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

Summit Locations, LLC v. Bd. of Trustees, Bath Township

2026-09-04T08:00:06-08:00

A company engaged in outdoor advertising sought to erect a large billboard in a business district of Bath Township, Ohio. The local zoning inspector denied its application, citing a categorical ban on “off-premises” signs under the township’s zoning resolution. The company’s proposed billboard would have been a two-sided structure, 30 feet tall and 360 square feet per side. Notably, the company did not challenge other relevant provisions of the zoning resolution, such as the bans on “pole signs” and “high-rise” signs, which also would have prohibited the proposed billboard. The company, joined by a related entity, filed suit in the United States District Court for the Northern District of Ohio, asserting that the off-premises sign ban violated the First Amendment and conflicted with Ohio law. The defendants, Bath Township’s board of trustees and zoning officials, moved to dismiss on the ground that the plaintiffs lacked standing because even if the off-premises ban were invalidated, other unchallenged provisions would still bar the billboard. The district court agreed and dismissed the case, declining to exercise supplemental jurisdiction over the state law claim. On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s dismissal. The court held that the plaintiffs lacked Article III standing because invalidating the off-premises sign ban would not redress their injury, as the bans on pole and high-rise signs would independently prohibit the billboard. The court found that this reasoning was controlled by its prior decision in Midwest Media Property, L.L.C. v. Symmes Township. The Sixth Circuit also found that the plaintiffs had forfeited any alternative standing theories, such as those based on the permitting process or application fees, by not properly raising them. The judgment of the district court was affirmed. View "Summit Locations, LLC v. Bd. of Trustees, Bath Township" on Justia Law

NLRB v. VNS Fed. Servs., LLC

2026-09-03T11:30:06-08:00

Israel Bo Sword worked as a heavy equipment operator for VNS Federal Services, LLC at the Portsmouth Gaseous Diffusion Plant in Ohio, where he and co-workers were represented by the International Union of Operating Engineers, Local 18. VNS was bound by the General Presidents’ Project Maintenance Agreement (GPPMA) in its dealings with the Union. In February 2020, Sword complained to his supervisor that a side agreement guaranteeing another operator 40 hours per week violated the collective bargaining agreement, and he later sought assistance from his union representative to address his concerns. Shortly after the union meeting with management about Sword’s complaint, Sword was permanently laid off, while other operators returned to work. Sword filed unfair labor practice charges against VNS with the National Labor Relations Board (NLRB), alleging unlawful discharge in retaliation for engaging in protected concerted activity. After a hearing, an administrative law judge found that VNS violated Sections 8(a)(3) and (1) of the National Labor Relations Act (NLRA). VNS filed exceptions, but the NLRB affirmed the ALJ’s findings and issued an order requiring VNS to offer Sword reinstatement, provide backpay, and post remedial notices. The NLRB declined to resolve disputes over remedies at that stage, following its practice of deferring such issues to compliance proceedings. The United States Court of Appeals for the Sixth Circuit reviewed the NLRB’s petition to enforce its order. The court found substantial evidence supporting the NLRB’s determination that Sword engaged in protected concerted activity, that VNS discharged him because of animus toward that activity, and that VNS’s justification for the layoff was pretextual. The Sixth Circuit granted enforcement of the NLRB’s order in full, declining to address challenges to the scope of remedies until compliance proceedings are completed. View "NLRB v. VNS Fed. Servs., LLC" on Justia Law

United States v. Boyd

2026-09-02T12:30:06-08:00

While serving a sentence for manslaughter and assault in a South Carolina prison, the defendant used a contraband cell phone to pose as an underage girl on a dating app. He initiated contact with a 22-year-old Michigan man, referred to as B.G., and exchanged sexually explicit messages and images. After revealing (falsely) that the girl was underage, the defendant, posing as the girl’s grandparent, threatened to expose B.G. to his family and law enforcement unless B.G. sent money. The defendant then sent explicit messages to B.G.’s ex-fiancée and her mother and publicly posted accusations of pedophilia on social media. Shortly after these threats and exposures, B.G. died by suicide. A federal grand jury indicted the defendant on charges including attempted extortion under the Hobbs Act, stalking with intent to harass and intimidate, and multiple counts of wire fraud. A jury in the United States District Court for the Western District of Michigan found him guilty on all counts. At sentencing, the district court applied the Sentencing Guideline for extortion by force or threat of injury or serious damage (U.S.S.G. § 2B3.2), and added enhancements for discharge of a firearm and for the victim sustaining life-threatening injury, resulting in a total sentence of 272 months’ imprisonment. The defendant objected to the choice of Guideline, the enhancements, and the consecutive nature of the sentences, but the district court overruled these objections. On appeal, the United States Court of Appeals for the Sixth Circuit held that the district court correctly used the extortion Guideline rather than the blackmail Guideline. However, the appellate court concluded that the enhancements for firearm discharge and life-threatening injury were procedurally unreasonable, as there was no evidence the defendant willfully caused B.G.’s suicide. The court affirmed the application of the correct Guideline but reversed the application of the enhancements, remanding for resentencing without them. View "United States v. Boyd" on Justia Law

