil war in Liberia and become a U.S. resident in 2016 was convicted twice under Michigan law for possessing a loaded firearm in a vehicle, and later for embezzlement. Following his most recent conviction, the Department of Homeland Security initiated removal proceedings. At his removal hearing, his attorney conceded removability and applied for cancellation of removal. The Immigration Judge (IJ) denied this relief, focusing solely on the discretionary factors, as eligibility was uncontested. The petitioner appealed to the Board of Immigration Appeals (BIA), arguing that the IJ should have granted cancellation based on the equitable balance of factors. The BIA affirmed the IJ’s decision. Subsequently, represented by new counsel, the petitioner filed a motion to reconsider and reopen, alleging ineffective assistance by prior counsel and challenging whether his Michigan firearm conviction qualified as a removable firearms offense under federal law. He included supporting documents for his ineffective assistance claim. The Department of Homeland Security also moved to reopen and dismiss the proceedings, citing changed circumstances. The BIA denied both motions, finding the petitioner had not complied with procedural requirements for ineffective assistance claims—specifically, he failed to provide evidence that notice and a bar complaint had been sent. The BIA also denied the government’s motion, noting it lacked explanation or supporting new facts. The United States Court of Appeals for the Sixth Circuit reviewed the case. It dismissed the petitioner’s first petition, holding that his arguments were either unexhausted or jurisdictionally barred. The court denied the second petition, finding the BIA did not abuse its discretion in denying relief for ineffective assistance due to lack of procedural compliance, and also properly denied the government’s motion to reopen and dismiss for lack of supporting evidence. View "Morris v. Blanche" on Justia Law

United States v. Hall

2026-06-25T12:30:38-08:00

Montez Hall began engaging in criminal activity as a teenager, joining the Bloods gang and participating in violent crimes, including multiple attempted murders and the killing of an innocent woman, Alexandra Franklin. Hall was prosecuted in both state and federal court for his involvement in gang-related crimes, including murder, drug trafficking, and racketeering. He ultimately pled guilty to two federal charges as part of a plea deal, which led to a 30-year federal sentence to be served consecutively with his state sentence. After exhausting several unsuccessful post-conviction and compassionate-release motions, Hall filed a new motion for compassionate release in the United States District Court for the Middle District of Tennessee. He argued that his youth at the time of the offense and his substantial rehabilitation while incarcerated constituted “extraordinary and compelling” reasons for reducing his sentence. The district court agreed in part, reducing his sentence by eight years based on Hall’s youth and rehabilitation, while rejecting his other arguments. The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision for abuse of discretion. The appellate court found that its precedent, particularly United States v. Hunter, clearly foreclosed the use of youth and rehabilitation as “extraordinary and compelling” reasons for compassionate release under 18 U.S.C. § 3582(c)(1)(A). The Sixth Circuit held that its prior interpretations of the statute take precedence over any conflicting Sentencing Commission policy statements. The court concluded that the district court abused its discretion by granting Hall’s motion on impermissible grounds, and therefore reversed the order granting a sentence reduction. View "United States v. Hall" on Justia Law

United States v. Benson

2026-06-24T11:00:48-08:00

The United States government, acting through the Attorney General, demanded that the Michigan Secretary of State provide an unredacted copy of Michigan’s statewide voter registration list, which includes sensitive personal information like dates of birth, driver’s license numbers, and partial social security numbers. The Secretary of State provided only a version with personal information redacted, citing concerns about the lack of statutory authority for the federal government’s request. The government then filed suit, seeking to compel production of the unredacted list. In the United States District Court for the Western District of Michigan, the Secretary of State, the State of Michigan, and certain intervenors moved to dismiss the complaint. The district court granted the motions, concluding that Title III of the Civil Rights Act of 1960 did not authorize the federal government’s demand for the unredacted voter file. The government appealed, contesting only the dismissal of its claim under Title III. The United States Court of Appeals for the Sixth Circuit reviewed the district court’s dismissal de novo. The court held that Michigan’s qualified voter file is not a “record” that “comes into the possession” of the Secretary of State within the meaning of Title III, as it is an internally generated database rather than a record acquired from a third party. The court also determined that the government failed to comply with Title III’s procedural requirements for making such a demand, as its letters did not contain both the basis and the purpose for the request as required by statute. Accordingly, the Sixth Circuit affirmed the judgment of the district court, holding that the Secretary of State did not violate Title III by refusing to provide the unredacted voter file. View "United States v. Benson" on Justia Law

United States v. Hoover

2026-06-24T11:00:47-08:00

A law enforcement officer in Ohio stopped a driver after observing multiple traffic violations. Upon approaching the vehicle, the officer noticed drug paraphernalia and received a suspicious learner’s permit from the driver, whose appearance did not match the permit’s photo. Further investigation revealed that the passenger did have a valid driver’s license despite initially indicating otherwise. During questioning about drugs, the officer observed a firearm in the car, which led to a search that uncovered fentanyl and other drug-related materials. The driver was ultimately indicted on charges including possession of fentanyl with intent to distribute, possession of a firearm in furtherance of drug trafficking, and being a felon in possession of a firearm. The United States District Court for the Northern District of Ohio oversaw pretrial proceedings marked by the defendant’s attempts to change counsel and disputes regarding acceptance of responsibility in plea negotiations. The district court made statements suggesting it would not grant credit for acceptance of responsibility in any plea, even when plea negotiations remained open. A jury convicted the defendant on all charges, and after evidence surfaced that the defendant continued drug activity while detained, the district court denied a reduction for acceptance of responsibility and sentenced him to a total of 420 months in prison. On appeal, the United States Court of Appeals for the Sixth Circuit reviewed several claims, including improper judicial participation in plea negotiations, denial of a suppression motion, the constitutionality of the felon-in-possession statute as applied, career offender status, and the timing of resentencing. The Sixth Circuit held that although the district court violated Rule 11(c)(1) by improperly participating in plea discussions, the error was harmless because the defendant was not prejudiced. The court also affirmed the denial of the suppression motion, upheld the constitutionality of the firearm conviction, agreed with the career offender classification, and found no reversible error in the resentencing process. The convictions and sentences were affirmed. View "United States v. Hoover" on Justia Law

Boa-Bonsu v. Owusu

2026-06-22T12:00:47-08:00

A mother removed her eight-year-old son, B.B., from Finland, where he had lived his entire life, to the United States, in violation of a Finnish joint custody agreement with the child’s father. The parents had previously separated amid the mother’s allegations of abuse, though those allegations were disputed and did not involve direct harm to B.B. After the mother settled in Ohio, the father filed a petition in federal court pursuant to the Hague Convention on the Civil Aspects of International Child Abduction, seeking the child’s return to Finland. The United States District Court for the Southern District of Ohio conducted a two-day hearing, including an in-camera interview with the child. The district court found that the father established a wrongful removal under the Convention. The court then examined the mother’s defenses under Article 12 and Article 13, rejecting claims of consent and grave risk of harm. Ultimately, the district court found that the age and maturity exception applied: B.B., though only eight, was found sufficiently mature for his views to be considered, and he clearly objected to returning to Finland for several particularized reasons. The court also found no clear evidence of undue influence by the mother over the child’s testimony. On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s factual findings for clear error and its legal conclusions de novo. The Sixth Circuit held that the district court did not clearly err in finding B.B. sufficiently mature or in crediting his particularized objections to return. The court further found no clear error in the district court’s assessment of the absence of undue influence. The Sixth Circuit affirmed the district court’s denial of the petition for return. View "Boa-Bonsu v. Owusu" on Justia Law

NetChoice, LLC v. Yost

2026-06-18T13:00:38-08:00

The case concerns a challenge to Ohio’s Parental Notification by Social Media Operators Act, which requires operators of certain social media platforms to obtain verifiable parental consent before unemancipated children under sixteen can enter into contracts to use their services. The Act defines covered operators based on features such as enabling social interaction, profile creation, and content sharing, and details factors to determine whether a site targets or is likely to be accessed by minors. The law imposes civil penalties for non-compliance and grants enforcement authority to the Ohio Attorney General. When the Act was set to take effect, NetChoice, LLC—a trade association representing major online platforms—sued the Ohio Attorney General in the United States District Court for the Southern District of Ohio. NetChoice argued the Act was unconstitutional on First Amendment and vagueness grounds, asserting that it would chill protected speech and was impermissibly vague about which platforms were covered. The district court agreed, finding that NetChoice had standing, that the Act was a facially unconstitutional content-based restriction on speech that failed strict scrutiny, and that it was unconstitutionally vague. The court permanently enjoined enforcement of the Act. The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court’s judgment. The appellate court held that NetChoice lacked third-party standing to assert the First Amendment rights of its members’ minor users due to a conflict of interest between the trade group and the affected minors. The court further found that, even considering NetChoice’s own First Amendment and vagueness claims, NetChoice failed to show the Act was facially unconstitutional. The Sixth Circuit held that the Act, while content-based and subject to strict scrutiny, was narrowly tailored to compelling state interests in protecting children and was not impermissibly vague in all its applications. The case was remanded for entry of judgment in favor of the Attorney General. View "NetChoice, LLC v. Yost" on Justia Law

Rubicon Real Estate Holdings v. City of Pontiac

2026-06-18T13:00:38-08:00

A Michigan-based real estate developer and related parties sought to redevelop a commercial property in the City of Pontiac to include medical marijuana cultivation and processing facilities. After purchasing the property in 2019, the developer obtained rezoning approval from the city, but the process of securing required permits and special exceptions for tenants became protracted. The city clerk cited deficiencies in tenant applications and, at one point, argued that the project violated city ordinances regarding overlay districts for marijuana businesses. Despite eventual approvals—including a court order requiring the city to issue permits—the tenants withdrew due to the delays, and the project collapsed. Subsequently, the developer’s affiliate lost another business opportunity, which plaintiffs attributed to city officials’ retaliation. The plaintiffs filed suit in Oakland County Circuit Court, seeking injunctive, declaratory, and monetary relief, and later brought civil rights claims under 42 U.S.C. § 1983 in the United States District Court for the Eastern District of Michigan. The district court granted summary judgment for the city and the city clerk, finding insufficient evidence of constitutional violations and concluding that the delays and alleged retaliation did not violate the plaintiffs’ rights. On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The court held that the plaintiffs lacked a cognizable property interest under the Due Process Clause because city approval for marijuana facilities was discretionary, not a matter of right. The court also found that the delays did not constitute a “taking” under the Fifth Amendment, as the length and nature of the delays were not extraordinary. The equal protection claim failed for lack of evidence that similarly situated applicants were treated more favorably. Finally, the court determined that the plaintiffs’ First Amendment retaliation claim could not proceed against the city because the mayor lacked final policymaking authority over zoning and no municipal policy or custom was established. View "Rubicon Real Estate Holdings v. City of Pontiac" on Justia Law

United States v. Harris

2026-06-16T13:00:40-08:00

Samuel Harris established a medical marketing company, Secure Health, to promote cancer-screening tests to Medicare and Medicaid recipients. The company sent salespeople door-to-door, paid telemedicine providers and employees on a per-patient basis, and referred patients to a laboratory, Crestar, which compensated Secure Health per referral. Crestar billed federal healthcare programs, generating substantial income. Harris sought legal advice regarding the business model; his attorney, Christopher Esseltine, provided a compliance memorandum premised on the belief that employees were paid a flat salary, not per patient. Despite this, Harris paid employees and doctors per patient, raising concerns under the Anti-Kickback Statute, which prohibits remuneration for patient referrals in federally funded healthcare programs. After federal agents investigated Secure Health, Harris was indicted in the United States District Court for the Middle District of Tennessee on several counts, including conspiring to violate the Anti-Kickback Statute and receiving kickbacks for patient referrals. Following a lengthy trial, the jury convicted Harris on counts related to the Anti-Kickback Statute and acquitted him of healthcare fraud charges. The district court sentenced Harris to 30 months, below the guideline range. The United States Court of Appeals for the Sixth Circuit reviewed Harris’s appeal, focusing on three main issues: the district court’s refusal to instruct the jury on an advice-of-counsel defense, denial of a mistrial following a prosecutorial remark, and exclusion of a full recording as hearsay evidence. The Sixth Circuit held that Harris failed to fully disclose pertinent facts to his attorney, specifically the per-patient payment structure, and thus was not entitled to the advice-of-counsel instruction. The court also found no abuse of discretion in denying a mistrial or in the evidentiary ruling. The convictions and sentence were affirmed. View "United States v. Harris" on Justia Law

Baro v. Blanche

2026-06-16T13:00:40-08:00

The petitioner, a native of Guinea, entered the United States in 2015 after suffering severe abuse in her home country, including female genital mutilation and physical violence from an arranged marriage. She overstayed her nonimmigrant visa due to credible threats from her ex-husband if she returned. In 2022, she was charged as removable for overstaying her visa. She applied for asylum, withholding of removal, and protection under the Convention Against Torture, but an immigration judge denied all relief. The judge found her asylum claim untimely, determined her abuse was not on account of a protected ground for withholding, and ruled she did not establish government acquiescence to torture. After the immigration judge’s denial in June 2024, the petitioner was promptly informed of her right to appeal to the Board of Immigration Appeals (BIA), which required filing within 30 days. She sought new counsel but was hospitalized for several days due to a severe sickle-cell crisis and remained in pain for months. She did not attempt to appeal until she began feeling better in September 2024, eventually retaining new counsel in late October. The appeal was not filed until December 2024, over five months after the deadline. The BIA denied her motion for equitable tolling, concluding she failed to show extraordinary circumstances or due diligence, particularly because she offered insufficient medical documentation for her incapacity and delayed further even after retaining counsel. The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the 30-day deadline for appealing to the BIA is a non-jurisdictional claim-processing rule, not a jurisdictional bar. The court further held that the BIA’s equitable tolling decision is subject to deferential review and that the BIA did not abuse its discretion in finding a lack of due diligence. Accordingly, the Sixth Circuit denied the petition for review. View "Baro v. Blanche" on Justia Law

Hall v. Trivest Partners L.P.

2026-06-16T13:00:40-08:00

Several Michigan residents purchased expensive solar-panel systems from a company that promised substantial reductions in their electricity bills. The company’s advertising, prepared in part by entities connected to Trivest Partners, promoted significant savings and government payments, but the plaintiffs experienced little to no reduction in their bills and, in some cases, saw increases. The company, which operated in both Michigan and Florida, later went bankrupt. Alleging fraud and racketeering violations, the plaintiffs brought a civil RICO action and a Michigan Consumer Protection Act claim against Trivest Partners, its affiliates (all Florida entities), and the company founder. In the United States District Court for the Eastern District of Michigan, the two Florida-based Trivest defendants moved to dismiss for lack of personal jurisdiction, arguing that the civil RICO statute did not allow them to be sued in Michigan, as a court in Florida could exercise jurisdiction over all defendants. The district court denied the motion, holding that several practical factors—including the pending status of the case in Michigan, local counsel, and comparative convenience—favored retaining jurisdiction. The plaintiffs later added additional Trivest-related defendants, also Florida citizens, with the court again finding personal jurisdiction. The United States Court of Appeals for the Sixth Circuit reviewed the district court’s interpretation of 18 U.S.C. § 1965(b) de novo. The appellate court held that the district court’s reasons, grounded in convenience and practical considerations, were insufficient as a matter of law to satisfy the “ends of justice require” standard under § 1965(b). The Sixth Circuit concluded that interests of convenience alone cannot justify asserting personal jurisdiction over defendants with no minimum contacts to the forum. The court reversed the district court’s order denying dismissal and vacated the order denying the Trivest defendants’ motions to compel arbitration. View "Hall v. Trivest Partners L.P." on Justia Law

United States v. Herrell

2026-06-16T13:00:38-08:00

Three physicians—Evann Herrell, Mark Grenkoski, and Keri McFarlane—worked at Express Health Care, a clinic claiming to treat opioid addiction but operating as a pill mill. The clinic prescribed controlled substances in high volumes for cash, disregarding legitimate medical standards. Doctors spent minimal time with patients, ignored signs of diversion, and falsified records. EHC also submitted fraudulent Medicare claims by ordering unnecessary drug tests. McFarlane eventually cooperated with the FBI. Herrell, Grenkoski, and McFarlane were among the few who went to trial after most other clinic staff pleaded guilty. The United States District Court for the Eastern District of Kentucky conducted a 30-day jury trial, resulting in convictions for conspiracy to distribute controlled substances, falsifying medical records, wire and health care fraud, and money laundering. The defendants filed post-trial motions for acquittal and new trials, which the district court denied. Each defendant was sentenced to prison and filed timely appeals, raising challenges related to sufficiency of the evidence, evidentiary rulings, jury instructions, trial severance, and sentencing. The United States Court of Appeals for the Sixth Circuit reviewed the case. Applying the appropriate standards of review—including abuse of discretion for evidentiary and severance decisions and de novo review for legal questions—the court found sufficient evidence to support all convictions. It held the challenged evidentiary rulings were either correct or harmless. The jury instructions appropriately conveyed the required mens rea under Supreme Court precedent. The court determined that denial of severance for McFarlane was not an abuse of discretion and that cumulative error did not warrant reversal. Grenkoski’s challenge to sentencing correction was rejected due to jurisdictional limits. The Sixth Circuit affirmed all convictions and sentences. View "United States v. Herrell" on Justia Law

United States v. Taylor

2026-06-16T13:00:38-08:00

In this case, the defendant was involved in a car accident in the early morning hours, after which a witness observed him exiting the overturned vehicle with a bag containing drugs and a firearm. When the witness refused to take the bag, the defendant hid it by the roadside and left the scene in another vehicle. Police later recovered the bag, which contained cocaine, a loaded revolver, and ammunition. The vehicle was registered to the defendant. The government’s key witness at trial testified about the defendant’s actions, and his testimony was the only direct evidence linking the defendant to the bag. After the first trial, the defendant was convicted on all counts: possession with intent to distribute cocaine, possession of a firearm in furtherance of drug trafficking, and being a felon in possession of a firearm. However, the United States Court of Appeals for the Sixth Circuit reversed those convictions, finding that the United States District Court for the Eastern District of Kentucky had improperly limited the defendant’s ability to cross-examine the witness about matters relevant to his bias and motivation. A retrial followed, during which the defendant sought to obtain more information about the witness’s criminal history and potential benefits received for his testimony, but was unable to secure expunged records from state court officials. Upon appeal after the second trial, the United States Court of Appeals for the Sixth Circuit reviewed whether the District Court’s refusal to compel production of the witness’s criminal file and its limitations on cross-examination violated the defendant’s rights under the Confrontation Clause. The Sixth Circuit held that the Confrontation Clause does not grant a defendant a pretrial right to compelled discovery of documents for cross-examination purposes, and that the District Court allowed sufficient latitude for cross-examination to satisfy constitutional requirements. The judgment of conviction was affirmed. View "United States v. Taylor" on Justia Law