United States v. Hilton

2026-09-01T11:30:07-08:00

The defendant pleaded guilty to possession with intent to distribute methamphetamine and possession of a firearm in furtherance of a drug trafficking crime. Both offenses carried statutory mandatory minimum sentences of 60 months, with the firearm sentence required to run consecutively. The United States District Court for the Eastern District of Tennessee calculated the defendant’s Guidelines range as 120 to 131 months and imposed a 120-month sentence. Later, after the defendant provided substantial assistance to the government, the court granted a Rule 35(b) motion and reduced the sentence to 100 months. Following her resentencing, the United States Sentencing Commission adopted Amendment 821, which changed how criminal-history points are calculated and was made retroactive. Under the new calculation, the defendant’s criminal-history category would have been lower, resulting in a reduced Guidelines range. The defendant moved pro se for a further sentence reduction under 18 U.S.C. § 3582(c)(2), arguing that Amendment 821 lowered her sentencing range. The district court denied the motion, finding her sentence was not “based on” a Guidelines range but on statutory minimums, and denied a subsequent motion for reconsideration. The defendant appealed both orders, resulting in two consolidated appeals. The United States Court of Appeals for the Sixth Circuit reviewed the district court’s eligibility determination de novo. It held that the defendant’s sentence was indeed “based on a sentencing range that has subsequently been lowered” by the Sentencing Commission, specifically Amendment 821. The court found that the relevant Guidelines range, excluding mandatory minimums due to the prior substantial-assistance reduction, had been lowered. Accordingly, the Sixth Circuit vacated the district court’s order denying the initial motion and remanded for further proceedings to consider other eligibility requirements. The second appeal was dismissed as moot. View "United States v. Hilton" on Justia Law

United States v. Hoffpowier

2026-08-28T11:00:07-08:00

The case concerns Michael C. Hoffpowier, who was investigated after his estranged wife, B.H., reported to law enforcement that he had scheduled an appointment at her workplace under a false name and had a history of harassing her across multiple states. Officers responding to the scene located Hoffpowier’s vehicle in a nearby parking lot. Upon approaching, they observed behavior they interpreted as a potential flight risk, including the vehicle being put in reverse. Hoffpowier was handcuffed after failing to comply with commands to approach an officer. While detained, officers reviewed text messages between Hoffpowier and B.H. and, with his consent, observed binoculars and a gun magazine in his vehicle. A search of the vehicle revealed firearms and a silencer. The United States District Court for the Eastern District of Tennessee denied Hoffpowier’s motion to suppress the evidence obtained from the search, concluding that the handcuffing did not constitute an arrest and that there was a reasonable basis to believe the vehicle contained evidence related to stalking. The magistrate judge’s report and recommendation to deny suppression was adopted after Hoffpowier’s objections were overruled, in part because he did not update his arguments in light of the report’s analysis. Hoffpowier subsequently pleaded guilty to possession of an unregistered silencer. On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s decision. The court held that the officers’ use of handcuffs during the investigatory stop was reasonable given the circumstances and did not convert the stop into an arrest. It further held that the presence of binoculars visible in the vehicle provided a reasonable basis to believe that the vehicle contained evidence pertinent to the stalking offense, justifying the warrantless search under the search-incident-to-arrest exception. View "United States v. Hoffpowier" on Justia Law

NetChoice, LLC v. Skrmetti

2026-08-28T11:00:07-08:00

A trade association representing internet companies challenged the enforcement of a new Tennessee statute designed to protect minors from social media risks. The law requires social media companies to verify the ages of all prospective account holders and secure parental consent before allowing minors to create accounts. It also mandates that parents be given tools to supervise their children’s accounts. The association argued that its members would suffer unrecoverable compliance costs and that the law would restrict their and their users’ First Amendment rights. The United States District Court for the Middle District of Tennessee denied the association’s motion for a preliminary injunction. The district court concluded that the association had not established irreparable harm, finding that the alleged loss of First Amendment freedoms was not sufficiently certain or imminent, and that unrecoverable compliance costs did not qualify as irreparable harm. Because the court found no irreparable harm, it did not consider the other preliminary injunction factors. The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial. The appellate court disagreed with the lower court’s analysis of irreparable harm, holding that both unrecoverable compliance costs and the loss of First Amendment freedoms can satisfy the threshold requirement for irreparable harm. The court explained that compliance costs need not be extraordinary to be considered irreparable and that the chilling effect on speech, even before enforcement, can constitute irreparable harm if enforcement is likely and imminent. The Sixth Circuit vacated the district court’s order and remanded the case for further consideration of all preliminary injunction factors, directing the lower court to weigh the harm asserted and address the remaining legal standards as appropriate. View "NetChoice, LLC v. Skrmetti" on Justia Law

Williams v. Mastronardi Produce-USA, Inc.