Reguli v. Hetzel

2026-06-16T13:00:37-08:00

A lawyer and parents’ rights activist assisted her client in evading a Tennessee juvenile court’s order that awarded temporary custody of the client’s child to the Department of Children’s Services. The client, a single mother, fled with her daughter after being investigated for suspected child neglect. The lawyer joined the client and child at a hotel, and when they received a missing child alert, they disabled their phones and went to the lawyer’s home to avoid authorities. The police located them the following day, and the state took custody of the children. After an extended custody dispute, the state returned the children and dismissed its petition. While the custody case was ongoing, the Department of Children’s Services and local police investigated and eventually indicted both the lawyer and her client on charges related to custodial interference. Both were convicted by juries, but on appeal, the Tennessee Court of Criminal Appeals vacated the convictions. The appellate court concluded that the statute at issue required proof that the alleged interference occurred after a period of lawful visitation, an element not present in this case. The lawyer and her client then filed a federal suit in the United States District Court for the Middle District of Tennessee, alleging malicious prosecution, conspiracy, and other claims against various officials and the City of Brentwood. The district court dismissed all claims, holding that the defendants were entitled to qualified or absolute immunity and that the Monell claim against the city failed because the officers lacked final policymaking authority. On appeal, the United States Court of Appeals for the Sixth Circuit affirmed. The Sixth Circuit held that the individual defendants were entitled to immunity and that the Monell claim failed as a matter of law. The court confirmed that the law provides no recourse against prosecutors and officers acting within their respective protected functions under these circumstances. View "Reguli v. Hetzel" on Justia Law

Ahmed v. Hamtramck Public Schools

2026-06-15T12:00:46-08:00

During the COVID-19 pandemic, the Superintendent of Hamtramck Public Schools took voluntary medical leave under the Family and Medical Leave Act (FMLA). When she prepared to return, the school district placed her on paid administrative leave pending an investigation into alleged misconduct. While on leave, she filed charges of discrimination with government agencies and was not allowed to return to her duties for over a year. She alleged that these actions were the result of retaliation and discrimination after she had involuntarily reassigned several teachers, which had sparked conflict with the school board and teachers’ union. While still on paid leave, the Superintendent filed suit in the United States District Court for the Eastern District of Michigan against the school district, several board members, and the teachers’ union, alleging multiple claims including discrimination based on disability, sex, and national origin, as well as retaliation. She attempted to amend her complaint multiple times. The district court denied her motion to file a Fourth Amended Complaint, holding that the proposed amendments were futile, and granted the defendants’ motions to dismiss the original complaint with prejudice. She then appealed. The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial of leave to amend de novo. The appellate court held that the district court erred in finding that her proposed claims for FMLA retaliation and Title IX sex discrimination were futile. The Sixth Circuit concluded that her allegations plausibly stated claims under both statutes, applying the correct legal standards. The appellate court vacated the district court’s dismissal, reversed its futility determination, and remanded the case so the plaintiff could proceed with her amended complaint. View "Ahmed v. Hamtramck Public Schools" on Justia Law

United States v. White

2026-06-15T12:00:46-08:00

Karl White operated a significant drug trafficking organization in Kalamazoo, Michigan, amassing substantial wealth and repeatedly evading law enforcement until his arrest following a sting operation. He was charged with multiple drug and firearm offenses, with evidence at trial including witness testimony of violence and intimidation against those who cooperated with authorities. The jury convicted him on all counts, and after a resentencing prompted by an earlier appeal correcting the drug quantity attributed to him, he received a 35-year prison sentence. Following his incarceration, White developed severe medical issues, including paralysis and blindness resulting from meningitis, and later experienced mental health challenges. Despite these conditions, he was reported to have verbally abused prison staff. In 2025, White sought compassionate release from the United States District Court for the Western District of Michigan, arguing that his deteriorated health constituted an “extraordinary and compelling” reason for sentence reduction. The district court agreed that his condition was extraordinary but denied release, reasoning that the seriousness of his crimes, the need to deter similar conduct, and the ongoing risk he posed to the public outweighed his medical hardships. The United States Court of Appeals for the Sixth Circuit reviewed the denial for abuse of discretion. The court found that the district court had properly considered the relevant sentencing factors under 18 U.S.C. § 3553(a), sufficiently addressed White’s arguments regarding his health and risk to the public, and provided a reasoned explanation for its decision. The appellate court held that disagreement with how the district court balanced these factors did not warrant reversal and that the district court had acted within its wide discretion. The Sixth Circuit affirmed the district court’s denial of compassionate release. View "United States v. White" on Justia Law

United States v. Hamaed

2026-06-12T11:00:39-08:00

Several pharmacists in Michigan and Ohio operated independent pharmacies where they engaged in fraudulent billing practices. Rather than reversing insurance claims for prescriptions that were never picked up by patients, these pharmacists intentionally left the claims uncorrected, thereby receiving payments for medications that were not actually dispensed. They also increased the volume of such claims by waiving copays and substituting generic drugs for brand-name ones while billing for the more expensive medication. An audit by Qlarant, a government contractor, uncovered that the pharmacies had billed Medicare and Medicaid for far more medication than they had purchased, resulting in significant financial losses to insurers. The United States District Court for the Eastern District of Michigan tried four of the charged pharmacists after their co-defendants pleaded guilty. A jury convicted all four of conspiracy to commit healthcare and wire fraud, with additional healthcare fraud convictions for two defendants. The district court granted a motion for acquittal on some substantive counts, sentenced the defendants to terms ranging from 24 to 120 months, and imposed restitution obligations commensurate with their roles in the scheme. The defendants appealed, raising issues about the admission of expert testimony, evidentiary rulings, variance from the indictment, jury polling, sentencing enhancements, and restitution orders. The United States Court of Appeals for the Sixth Circuit reviewed the convictions and sentences. It held that the admission of the government’s expert testimony did not violate the Confrontation Clause, that the district court properly excluded certain defense evidence and did not err in qualifying the expert in front of the jury, and that the evidence supported a single overarching conspiracy. The court also found no error in the calculation of loss amounts, enhancements for sophisticated means, or the procedure and amount of restitution. The Sixth Circuit affirmed the judgments of the district court. View "United States v. Hamaed" on Justia Law

Ward v. Brotzke

2026-06-12T11:00:38-08:00

A man was observed by Detroit police officers in a convenience store with a partially concealed handgun. Upon being questioned, he admitted he did not have a concealed pistol license. An officer ordered him to keep his hands raised, but he failed to comply and instead pulled out the weapon, pushing the officer and attempting to flee. Two other officers responded; one fired twice but missed, while another fired several shots as the man moved toward the exit, hitting him multiple times. The man survived and subsequently sued the officers for excessive force under both federal and Michigan state law. The United States District Court for the Eastern District of Michigan granted summary judgment for the officers, finding they were protected by qualified immunity. The plaintiff appealed, but only pursued claims against the two officers who fired their weapons, abandoning his claims against the third officer. The district court’s decision was based on its determination that the officers had not violated the plaintiff’s constitutional rights and were entitled to immunity. The United States Court of Appeals for the Sixth Circuit reviewed the district court’s grant of summary judgment de novo, considering the facts most favorably to the plaintiff and using video evidence to resolve disputed facts. The court held that the officer who fired and hit the plaintiff seized him, but that the officer who fired and missed did not seize him under the Fourth Amendment. The court further concluded that the force used by the officer who struck the plaintiff was reasonable, given the circumstances and the officer’s perception of an immediate threat. The Sixth Circuit also found that both officers were entitled to state-law immunity for assault and battery claims under Michigan law. The district court’s judgment was affirmed. View "Ward v. Brotzke" on Justia Law

Boddy v. Grech

2026-06-10T12:30:37-08:00

At a school board meeting in Xenia, Ohio, a member of the public sought to use her allotted time during the public comment period to criticize the school district’s handling of alleged critical race theory instruction, as well as the conduct of the superintendent and board. Although her remarks were calmly delivered, board president Mary Grech interrupted her, threatened to cut her microphone, and eventually did so, recessing the meeting amid disruptions from the audience. The speaker was not permitted to complete her five-minute comment, nor was she allowed additional time after the meeting resumed. The individual who was silenced brought a lawsuit against the school board and its president under 42 U.S.C. § 1983, arguing that her First Amendment rights were violated. She sought a preliminary injunction to prevent enforcement of the board’s public comment policy against her in the future. The United States District Court for the Southern District of Ohio conducted a hearing and denied the request for a preliminary injunction. The court concluded that the plaintiff had not demonstrated a strong likelihood of success on the merits or irreparable harm, and found the facts and motives for the board president’s actions to be equivocal. The United States Court of Appeals for the Sixth Circuit reviewed the matter and reversed the district court’s denial of the preliminary injunction. The appellate court held that the plaintiff’s speech—critical of school officials—was protected by the First Amendment and did not fall into any unprotected category. The court found that the board president engaged in impermissible viewpoint discrimination by curtailing speech because of its critical content, and also ratified a heckler’s veto by silencing the speaker rather than the disruptive audience. The Sixth Circuit concluded that the plaintiff demonstrated a strong likelihood of success on the merits and that irreparable harm to constitutional rights was presumed. The case was remanded with instructions to grant the preliminary injunction. View "Boddy v. Grech" on Justia Law

Voutsiotis v. PNC Bank, NA

2026-06-08T11:02:25-08:00

An individual named Antonas established investment entities and solicited funds from members of his community, ultimately losing much of the invested money and covering up losses through fraudulent means. After Antonas’s actions came to light, and following his death by suicide, a group of investors initiated several lawsuits against various parties, including Antonas’s estate, other investors, a brokerage firm, and, in this particular action, a bank (PNC) and one of its employees (Koutrodimos), alleging that the bank and its employee facilitated or failed to prevent Antonas’s fraud. The case was originally filed in an Ohio state court, but PNC removed it to the United States District Court for the Northern District of Ohio, asserting that the non-diverse defendant (Koutrodimos) had been fraudulently joined to defeat diversity jurisdiction. The district court agreed, dismissed Koutrodimos from the lawsuit, denied the plaintiffs’ motion to remand to state court, and subsequently granted PNC’s motion to dismiss for failure to state a claim. The plaintiffs appealed these decisions. The United States Court of Appeals for the Sixth Circuit reviewed the district court’s rulings de novo where appropriate. The court held that the plaintiffs had no colorable claim against the non-diverse PNC employee because the complaint failed to allege specific fraudulent acts, did not establish a duty of disclosure under Ohio law, and included causes of action (such as aiding and abetting fraud) not recognized under Ohio law. Regarding PNC, the court found that the Ohio Uniform Fiduciary Act barred the claims, as the complaint did not plausibly allege PNC’s actual knowledge or bad faith in connection with Antonas’s misconduct. The court affirmed the district court’s denial of remand and dismissal of all claims against both defendants. View "Voutsiotis v. PNC Bank, NA" on Justia Law

Dodaj v. Blanche

2026-06-08T11:02:25-08:00

An individual who immigrated to the United States from Albania as a child and later became a lawful permanent resident was found removable due to convictions for a firearms offense and two crimes involving moral turpitude. His criminal history included larceny, attempted home invasion, driving-related offenses, and forgery. Despite these convictions, the Immigration Judge found that the hardships his removal would cause his family—particularly his ailing mother—outweighed the negative factors and granted cancellation of removal. Following this decision, the Department of Homeland Security appealed to the Board of Immigration Appeals (the Board). The Board reversed the Immigration Judge, concluding that the individual's positive equities did not outweigh his substantial criminal record and vacated the grant of cancellation, ordering his removal to Albania. The individual then petitioned for review of the Board’s decision and separately sought reconsideration and reopening before the Board, arguing procedural and substantive errors regarding his removability. The Board denied his motion for reconsideration, citing waiver of removability challenges, lack of entitlement to relief under new legal authority, and absence of new material evidence. The United States Court of Appeals for the Sixth Circuit reviewed both petitions. The court held that it lacked jurisdiction to review the Board’s discretionary denial of cancellation of removal, as the challenge was based on disagreement with the Board’s weighing of discretionary factors, not on legal or constitutional grounds. The court further held that the individual had waived his challenge to the removability finding by failing to appeal it and that the Board was not required to revisit that issue. The Sixth Circuit therefore denied both petitions for review. View "Dodaj v. Blanche" on Justia Law

Halbower v. Hiscox Syndicate 33 of Lloyd's of London

2026-05-29T12:00:39-08:00

A fire destroyed the home of Julie and Matthew Halbower in Michigan, resulting in the loss of five valuable artworks held by the Halbower Legacy Trust. Three of the paintings were acknowledged as covered under an insurance policy procured through a Lloyd’s Broker, with Hiscox Syndicate 33 listed as the underwriter. Hiscox paid for those three but denied coverage for two others, claiming they were not included in the insurance schedule held by the Lloyd’s Broker. Julie, as trustee, then sued Hiscox for breach of contract and declaratory judgment in Michigan state court, seeking the value of the two denied paintings. After removal to the United States District Court for the Western District of Michigan, Hiscox moved to dismiss the action. The district court granted the motion, finding that the insurance policy only covered works listed in the schedule maintained by the Lloyd’s Broker, and thus the denied paintings were not covered. Julie appealed that decision. The United States Court of Appeals for the Sixth Circuit reviewed the case and focused on whether diversity jurisdiction was properly established. The court explained that the citizenship of the Lloyd’s Syndicate for jurisdictional purposes depends on the citizenship of each underwriting member (known as "Names"), not just the Managing Agent. The district court had relied only on the Managing Agent’s citizenship, which was insufficient. The Sixth Circuit vacated the district court’s dismissal and remanded the case for further proceedings, including discovery to establish the citizenship of each underwriting Name of Hiscox Syndicate 33, as required for diversity jurisdiction under 28 U.S.C. § 1332(a). View "Halbower v. Hiscox Syndicate 33 of Lloyd's of London" on Justia Law

Dannah v. City of Grand Rapids

2026-05-29T12:00:39-08:00

During a late-night traffic stop in Grand Rapids, Michigan, officers pulled over a vehicle for a traffic violation. The driver consented to a search of the car. Officers asked passenger Fahirri Dannah to exit the vehicle and attempted to frisk him for weapons. Despite repeated commands to place his hands on his head, Dannah moved his hands toward his waist and disregarded officers’ instructions. As the frisk began, Dannah pulled away and attempted to flee. Officers tackled him, and during a prolonged struggle marked by Dannah’s resistance, they used physical force, including punching and restraining him, until he was handcuffed. Dannah was arrested for assault, battery, and resisting a police officer. Dannah subsequently filed a federal lawsuit under 42 U.S.C. § 1983 against the officers and the City of Grand Rapids, alleging unlawful search, seizure, and excessive force. The United States District Court for the Western District of Michigan granted summary judgment to Officer Kaiser on the search and seizure claims and to the City on the Monell claim, but denied summary judgment to several officers on the excessive force claims, rejecting their qualified immunity defense. The United States Court of Appeals for the Sixth Circuit reviewed the denial of qualified immunity. The court held that, even taking the facts in Dannah’s favor, precedent did not clearly establish that the officers’ use of force in response to Dannah’s active, physical resistance during an interrupted frisk was excessive under the Fourth Amendment. The court distinguished prior cases cited by Dannah and concluded that the officers did not violate any clearly established law. Therefore, the court reversed the district court’s denial of qualified immunity to the officers on the excessive force claims. View "Dannah v. City of Grand Rapids" on Justia Law

Nwosu v. Blanche

2026-05-29T12:00:38-08:00

A Nigerian citizen entered the United States in 2002 on a business visa, which expired the following year. He remained in the country, married, later separated, and began living with a new partner, a U.S. citizen, with whom he has three children. The government initiated removal proceedings against him in 2010. He conceded removability but sought withholding of removal, alleging he would face danger in Nigeria due to his father’s kidnapping in 2004, and applied for cancellation of removal based on the potential hardship to his children if he were deported. An immigration judge denied both forms of relief. For withholding of removal, the judge found the petitioner credible but ruled that he failed to sufficiently corroborate his testimony about his father’s kidnapping, as he did not provide police, court records, or affidavits from family members that would support his claims. For cancellation of removal, the judge determined the petitioner had not shown that his removal would impose the required “exceptional and extremely unusual hardship” on his children, noting that the children would remain in the U.S., are healthy, and that their mother works full-time as a nurse. The Board of Immigration Appeals affirmed the immigration judge's decision on both grounds. The United States Court of Appeals for the Sixth Circuit reviewed the Board’s decision, applying a highly deferential standard for factual findings. The court held that a reasonable factfinder could require corroborating evidence for the kidnapping claim and that the petitioner had adequate opportunity to explain its absence. Regarding cancellation of removal, the court found that the evidence did not compel a finding of the requisite hardship to the petitioner’s children. The court denied the petition for review, upholding the decisions of the Board of Immigration Appeals and the immigration judge. View "Nwosu v. Blanche" on Justia Law

United States v. Miclaus

2026-05-29T12:00:37-08:00

Between 2007 and 2016, a group operating from Romania, including the defendant, engaged in a range of cybercrimes targeting U.S. victims. Their activities included an eBay auction fraud scheme, cryptocurrency mining, and identity theft, which together infected tens of thousands of computers and resulted in millions of dollars in losses. The defendant, along with two co-conspirators, was indicted on multiple counts, including conspiracy to commit wire fraud, aggravated identity theft, and money laundering. One co-conspirator pleaded guilty, while the defendant and another went to trial and were convicted on all counts except for a sentencing enhancement. The United States District Court for the Northern District of Ohio initially sentenced the defendant to 216 months' imprisonment and did not impose restitution, after the government stated it was not seeking restitution at that time. In contrast, the co-conspirator who pleaded guilty was ordered to pay substantial restitution. The defendant appealed certain sentencing enhancements, and the United States Court of Appeals for the Sixth Circuit affirmed some enhancements, reversed others, and remanded the case for resentencing. On remand, the district court treated the remand as a general one, held a de novo resentencing, and imposed restitution for the first time in the amount of $853,651.99, to be shared jointly and severally with co-defendants. The defendant did not object to restitution at resentencing but subsequently appealed, arguing that restitution had been waived, that he was denied access to the underlying restitution information, and that the imposition of restitution was vindictive. The United States Court of Appeals for the Sixth Circuit held that, under its precedent, a general remand permits the government to seek restitution even if it was previously waived, and that restitution was mandatory under the relevant statute. However, the court found plain error in the process used, as the defendant was not provided with the underlying restitution information as required. The court affirmed the imposition of restitution but vacated and remanded for resentencing on the restitution amount. View "United States v. Miclaus" on Justia Law

Flight Options, LLC v. United States

2026-05-27T13:00:38-08:00

Flight Options, a company providing fractional-share private jet services, charged its clients both fixed monthly management fees (covering overhead, maintenance, and administrative costs) and usage fees based on actual flight time. For years, Flight Options, consistent with industry practice and IRS guidance, collected federal excise tax only on the usage fees, not the fixed fees. This approach was based on the understanding that the excise tax under 26 U.S.C. § 4261 applied only to payments for actual air transportation, not general overhead. The Internal Revenue Service later changed its position and assessed approximately $39 million in taxes, interest, and penalties against Flight Options for the period between 2009 and 2012, claiming the excise tax should also have been collected on the fixed management fees. Flight Options challenged the assessment in the United States District Court for the Northern District of Ohio. The magistrate judge ruled in favor of the government, holding that the fixed fees were subject to the excise tax and imposing penalties for failure to collect. Upon appeal, the United States Court of Appeals for the Sixth Circuit reviewed the statutory language, context, and relevant regulations. The court found that the excise tax applies only to amounts paid for specific flights (usage fees) and not to fixed overhead or management charges. The court emphasized the need for "precise and not speculative" notice to third-party tax collectors before imposing withholding obligations, which the IRS had not provided regarding fixed fees. The court also rejected the government's argument that informal IRS guidance or internal memoranda could create such an obligation. Accordingly, the Sixth Circuit reversed the judgment of the district court, holding that Flight Options was not liable for the assessed taxes, interest, or penalties on the fixed fees. View "Flight Options, LLC v. United States" on Justia Law

Reinhardt v. Prince

2026-05-27T13:00:37-08:00

A property owner in Bay County, Michigan, failed to pay property taxes in 2019, resulting in the county initiating a foreclosure process under Michigan’s General Property Tax Act (GPTA). After a three-year timeline, a Michigan circuit court entered a foreclosure judgment in February 2022, which would vest absolute title in the county treasurer if the tax debt was not paid by March 31, 2022. The owner did not pay, and the county received title. Shortly after, the owner filed for Chapter 13 bankruptcy and sought to avoid the transfer of title as a preferential transfer under the Bankruptcy Code. The county treasurer withdrew the property from auction due to the bankruptcy filing. The parties stipulated to key facts, including the amount of debt, estimated property value, and minimum bid, but disputed whether the transfer met the requirements for avoidance under 11 U.S.C. § 547(b). The United States Bankruptcy Court for the Eastern District of Michigan granted summary judgment to the county treasurer, finding that although the transfer occurred within the 90-day lookback period, the owner failed to satisfy the "more than" test under § 547(b)(5). The United States District Court for the Eastern District of Michigan affirmed, agreeing that the owner could not show the transfer enabled the treasurer to receive more than he would in a hypothetical Chapter 7 liquidation. Upon appeal, the United States Court of Appeals for the Sixth Circuit reviewed the legal conclusions de novo and factual findings for clear error. The Sixth Circuit held that the transfer occurred within the 90-day lookback period, and that the owner established the transfer was preferential under § 547(b)(4) and § 547(b)(5), specifically because the treasurer would receive a 5% sales commission not available in Chapter 7 liquidation. The district court’s judgment was reversed. View "Reinhardt v. Prince" on Justia Law

Estate of Worrell v. Thang, Inc.

2026-05-27T13:00:37-08:00

George Bernard Worrell, Jr., a foundational member and arranger for the musical group Parliament-Funkadelic, collaborated with George Clinton and Thang, Inc. from 1969 to 1981. In 1976, Worrell was presented with a contract (the “1976 Agreement”) by Thang, Inc., which purported to grant Thang full ownership of sound recordings Worrell contributed to, in exchange for royalties. Over the years, Worrell and his estate asserted that Thang and Clinton failed to pay royalties due under this agreement. Worrell died in 2016, and his estate became the plaintiff in subsequent litigation. After Worrell’s estate sued Thang and Clinton in New York state court for breach of contract related to the 1976 Agreement, the New York Supreme Court dismissed the suit. The court found that the agreement was not enforceable because it had not been signed by Thang, and the estate did not refute this. Subsequently, the estate filed a new action in the United States District Court for the Eastern District of Michigan, seeking a declaration of joint copyright ownership in the sound recordings and an accounting of royalties. The district court granted summary judgment for the defendants on statute of limitations grounds, holding that the estate’s copyright claims were untimely. The United States Court of Appeals for the Sixth Circuit reviewed the case and determined that genuine disputes of material fact precluded summary judgment. The court held that, given the unique circumstances—including the parties’ decades-long conduct in apparent reliance on the 1976 Agreement—there was a factual question as to whether Clinton and Thang had “plainly and expressly repudiated” Worrell’s copyright co-ownership before 2020. The Sixth Circuit reversed the district court’s judgment and remanded for further proceedings, holding that part of the estate’s copyright-ownership claim is timely. The court also found genuine disputes of material fact as to Worrell’s status as a co-author of the recordings. View "Estate of Worrell v. Thang, Inc." on Justia Law

Cotton v. Hughes

2026-05-22T12:30:59-08:00

Two men were convicted of murder in Michigan in 2001, based on eyewitness identification and the testimony of a jailhouse informant. Years later, new evidence emerged suggesting that key witness testimony was fabricated, critical exculpatory evidence was withheld, and that two police officers were involved in this misconduct. The plaintiffs’ convictions were vacated in 2020 after nearly two decades of imprisonment, following an investigation by the Wayne County Conviction Integrity Unit, which found the original trials fundamentally unfair. After their release, the men filed suit in the United States District Court for the Eastern District of Michigan, alleging violations of their constitutional rights. They asserted claims under Brady v. Maryland for suppression of favorable evidence, malicious prosecution, and fabrication of evidence under both federal and state law. The two defendant officers sought summary judgment, arguing for qualified immunity, statutory immunity, and invoking the Heck doctrine and collateral estoppel. The district court granted summary judgment on some claims but denied it on others, finding genuine disputes of material fact precluded summary judgment for several claims, including some Brady, malicious prosecution, and fabrication of evidence claims. The officers appealed the partial denial. The United States Court of Appeals for the Sixth Circuit reviewed the case and dismissed the appeal in part for lack of interlocutory jurisdiction over certain issues, such as those involving factual disputes and the Heck doctrine. For the claims over which it had jurisdiction, the Sixth Circuit affirmed the district court’s denial of summary judgment. The court held that the officers were not entitled to qualified immunity or collateral estoppel on the remaining Brady, malicious prosecution, and fabrication of evidence claims, allowing those claims to proceed to trial. The disposition was thus affirmed in part and dismissed in part. View "Cotton v. Hughes" on Justia Law

Ewalt v. GateHouse Media Ohio Holdings II, Inc.

2026-05-22T12:30:59-08:00

Plaintiffs filed a putative class action against GateHouse Media in Ohio state court, alleging claims that met the requirements for federal jurisdiction under the Class Action Fairness Act (CAFA). GateHouse timely removed the case to the United States District Court for the Southern District of Ohio, where the parties litigated for several years. The district court eventually denied class certification and, based on that denial, remanded the case to state court, concluding it could no longer exercise jurisdiction and declining to exercise supplemental jurisdiction over remaining claims. After the case returned to state court, it remained inactive until plaintiffs renewed their motion for class certification. GateHouse then removed the case to federal court a second time, asserting that this renewed motion provided a new basis for removal under CAFA. Plaintiffs moved to remand, arguing the removal was untimely. The district court denied the remand motion, finding that its earlier remand order had created ambiguity about federal jurisdiction and, under principles of equity, tolled the 30-day removal deadline. Plaintiffs sought and were granted interlocutory review by the United States Court of Appeals for the Sixth Circuit. The United States Court of Appeals for the Sixth Circuit held that the 30-day deadline for removal under 28 U.S.C. § 1446(b)(1) is strict and cannot be equitably tolled, as clarified by the Supreme Court in Enbridge Energy, LP v. Nessel ex rel. Michigan. The Sixth Circuit concluded that GateHouse’s second removal was untimely because the original complaint had already triggered the removal clock, and subsequent events, including renewed class certification efforts, did not restart it. The appellate court reversed the district court’s order and instructed that the case be remanded to state court. View "Ewalt v. GateHouse Media Ohio Holdings II, Inc." on Justia Law

Karacson v. Shaver

2026-05-20T12:30:39-08:00

After a fire destroyed a Michigan home in 2017, investigators determined it was intentionally set, focusing their investigation on the homeowner, Steve Karacson. Evidence included the smell of gasoline, multiple fire origins, cell phone location data placing Karacson near the house just before the fire, and a receipt for gas and gloves purchased hours before the incident. Karacson, who had fire insurance, claimed he was out of state but evidence contradicted this. He was subsequently charged with arson and insurance fraud. Following his plea of not guilty, Karacson sought to replace his court-appointed attorney due to disagreements and grievances. The trial court initially denied his request, but his attorney withdrew, and a second attorney was appointed. This relationship also deteriorated, leading Karacson to request self-representation. On the day of jury selection, after warnings from the court about the risks and complexities of self-representation, Karacson affirmed his desire to proceed pro se, with standby counsel available. After a lunch break, he again requested new counsel, which the court denied due to the timing. Karacson proceeded to represent himself, and a jury convicted him on all counts. He received a seven-year sentence. Karacson appealed to the Michigan Court of Appeals, alleging deprivation of counsel, among other claims. The court rejected his arguments, finding that he had knowingly and voluntarily waived his right to counsel and was not entitled to substitute counsel at trial. The Michigan Supreme Court denied leave to appeal and reconsideration. Karacson then petitioned the United States District Court for the Eastern District of Michigan for habeas relief, claiming a Sixth Amendment violation. The district court denied relief, finding the state court’s determination reasonable, but granted a certificate of appealability. The United States Court of Appeals for the Sixth Circuit affirmed the district court’s denial of habeas relief. The court held that under AEDPA’s highly deferential standard, the Michigan appellate court reasonably found Karacson’s waiver of counsel was knowing, intelligent, and voluntary. The court also determined that Karacson was not faced with a choice between unprepared counsel and no counsel, and thus was not deprived of a voluntary waiver. View "Karacson v. Shaver" on Justia Law

PCC Airfoils, LLC v. Daugherty

2026-05-19T12:30:41-08:00

An engineer who had worked for more than two decades at a manufacturing company resigned after a demotion and accepted a leadership position at a competitor. As he was leaving, the company discovered that he had potentially printed several documents containing confidential information about its products. Although forensic analysis could not confirm that he actually printed these documents, the company concluded he had taken trade secrets and sued him and his new employer, alleging breach of a confidentiality agreement and misappropriation of trade secrets. The company sought a preliminary injunction to prevent disclosure of the alleged secrets and to restrict the engineer’s work with the competitor. The United States District Court for the Northern District of Ohio denied the preliminary injunction. The district court ruled that the company failed to meet its burden by not providing “clear and convincing” evidence for each of the four required factors for a preliminary injunction: likelihood of success on the merits, risk of irreparable harm, risk of harm to others, and the public interest. The court treated each factor as a separate prerequisite, each requiring clear and convincing proof. The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision for abuse of discretion, clarifying that the district court had committed a legal error. The appellate court held that the correct approach is to weigh all four preliminary injunction factors together in a sliding-scale analysis, not to require clear and convincing evidence for each factor individually. It explained that a heightened standard of proof is not mandated unless required by statute, the Constitution, or in rare cases involving unusually coercive government action, none of which applied here. The Sixth Circuit reversed the district court’s decision and remanded the case for reconsideration under the appropriate standard. View "PCC Airfoils, LLC v. Daugherty" on Justia Law

Ansari v. Jimenez

2026-05-14T13:00:38-08:00

The case centers on Alexandre Ansari, who was convicted in Michigan state court of first-degree murder and two counts of assault with intent to commit murder following a shooting incident in Detroit. Despite eyewitness identifications at trial, subsequent investigation by the Wayne County Prosecutor’s Office Conviction Integrity Unit uncovered evidence implicating another individual, Jose Sandoval, and raised doubts about Ansari’s involvement. The Conviction Integrity Unit’s findings criticized Detective Moises Jimenez for failing to investigate Sandoval due to concerns about cartel connections. As a result, Ansari’s convictions and sentence were vacated by the Wayne County Circuit Court, and he was released from prison. Following his release, Ansari filed a federal civil action in the United States District Court for the Eastern District of Michigan under 42 U.S.C. § 1983, alleging that Detective Jimenez had violated his Fourteenth Amendment rights by withholding material exculpatory evidence in violation of Brady v. Maryland and Giglio v. United States. The City of Detroit was dismissed from the suit, leaving Jimenez as the sole defendant. After an initial mistrial, a second jury found in favor of Ansari and awarded him $10 million. The district court denied Jimenez’s motions for judgment as a matter of law, for a new trial, and for qualified immunity. On appeal, the United States Court of Appeals for the Sixth Circuit reviewed three main issues: whether Ansari’s § 1983 claim was barred by Heck v. Humphrey, whether Jimenez was entitled to qualified immunity, and whether a new trial was warranted. The court held that Heck did not bar Ansari’s claim because his convictions had been vacated by a state court. The court also affirmed the denial of qualified immunity, finding the Brady obligations of police officers to be clearly established in the Sixth Circuit. Finally, the court concluded that the district court had not abused its discretion regarding evidentiary rulings, jury instructions, closing arguments, or cumulative error. The Sixth Circuit affirmed the district court’s judgment. View "Ansari v. Jimenez" on Justia Law

Paris v. MacAllister Machinery Co.

2026-05-14T13:00:38-08:00

Daniel Paris, an employee of MacAllister Machinery Company and member of the International Union of Operating Engineers, Local 324, was terminated following a series of disciplinary issues, including performance deficiencies, attendance problems, and violations of company policy. After signing a “last chance” agreement, Paris’s employment was terminated when he violated its terms. Paris claimed he was discriminated against due to his union affiliation and age, and that he was subjected to harsher scrutiny than his peers. He also alleged that after reporting harassment and requesting information about taking leave for mental health issues, he was not properly supported by the Union and ultimately lost his job. Following his termination, Paris filed suit in the United States District Court for the Eastern District of Michigan, asserting claims under the Family and Medical Leave Act (FMLA), the Labor Management Relations Act (LMRA), and the Michigan Elliott-Larsen Civil Rights Act (ELCRA) against both MacAllister and the Union. The district court dismissed the LMRA claims against both defendants for failure to state a claim, finding Paris had not plausibly alleged that the Union breached its duty of fair representation. The court also declined to exercise supplemental jurisdiction over the ELCRA claims. After discovery, the district court granted summary judgment for MacAllister on the remaining FMLA claims. The United States Court of Appeals for the Sixth Circuit affirmed the district court’s decisions. The court held that Paris failed to establish a “serious health condition” under the FMLA because he did not seek treatment or provide required documentation. While it concluded that Paris’s inquiry about FMLA leave was a protected activity, it found MacAllister had legitimate, nondiscriminatory reasons for his termination, unconnected to FMLA retaliation or interference. The appellate court also affirmed dismissal of the LMRA claims, finding Paris did not plausibly allege breach of the Union’s duty or properly preserve related arguments on appeal. View "Paris v. MacAllister Machinery Co." on Justia Law

Mitchell v. Conrad

2026-05-14T13:00:38-08:00

A law enforcement officer conducted a traffic stop of an individual suspected of participating in a series of armed robberies. During the stop, the suspect, D’Juantez Mitchell, did not comply with police orders and drove his vehicle into the officer and toward another officer. In response, the officer shot and killed Mitchell. Mitchell’s estate and children challenged the officer’s use of deadly force, alleging violations of constitutional rights and Kentucky law. The United States District Court for the Western District of Kentucky granted the officer qualified immunity on federal claims brought under 42 U.S.C. § 1983, concluding there was no violation of clearly established federal law. However, the district court denied the officer’s motion for summary judgment on the state-law claims, finding a genuine dispute as to whether the officer acted in subjective good faith, and thus denied Kentucky qualified official immunity. On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial of qualified official immunity under Kentucky law de novo. The appellate court held that the officer’s use of deadly force constituted a discretionary act under Kentucky law and that the plaintiffs failed to provide evidence sufficient to rebut the presumption that the officer acted in good faith. The court found that neither purported inconsistencies in the officer’s testimony nor affidavits concerning his general racial animus created a genuine issue of material fact regarding his subjective intent during the incident. The court emphasized that the video evidence showed the officer and another were in imminent danger when the vehicle moved, supporting the officer’s stated belief that deadly force was necessary. The Sixth Circuit reversed the district court’s denial of qualified official immunity, holding that the officer was entitled to immunity from the state-law claims. View "Mitchell v. Conrad" on Justia Law

United States v. London

2026-05-14T13:00:38-08:00

The defendant was indicted on six federal charges related to two separate incidents—one on November 18, 2021, and another on June 6, 2022. He was ultimately acquitted of all charges arising from the first incident but convicted on three counts stemming from the June 6 event. On that date, law enforcement arrested him in a parking lot after receiving a tip from a confidential informant. Officers discovered a firearm on the driver’s seat of a car he had just exited, along with substantial quantities of drugs, cash, and items commonly associated with drug distribution. During the trial, the prosecution introduced evidence of a prior firearm conviction after defense questioning “opened the door.” The jury found him guilty on charges of being a felon in possession of a firearm, possessing controlled substances with intent to distribute, and possessing a firearm in furtherance of a drug trafficking crime. The United States District Court for the Middle District of Tennessee denied the defendant’s motions for acquittal, a new trial, and a request to interview a juror who had expressed concerns during deliberations. It also denied claims of ineffective assistance of counsel based on an alleged conflict arising after trial, when one of the defense attorneys briefly represented a crime analyst involved in the case. On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the sufficiency of the evidence de novo, the admission of prior conviction evidence for abuse of discretion, and conflict of interest claims de novo for legal conclusions. The appellate court held that sufficient evidence supported all convictions, the district court did not abuse its discretion by admitting the prior conviction, there was no actual conflict of interest affecting trial counsel’s performance, and the district court properly denied post-verdict juror interviews. The Sixth Circuit affirmed the lower court’s judgment. View "United States v. London" on Justia Law

United States v. Mirsad Ramic

2026-05-13T12:00:33-08:00

Mirsad Ramic, a naturalized U.S. citizen originally from Bosnia, traveled from the United States to Syria, where he joined ISIS and participated in the siege of Kobane. The attack resulted in significant civilian displacement and mass casualties. Ramic received military-style training from ISIS, fought on the front lines, and later publicly expressed support for ISIS’s violent acts via social media. After becoming disillusioned with ISIS, he was detained in Turkey for five years before being extradited to the United States, where he was charged with conspiring to provide material support to a foreign terrorist organization and receiving military-type training from such an organization. A jury in the United States District Court for the Western District of Kentucky convicted Ramic on all counts. The district court calculated his Sentencing Guidelines range as 360 to 600 months’ imprisonment but sentenced him to only 101 months, citing his perceived lesser involvement in violence and referencing national sentencing statistics as justification. Both Ramic and the government appealed: Ramic challenged the application of the terrorism sentencing enhancement, while the government argued the sentence was substantively unreasonable and too low. The United States Court of Appeals for the Sixth Circuit affirmed the district court’s application of the terrorism enhancement, holding that “government” in the relevant statute includes entities regardless of U.S. recognition, and that Ramic’s conduct was calculated to affect the United States. However, the Sixth Circuit found the sentence substantively unreasonable, concluding that the district court minimized the seriousness of Ramic’s crimes, over-relied on national sentencing data, and failed to adequately consider the need to protect the public from future crimes. The Sixth Circuit vacated Ramic’s sentence and remanded for resentencing. View "United States v. Mirsad Ramic" on Justia Law

Tumbleson v. Lakota Local Sch. Dist.