2026-08-28T11:00:07-08:00

The plaintiff alleged she experienced race and gender discrimination, harassment, and retaliation while employed at a facility operated by a subsidiary corporation in Michigan. Initially, she sued the parent corporation, claiming it was her employer and responsible for the alleged misconduct. The parent corporation contended she had sued the wrong entity and provided evidence that the subsidiary, not the parent, was her employer. The district court in the first case sided with the parent corporation, finding that it was not the plaintiff’s employer and that the complaint did not support a joint-employer theory or veil-piercing. After this ruling, the plaintiff filed a new suit against the subsidiary, asserting similar factual allegations and an additional hostile work environment claim under Michigan law. In the United States District Court for the Eastern District of Michigan, the subsidiary moved to dismiss the new case, arguing that claim preclusion barred the suit because the parent and subsidiary were in privity. The district court rejected the argument that the subsidiary had controlled the prior litigation but applied a “close-and-significant-relationship” test based on the parent-subsidiary relationship and equitable considerations. Concluding that privity existed and the other elements of claim preclusion were met, the district court granted the subsidiary’s motion to dismiss. The United States Court of Appeals for the Sixth Circuit reviewed the dismissal de novo. The appellate court held that the district court erred by applying the “close-and-significant-relationship” test for privity, rather than the six recognized exceptions to nonparty preclusion from Taylor v. Sturgell. None of the exceptions—pre-existing substantive legal relationship, control, or adequate representation—applied to the facts. Therefore, claim preclusion did not bar the plaintiff’s suit against the subsidiary. The Sixth Circuit reversed the district court’s decision. View "Williams v. Mastronardi Produce-USA, Inc." on Justia Law

Gomez-Echeverria v. Purpose Point Harvesting, LLC

2026-08-28T11:00:06-08:00

A group of Guatemalan nationals were recruited under the H-2A visa program by a Michigan agricultural company and its owners to work seasonal jobs between 2017 and 2019. The plaintiffs alleged that the defendants illegally charged recruitment fees, underpaid wages, forced them to live in poor conditions, confiscated personal documents, limited their freedom, and threatened them with deportation if they complained. The plaintiffs claimed these actions violated federal anti-trafficking laws, the Fair Labor Standards Act, Michigan labor and trafficking statutes, and state contract law. In the United States District Court for the Western District of Michigan, the case proceeded to a jury trial. The jury found in favor of the plaintiffs on most claims, awarding both compensatory and punitive damages, while denying certain claims against one defendant and rejecting the defendants’ counterclaims. The district court denied the defendants’ motions for mistrial, to dismiss for forum non conveniens, for a new trial, and for remittitur of punitive damages. The court entered judgment for the plaintiffs, including damages, attorney fees, and costs. The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the punitive damages awarded were not grossly excessive or arbitrary and thus did not violate due process, applying the guideposts from BMW of North America, Inc. v. Gore and State Farm Mutual Automobile Insurance Co. v. Campbell. The court also found no abuse of discretion in the district court’s evidentiary rulings, denial of a mistrial, or in allowing the case to proceed in Michigan rather than Guatemala. The court further concluded that alleged statute of limitations defenses were either inapplicable or waived. The Sixth Circuit affirmed the district court’s judgment in all respects. View "Gomez-Echeverria v. Purpose Point Harvesting, LLC" on Justia Law

Zimmermann v. Labish

2026-08-27T11:30:22-08:00

A fourteen-year-old student, JPZ, was suspended from school following an altercation. The school principal, Melissa Arendts, notified JPZ's mother and requested JPZ be picked up. Upon arrival, JPZ's grandmother found him isolated and awaiting questioning by Scott Labish, a sheriff’s deputy serving as a school resource officer. Labish, in uniform, questioned JPZ, allegedly in a threatening manner, and told him about a “Three Strike” policy that would result in criminal prosecution and expulsion after another infraction. JPZ became distressed, left school, and subsequently died by suicide at home several hours later. JPZ's father, Brian Zimmermann, as administrator of JPZ’s estate, sued Arendts, Labish, the school district, and Macomb County, alleging federal due process violations and state law claims. The United States District Court for the Eastern District of Michigan dismissed the wrongful death claim but allowed four other claims to proceed: deprivation of substantive due process, conspiracy, intentional infliction of emotional distress, and Monell liability. Defendants moved to dismiss the remaining claims based on qualified and state governmental immunity and deficiencies in the Monell claim. The district court denied these motions in part, leading to an interlocutory appeal by the defendants. The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial de novo. The Sixth Circuit held that the facts did not support a substantive due process claim under the state-created danger doctrine, as the defendants neither increased JPZ’s risk of harm from a third party nor acted with deliberate indifference. The conspiracy and Monell claims failed because no underlying constitutional violation was adequately alleged. The court also found the defendants entitled to state governmental immunity for the intentional infliction of emotional distress claim, as the conduct alleged did not indicate malice. The Sixth Circuit reversed the district court’s denial of the motions to dismiss and remanded the case. View "Zimmermann v. Labish" on Justia Law