2026-05-13T12:00:33-08:00

An art teacher with progressive hearing and vision loss, caused by Usher syndrome, sought approval from her Ohio school district to use paid sick leave for a mandatory three-week out-of-state training course required to obtain a guide dog. The district denied her request for paid leave, reasoning that the training did not qualify as “personal illness” under its sick-leave policy, but allowed her to take unpaid leave as an accommodation under the Americans with Disabilities Act (ADA). She attended the training using unpaid leave, obtained the guide dog, and then, after unsuccessful further communication with the district, brought suit alleging violations of the ADA and the Family and Medical Leave Act (FMLA). The United States District Court for the Southern District of Ohio granted summary judgment for the school district. The court found that her ADA disparate treatment claim failed due to a lack of evidence that nondisabled employees were treated more favorably in similar circumstances. The court also found that the district’s offer of unpaid leave constituted a reasonable accommodation under the ADA, as the law does not require the employer to provide the employee’s preferred accommodation if another reasonable one is offered. Regarding the FMLA claim, the district court concluded that paid sick leave was not required because the school district would not “normally” provide paid sick leave for this type of absence under its policy. The United States Court of Appeals for the Sixth Circuit affirmed. It held that the plaintiff could not prevail on her ADA disparate treatment claim because she failed to show that similarly situated nondisabled employees received paid sick leave for comparable non-illness-related absences. Her failure-to-accommodate claim failed because unpaid leave was a reasonable accommodation, and the ADA does not mandate provision of the employee’s preferred form of leave. The FMLA claim failed because the district’s policy did not normally allow paid sick leave for guide dog training, and the plaintiff did not sufficiently challenge the district court’s interpretation of the policy. View "Tumbleson v. Lakota Local Sch. Dist." on Justia Law

Ibrahim Alzandani v. Hamtramck Public Schools

2026-05-12T13:00:34-08:00

Three Michigan parents alleged that a local public school district systematically denied their children access to special education services required by federal law. One child with autism reportedly received only a few hours of aide support each day, another autistic child was promised speech therapy that was not provided, and a third child with Down syndrome was allegedly denied evaluation and services altogether. In response, two parents filed complaints with the Michigan Department of Education, which found that the school district violated the children’s rights to a free and appropriate public education under the Individuals with Disabilities Education Act (IDEA) and issued corrective action plans. However, none of the parents pursued the IDEA’s due process complaint process. The parents and children instead filed a class action in the United States District Court for the Eastern District of Michigan against the school district, Wayne County Regional Educational Service Agency, and the Michigan Department of Education. They alleged violations of the IDEA, Americans with Disabilities Act, Rehabilitation Act, and Michigan law, seeking injunctive relief and damages. The defendants moved to dismiss, arguing the plaintiffs failed to exhaust IDEA administrative remedies. The district court denied the motion, holding that exhaustion was not required for “systemic” failures, and certified the issue for interlocutory appeal. The United States Court of Appeals for the Sixth Circuit reviewed the appeal and held that the IDEA does not recognize a “systemic violations” exception to its exhaustion requirement. The court ruled that parents must pursue the IDEA’s due process hearing before filing suit, even in cases alleging district-wide failures related to staffing and funding. The court concluded that none of the recognized exceptions to exhaustion applied and reversed the district court’s decision, foreclosing the lawsuit until administrative remedies are exhausted. View "Ibrahim Alzandani v. Hamtramck Public Schools" on Justia Law

Fischer v. Thomas

2026-05-12T13:00:34-08:00

Two individuals campaigned for judicial positions in Kentucky’s 2022 elections. During their campaigns, they publicly described themselves using terms such as “conservative,” “Republican,” or “the Conservative Republican,” and one used a generic elephant image. They also received, but did not solicit, endorsements from Republican committees and pro-life organizations, which were referenced or visually displayed in campaign materials. Their conduct prompted complaints to the Kentucky Judicial Conduct Commission, which sent warning letters suggesting that their actions might violate specific provisions of the Kentucky Code of Judicial Conduct related to party nominations, endorsements, and making commitments on issues. After receiving the warning letters and being asked to respond, both candidates objected to the vagueness of the allegations. Fearing imminent enforcement, they filed suit in the United States District Court for the Eastern District of Kentucky, seeking declaratory and injunctive relief on First Amendment grounds. The district court initially denied a preliminary injunction for lack of standing, but the United States Court of Appeals for the Sixth Circuit granted an emergency injunction pending appeal, finding a credible threat of enforcement. After further proceedings, the district court granted summary judgment for the candidates on most claims, holding that certain rules were unconstitutional as applied to their speech and that one rule was unconstitutionally vague, and it issued a permanent injunction. The Commission appealed, and the candidates cross-appealed. The United States Court of Appeals for the Sixth Circuit held that the candidates had standing and that their as-applied challenges to the “Nominee,” “Endorsement,” and “Commitment” rules succeeded. The court determined the candidates’ campaign speech was protected by the First Amendment and affirmed an injunction preventing the Commission from enforcing those rules as applied to their speech, but declined to extend relief to facial challenges. The court affirmed in part and reversed in part, tailoring relief to the candidates’ specific conduct. View "Fischer v. Thomas" on Justia Law

Griswold v. Trinity Health Michigan

2026-05-11T13:00:35-08:00

After a domestic disturbance in 2018, John Griswold was arrested by police in Brighton, Michigan, after admitting to ingesting several pills, which were identified as ulcer medication. He was medically evaluated at the jail and sent to the hospital, where doctors diagnosed him with a nasal fracture, found him stable, and medically cleared him for incarceration. Griswold returned to jail, appearing lethargic and refusing to answer questions. He vomited once in his cell and remained seated, periodically moving his arms, legs, and head. Jail staff conducted frequent checks but did not clean up the vomit or seek additional medical attention. Several hours later, Griswold was found unresponsive and pronounced dead; toxic levels of Trazodone were found in his blood. Griswold’s estate brought claims under 42 U.S.C. § 1983 against jail officials, alleging deliberate indifference to his medical needs, in the United States District Court for the Eastern District of Michigan. The district court granted summary judgment to some defendants but denied it to Livingston County and several individual officers, holding that there was a genuine dispute whether these defendants were deliberately indifferent and denying their claim of qualified immunity. On appeal, the United States Court of Appeals for the Sixth Circuit reviewed de novo the district court’s denial of qualified immunity. The Sixth Circuit held that, under the law applicable in 2018 (the Farmer v. Brennan standard), Griswold’s condition did not present “obvious” symptoms that would require medical attention from a layperson’s perspective. The court found that existing precedent did not clearly establish that the defendants’ conduct violated Griswold’s constitutional rights. Therefore, the Sixth Circuit concluded that the jail officials were entitled to qualified immunity and reversed the district court’s denial of summary judgment. View "Griswold v. Trinity Health Michigan" on Justia Law

Lopez-Campos v. Raycraft

2026-05-11T13:00:33-08:00

A group of noncitizens from Mexico, El Salvador, Venezuela, Nicaragua, and Guatemala, who had lived in the United States for years without lawful status, were arrested by federal immigration authorities and detained under 8 U.S.C. § 1225(b)(2)(A) without being granted bond hearings. Most had only minor traffic offenses and many were parents to U.S.-citizen children. Their detention was based on the interpretation that, as “applicants for admission,” they were subject to mandatory detention without individualized assessment of flight risk or dangerousness. Each petitioner filed a writ of habeas corpus in either the United States District Court for the Eastern District of Michigan or the Western District of Michigan. They argued that they should have been detained, if at all, under 8 U.S.C. § 1226, which allows for bond hearings, not under the mandatory detention provision. They also claimed that detention without a bond hearing violated their Fifth Amendment due process rights. The district courts agreed with the petitioners, holding that § 1226(a) governed their detention, requiring bond hearings, and that detention without such a hearing violated due process for those who had lived in the interior of the United States for years. The United States Court of Appeals for the Sixth Circuit reviewed these consolidated appeals. The court held that noncitizens present in the interior of the United States who have not affirmatively sought lawful entry are not “seeking admission” under § 1225(b)(2)(A) and therefore are not subject to mandatory detention without bond. Instead, their detention is governed by § 1226, which requires an individualized bond hearing. The court also affirmed that detaining such noncitizens without a bond hearing violates the Fifth Amendment’s Due Process Clause. The court affirmed the district courts’ judgments granting habeas relief. View "Lopez-Campos v. Raycraft" on Justia Law

Overstreet v. Ontonagon County

2026-05-08T11:00:34-08:00

A man with a history of mental health issues was detained at a county jail after being arrested for firing shots at a neighbor’s house and exhibiting delusional behavior. During the booking process, he denied any current or past suicidal thoughts and indicated he had no plans to harm himself. The jail’s intake procedures included standard suicide risk screening, and he was placed in a cell used for new inmates during the COVID-19 pandemic. Several days later, without prior warning or indication of suicidal intent, he used an electric fan cord to hang himself in his cell. The United States District Court for the Western District of Michigan granted summary judgment to the county, the sheriff, and the corrections officers. The court found that no reasonable jury could conclude that any officer subjectively believed there was a strong likelihood the detainee would commit suicide, as required under the pre-Brawner v. Scott County deliberate indifference standard then applicable. The court also rejected the claim against the county under Monell v. Department of Social Services, holding that there was no evidence the county’s policies were adopted with deliberate indifference to inmates’ constitutional rights. The court declined to exercise supplemental jurisdiction over state law claims. The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision de novo. It affirmed the grant of summary judgment, holding that the officers were entitled to qualified immunity because the evidence did not support that they subjectively perceived a strong likelihood of suicide. The court also held that the county’s policies did not demonstrate deliberate indifference under clearly established law and that there was no basis for Monell liability. Thus, the appellate court affirmed dismissal of all federal claims. View "Overstreet v. Ontonagon County" on Justia Law

Mackinac Center for Pub. Policy v. Dep't of Education

2026-05-08T11:00:33-08:00

During the COVID-19 pandemic, the U.S. Department of Education suspended federal student-loan payments and froze interest accrual for borrowers from 2020 through 2023. For participants in loan-forgiveness programs, the Department counted these months of nonpayment toward the forgiveness requirements. After the Supreme Court invalidated a broader debt cancellation program, the Department also instituted a twelve-month “on-ramp” to repayment, during which borrowers would not be penalized for missed payments, though interest would accrue but not capitalize. The plaintiff, a nonprofit public service employer, asserted that these actions diminished statutory incentives meant to help such employers attract and retain college-educated workers, thereby causing it economic harm and unfairly increasing competition from private sector employers. The United States District Court for the Eastern District of Michigan reviewed the case after the nonprofit sued the Department of Education and associated officials. The complaint alleged violations of the Constitution and the Administrative Procedure Act. The Department moved to dismiss on the ground that the nonprofit lacked Article III standing. The district court agreed, finding that the plaintiff failed to allege a concrete injury and dismissed the case for lack of subject-matter jurisdiction. On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s dismissal. The Sixth Circuit held that the nonprofit’s allegations were speculative and lacked specific facts showing direct economic injury or increased competition traceable to the Department’s actions. The court explained that the plaintiff did not sufficiently allege lost revenue, recruitment difficulties, or concrete competitive harm. Thus, the court concluded that the plaintiff failed to establish the injury in fact required for Article III standing, and affirmed the dismissal for lack of subject-matter jurisdiction. View "Mackinac Center for Pub. Policy v. Dep't of Education" on Justia Law

Energy & Policy Inst. v. TVA

2026-05-08T11:00:32-08:00

A public interest organization sought documents from a federally owned corporation under the Freedom of Information Act (FOIA). The documents concerned communications with two industry groups and a contract with an insurance provider. The agency produced some documents, redacted or withheld others, and justified these actions under FOIA Exemptions Four (confidential commercial information), Five (privileged inter- or intra-agency memoranda), and Six (personal privacy). The organization administratively appealed and, after the appeals were denied, filed suit in federal district court. During litigation, the agency released additional documents following new representations from a third-party law firm involved in the disputed communications. The United States District Court for the Eastern District of Tennessee granted summary judgment to the agency, finding its withholdings and redactions justified under FOIA’s exemptions, based on the agency’s Vaughn index and supporting affidavits. The court also denied the organization’s motion for attorneys’ fees, holding that the additional disclosures during litigation were not voluntary or unilateral actions by the agency but instead resulted from the third party’s change in position. On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s summary judgment ruling de novo and reversed in part. The Sixth Circuit held that certain withholdings and redactions were not justified under Exemption Four, specifically some logistical information, the name of the insurance representative, and, to the extent already public, names of current industry group members. The court also held that Exemption Six did not justify withholding company names or business email domain names. The Sixth Circuit reversed the district court’s denial of attorneys’ fees eligibility, clarifying that the agency’s voluntary mid-litigation disclosures could render the plaintiff eligible for fees, and remanded for further factual findings regarding causation and entitlement. The judgment was otherwise affirmed. View "Energy & Policy Inst. v. TVA" on Justia Law

United States v. Bell

2026-05-07T12:30:34-08:00

A woman suffering a heroin overdose in Detroit in 2016 reported to doctors that she was in a dangerous situation linked to her residence at the Victory Inn motel. She disclosed that Darrick Bell supplied her with drugs and coerced her into prostitution at the motel to repay drug debts. Law enforcement investigated and discovered evidence of a large criminal enterprise at the Victory Inn, including multiple women engaged in prostitution, substantial quantities of drugs, and related paraphernalia. Police identified Bell as the ringleader, who controlled the operation, supplied drugs, and used violence and coercion. After a national manhunt, Bell was apprehended in 2019 and tried on drug and sex trafficking charges. At trial in the United States District Court for the Eastern District of Michigan, the government presented extensive surveillance, text messages, and witness testimony. The jury found Bell guilty of conspiracy to distribute drugs, possession with intent to distribute, and maintaining drug-distribution premises, but acquitted him of one sex trafficking charge and was deadlocked on four others, which were later dismissed. The district court sentenced Bell to 336 months, below the guidelines range. The United States Court of Appeals for the Sixth Circuit reviewed Bell’s conviction and sentence. Bell argued that the district court erred in admitting text message evidence, that the evidence was insufficient for conviction, that a government witness’s statements warranted a new trial, and that several sentencing enhancements were improper. The Sixth Circuit found no abuse of discretion by the district court in admitting the text messages, concluded the evidence supported the convictions and drug quantities, and upheld all sentencing enhancements. The appellate court affirmed the district court’s judgment. View "United States v. Bell" on Justia Law

Martin v. Fed. Rsrv. Bank of Cleveland

2026-05-07T12:30:34-08:00

The plaintiff worked as a Project Director and participated in her employer’s long-term disability (LTD) plan, which was administered by Matrix Absence Management on behalf of the Federal Reserve Bank of Cleveland. After taking leave due to ongoing symptoms from long-haul COVID-19, the plaintiff applied for LTD benefits under the plan, which required proof of total disability. Matrix reviewed the medical evidence—including opinions from both treating and independent physicians—and denied her claim, concluding that as of her leave date, she was not totally disabled under the plan’s terms. The plaintiff appealed this denial, but Matrix upheld its decision after additional review. The United States District Court for the Northern District of Ohio heard the plaintiff’s subsequent lawsuit against the Bank, Matrix, and the plan, asserting breach of contract and breach of fiduciary duty. The district court denied the plaintiff’s requests for discovery beyond the administrative record and granted judgment on the administrative record in favor of the defendants. The court found that New York contract law, not ERISA, applied, and review was limited to whether Matrix’s decision was arbitrary, made in bad faith, or the result of fraud, given the plan’s broad delegation of discretionary authority to Matrix. On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The Sixth Circuit held that the district court correctly applied New York contract law and the arbitrary-and-capricious standard of review. The appellate court found no abuse of discretion in denying discovery beyond the administrative record, as the plaintiff did not establish a colorable claim of conflict of interest or procedural defect. The Sixth Circuit concluded that Matrix’s denial had a reasonable basis in the administrative record and thus was not arbitrary or capricious. The judgment for the defendants was affirmed. View "Martin v. Fed. Rsrv. Bank of Cleveland" on Justia Law

United States v. Barton

2026-05-06T12:00:35-08:00

The defendant was originally convicted in the Middle District of Florida for receiving child pornography and sentenced to eighty-four months in prison followed by fifteen years of supervised release. After completing his custodial sentence, his supervision was transferred to the Northern District of Ohio. While on supervised release, he committed several violations, including a misdemeanor disorderly conduct offense, unauthorized travel outside his district, and possessing an unapproved internet-connected device used to view adult pornography and interact with others online. He admitted to these violations. Upon review of his violations, the United States District Court for the Northern District of Ohio conducted a revocation hearing. The court presented the defendant with an ultimatum: serve six months in prison immediately or continue on supervision with the warning that any future violation, no matter how minor, would result in the statutory-maximum two-year prison term. The defendant chose to remain on supervision. Shortly thereafter, he committed additional violations similar to the previous ones, again admitting to them. At a second violation hearing, the district court imposed the full two-year statutory maximum, explicitly referencing the ultimatum given at the prior hearing as the basis for its decision. The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that when a district court predetermines a supervisee’s revocation prison term in advance—by promising a particular sentence for any future violation and then imposing that sentence without individualized consideration of the circumstances—the sentence is both procedurally and substantively unreasonable. The Sixth Circuit vacated the district court’s judgment and remanded the case for further proceedings, emphasizing that revocation terms must be determined after individualized assessment and consideration of the relevant statutory factors, not based solely on prior warnings or promises. View "United States v. Barton" on Justia Law

Block v. Canepa

2026-05-06T12:00:34-08:00

An Ohio resident and an Illinois wine retailer challenged two Ohio laws regarding wine importation. The first law prohibits out-of-state retailers from shipping wine directly to Ohio consumers, while permitting in-state retailers to do so. The second law bars Ohio residents from personally bringing more than six bottles of wine purchased outside Ohio into the state within any thirty-day period, though it allows up to 288 bottles if purchased inside Ohio. The plaintiffs argued that both laws discriminate against out-of-state businesses and consumers, violating the Commerce Clause of the U.S. Constitution. The case was first heard in the United States District Court for the Southern District of Ohio. That court found the shipping restriction constitutional under the Twenty-first Amendment and concluded that the plaintiffs lacked standing to challenge the transportation limit. On appeal, the United States Court of Appeals for the Sixth Circuit reversed, clarifying that the appropriate test comes from Tennessee Wine & Spirits Retailers Association v. Thomas, and remanded for further proceedings. On remand, after additional discovery, the district court again granted summary judgment to the defendants, evaluating the restrictions as part of Ohio’s three-tier alcohol regulatory system and finding the restrictions justified. The United States Court of Appeals for the Sixth Circuit reviewed the case and held that the plaintiffs had standing. The court found that the challenged restrictions were not essential components of Ohio’s three-tier system and must be evaluated independently under the Tennessee Wine test. The court concluded that Ohio’s justifications for the restrictions—public health, safety, price control, and temperance—were speculative or undermined by evidence that Ohio allows similar activities by other out-of-state entities. The court held that both laws are unconstitutional because their predominant effect is economic protectionism, not the protection of public health or safety. The district court’s judgment was reversed and the case remanded for further proceedings consistent with this opinion. View "Block v. Canepa" on Justia Law

Hess v. Oakland County

2026-05-05T12:00:33-08:00

During a December 2023 election recount at the Oakland County Courthouse in Michigan, Andrew Hess, serving as an observer, raised concerns about ballot-box tampering with the county’s director of elections, Joseph Rozell. Following a tense exchange, Hess left the recount room and, in the courthouse lobby, remarked to another member of the public, “hang Joe for treason.” The comment was overheard by a county receptionist, who later reported it to law enforcement. Although Hess was not removed from the event, months later Oakland County prosecutors charged him with a felony under Michigan’s terrorist-threat statute for this statement. The charge was initially dismissed after the Michigan Court of Appeals found the statute facially unconstitutional, but the Michigan Supreme Court later vacated that decision, and the potential for prosecution was revived. In response, Hess filed a civil action under 42 U.S.C. § 1983 in the United States District Court for the Eastern District of Michigan, seeking declaratory and injunctive relief, as well as damages, primarily arguing that the prosecution violated his First Amendment rights. He also sought a preliminary injunction to prevent any renewed prosecution under the statute. The district court denied the preliminary injunction, finding Hess unlikely to succeed on his constitutional claims and failing to demonstrate irreparable harm. Upon appeal, the United States Court of Appeals for the Sixth Circuit reviewed the denial of the preliminary injunction. The appellate court held that while Hess was likely to succeed on the merits of his as-applied First Amendment claim—concluding his statement did not constitute a true threat—he had not shown irreparable harm because any threatened prosecution targeted only his past speech, not future speech. Furthermore, Michigan’s state-court procedures offered him a fair and prompt opportunity to litigate his First Amendment defense. Accordingly, the Sixth Circuit affirmed the district court’s denial of the preliminary injunction. View "Hess v. Oakland County" on Justia Law

United States v. Singh

2026-05-05T12:00:33-08:00

A man who was born in India entered the United States illegally and sought asylum, which was denied. He then submitted a second asylum application under a false identity and later married a U.S. citizen, using the same false information to obtain permanent residency and, eventually, naturalization as a U.S. citizen. After obtaining a U.S. passport and reentering the country, he was questioned by border agents and gave false answers regarding his identity. As a result, he was charged with using a fraudulently obtained passport and making false statements to federal agents. He pleaded guilty to the passport charge, with the other charge dismissed, and was sentenced to probation. Both his plea agreement and the district court informed him of potential immigration consequences, including possible loss of citizenship. Later, the government initiated denaturalization proceedings, alleging that he had illegally procured citizenship through fraud and misrepresentation. The man petitioned the United States District Court for the Eastern District of Michigan for a writ of coram nobis, arguing ineffective assistance of counsel because his lawyer did not advise him that his guilty plea could lead to denaturalization. The district court denied the petition, and the United States Court of Appeals for the Sixth Circuit affirmed, finding he had not shown a reasonable probability that, but for his counsel’s advice, he would have chosen a different course. After a Second Circuit decision in Farhane v. United States adopted a broader view of counsel’s obligations, he sought reconsideration, which was also denied. The United States Court of Appeals for the Sixth Circuit reviewed the appeal and held that the Sixth Amendment does not require defense attorneys to advise naturalized citizens that a guilty plea may carry the risk of denaturalization and eventual deportation. The court affirmed the district court’s denial of the motion for reconsideration. View "United States v. Singh" on Justia Law

Vaughn v. Rea

2026-05-04T12:30:35-08:00

Police officers responded to reports of an abandoned car partially blocking a highway lane. The vehicle’s driver, later identified as Mohammad Isaifan, was said to be wearing a tactical vest and camouflage clothing, and several rounds of ammunition and a handgun were found in the car. Officers Akers and Rea, after learning the driver’s address, observed a man matching Isaifan’s description walking nearby. When approached, Isaifan fled into a wooded area. The officers followed, repeatedly identifying themselves and ordering Isaifan to show his hands and get on the ground. Isaifan initially complied partially, but then stopped following commands. He walked toward the officers, resisted detention, and reached for a pistol on his hip. In the ensuing seconds, Isaifan drew his gun and began to turn toward the officers, who then fired multiple shots, killing him. The United States District Court for the Northern District of Ohio considered Vaughn’s claims, brought on behalf of Isaifan’s estate, that the officers used excessive force in violation of the Fourth Amendment. The district court granted summary judgment to the officers on the basis of qualified immunity, concluding that their conduct was objectively reasonable under the circumstances. Vaughn appealed solely on the excessive force issue. The United States Court of Appeals for the Sixth Circuit reviewed the district court’s grant of summary judgment de novo. The appellate court held that the officers’ use of deadly force was objectively reasonable, as Isaifan posed an imminent threat by drawing his weapon and turning toward the officers. The court concluded that no genuine dispute of material fact existed regarding the officers’ actions and affirmed the grant of qualified immunity. Accordingly, the judgment of the district court was affirmed. View "Vaughn v. Rea" on Justia Law

Stanalajczo v. Perry

2026-05-04T12:30:34-08:00

An adjunct clinical professor at a university dental school supervised students in a clinic that, during the summer of 2022, required faculty and students to wear heavy protective equipment as part of its COVID-19 response. Ongoing building renovations left the clinic without adequate air conditioning, making the protective gear uncomfortable and allegedly hazardous due to heat. The professor expressed his opposition to the policy through mass emails, a formal health complaint to the Michigan Occupational Safety and Health Administration (MiOSHA), and remarks at a school meeting. Some colleagues agreed with his concerns, while others found his communications unprofessional. After an internal investigation found his behavior violated university policies, the professor was asked to complete educational modules on workplace conduct. When he refused, he was terminated. The United States District Court for the Eastern District of Michigan reviewed the professor’s First Amendment retaliation claim brought under 42 U.S.C. § 1983 against various dental school administrators. The district court granted summary judgment for the defendants, ruling that neither the MiOSHA complaint nor the professor’s statements at the meeting addressed matters of public concern and that his meeting remarks were made in his capacity as a public employee. The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision de novo. The appellate court held that neither the MiOSHA complaint nor the meeting speech involved matters of public concern as required for First Amendment protection in the public employment context. The court emphasized that the professor’s speech focused on workplace conditions and employee grievances rather than broader issues of public import or patient safety. Because the professor failed to show he spoke on a matter of public concern, the court affirmed summary judgment for the defendants. View "Stanalajczo v. Perry" on Justia Law

Kerwin v. Trinity Health Grand Haven Hosp.

2026-05-01T12:30:33-08:00

A community hospital in western Michigan, previously operating under a different name, was acquired by a nationwide health system in June 2022. The hospital’s collective bargaining agreement with its employee union expired shortly before the acquisition, and the union affiliated with the SEIU. Negotiations for a new contract stalled, and an employee, Jamie Quinn, initiated a decertification petition to remove the union. After sufficient signatures were gathered, a formal decertification election was held in September 2023. The union attempted to block the ballot count with pending unfair labor practice charges, but eventually withdrew the blocking request. The next day, Quinn submitted a “disaffection petition” to hospital management, claiming majority support for removing the union, though the petition had multiple defects. Despite these issues, hospital management immediately withdrew recognition from the union, but the official election results, announced soon after, showed the union still had majority support. The National Labor Relations Board’s Regional Director filed a formal complaint against the hospital for unfair labor practices. An Administrative Law Judge found the hospital’s withdrawal of recognition unjustified, citing the petition’s defects and lack of objective evidence. The Board certified the union as the bargaining representative. While the Board’s review was pending, the Regional Director petitioned the United States District Court for the Western District of Michigan for a preliminary injunction under § 10(j) of the NLRA. The district court granted the injunction, ordering the hospital to resume bargaining with the union. The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision. While agreeing that the Director was likely to succeed on the merits, the appellate court found that the Director failed to show a clear likelihood of irreparable harm as required by Supreme Court precedent. The Sixth Circuit reversed the district court and vacated the injunction, holding that a § 10(j) injunction requires a clear showing of irreparable harm, which was not demonstrated here. View "Kerwin v. Trinity Health Grand Haven Hosp." on Justia Law

Oxlaj-Perez v. Blanche

2026-04-29T21:02:26-08:00

A Guatemalan national of indigenous Mayan Quiche descent entered the United States as an unaccompanied minor in 2015 and was placed in removal proceedings. He conceded removability and applied for asylum, withholding of removal, and protection under the Convention Against Torture, alleging persecution based on his indigenous identity. In a 2022 removal hearing, he testified regarding his experiences. The Immigration Judge found him credible but concluded he did not meet the legal standards for relief, ordering his removal to Guatemala. The petitioner timely appealed to the Board of Immigration Appeals. On February 10, 2025, the Board affirmed the removal order. The petitioner then filed a petition for review with the United States Court of Appeals for the Sixth Circuit, but did so 79 days after the Board’s final order—well beyond the 30-day deadline set by 8 U.S.C. § 1252(b)(1). Before the United States Court of Appeals for the Sixth Circuit, the government moved to dismiss the petition as untimely, arguing that the 30-day filing deadline was not subject to equitable tolling. The petitioner argued for equitable tolling, citing extraordinary circumstances and diligence. The Sixth Circuit held that, in light of the Supreme Court’s decision in Riley v. Bondi, the § 1252(b)(1) deadline is a claims-processing rule rather than jurisdictional, and is therefore subject to equitable tolling, following the interpretive framework from cases such as Holland v. Florida and Boechler, P.C. v. Commissioner. However, the court concluded that the petitioner did not demonstrate the requisite diligence or extraordinary circumstances to merit equitable tolling in this case. Accordingly, the Sixth Circuit dismissed the petition for review as untimely. View "Oxlaj-Perez v. Blanche" on Justia Law

Us v. Blanche

2026-04-29T21:02:25-08:00

A Guatemalan citizen who entered the United States unlawfully in 2000 was placed in removal proceedings after being arrested in connection with a criminal investigation. He conceded his removability but sought cancellation of removal under § 240A(b)(1) of the Immigration and Nationality Act, arguing that his deportation would cause “exceptional and extremely unusual hardship” to his two U.S.-citizen children. He and his wife, both of whom are the children’s sole providers, testified that if he were removed, the family would relocate to Guatemala, where the children would face significant financial, educational, and medical challenges. An Immigration Judge denied the application, finding that the children would not suffer hardship beyond what is typical for families facing deportation. The judge reasoned that the family had resources to transition to life in Guatemala, including the parents’ ability to work and certain assets that could assist their resettlement. The judge also noted that the children did not have unique medical or educational needs and that the hardships described—such as a lower standard of living and reduced educational opportunities—were not extraordinary. The Board of Immigration Appeals affirmed the Immigration Judge’s decision, and the petitioner then sought review from the United States Court of Appeals for the Sixth Circuit. The United States Court of Appeals for the Sixth Circuit, applying the substantial-evidence standard under the Illegal Immigration Reform and Immigrant Responsibility Act, held that the determination by the Board was conclusive unless any reasonable adjudicator would be compelled to conclude otherwise. The court found that the hardships identified did not rise to the level of “exceptional and extremely unusual hardship” required for cancellation of removal and that no reasonable adjudicator would be compelled to reach a contrary conclusion. The petition for review was denied. View "Us v. Blanche" on Justia Law

Deh v. Blanche

2026-04-29T21:02:25-08:00

A Mauritanian national entered the United States without valid documents and was detained by federal immigration authorities. He admitted removability but sought asylum, withholding of removal, and protection under the Convention Against Torture, claiming he had been enslaved and tortured in Mauritania. In his testimony before an immigration judge, he provided inconsistent accounts regarding his experiences and statements, including contradictions about where he lived, whether he had been arrested or tortured by police, and the fate of his family members. Different court-appointed interpreters assisted him during his hearings. The immigration judge found the petitioner not credible due to numerous inconsistencies and denied his applications for relief. The petitioner did not appeal the initial decision but later moved to reopen the proceedings, alleging that interpretation at one hearing was flawed because the interpreter had since been disqualified. He provided an affidavit expressing difficulty understanding the interpreter but did not specify any translation errors. The immigration judge denied the motion to reopen, and the Board of Immigration Appeals affirmed, noting the lack of objections at the hearing and absence of identified errors. The Board also rejected a request for sua sponte reopening, finding no exceptional situations. The United States Court of Appeals for the Sixth Circuit considered the petition for review. It held that the Board did not abuse its discretion in denying the motion to reopen because the petitioner failed to identify material translation errors or evidence likely to change the outcome. The court also found no due process violation, noting the petitioner did not object during the hearing or show that the judge was aware of interpretation problems. Finally, the court dismissed for lack of jurisdiction the claim regarding sua sponte reopening. The petition for review was denied in part and dismissed in part. View "Deh v. Blanche" on Justia Law

United States v. Simpson

2026-04-27T21:02:44-08:00

The case involved a defendant who, while armed, entered the backyard of a homeowner, shot the resident in the abdomen, and then stole his car. The victim endured extensive medical treatment, including multiple surgeries and physical therapy, and was left permanently injured and unable to work. The defendant was apprehended by police after attempting to flee in the stolen vehicle. During the investigation, he made statements suggesting the shooting was accidental and later provided a similar account during his Presentence Investigation Report interview. The United States District Court for the Western District of Tennessee presided over the case. A grand jury indicted the defendant on carjacking resulting in serious bodily injury and using, carrying, and discharging a firearm during a crime of violence. The defendant pleaded guilty during jury selection. At sentencing, the Presentence Investigation Report declined to apply a two-level reduction for acceptance of responsibility, referencing the timing of the plea and the defendant’s statements minimizing intent. The district court agreed, finding the defendant had not truthfully accepted responsibility and imposed a sentence within the Guidelines, totaling 217 months of imprisonment. On appeal to the United States Court of Appeals for the Sixth Circuit, the defendant argued that the district court erred in not granting the acceptance of responsibility reduction and that his sentence was substantively unreasonable. The Sixth Circuit held that the district court did not clearly err in denying the reduction, given the defendant’s ongoing minimization of his conduct. The appellate court also found the sentence substantively reasonable, as the district court properly considered the relevant sentencing factors and gave no unreasonable weight to any one factor. The Sixth Circuit affirmed the sentence. View "United States v. Simpson" on Justia Law

Clippinger v. State Farm Auto. Ins. Co.