United States v. Forrester

2026-08-27T11:30:19-08:00

Several individuals affiliated with the Clarksville, Tennessee chapter of the Mongols Motorcycle Club were indicted by a federal grand jury on charges including racketeering conspiracy (RICO), murder, kidnapping, drug trafficking, and related crimes. The Mongols, a national motorcycle gang with a history of violence and drug distribution, established a chapter in Clarksville around 2015. The group engaged in violent acts to assert dominance, including two murders: one of a woman believed to have stolen drugs and another of a former member following an internal dispute. They also participated in extensive methamphetamine and prescription pill trafficking, multiple assaults, kidnappings, and other crimes. The United States District Court for the Middle District of Tennessee presided over a joint trial of the seven remaining defendants after others pleaded guilty or died. The jury convicted the defendants on various counts, ranging from racketeering and drug conspiracy to violent crimes in aid of racketeering, money laundering, and accessory after the fact. Sentences ranged from approximately 18 years to mandatory life imprisonment, with some consecutive terms. On appeal, the United States Court of Appeals for the Sixth Circuit reviewed numerous arguments, including challenges to the sufficiency of the evidence, the use of a semi-anonymous jury, admission of expert and other evidence, and trial delays caused by COVID-19. The court also considered claims regarding jury instructions, denial of severance and mistrial motions, sentencing errors, and substantive unreasonableness of sentences. The Sixth Circuit found no reversible error. It held that sufficient evidence supported all convictions, the jury and trial procedures were within the district court’s discretion, and any instructional or sentencing issues did not warrant reversal or resentencing. Accordingly, the court affirmed the convictions and sentences of all appellants. View "United States v. Forrester" on Justia Law

Adams v. Med. Protective Co.

2026-08-27T11:30:17-08:00

Several patients suffered harm after undergoing surgeries performed by Abubakar Atiq Durrani, M.D., whose conduct involved unnecessary procedures and fraudulent misrepresentations about the need for surgery. Following Durrani’s indictment and flight from the United States, hundreds of injured patients pursued civil suits in Ohio state court, obtaining judgments against Durrani for negligence, fraud, and, in some cases, battery or lack of informed consent. After prevailing at trial but unable to collect damages directly from Durrani, the plaintiffs sought to enforce their judgments against his insurer, the Medical Protective Company (MedPro), under the terms of Durrani’s malpractice insurance policy. In the United States District Court for the Southern District of Ohio, the plaintiffs filed enforcement actions to compel MedPro to pay their verdicts and initiated a direct action against MedPro and its vice president, alleging bad faith and other torts related to MedPro’s handling of the litigation and denial of payment. The district court dismissed all claims, finding that the policy’s exclusion for damages “in consequence of” intentional torts (including fraud) barred coverage where the damages were inseparable from Durrani’s fraudulent acts, and that Ohio law permits only the insured—not third-party claimants—to assert bad faith claims against insurers. On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s decisions. The court held that MedPro’s policy exclusion applies when the plaintiffs’ damages directly arise from and cannot be separated from Durrani’s fraud. Where jury verdicts did not allocate damages between negligence and fraud, or where all remaining damages were tied to fraudulent acts, the plaintiffs could not plausibly claim coverage. The court further held that, under Ohio law, third-party claimants may not bring bad faith claims against insurers, and the plaintiffs failed to state any viable independent tort claims. The district court’s dismissals were therefore affirmed in all respects. View "Adams v. Med. Protective Co." on Justia Law

O'Connor v. Eubanks

2026-08-26T11:30:07-08:00

Dennis O’Connor had two non-interest-bearing financial accounts with private companies. After O’Connor lost contact with these companies, they transferred his accounts to the State of Michigan under the state’s Uniform Unclaimed Property Act, which governs the handling of unclaimed property. Michigan took custody of O’Connor’s accounts and deposited the funds into its general fund, where the money could generate interest for the state. When O’Connor learned of this, he contended that the state’s failure to pay him the interest earned while holding his money violated his constitutional rights. Previously, the United States District Court for the Eastern District of Michigan dismissed all of O’Connor’s claims, finding that the state took ownership of his accounts and thus owed him no interest. On an earlier appeal, the United States Court of Appeals for the Sixth Circuit affirmed the dismissal of his takings claims but vacated the dismissal of his due process claims and remanded for further proceedings. On remand, the district court again dismissed O’Connor’s due process claims, reasoning that Michigan’s ownership of the accounts meant O’Connor had no right to the interest and that the procedures provided were constitutionally sufficient. The United States Court of Appeals for the Sixth Circuit reviewed the dismissal de novo. The court held that under Michigan law, the state only assumes custody—not ownership—of unclaimed property, and the original owner retains title to both the principal and any interest generated. The court found that the district court erred by following contrary state appellate precedent and by concluding that O’Connor had no property interest in the funds or the interest. The court vacated the district court’s judgment dismissing the due process claims and remanded for further proceedings, directing the lower court to analyze the due process claim based on the correct understanding that O’Connor retained ownership rights. View "O'Connor v. Eubanks" on Justia Law