2026-04-24T11:30:33-08:00

State Farm, an automobile insurer, uses a standard process in Tennessee to determine the “actual cash value” (ACV) of vehicles totaled in accidents. This process involves comparing the insured’s vehicle to similar used vehicles listed for sale and then applying a “typical negotiation” adjustment, which reduces the estimated value based on the assumption that advertised prices are generally higher than actual sales prices. After her own totaled minivan was valued using this process, Jessica Clippinger agreed to the payout but later challenged the fairness of the typical-negotiation adjustment, arguing that it systematically undervalued cars and breached the insurance contract. She brought a putative class action on behalf of similarly situated State Farm customers. The United States District Court for the Western District of Tennessee initially required Clippinger to use the policy’s appraisal process. After the appraisal resulted in a higher valuation and State Farm paid the difference, the district court found that Clippinger’s claim was not moot, as she had allegedly been harmed by incurring appraisal costs. The court granted class certification, accepting Clippinger’s argument that damages could be determined by simply refunding the amount of the negotiation adjustment for each class member, and found that common questions predominated over individual ones. The United States Court of Appeals for the Sixth Circuit, sitting en banc, reversed the class certification order. The court held that, even if the negotiation adjustment was flawed, determining whether State Farm breached its contract for each class member would require individualized evidence about the actual cash value of each vehicle. The court concluded that these individualized valuation questions would predominate over any common issues, making class certification improper under Federal Rule of Civil Procedure 23(b)(3). The Sixth Circuit further held that the district court’s proposed formula for damages improperly abridged State Farm’s substantive right to present individualized defenses, violating the Rules Enabling Act. The case was remanded for further proceedings. View "Clippinger v. State Farm Auto. Ins. Co." on Justia Law

Driscoll v. Montgomery Cnty. Bd. of Comm'rs

2026-04-23T21:02:27-08:00

A man diagnosed with mental health disorders was behaving erratically in a public park, speaking in tongues and carrying a jug of lake water. Concerned park visitors contacted the non-emergency police line, reporting his unusual behavior but stating he was not armed. A deputy sheriff responded, received information that the man was making strange noises and carrying a jug, and was told he might have a lighter, but no weapons or dangerous substances were reported. The deputy confronted the man, immediately drew her weapon, and repeatedly ordered him to drop the jug and get on the ground. The man was noncompliant but not physically aggressive or threatening, and his hands were visible and empty. At one point, the deputy radioed that the man was “pouring gasoline,” despite no evidence supporting this belief. After a tense verbal exchange lasting a few minutes, the man advanced toward the deputy with empty hands, and she shot him, causing serious injuries. The man brought federal and state claims against the deputy and county officials in the United States District Court for the Southern District of Ohio. The district court dismissed many claims but allowed the Fourth Amendment excessive force claim, as well as state-law claims for battery, intentional infliction of emotional distress, and false arrest, to proceed against the deputy in her personal capacity. The district court denied the deputy’s motion for summary judgment based on qualified immunity and state-law immunity, finding that, viewed in the light most favorable to the plaintiff, the use of deadly force was not objectively reasonable, and the right violated was clearly established. On interlocutory appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s denial of qualified and statutory immunity. The court held that the deputy was not entitled to immunity because, under the plaintiff’s version of the facts, shooting an unarmed, nondangerous, mentally impaired person who was noncompliant but not threatening, violated clearly established Fourth Amendment law. The deputy was also not entitled to immunity under Ohio law for the same reasons. View "Driscoll v. Montgomery Cnty. Bd. of Comm'rs" on Justia Law

Ross v. Robinson, Hoover & Fudge, PLLC

2026-04-22T21:02:32-08:00

After purchasing a used car in Oklahoma with his then-wife, Alexander Ross divorced and relocated to Michigan, while his ex-wife kept the car in Oklahoma. The couple fell behind on payments, leading their creditor to repossess and sell the vehicle. The creditor retained an Oklahoma law firm, Robinson, Hoover & Fudge, PLLC (“RHF”), to sue both parties for the outstanding balance in Oklahoma state court. After unsuccessful attempts to serve Ross personally, including publishing notice in an Oklahoma newspaper, the court entered a default judgment against him. RHF later learned that Ross was residing and working in Michigan and proceeded to use the Oklahoma judgment to garnish Ross’s wages from his Michigan-based employer, Detroit Diesel. Ross filed suit against RHF in the United States District Court for the Eastern District of Michigan, alleging violations of the Fair Debt Collection Practices Act (FDCPA) and Michigan’s Regulation of Collection Practices Act (MRCPA). He claimed that RHF unlawfully garnished his Michigan wages without first domesticating the Oklahoma judgment as required by Michigan law. RHF moved to dismiss the case for lack of personal jurisdiction. The district court granted the motion, holding that RHF did not have sufficient contacts with Michigan to justify the exercise of personal jurisdiction. The United States Court of Appeals for the Sixth Circuit reversed the district court’s dismissal. The appellate court held that RHF had purposefully directed its actions at Ross in Michigan with knowledge of his residence and employment there, and that its actions caused harm in Michigan. The court found that both Michigan’s long-arm statute and the Due Process Clause permitted the exercise of personal jurisdiction over RHF. Accordingly, the Sixth Circuit remanded the case for further proceedings. View "Ross v. Robinson, Hoover & Fudge, PLLC" on Justia Law

White's Landing Fisheries, Inc. v. Ohio Dep't of Nat. Res. Div. of Wildlife

2026-04-22T21:02:32-08:00

A commercial fisherman from Erie County, Ohio, who owned a fisheries business, challenged a state rule that amended commercial fishing regulations to exclude seine fishers from receiving yellow perch quotas. The rule, promulgated by the Ohio Department of Natural Resources (ODNR), Division of Wildlife, allocated quotas exclusively to trap net fishers and prohibited the transfer of quotas to seine licenses. The fisherman alleged that this rule deprived him of economic value and constituted a taking without compensation, and further brought claims for breach of fiduciary duty and civil conspiracy against both state and federal defendants. The case was initially heard in the United States District Court for the Northern District of Ohio. The district court dismissed with prejudice all claims against Ohio and the state officials, holding that there was no protected property interest in the value of a fishing license or uncaught fish under the Takings Clause. The court also found that sovereign immunity barred all claims against the state and its officials, even if the claims otherwise had merit, and determined the state law claims were insufficiently pled. Claims against the federal defendants were dismissed without prejudice for defective service of process. On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s rulings de novo. The Sixth Circuit affirmed that sovereign immunity barred the takings and state law claims against Ohio and the state officials, rejecting the appellant’s arguments that these defendants had waived immunity or that recent Supreme Court and Ohio Supreme Court decisions required judicial review of the state rule. However, the appellate court held that because the dismissal was based on lack of subject matter jurisdiction, the claims against the state defendants should have been dismissed without prejudice. The court affirmed the dismissal of claims against the federal defendants. The judgment was thus affirmed in part and reversed in part, with instructions to dismiss the state claims without prejudice. View "White's Landing Fisheries, Inc. v. Ohio Dep't of Nat. Res. Div. of Wildlife" on Justia Law

Jones v. Shoop

2026-04-22T21:02:32-08:00

After the body of Susan Yates was found in an Akron cemetery in 2007, police arrested Phillip Jones, whose wife, Delores, later told a friend and police that her husband had confessed to the killing. Physical evidence, including DNA, and expert testimony linked Jones to the crime, and he was charged with aggravated murder, murder, and rape, with a death penalty specification. At trial, Jones admitted to causing Yates’s death but claimed it was accidental during consensual, rough sex. The prosecution presented evidence of violent sexual assault and similarities to a prior offense. Jones’s defense included his own testimony and mitigation evidence about his troubled background and mental health. Following conviction and a death sentence, Jones’s direct appeal to the Ohio Supreme Court raised constitutional and ineffective assistance of counsel claims. The court affirmed his conviction and sentence, and his application to reopen the appeal was denied. Post-conviction relief was also denied after an evidentiary hearing, with Ohio’s appellate courts concluding that any failures by counsel were not prejudicial or fell within reasonable professional judgment. Jones’s federal habeas petition before the U.S. District Court for the Northern District of Ohio was denied, though a certificate of appealability was granted on several claims. The United States Court of Appeals for the Sixth Circuit reviewed whether Jones’s Confrontation Clause rights were violated by admission of his wife’s out-of-court statements, and whether trial counsel provided ineffective assistance during both trial and penalty phases. The court held that the admission of some statements did not violate the Confrontation Clause, and that any error was harmless. It also found that counsel’s performance did not fall below constitutional standards, nor was there prejudice warranting relief. The Sixth Circuit affirmed the district court’s judgment, denying Jones’s habeas petition. View "Jones v. Shoop" on Justia Law

Ream v. U.S. Dep't of the Treasury

2026-04-21T21:02:03-08:00

John Ream, an Ohio resident and former aerospace engineer, wanted to distill whiskey at home but refrained from doing so because federal law prohibits operating or possessing a still in a dwelling house. Violating this ban is a felony punishable by imprisonment and fines. Ream, who otherwise would distill whiskey at home, brought suit challenging the constitutionality of the federal home-distilling ban, arguing that it exceeds Congress’s enumerated powers. The United States District Court for the Southern District of Ohio dismissed Ream’s suit, holding that he lacked standing because he had not purchased a still or been directly threatened with prosecution. The government had moved to dismiss on standing and constitutional grounds, while Ream sought summary judgment in his favor. The district court granted the government’s motion, finding Ream’s claimed injury too speculative. The United States Court of Appeals for the Sixth Circuit reviewed the case. It held that Ream had standing to challenge the law, as the only thing preventing him from distilling at home was the express statutory and regulatory prohibition, which was enforced through explicit threats of criminal punishment. The court concluded that Ream plausibly faced a credible threat of prosecution if he were to act. Turning to the merits, the Sixth Circuit held that the federal home-distilling ban is a necessary and proper means of collecting federal excise taxes on distilled spirits. The court reasoned that the ban was historically justified due to pervasive tax evasion and remains a reasonable, plainly adapted measure to secure the tax revenue. The court reversed the district court’s dismissal for lack of jurisdiction but instructed that judgment be entered for the defendants, upholding the constitutionality of the ban. View "Ream v. U.S. Dep't of the Treasury" on Justia Law

United States v. Clark

2026-04-17T06:02:43-08:00

Federal investigators executed a search warrant at an individual’s residence after he had sold controlled substances to a confidential informant on multiple occasions. The search uncovered cocaine, fentanyl, methamphetamine, firearms, and a large amount of cash. The individual was indicted in the United States District Court for the Northern District of Ohio on six counts related to drug trafficking and firearm possession. Over the course of one year, he was represented by four different attorneys. While represented by his third attorney, he pled guilty to all counts. Eleven days later, that attorney resigned from the practice of law due to pending disciplinary action. The defendant was subsequently appointed new counsel. After new counsel was appointed, the defendant sought to withdraw his guilty plea, arguing that his plea was not knowing, voluntary, or intelligent because of ineffective assistance of counsel. The district court denied the motion to withdraw the guilty plea without holding an evidentiary hearing. The court determined that there was no “fair and just” reason under Federal Rule of Criminal Procedure 11(d)(2)(B) for withdrawal and that its plea colloquy satisfied due process. The defendant was sentenced to a term of imprisonment and appealed the denial of his motion. The United States Court of Appeals for the Sixth Circuit reviewed the case and held that the district court abused its discretion by denying the motion to withdraw the guilty plea without first holding an evidentiary hearing. The appellate court found that unresolved factual disputes existed regarding the defendant’s knowledge and voluntariness in entering the plea, as well as the adequacy of his legal representation. The Sixth Circuit vacated the district court’s order denying the motion and remanded the case for an evidentiary hearing to resolve these issues. View "United States v. Clark" on Justia Law

United States v. Jackson

2026-04-15T11:30:35-08:00

Moreno Lee Jackson was involved in a series of firearms and drug-related crimes in Michigan between February and July 2024. Following his arrest by federal agents, Jackson, represented by counsel, entered into a plea agreement in which he admitted to illegally possessing a firearm as a felon. As part of this plea, he acknowledged that he had at least three prior convictions for violent felonies or serious drug offenses, making him subject to an enhanced mandatory minimum sentence under federal law. The presentence report identified four such predicate offenses. At his plea hearing, Jackson reaffirmed his understanding of the plea terms and the sentencing consequences, including the statutory minimum. The United States District Court for the Western District of Michigan accepted Jackson’s guilty plea. The court calculated his sentencing range under the Sentencing Guidelines, factoring in the Armed Career Criminal Act (ACCA) enhancement based on Jackson’s admitted prior convictions. After considering the relevant factors, the court imposed a sentence of 212 months’ imprisonment, which fell within the Guidelines range. Jackson did not object at sentencing to the application of the ACCA enhancement. On appeal, he argued that his sentence was procedurally unreasonable, contending that he did not have the requisite prior convictions for the enhancement. The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Jackson had explicitly and repeatedly waived his right to challenge the sentencing enhancement by agreeing, both in his plea agreement and at his plea hearing, that he had the necessary prior convictions. The Sixth Circuit concluded that this constituted a true waiver, not merely an invited error, and therefore declined to review his procedural-reasonableness claim. The court affirmed the judgment of the district court. View "United States v. Jackson" on Justia Law

Rieth-Riley Constr. Co., Inc. v. NLRB

2026-04-13T12:33:04-08:00

A construction company with a longstanding union relationship entered into negotiations for a new collective bargaining agreement in 2018, following the union’s withdrawal from a multiemployer contract. This led to protracted disputes, including strikes, litigation, and unfair labor practice charges. Amid negotiations, some employees sought to decertify the union, but the National Labor Relations Board (NLRB) dismissed these decertification petitions, finding a causal nexus between the company's alleged unfair labor practices and employee dissatisfaction. During ongoing litigation, the company unilaterally raised employee wages in 2021 and 2022 without bargaining with the union, then later refused to bargain with the union or provide requested information, instead claiming a right to judicial review of the decertification petition dismissals. Administrative proceedings before an Administrative Law Judge (ALJ) resulted in findings that the company had committed several unfair labor practices: granting unilateral wage increases, withdrawing recognition from the union, refusing to bargain, and failing to provide information. The ALJ ordered the company to recognize and bargain with the union, cease unfair labor practices, and provide the requested information. The NLRB affirmed these findings and the remedial order. The United States Court of Appeals for the Sixth Circuit reviewed the case, applying de novo review to legal conclusions and substantial evidence review to factual findings. The court held that the company failed to prove the union waived its right to bargain over wage increases, that the company's actions constituted an unlawful withdrawal of union recognition, and that the refusal to bargain and provide information were not justified as a “technical refusal to bargain” because the decertification petition dismissals did not alter the company's bargaining obligations. The court denied the company’s petition for review and enforced the NLRB’s order. View "Rieth-Riley Constr. Co., Inc. v. NLRB" on Justia Law

Lovell v. Cnty. of Kalamazoo

2026-04-10T15:00:36-08:00

A man with a documented history of severe mental illness and repeated suicide attempts was incarcerated in a Michigan jail after starting a fire at a psychiatric hospital in what was described as another suicide attempt. Lindsey O’Neil, who managed the jail’s mental-health unit, was aware of his recent hospitalization for suicidal ideation and past struggles but also observed that the strict suicide precautions—placement in a padded cell and a suicide-prevention gown—were causing him additional distress. Seeking to balance his mental health needs and suicide risk, O’Neil moved him to a less restrictive medical cell, allowed him to wear a regular jumpsuit, and ordered that he receive a suicide-prevention blanket instead of regular bedding. She also requested enhanced monitoring. Due to a miscommunication, jail staff gave him regular bedding, which he used to commit suicide. The man’s estate brought suit under 42 U.S.C. § 1983 and the Americans with Disabilities Act in the United States District Court for the Western District of Michigan, naming O’Neil, her employer, and others as defendants. The district court, adopting a magistrate judge’s recommendations, granted summary judgment to all defendants except O’Neil, finding that she was not entitled to qualified immunity. On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the denial of qualified immunity de novo. The court held that, at the time O’Neil acted, no clearly established law would have made it obvious to every reasonable official in her position that her compromise approach to housing the decedent constituted deliberate indifference to a known suicide risk. Thus, the Sixth Circuit concluded that O’Neil was entitled to qualified immunity, reversed the district court’s denial of that defense, and remanded the case for further proceedings. View "Lovell v. Cnty. of Kalamazoo" on Justia Law

Rieth-Riley Constr. Co. v. National Labor Relations Board

2026-04-08T13:00:36-08:00

A construction company operating in Michigan employed operating engineers represented by a union. Since at least 1993, collective bargaining occurred through a multiemployer association. In early 2018, with the expiration of their collective bargaining agreement approaching, the union gave notice that it wished to withdraw from multiemployer bargaining in order to negotiate individual contracts with employers, including the company at issue. Tensions rose when the company unilaterally stopped making benefit contributions, gave wage increases, and later sought to recover those payments directly from employees, all without bargaining with the union. The employer also participated in a lockout after the union refused to bargain on a multiemployer basis. Subsequently, the union organized a strike, citing the employer’s alleged unfair labor practices. An administrative law judge for the National Labor Relations Board (NLRB) found that the union’s withdrawal from multiemployer bargaining was timely and lawful, and that the company committed several unfair labor practices, including the lockout and unilateral changes to wages and benefits. The judge concluded, however, that the strike was economic in nature rather than an unfair labor practice strike. On appeal, the NLRB affirmed most of the administrative law judge’s findings but reversed on the nature of the strike, determining it was motivated at least in part by the company’s unfair labor practices. The NLRB issued an order requiring the company to bargain in good faith and temporarily prohibiting decertification attempts. The United States Court of Appeals for the Sixth Circuit reviewed the case. It held that the union’s withdrawal from multiemployer bargaining was timely under Supreme Court and Board precedent, that the company committed unfair labor practices by insisting on multiemployer bargaining, making unilateral wage and benefit changes, and implementing a lockout, and that substantial evidence supported the Board’s conclusion that the 2019 strike was partly an unfair labor practice strike. The court denied the company’s petition for review and granted enforcement of the NLRB’s order. View "Rieth-Riley Constr. Co. v. National Labor Relations Board" on Justia Law

McKee Foods Corp. v. BFP Inc.

2026-04-07T12:30:36-08:00

A Tennessee-based commercial bakery, which provides a self-funded health benefits plan governed by ERISA for its employees, structured its prescription drug benefits through a pharmacy benefit manager (PBM) and created an in-house pharmacy offering lower copays to employees. Tennessee enacted laws targeting PBMs, requiring pharmacy network access for any willing provider and prohibiting cost-sharing incentives to steer participants to certain pharmacies, including those owned by the plan sponsor. The bakery and its PBM excluded a pharmacy from their network after an audit, and after the pharmacy filed administrative complaints under the new Tennessee law, the bakery sought declaratory and injunctive relief in federal court, claiming ERISA preempted these PBM-focused state laws. The United States District Court for the Eastern District of Tennessee found that the bakery, as plan fiduciary, had standing to bring a pre-enforcement challenge. The court concluded that the Tennessee PBM laws were preempted by ERISA because they required specific plan structures, governed central aspects of plan administration, and interfered with uniform national plan administration. The district court granted summary judgment in favor of the bakery, permanently enjoining the Tennessee Commissioner from enforcing the PBM laws against the bakery’s health plan or its PBM. On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court agreed with the district court’s analysis, holding that the challenged Tennessee PBM statutes have an impermissible connection with ERISA plans and are therefore preempted. The court found that the laws mandated network structure and cost-sharing provisions, interfering directly with ERISA plan administration. The Sixth Circuit also held that the ERISA saving clause did not preserve these laws from preemption due to the deemer clause’s application to self-funded plans. The judgment of the district court was affirmed. View "McKee Foods Corp. v. BFP Inc." on Justia Law

Gamas-Vicente v. Blanche

2026-04-07T12:30:36-08:00

A Guatemalan national entered the United States illegally as a minor and was charged with removability. He twice failed to appear at scheduled immigration hearings, resulting in an in absentia removal order, which was later rescinded after he successfully moved to reopen his case. He conceded his removability and sought asylum, withholding of removal, and protection under the Convention Against Torture, citing threats and assaults from the Mara 18 gang due to his refusal to join, harm to his sister allegedly in retaliation, and his Mayan ethnicity. He also claimed the Guatemalan authorities would not protect him due to discrimination against Mayans. The Immigration Judge (IJ) found his testimony credible but identified inconsistencies in his statements and supporting evidence. The IJ held that the four social groups he identified—various groupings of young men, indigenous men, those lacking police protection, and his family—were either too broad or not sufficiently particular to be recognized under Guatemalan society as required for asylum or withholding of removal. The IJ further found that he was targeted by the gang for recruitment, not because of group membership, and that his experiences did not rise to the level of persecution. The IJ also denied his claim under the Convention Against Torture. The Board of Immigration Appeals adopted and affirmed the IJ’s decision, finding that he had waived his CAT claim. On review, the United States Court of Appeals for the Sixth Circuit denied his petition. The court held that he had forfeited arguments concerning the social groups he identified before the agency and failed to exhaust new social group arguments presented in his petition. Without establishing membership in a particular social group, his asylum and withholding of removal claims could not succeed. The court also found his remaining challenges either unexhausted or meritless. View "Gamas-Vicente v. Blanche" on Justia Law

United States v. McNoriell

2026-04-06T11:30:35-08:00

DEA agents recruited a drug trafficker, Michael Allen, as a confidential source and discovered Allen was obtaining heroin and cocaine from Joseph McNoriell. Working with agents, Allen arranged a purchase of two kilograms of cocaine from McNoriell in a controlled operation. Shortly before the planned arrest, Allen, without law enforcement’s knowledge, purchased heroin from McNoriell to avoid suspicion. Agents recorded Allen’s subsequent calls with McNoriell arranging the cocaine transaction. On the day of the planned purchase, law enforcement surveilled McNoriell and two co-conspirators, stopped their vehicles, and recovered two kilograms of cocaine. A grand jury indicted McNoriell for conspiracy to distribute heroin and cocaine and possession with intent to distribute cocaine. Throughout proceedings in the United States District Court for the Western District of Michigan, McNoriell changed attorneys multiple times and eventually elected to represent himself, with standby counsel appointed. Pretrial, the court conducted Faretta hearings to ensure McNoriell’s waiver of counsel was knowing and voluntary and allowed him to determine the division of trial responsibilities with standby counsel, including decisions about participation in sidebar conferences. At trial, McNoriell and his standby counsel shared duties such as cross-examination and objections. The jury convicted McNoriell on both counts, finding each involved at least 500 grams of cocaine. The court imposed a 110-month sentence, including a leadership enhancement over McNoriell’s objection. On appeal, the United States Court of Appeals for the Sixth Circuit addressed McNoriell’s claims regarding exclusion from sidebar conferences, duplicity of the indictment, admission of certain testimony and text messages, interpretation of recorded calls, and the leadership enhancement at sentencing. The court held there was no violation of McNoriell’s constitutional rights due to his acquiescence to hybrid representation, no prejudicial duplicity in the indictment, no plain error in admitting testimony or text messages, and no error in interpreting communications or applying the sentencing enhancement. The Sixth Circuit affirmed the district court’s judgment. View "United States v. McNoriell" on Justia Law

Rieth-Riley Construction Co. v. Operating Engineers Local 324

2026-04-03T10:31:25-08:00

A construction company and several employee plaintiffs were involved in a labor dispute with a group of union-affiliated fringe benefit funds and their trustees. The company had employed members of a local union and, under a collective bargaining agreement (CBA), was required to contribute to a set of employee benefit funds for each hour worked. When the CBA expired and was mutually terminated, the company and union failed to negotiate a new agreement. The company continued attempting to make contributions to the funds, but the funds’ trustees eventually refused to accept them unless the company provided written confirmation of its agreement to abide by the funds’ governing documents. The company declined, arguing that federal labor law required the funds to continue accepting contributions during negotiations. The funds then stopped accepting contributions, and the company placed the rejected payments into escrow. The company and employees filed suit in the United States District Court for the Eastern District of Michigan, asserting that the funds’ trustees had breached their fiduciary duties under the Employee Retirement Income Security Act (ERISA) by refusing the contributions, and seeking declaratory and injunctive relief. The district court dismissed the complaints, finding that the ERISA claims were preempted by the Garmon doctrine, which generally requires courts to defer to the National Labor Relations Board (NLRB) on matters arguably subject to sections 7 or 8 of the National Labor Relations Act (NLRA). The district court also denied motions for a preliminary injunction and for leave to amend the complaint. On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The Sixth Circuit held that the plaintiffs’ ERISA claims were preempted under the Garmon doctrine because they were inextricably linked to labor law questions subject to the NLRB’s primary jurisdiction. The court also found that the district court properly denied the requests for preliminary injunctive relief and for leave to amend the complaint, as any amendment would have been futile. View "Rieth-Riley Construction Co. v. Operating Engineers Local 324" on Justia Law

United States v. Vannelli

2026-04-03T10:31:25-08:00

Federal law enforcement discovered that a 13-year-old girl had posted an online solicitation offering her virginity, which included her personal contact information. Investigators determined that an adult, David Lynn Vannelli, had responded to the post, engaged in explicit conversations with the minor, solicited and received nude images, sent explicit photos of himself, and planned to meet the girl for sexual activity. Vannelli, who was 39 years old and resided in South Carolina, took steps to avoid detection and arranged to meet the girl in Tennessee, where he was arrested by law enforcement. He was charged with several serious federal offenses, including sexual exploitation of a minor, coercion and enticement of a minor, interstate travel with intent to engage in illicit sexual conduct, and transferring obscene material to a minor. Vannelli negotiated a plea agreement with the government under Federal Rule of Criminal Procedure 11(c)(1)(C), recommending a 180-month sentence. The United States District Court for the Middle District of Tennessee reserved decision until reviewing the presentence investigation report, which calculated a significantly higher advisory sentencing range due to a five-level enhancement for engaging in a pattern of activity involving prohibited sexual conduct. The district court ultimately rejected the plea agreement, citing the seriousness of the offense, the need to protect the public, and concerns about unwarranted sentencing disparities. After a hearing, Vannelli chose not to withdraw his plea. The district court sentenced him to 252 months in prison, followed by a lifetime of supervised release. On appeal, the United States Court of Appeals for the Sixth Circuit reviewed both the rejection of the plea agreement and the application of the sentencing enhancement. The Sixth Circuit held that the district court did not abuse its discretion in rejecting the plea agreement, as it provided sound, case-specific reasons. The court further held that the sentencing enhancement for engaging in a pattern of activity was properly applied, even assuming the Supreme Court’s definition of “occasions” in Wooden v. United States applied. The judgment of the district court was affirmed. View "United States v. Vannelli" on Justia Law

Petsche v. Hruby

2026-04-03T10:31:25-08:00

A former member of a city council in Brecksville, Ohio, who owned a roofing company, participated in several council votes related to the construction of a new police station. His company was selected as the roofing subcontractor for the project, but he did not disclose his financial interest to the council. After his ownership came to light through the mayor’s review of project documents, the mayor and the city law director reported his actions to the Ohio Ethics Commission. The Ethics Commission investigated and ultimately referred the matter to the Cuyahoga County Prosecutor, resulting in a grand jury indictment on charges of unlawful interest in a public contract. The councilmember was acquitted after a bench trial. He alleged that the city officials had initiated the ethics complaint in retaliation for his public criticism of the council’s handling of a separate debt issue and that the officials had made false statements or omitted material facts in their communications with the Ethics Commission. The United States District Court for the Northern District of Ohio granted summary judgment to the individual officials and the city on all claims. On appeal, the plaintiff limited his arguments to his claims under 42 U.S.C. § 1983 for retaliatory prosecution and malicious prosecution. The United States Court of Appeals for the Sixth Circuit reviewed the case de novo and affirmed the district court’s judgment. The court held that the grand jury indictment established a presumption of probable cause that the plaintiff was unable to rebut. The court found that, because the plaintiff voted on ordinances advancing the contract in which he had a financial interest, he could not invoke the relevant statutory affirmative defense. Additionally, the court ruled that the exception in Lozman v. City of Riviera Beach, 585 U.S. 87 (2018), did not apply, as the facts and legal context differed. The Sixth Circuit therefore affirmed the dismissal of all claims. View "Petsche v. Hruby" on Justia Law

United States v. Delaine

2026-04-02T12:30:38-08:00

The defendant, already a convicted felon, fired a gun several times in and around a motel room in Chattanooga, Tennessee. When police responded, they heard gunshots coming from the room. After officers announced themselves and ordered those inside to exit, the defendant left the room with a woman. A search revealed a pistol, spent shell casings, and bullet holes. The defendant admitted firing the weapon, knowing he was prohibited from possessing a firearm due to his prior convictions. The United States District Court for the Eastern District of Tennessee was the first to handle this case. The defendant entered a plea agreement, pleading guilty to one count of being a felon in possession of a firearm. The government sought an enhanced sentence under the Armed Career Criminal Act (ACCA), arguing that the defendant had three prior convictions that qualified as “violent felonies” under the Act: Florida aggravated assault, Florida felony battery, and Ohio domestic violence. The district court agreed, applied the ACCA’s 15-year mandatory minimum, and sentenced the defendant to 188 months in prison. On appeal, the United States Court of Appeals for the Sixth Circuit reviewed whether the district court properly counted the three prior convictions as “violent felonies” under the ACCA. The appellate court addressed the defendant’s arguments that his prior offenses did not meet the ACCA’s requirements, specifically focusing on the elements of force and intent as interpreted by Supreme Court precedent. The Sixth Circuit held that all three offenses qualified as violent felonies, finding that each required at least knowing or intentional use of force, as required by the ACCA’s elements clause. The court affirmed the district court’s application of the sentencing enhancement and the resulting sentence. View "United States v. Delaine" on Justia Law

Mercer v. Stewart

2026-04-02T12:30:37-08:00

Police discovered the bodies of two men, both shot in the head, in a burning car in Jackson County, Michigan. Barbara Mercer lived with her boyfriend, Richard Janish, and her friend, Jessica Campbell. Mercer had recently tricked one of the victims, Thomas, into giving her crack cocaine without payment, resulting in threatening messages from Thomas. The night of the killing, Mercer and Janish discussed the threats, and Janish ultimately shot and killed both victims. Mercer and Janish then attempted to destroy evidence by burning the bodies in the victims’ car. Both were arrested, and their statements to police, as well as Campbell’s testimony, formed the basis of the prosecution’s case. Mercer was convicted by a jury of two counts of second-degree murder, tampering with evidence, and arson. The Michigan Court of Appeals affirmed Mercer’s convictions, rejecting her claims that the trial court erred by denying a defense-of-others jury instruction, that her counsel was ineffective, and that the prosecutor committed misconduct during closing arguments. The Michigan Supreme Court denied further review. Mercer then filed a federal habeas petition in the United States District Court for the Eastern District of Michigan. The district court granted habeas relief on the ground that Mercer’s due process rights were violated when the trial court failed to give a defense-of-others instruction, but denied relief on her other claims. The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court’s grant of habeas relief on the jury-instruction claim, holding that Mercer’s claim did not satisfy the requirements for relief under the Antiterrorism and Effective Death Penalty Act. The Sixth Circuit affirmed the district court’s denial of relief on Mercer’s remaining claims regarding ineffective counsel and prosecutorial misconduct, finding that the state court’s decisions were not contrary to or unreasonable applications of clearly established federal law. View "Mercer v. Stewart" on Justia Law

Ramgoolam v. Gupta

2026-04-02T12:30:37-08:00

A Canadian citizen married an American citizen in 2017. The couple lived in Canada until 2020, then moved to Hawaii, where the American spouse began working as a physician. The Canadian spouse entered the United States on a tourist visa and soon applied for lawful permanent residency. To support this application, the American spouse signed a federal Affidavit of Support, committing to maintain the non-citizen’s income above 125% of the federal poverty line. The Canadian spouse obtained permanent residency in 2021. Around that time, the marriage ended, and the American spouse moved to Michigan and filed for divorce. In 2022, the parties entered into a settlement agreement and consented divorce judgment in Michigan, in which they resolved all issues—including spousal support—and released any claims against each other. The Canadian spouse later filed suit in the United States District Court for the Eastern District of Michigan, alleging that his former spouse had failed to provide the financial support required by the Affidavit of Support. The former spouse moved to dismiss, arguing that the district court lacked jurisdiction under the Rooker-Feldman doctrine and that the divorce judgment precluded the claim. The district court rejected the jurisdictional argument but agreed that claim preclusion under Michigan law barred the lawsuit, and dismissed the action. On appeal, the United States Court of Appeals for the Sixth Circuit affirmed. The court held that federal courts must give state court judgments the same preclusive effect they would have under state law, pursuant to the Full Faith and Credit Act. The court ruled that Michigan claim preclusion law applied, and that the prior divorce judgment barred the new lawsuit because the claim could have been raised in the divorce proceedings. The court also rejected arguments that federal law or preemption required a different result. View "Ramgoolam v. Gupta" on Justia Law

Aaron v. King

2026-04-01T13:00:38-08:00

After a series of violent crimes in Detroit, including a gas station robbery and a home invasion, police identified Derek Aaron as the primary suspect based on witness descriptions, security footage, and phone records. Officers located Aaron at a local gas station, where they attempted to arrest him without explicitly informing him of the arrest. Aaron, a large man, resisted by refusing to place his hands behind his back, repeatedly asking for an explanation, and physically pulling his arms away. The officers responded by taking him to the ground and using knee strikes to subdue him before successfully handcuffing him. Subsequent criminal charges against Aaron were dismissed, possibly due to his autism diagnosis, which was unknown to the officers at the time. Aaron, through his legal guardian, filed suit in the United States District Court for the Eastern District of Michigan, alleging that the officers used excessive force during the arrest and that other officers failed to intervene. The officers moved for summary judgment on the basis of qualified immunity. The district court granted qualified immunity on the failure-to-intervene claims but denied it on the excessive force claims, finding that a jury could determine the officers violated clearly established rights. The officers appealed the denial. The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court’s denial of qualified immunity on the excessive force claims. The appellate court held that, given the seriousness of the suspected crimes, Aaron’s physical resistance, and the absence of a clearly established legal prohibition against the officers’ conduct under similar circumstances, the officers did not violate Aaron’s clearly established constitutional rights. Therefore, the officers were entitled to qualified immunity, and the district court’s order was reversed. View "Aaron v. King" on Justia Law

Department of Labor v. Americare Healthcare Services

2026-04-01T13:00:38-08:00

Americare Healthcare Services, Inc., a third-party home care provider in Ohio, and its owner, Dilli Adhikari, hired live-in workers—most of whom cared for their own family members—to provide services to elderly or disabled clients. Between October 2018 and October 2021, Americare failed to pay overtime wages to these employees, claiming entitlement to exemptions under the Fair Labor Standards Act (FLSA): the “Companionship Services Exemption” and the “Live-In Exemption.” The Department of Labor, however, had promulgated a 2013 regulation that prohibited third-party employers from relying on these exemptions. The United States District Court for the Southern District of Ohio granted summary judgment to the Department of Labor, finding Americare and Adhikari liable for willful violations of the FLSA’s overtime requirements. The district court further held that the 2013 Third-Party Regulation was valid, and that Americare and Adhikari lacked standing to challenge a related regulatory definition that narrowed the scope of “companionship services.” Americare and Adhikari appealed only the district court’s rulings on the regulation’s validity and their lack of standing. The United States Court of Appeals for the Sixth Circuit reviewed the case, applying the framework for agency rulemaking authority post-Loper Bright Enterprises v. Raimondo. The Sixth Circuit held that the FLSA’s express statutory delegation allowed the Department of Labor to define and delimit the applicability of the companionship and live-in exemptions, including excluding third-party employers from their reach. The court further held that Americare and Adhikari lacked standing to challenge the definition of companionship services because the bar to their use of the exemption arose from the third-party regulation, not from the definition itself. The judgment of the district court was therefore affirmed. View "Department of Labor v. Americare Healthcare Services" on Justia Law