Woodcock v. Univ. of Kentucky

2026-08-24T11:30:06-08:00

A tenured law professor at a state university posted an online petition calling for military action against Israel. The university responded by placing the professor on administrative leave and restricting his campus access while it investigated whether his actions violated university policy or law. The investigation included notices to the professor, requests for evidence, and allegations from students, but had not progressed beyond the preliminary fact-finding stage. No formal hearing or charges had been initiated by the university at the time of the lawsuit. The professor filed suit in the United States District Court for the Eastern District of Kentucky, seeking a preliminary injunction to stop the university’s actions. The university moved for abstention under the doctrine established in *Younger v. Harris*, arguing that the ongoing university investigation constituted a state proceeding warranting federal court abstention. The district court agreed with the university and abstained from hearing the case, prompting the professor to appeal. The United States Court of Appeals for the Sixth Circuit reviewed the district court’s abstention decision de novo. The Sixth Circuit held that the university’s investigation was still in a preliminary, investigatory stage and did not constitute an ongoing formal proceeding as required under the *Younger* abstention framework. The court distinguished the circumstances from prior cases involving formal disciplinary hearings, noting that no formal charges or hearings had yet been initiated. As a result, the Sixth Circuit reversed the district court’s decision to abstain and remanded the case for consideration of the professor’s motion for a preliminary injunction. View "Woodcock v. Univ. of Kentucky" on Justia Law

Metcalf v. Michigan

2026-08-24T11:30:06-08:00

A quadriplegic individual applied to become a foster parent in Michigan, relying on a network of full-time aides and informal caregivers to assist with physical tasks. Despite successfully completing initial steps of the application process, her physician’s medical statement indicated she was physically incapable of caring for a foster child. The private agency overseeing her application, after home visits and a review of her situation, recommended against granting her a foster license, citing several state regulatory provisions related to the physical and mental health required of foster parents. The state agency subsequently administratively closed her application, permitting her to reapply at any time or provide additional information. The United States District Court for the Eastern District of Michigan reviewed the case after the applicant sued the State of Michigan, individual officials, and the private agency, alleging violations of the Americans with Disabilities Act (ADA), the Rehabilitation Act, and the Equal Protection Clause. The parties filed cross-motions for summary judgment. The district court granted summary judgment in favor of the defendants on all claims, finding that the applicant’s proposed accommodation—her network of aides—was not a reasonable accommodation under the ADA or Rehabilitation Act, and that the defendants’ actions were rationally related to legitimate state interests. The United States Court of Appeals for the Sixth Circuit affirmed the district court’s grant of summary judgment. The court held that while the ADA and Rehabilitation Act require individualized assessments and reasonable accommodations, the applicant’s patchwork of formal and informal assistance did not reliably assure the physical care of foster children, making her accommodation request unreasonable. The court also found no facial disability discrimination in Michigan’s foster care regulations and concluded that the defendants’ actions did not violate Equal Protection, as they were rationally related to ensuring child safety. View "Metcalf v. Michigan" on Justia Law

OPERS v. FHLMC

2026-08-21T11:31:22-08:00

A large public pension fund alleged that a government-sponsored enterprise and three of its senior officers made false and misleading statements regarding the company’s exposure to subprime and Alt-A mortgages during a period preceding the 2008 financial crisis. The pension fund claimed that the company’s public statements and disclosures understated its exposure to high-risk loans, while internal documents and risk assessments suggested a much greater level of risk. It further argued that, when the company’s actual exposure came to light, its stock price fell, resulting in significant losses to shareholders. Previously, the United States District Court for the Northern District of Ohio denied class certification, excluded the pension fund’s expert, and granted summary judgment to the defendants. The court concluded that the pension fund failed to establish reliance due to an inability to show that the company’s stock traded in an efficient market, improperly rejected the fund’s price-maintenance theory of fraud, found insufficient evidence to support loss causation and damages, and determined the defendants did not act with scienter. The court also found no actionable misstatements regarding credit-risk and underwriting standards, and dismissed control-person liability claims after finding no underlying securities violation. On appeal, the United States Court of Appeals for the Sixth Circuit reversed in part, vacated in part, and remanded. The appellate court held that the pension fund presented sufficient evidence for a jury to find that the company made materially false or misleading statements regarding its subprime and Alt-A exposure, and that issues of scienter and reliance were present. The court determined that the lower court erred in rejecting the price-maintenance theory and improperly excluded the plaintiff’s expert. It also concluded that the fund should be allowed another opportunity to seek class certification and to present evidence of loss causation and damages. The court reinstated the underlying securities fraud and control-person liability claims for further proceedings. View "OPERS v. FHLMC" on Justia Law

Till v. King

2026-08-21T11:31:21-08:00

A 15-year-old, ELG, participated in a vocational program for teenagers that included a visit to a Michigan district court. During a lecture given by Judge Kenneth J. King about his career, ELG fell asleep, which offended Judge King. In response, Judge King orchestrated a plan to “scare her straight” by having ELG handcuffed, placed in a detention cell, required to wear a prison jumpsuit, and later subjected her to a mock trial in front of her peers, which was streamed online. There was no official court proceeding, case number, or record associated with these actions, and Judge King later admitted his actions were intended to teach ELG a lesson for perceived disrespect. Following these events, Latoreya Till, ELG’s mother, filed a lawsuit in the United States District Court for the Eastern District of Michigan. The complaint alleged violations of ELG’s Fourth Amendment rights and state law torts. Judge King moved to dismiss the case, arguing judicial immunity protected him from suit. The district court denied his motion, finding that the conduct alleged was not within the scope of judicial functions. Judge King appealed, and Till cross-appealed on an alternative theory. The United States Court of Appeals for the Sixth Circuit reviewed the lower court’s denial of the motion to dismiss de novo. It held that Judge King’s alleged actions were not judicial acts because they did not constitute functions normally performed by a judge nor did they occur in his judicial capacity. The court further found that Till’s alternative argument, based on a “complete absence of all jurisdiction,” was inapplicable. The Sixth Circuit affirmed the district court’s decision, holding that Judge King was not entitled to judicial immunity at this stage of the proceedings. View "Till v. King" on Justia Law

Gordon v. City of Hamtramck, Mich.