Dutton v. Shaffer

2026-04-01T13:00:37-08:00

A sitting district court judge in Kentucky faced potential discipline from the state Judicial Conduct Commission (JCC) after making statements to a newspaper during her reelection campaign. The statements concerned her prior suspension for inappropriate comments about an attorney accused of diverting funds from her husband’s law firm. The JCC claimed her remarks to the newspaper were false or misleading, implicated her opponent, and downplayed the seriousness of her misconduct. The Commission sent her a proposed agreed public reprimand order, which she refused to sign. Believing the JCC’s actions chilled her speech and threatened enforcement under three specific judicial conduct rules, the judge sued JCC officials, alleging violations of her First Amendment rights. The United States District Court for the Eastern District of Kentucky partially granted and partially denied the judge’s claims. It granted her summary judgment and a permanent injunction on her as-applied challenge to Rule 4.1(A)(11), which prohibits judicial candidates from knowingly making false statements of material fact, finding the JCC’s enforcement against her statements unconstitutional. However, the district court denied her as-applied challenges to Rules 1.2 and 2.4(B), which address judicial independence and the influence of personal relationships, as well as her facial challenges to all three rules. The United States Court of Appeals for the Sixth Circuit found the judge had standing to sue and that the district court properly granted her an injunction under Rule 4.1(A)(11). However, the appellate court held that the district court erred in denying her as-applied challenges to Rules 1.2 and 2.4(B), as the JCC’s enforcement was not supported by evidence of false statements. The Sixth Circuit affirmed the injunction as to Rule 4.1(A)(11), reversed as to Rules 1.2 and 2.4(B), and remanded for entry of a permanent injunction against enforcement of all three rules as applied to the judge’s statements. View "Dutton v. Shaffer" on Justia Law

United States v. Collins

2026-04-01T13:00:37-08:00

The defendant pleaded guilty in 2010 to conspiracy to distribute and possess with intent to distribute a large quantity of cocaine base, for which he was sentenced to a lengthy prison term and a supervised release period. His sentence was later reduced under the First Step Act, resulting in a shorter prison term and an eight-year supervised release. After his release, the defendant demonstrated significant rehabilitation, complied with all conditions of supervision, and maintained steady employment and a stable residence, with no new criminal conduct. Following his positive adjustment, the defendant filed three separate motions in the United States District Court for the Eastern District of Tennessee seeking early termination of his supervised release. The district court denied the first motion, acknowledging his model behavior but emphasizing the seriousness of his offense and the statutory minimum term. The second motion was denied based solely on the judge’s custom of not considering early termination until at least half of the supervised release term had been served. After appealing this denial, the defendant filed a third motion, which the district court also denied, reiterating the importance of its fifty-percent custom and referencing deterrence and public safety. The United States Court of Appeals for the Sixth Circuit reviewed the consolidated appeals. The court held that the district court abused its discretion by employing a blanket rule requiring completion of at least half the supervision term before considering early termination, instead of conducting an individualized assessment under the relevant statutory factors in 18 U.S.C. § 3553(a) and § 3583(e)(1). The appellate court concluded that the district court’s reliance on its custom, without adequate consideration of the defendant’s circumstances and the statutory factors, was improper. The Sixth Circuit vacated the district court’s orders and remanded for further proceedings. View "United States v. Collins" on Justia Law

In re Tucker

2026-03-30T12:30:37-08:00

After receiving a chapter 7 discharge, the debtor filed for chapter 13 protection just two days later. She owned a vehicle subject to a lien held by a secured creditor, Santander, and proposed a chapter 13 plan allowing her to keep the vehicle by paying Santander’s claim in full with modified interest. However, due to the timing of her prior chapter 7 discharge, she was ineligible for a chapter 13 discharge under section 1328(f) of the Bankruptcy Code. Recognizing this, her plan provided that Santander would retain its lien until the debt was paid in full or until completion of all plan payments, rather than until a discharge was entered. The United States Bankruptcy Court for the Northern District of Ohio considered Santander’s objection that the plan failed to comply with section 1325(a)(5)(B)(i)(I), which allows a creditor to retain its lien until the debt is paid in full under nonbankruptcy law or until a discharge under section 1328. The bankruptcy court overruled Santander’s objection and confirmed the plan, reasoning that the plan met all the substantive requirements and that strict adherence to the statutory discharge provision would elevate form over substance. On appeal, the United States Bankruptcy Appellate Panel of the Sixth Circuit reviewed the bankruptcy court’s order de novo. The Panel held that the statutory language of section 1325(a)(5)(B)(i)(I) is unambiguous and mandatory: a secured creditor must retain its lien until the debt is paid in full under nonbankruptcy law or until a chapter 13 discharge is entered. Because the debtor was ineligible for a discharge, and Santander did not accept the plan, the bankruptcy court erred by confirming a plan that added a new event not found in the statute (completion of plan payments). The Panel reversed the bankruptcy court’s confirmation order and remanded for further proceedings consistent with its opinion. View "In re Tucker" on Justia Law

Smith v. Securities and Exchange Commission

2026-03-27T11:31:18-08:00

Eric Smith was the majority owner, chairman, and CEO of Consulting Services Support Corporation (CSSC), which wholly owned CSSC Brokerage Services, Inc. (CSSC-BD), a registered FINRA broker-dealer. Although CSSC-BD was registered, Smith did not personally register with FINRA, claiming an exemption so long as he was not involved in managing the securities business. However, between 2010 and 2015, Smith actively managed CSSC-BD, including overseeing debt offerings, preparing offering documents with false statements, and soliciting investments totaling $130,000 from four investors. A FINRA examination and investor complaints uncovered these activities. Following an investigation, FINRA’s Department of Enforcement filed a complaint against Smith for violations of federal securities laws and FINRA rules. After a disciplinary proceeding, FINRA found against Smith and imposed sanctions, including $130,000 in restitution and a bar from associating with any FINRA member. Smith appealed to the United States Securities and Exchange Commission (SEC), which affirmed FINRA’s findings and sanctions. Smith then sought review in the United States Court of Appeals for the Sixth Circuit, arguing that FINRA lacked jurisdiction over him and that the proceedings violated his rights under Article III and the Seventh Amendment. The United States Court of Appeals for the Sixth Circuit held that FINRA had statutory authority to discipline Smith because, despite not registering, he controlled a FINRA member firm and was therefore a “person associated with a member” under the relevant statute. The court found Smith’s constitutional claims barred because he failed to raise them before the SEC as required by statute, and none of the exceptions to the exhaustion requirement applied. The petition for review was denied. View "Smith v. Securities and Exchange Commission" on Justia Law

Machelle Pearson v. MDOC

2026-03-26T13:30:37-08:00

Four women incarcerated at the Huron Valley Correctional Facility in Michigan suffered from persistent, painful rashes between 2016 and 2019. Despite repeated complaints, medical staff—contracted through Corizon Health—failed to diagnose scabies, instead providing ineffective treatments and attributing the condition to environmental factors like improper laundering. It was only after an outside dermatologist intervened that scabies was correctly identified, prompting prison-wide treatment efforts. However, these efforts were delayed and, in some cases, inadequate, resulting in prolonged suffering for the affected inmates. After their experiences, the four women filed suit in the United States District Court for the Eastern District of Michigan against multiple defendants, including high-level Michigan Department of Corrections officials and Wayne State University medical officers, alleging Eighth Amendment violations and state-law negligence. The district court found that the women’s complaint plausibly alleged “clearly established” Eighth Amendment violations by all defendants and denied the officials’ request for qualified immunity. The court also rejected a claim of state-law immunity, finding that the officials could be the proximate cause of the inmates’ injuries under Michigan law. On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s denials. The Sixth Circuit held that existing precedent did not “clearly establish” that the non-treating prison officials’ reliance on contracted medical providers was so unreasonable as to violate the Eighth Amendment. Thus, it reversed the district court’s denial of qualified immunity on the federal damages claims. However, the appellate court affirmed the denial of state-law immunity, finding the plaintiffs adequately pleaded proximate cause under Michigan law. The case was remanded for further proceedings consistent with these holdings. View "Machelle Pearson v. MDOC" on Justia Law

Victory Global, LLC v. Fresh Bourbon, LLC

2026-03-26T13:30:37-08:00

A dispute arose between two bourbon companies, each owned by African Americans, regarding which could claim to be the first to distill bourbon in Kentucky. Victory Global, operating as Brough Brothers, began by sourcing bourbon from Indiana in 2020 and later opened its own distillery in Louisville, filling its first barrel of Kentucky bourbon at the end of that year. Fresh Bourbon, started by the Edwardses, developed its recipe and, lacking a distillery, began distilling bourbon at Hartfield & Co. in Bourbon County in 2018 with increasing hands-on involvement. Fresh Bourbon sold its Kentucky-made bourbon in 2020 and later opened its own distillery in Lexington in 2022 or 2023. Both companies marketed themselves as African American-owned, but Brough Brothers objected to Fresh Bourbon’s claims of being the first, arguing those statements were false or misleading. The United States District Court for the Eastern District of Kentucky reviewed the case on summary judgment. Brough Brothers alleged false advertising under the Lanham Act, asserting that Fresh Bourbon’s marketing contained literally false statements about being the first African American distillery or having the first African American master distiller since slavery. The district court found that the contested statements were, at most, misleading rather than literally false, and that Brough Brothers had not introduced evidence that consumers were actually deceived. It also concluded there was no showing of material impact on consumer decisions. The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision de novo. The Sixth Circuit affirmed summary judgment for Fresh Bourbon, holding that the statements in question were ambiguous and not literally false. The court emphasized that, absent unambiguously false statements, Brough Brothers needed to present evidence of consumer deception, which it failed to do. Thus, Brough Brothers’ claims under the Lanham Act could not survive. The decision of the district court was affirmed. View "Victory Global, LLC v. Fresh Bourbon, LLC" on Justia Law

BLC Lexington SNF, LLC v. Bonnie Town

2026-03-26T13:30:37-08:00

Linda Elam, after suffering significant medical issues including a stroke and complications from cancer treatment, was admitted to a nursing home operated by BLC Lexington SNF, LLC for rehabilitation. Her sister, Bonnie Townsend, acting under a power of attorney, handled the admission process and signed both the admission and an optional arbitration agreement as Elam’s representative. Following further health decline, Elam died, and her estate alleged that her death resulted from negligent care at the facility. After the estate filed suit in Kentucky state court against BLC Lexington and a former administrator, BLC Lexington responded in federal court, seeking to compel arbitration based on the agreement Townsend signed. The United States District Court for the Eastern District of Kentucky compelled arbitration for nearly all claims except wrongful death claims by nonsignatories. An arbitrator, after a week-long hearing, ruled in favor of BLC Lexington on all claims, finding Townsend had not met her burden of proof. The district court then confirmed the arbitration award, denying Townsend’s motions for reconsideration and to vacate the award. On appeal to the United States Court of Appeals for the Sixth Circuit, Townsend argued that compelling arbitration was improper because she did not sign as attorney-in-fact, that the arbitration agreement was indefinite, and that post-arbitration relief was warranted due to alleged arbitrator misconduct and the application of an incorrect legal standard. The Sixth Circuit affirmed the district court’s decisions, holding that the arbitration agreement was enforceable under Kentucky law, Townsend had acted as Elam’s representative, and no intervening change in law or arbitrator misconduct justified vacating the award. The court also found the arbitrator applied the correct evidentiary standard. The judgment of the district court was affirmed. View "BLC Lexington SNF, LLC v. Bonnie Town" on Justia Law

Schoening Investment LP v. Cincinnati Casualty Company

2026-03-25T10:03:42-08:00

A Florida-based limited partnership invested in commercial real estate in Kentucky and purchased insurance for those properties from an insurer. The insured property suffered damage in March 2022, and the partnership promptly filed a claim. The insurer’s adjuster evaluated the damage, determined it was repairable, and offered to pay the cost of repairs minus a deduction for depreciation, explaining that the insured could recover the deducted amount after completing repairs. The partnership had purchased additional coverage that would pay for repairs “without deduction for depreciation” if repairs were completed within two years; however, at the time of the claim, the repairs had not been made. After rejecting the insurer’s offer, the partnership filed a putative class action in the United States District Court for the Southern District of Ohio, arguing that the insurer breached the policy by deducting depreciation from the repair-cost settlement. The insurer moved to dismiss the complaint for failure to state a claim. The district court granted the motion, finding that the policy allowed the insurer to deduct depreciation unless and until the insured completed repairs, at which point the depreciation could be recovered under the optional coverage. The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that, under Kentucky law and the specific terms of the policy, the insurer was permitted to deduct depreciation from the payment for repair costs because the insured had not yet completed repairs. The court found that the optional coverage only eliminated the depreciation deduction if the insured actually repaired the property, which had not occurred. The Sixth Circuit affirmed the district court’s dismissal, concluding that the insurer’s actions were consistent with the contract’s terms. View "Schoening Investment LP v. Cincinnati Casualty Company" on Justia Law

United States v. Curry

2026-03-23T12:00:36-08:00

Police officers found the defendant unconscious in the driver’s seat of a vehicle parked behind an apartment building. During the ensuing welfare check, officers observed a firearm with a large drum magazine in the vehicle’s center console, along with suspected narcotics, a digital scale, sandwich bags (some containing substances), empty bags, cash, and several cellphones. The substances later tested positive for controlled drugs, including cocaine, fentanyl, methamphetamine, and psilocin. The vehicle was registered to another individual, Francine Gill. After his arrest, the defendant made jail calls referencing large amounts of money on Cash App cards and discussing the car with Gill. A federal grand jury indicted the defendant on six counts, including possession of controlled substances with intent to distribute, using or carrying a firearm during a drug trafficking crime, and being a felon in possession of a firearm. At trial in the United States District Court for the Northern District of Ohio, the prosecution presented evidence connecting the defendant to the drugs, cash, and firearm, including the jail call excerpts. The district court overruled the defendant’s objection to the admission of the calls. The jury convicted the defendant of possession with intent to distribute cocaine, using or carrying a firearm during and in relation to a drug trafficking crime, and being a felon in possession of a firearm. He was acquitted on other drug counts. The district court sentenced him to 154 months’ imprisonment after considering his health conditions and criminal history, but declined to grant a downward departure or variance. The United States Court of Appeals for the Sixth Circuit affirmed the convictions and sentence. The court held that sufficient evidence supported the convictions, that the district court did not abuse its discretion in admitting the jail calls, and that the sentence was substantively reasonable. The court also held that the denial of a downward departure was unreviewable because the district court understood its authority to grant one. View "United States v. Curry" on Justia Law

Grady v. Cratsenburg

2026-03-23T12:00:36-08:00

Daniel and Shatina Grady were arrested by police during a late-night shooting investigation outside a Michigan residence owned by their daughter. The Gradys lived nearby and approached the scene, filming officers and questioning their authority as they crossed into a perimeter that officers had established around the house suspected to contain the shooter. Despite receiving repeated commands to step back, the Gradys refused and continued to challenge the officers verbally. After warnings, the officers arrested them for interfering with the investigation, which led to a physical struggle. The Gradys were prosecuted in Michigan state court for assaulting, resisting, or obstructing the officers and damaging a police cruiser but were acquitted by a jury. While those charges were pending, the Gradys filed a civil suit in the United States District Court for the Eastern District of Michigan, raising several claims, including First Amendment retaliation. The district court found that the officers had probable cause to arrest the Gradys for failing to comply with lawful orders but allowed the First Amendment claim to proceed under the exception recognized in Nieves v. Bartlett. The district court concluded that the Gradys presented evidence that other bystanders, who had not criticized the police and were not arrested, were similarly situated. The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial of qualified immunity to the officers. The appellate court held that the other bystanders cited by the Gradys were not similarly situated because they did not enter the established perimeter or defy police orders. The court further found that the Gradys did not provide other objective evidence to satisfy the Nieves exception. As a result, the presence of probable cause defeated the Gradys’ First Amendment retaliatory arrest claim. The Sixth Circuit reversed the district court’s decision and remanded the case for further proceedings. View "Grady v. Cratsenburg" on Justia Law

United States v. Bailey

2026-03-23T12:00:36-08:00

Federal authorities investigated a drug trafficking scheme operating within Tennessee prisons, led by members of the Aryan Nation gang. Michael Bailey, while incarcerated, coordinated with James Payne (outside prison) to distribute methamphetamine and fentanyl. Bailey used contraband cell phones to direct drug purchases and sales, communicating with his girlfriend, mother, and other associates to manage the operation and profits. Law enforcement apprehended several participants, seized drugs and cash, and collected evidence, including recorded calls and testimony from co-conspirators. After an indictment, a jury in the United States District Court for the Western District of Tennessee found Bailey guilty of two counts of conspiracy to possess with intent to distribute controlled substances. He was sentenced to concurrent 300-month prison terms. Bailey moved for a judgment of acquittal and a new trial, arguing errors in jury instructions, evidence admission, and insufficient evidence, but the district court denied his motions. He then appealed to the United States Court of Appeals for the Sixth Circuit. The Sixth Circuit reviewed Bailey’s claims. It held that the jury instructions on conspiracy accurately stated the law, even after subsequent amendments to the pattern instructions. The court found no error in not giving a specific instruction on law enforcement testimony, as the standard instructions on witness credibility sufficed. The district court did not abuse its discretion in admitting evidence of gang affiliation, disciplinary records regarding cell phone possession, or a recorded phone call, finding them relevant and not unfairly prejudicial. Lastly, the appellate court held that sufficient evidence supported Bailey’s convictions. The court affirmed the district court’s judgment. View "United States v. Bailey" on Justia Law

United States v. Hostettler

2026-03-20T11:30:37-08:00

A defendant with a prior felony conviction was found with a firearm while on supervised release, in violation of federal law prohibiting felons from possessing firearms. The conduct leading to the indictment included absconding from supervision and being discovered with a gun, which also violated the terms of his supervised release. He moved to dismiss the federal indictment, arguing that the statute was unconstitutional both on its face and as applied to him, relying on recent Supreme Court decisions concerning the Second Amendment. The United States District Court for the Northern District of Ohio granted the motion to dismiss, finding the relevant federal statute unconstitutional as applied to the defendant. The district court placed the burden on the government to justify the restriction, considered only the defendant's felony convictions (not his entire criminal record), and did not account for his supervised release status. The government appealed to the United States Court of Appeals for the Sixth Circuit. While the appeal was pending, the Sixth Circuit issued new precedent clarifying the proper standard for reviewing Second Amendment challenges. This precedent shifted the burden to the defendant to show he is not dangerous and required courts to consider the full criminal history and supervised release status. The United States Court of Appeals for the Sixth Circuit determined that the district court had not applied the correct legal standard and that the existing record was insufficient for an individualized dangerousness determination. The appellate court vacated the district court’s dismissal and remanded for reconsideration of the motion to dismiss, instructing the district court to apply the correct legal standard consistent with current circuit precedent and to provide the defendant an opportunity to demonstrate he is not dangerous. View "United States v. Hostettler" on Justia Law