2026-08-21T11:31:21-08:00

In this case, two individuals served as members of the Human Relations Commission (HRC) in Hamtramck, Michigan, which oversaw city-owned flagpoles along a main avenue. For a decade, the HRC operated under an unwritten policy that allowed residents to request flags to be flown, including flags of different nations and various groups, such as the Pride flag. After a change in city administration in 2021, tension arose when the HRC flew the Pride flag in 2022. Responding to controversy, the newly elected City Council enacted a resolution in 2023 restricting the flagpoles to only certain flags—specifically, the American, Michigan, Hamtramck, and Prisoner of War flags, as well as those of nations representing the city’s international character. When the plaintiffs raised the Pride flag in defiance, the City Council removed them from the HRC and stripped the HRC’s authority over the flagpoles. The plaintiffs then brought suit in the United States District Court for the Eastern District of Michigan, alleging violations of the Free Speech, Establishment, and Equal Protection Clauses. The district court granted summary judgment in favor of the City and its officials, finding that after the 2023 resolution, the flagpoles served as a forum for government speech, not private speech, and that the resolution was facially neutral regarding religion and not motivated by religious purpose. The court also determined that the plaintiffs had not adequately developed an equal protection claim. On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The Sixth Circuit held that the City permissibly closed the flagpoles to private speech, making them a vehicle solely for government speech, and thus the plaintiffs’ Free Speech Clause claim failed. The court also held that the plaintiffs’ Establishment Clause claim was unavailing, as there was no evidence the resolution’s primary purpose was to advance religion. Finally, the court concluded the plaintiffs had forfeited their equal protection claim by not developing it. View "Gordon v. City of Hamtramck, Mich." on Justia Law

Laurel Hill Mgmt. Servs., Inc v. La-Z-Boy Inc.

2026-08-19T11:00:39-08:00

A company sponsored a health benefit plan for its employees, which was administered by another entity. An employee under this plan, referred to as Patient AA, sought medical treatment from several out-of-network providers. Before providing care, these providers contacted the plan administrator to confirm the reimbursement rate. The administrator’s employees orally stated that reimbursement would be at the usual, customary, and reasonable (UCR) rate, a standard commonly used in the industry. Relying on these assurances, the providers treated Patient AA. When they later sought payment, they were reimbursed at a much lower rate, calculated according to Medicare rates, not the promised UCR rate. The providers sued both the employer and the plan administrator, asserting state-law claims for negligent misrepresentation and promissory estoppel based on the oral statements about reimbursement. The action began in California state court but was removed to federal court and transferred to the United States District Court for the Eastern District of Michigan. The defendants moved to dismiss the complaint, arguing that the claims were preempted by the Employee Retirement Income Security Act of 1974 (ERISA). The district court agreed, applying the Sixth Circuit’s decision in Cromwell v. Equicor-Equitable HCA Corp., and dismissed the complaint with prejudice, finding that the claims “related to” the ERISA plan and were thus preempted. The district court also denied the providers’ post-judgment request for leave to amend their complaint. The United States Court of Appeals for the Sixth Circuit affirmed. The court held that, under its precedent in Cromwell, ERISA expressly preempts state-law negligent-misrepresentation and promissory-estoppel claims by third-party healthcare providers when those claims are based on oral assurances regarding the terms of coverage or reimbursement under an ERISA-governed plan. The district court’s dismissal with prejudice was upheld. View "Laurel Hill Mgmt. Servs., Inc v. La-Z-Boy Inc." on Justia Law

United States v. Neal

2026-08-19T11:00:39-08:00

Steven Neal was charged with attempting to entice a 12-year-old girl to engage in illegal sexual activity over a nearly two-year period, during which he also sexually assaulted the victim on two occasions. Neal communicated with the girl through Facebook Messenger and, during the charged period, committed the assaults—one in July 2022 at a cabin and another in August 2023 at his home. Neal pleaded guilty to the enticement charge and admitted to the assaults during his plea. In the United States District Court for the Eastern District of Kentucky, Neal’s presentence report recommended several sentencing enhancements based on the two sexual assaults. Neal objected, arguing that only his messaging, not the assaults, should be considered for sentencing. The district court overruled his objections, finding the assaults to be “relevant conduct” under U.S.S.G. § 1B1.3, applying cross-references and enhancements to arrive at a guidelines range of 292 to 365 months. Neal was sentenced to 292 months’ imprisonment. On appeal to the United States Court of Appeals for the Sixth Circuit, Neal challenged both the procedural and substantive reasonableness of his sentence. The Sixth Circuit found that the district court correctly considered the assaults as relevant conduct since they occurred during the commission of the continuing enticement offense, had a logical relationship to it, and were independently criminal. The court also found no error in applying the sentencing enhancements and rejected arguments that their application resulted in impermissible double counting. The appellate court further determined that the sentence, imposed at the bottom of the guidelines range, was substantively reasonable given the seriousness of the offense and the district court’s consideration of mitigating factors. The Sixth Circuit affirmed the district court’s judgment. View "United States v. Neal" on Justia Law

United States v. Clay

2026-08-19T11:00:39-08:00

While on parole for prior state drug offenses, Frank Clay, Jr. was involved in a late-night disturbance at a convenience store in Grand Rapids, Michigan, in July 2024. Witnesses reported that Clay was carrying a firearm and acting aggressively. When law enforcement arrived, Clay resisted arrest and, during the struggle, bit an officer on the groin, causing an injury that required medical attention. Upon searching Clay, officers found a pistol, approximately 16 grams of cocaine divided into 11 baggies, and $230 in cash. Later investigation revealed that the pistol was reported as stolen and that Clay was on parole for multiple drug convictions. Clay was charged in the United States District Court for the Western District of Michigan with possessing a firearm as a felon and pleaded guilty without a plea agreement. At sentencing, the Probation Office recommended three sentencing enhancements: reckless endangerment (for biting the officer), possession of a firearm in connection with another felony (possessing cocaine with intent to distribute), and possession of a stolen firearm. Clay objected to each enhancement and also requested that his federal sentence run concurrently with any potential state sentence for parole violation. The district court overruled his objections, applied all three enhancements, and imposed a sentence of 151 months to run consecutive to any state sentence. On appeal to the United States Court of Appeals for the Sixth Circuit, Clay challenged the application of the three sentencing enhancements and the imposition of a consecutive sentence. The Sixth Circuit held that the district court did not err in applying the enhancements: the evidence supported findings of reckless endangerment, intent to distribute cocaine, and possession of a stolen firearm. The court also found no error in the imposition of a consecutive sentence, noting that the district court’s reasoning was sufficient. The judgment of the district court was affirmed. View "United States v. Clay" on Justia Law

West v. United States

2026-08-14T11:30:40-08:00

Roy Christopher West was convicted in 2007 of using interstate facilities to commission a murder-for-hire, after Leonard Day, who had stolen from West, was killed in Detroit. Evidence showed West offered money for Day’s murder and coordinated with two accomplices, supplying them with weapons and vests. After Day was shot, cell phone data placed one accomplice at the scene, and subsequent calls and conversations implied West’s involvement and satisfaction with the outcome. West was charged under 18 U.S.C. § 1958, which carries a ten-year maximum unless “death results,” in which case a mandatory life sentence applies. However, the indictment did not specifically charge the “death results” enhancement, nor was the jury instructed on it. Following his conviction, West’s direct appeal to the United States Court of Appeals for the Sixth Circuit raised various evidentiary issues but not the Apprendi error concerning the sentencing enhancement. The Sixth Circuit affirmed his conviction. West’s initial motion under 28 U.S.C. § 2255 also did not include the Apprendi claim. His conviction became final in 2013, and he filed his § 2255 motion just before the one-year deadline. Years later, he raised the Apprendi issue for the first time in a Rule 60(b)(6) motion after unsuccessful attempts at compassionate release and other post-conviction relief. The United States District Court for the Eastern District of Michigan denied the Rule 60(b) motion, holding that any renewed § 2255 claim would be time-barred and that West did not qualify for equitable tolling or other exceptions. The United States Court of Appeals for the Sixth Circuit affirmed the district court’s denial, holding that Rule 60(b)(6) relief was unavailable because any underlying Apprendi-based claim would be barred by § 2255’s one-year statute of limitations and West failed to demonstrate grounds for tolling or an actual innocence exception. The court ruled that procedural barriers and lack of diligence prevented reopening the judgment. View "West v. United States" on Justia Law

United States v. Barber

2026-08-14T11:30:40-08:00

Tianna Barber was implicated in a major drug trafficking operation in Toledo, Ohio, which sourced heroin, fentanyl, cocaine, and methamphetamine from a Mexican cartel. Federal investigators, after surveilling a courier and Derrick Murphy, uncovered Barber’s involvement as Murphy’s intermediary while he was incarcerated. She facilitated drug transactions, stored drugs at her home, transported proceeds, purchased a firearm for Murphy, and personally sold drugs. Based on these activities, Barber was indicted on conspiracy, distribution, possession with intent to distribute, and facilitating drug felonies by telephone. A jury in the United States District Court for the Northern District of Ohio found Barber guilty of conspiracy, distribution, and possession counts, and one count of using a telephone to further a drug felony, but acquitted her on a second telephone facilitation count. The jury specified that she conspired to distribute less than the charged amounts for each drug. At sentencing, the Probation Office attributed higher drug quantities to Barber based on trial testimony, leading to objections from her regarding witness credibility and the appropriateness of considering drug quantities not found by the jury. The district court overruled her objections, adopted the Probation Office’s findings, and imposed a sentence below the advisory guidelines range. The United States Court of Appeals for the Sixth Circuit reviewed Barber’s appeal. She challenged evidentiary rulings, arguing improper expert interpretation of jail calls and a Confrontation Clause violation regarding a video of a controlled buy, and contested her sentence as relying on acquitted conduct. The Sixth Circuit held the evidentiary rulings were not erroneous under the applicable standards of review, found no Confrontation Clause violation as the challenged statements were not hearsay, and concluded the district court did not plainly err in its sentencing calculation, as the conduct considered overlapped with her convictions. The court affirmed the judgment. View "United States v. Barber" on Justia Law

Am. Freedom Law Center v. Nessel

2026-08-14T11:30:40-08:00

A public interest law firm known for its advocacy on religious liberty and free speech was included on a list of "hate groups" published by the Southern Poverty Law Center (SPLC) in 2015, and has remained on the list since. In February 2019, Michigan’s Attorney General and the then-Director of the Michigan Department of Civil Rights issued a press release responding to the SPLC’s latest "Hate Map," noting an increase in such groups and announcing new state initiatives. Although the press release did not name the law firm, it linked to the SPLC report. The law firm alleged that it suffered reputational, economic, and organizational harm as a result, claiming a chilling effect on its First Amendment rights and seeking declaratory and injunctive relief against the officials. The United States District Court for the Western District of Michigan initially found that the law firm had adequately pleaded standing, as the press release arguably conferred the state’s “imprimatur” on the SPLC’s list, potentially harming the law firm’s reputation. The court denied the officials’ motion to dismiss at the pleading stage. However, following discovery and summary judgment motions, the district court concluded that the law firm failed to present sufficient evidence of a cognizable injury in fact traceable to the defendants’ actions or likely to be redressed by the requested relief, and granted summary judgment for the officials on standing grounds. The United States Court of Appeals for the Sixth Circuit reviewed the district court’s summary judgment ruling de novo. The Sixth Circuit held that the law firm had not demonstrated that the officials’ press release caused it any incremental reputational or economic injury beyond that resulting from the SPLC’s designation, nor that any such injury was ongoing or likely to recur. The court further found the law firm’s diversion-of-resources theory forfeited and unsupported. The judgment for the defendants was affirmed. View "Am. Freedom Law Center v. Nessel" on Justia Law

SW Nashville EB Owner, LLC v. Metro. Gov't of Nashville & Davidson Cnty.

2026-08-14T11:30:39-08:00

The dispute centers on a property owner that purchased a vacant and dilapidated parcel in Nashville’s East Bank district, intending to redevelop it into a multi-family residential project in accordance with local zoning rules. The owner submitted a building permit application that, according to its allegations, fully complied with all applicable zoning requirements. However, in mid-2022, the local government placed an indefinite “development hold” on the property, effectively barring any consideration or approval of the permit. The stated reason was that authorities were assessing possible routes for a planned major roadway that might require acquisition of part of the property. As a result, the owner claims the property has become undevelopable and unsellable, resulting in millions of dollars in carrying costs. After unsuccessful efforts to have the hold lifted, the owner filed suit in state court, alleging violations of the Takings and Due Process Clauses of the U.S. Constitution and the Tennessee Constitution. The case was removed to the United States District Court for the Middle District of Tennessee, where the defendants moved to dismiss on several grounds, including untimeliness and qualified immunity. The district court, on its own initiative, dismissed the complaint for lack of “jurisdictional” ripeness, reasoning that there had been no final decision on the permit application. On appeal, the United States Court of Appeals for the Sixth Circuit considered only the ripeness issue. The court held that the owner’s claims were both constitutionally and prudentially ripe because the local government’s development hold constituted a definitive, final decision barring any development of the property. The appellate court reversed the district court’s dismissal and remanded the case for further proceedings on the remaining issues. View "SW Nashville EB Owner, LLC v. Metro. Gov't of Nashville & Davidson Cnty." on Justia Law

Antol v. English

2026-08-13T10:30:38-08:00

A Michigan resident who owned a smoke shop that offered a promotion—purchasing a pipe and receiving marijuana as a gift—became the subject of a multi-year investigation by state police officers. Undercover officers repeatedly visited the shop, purchased pipes, and received marijuana, gathering evidence that the business was operating without a state dispensary license. Officers also examined the business’s financial records and concluded that income was underreported. Based on these findings, an officer submitted an affidavit to obtain a search warrant for the owner’s home. During the search, the owner was handcuffed, detained outside, and denied use of his restroom, ultimately being forced to urinate in his yard. The search led to criminal charges, to which the owner later pled guilty to one count in exchange for dismissal of another. The United States District Court for the Western District of Michigan reviewed the owner’s civil suit brought under 42 U.S.C. § 1983, which alleged that the officers violated his Fourth Amendment rights by executing an invalid search warrant and by refusing to allow him to use his restroom while detained. He also brought a Fourteenth Amendment substantive due process claim. The district court granted the officers qualified immunity and dismissed all claims, finding the warrant supported by probable cause and the alleged constitutional violations not clearly established. On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the dismissal of the Fourth Amendment unlawful search claim, finding the warrant was supported by probable cause even after removing the alleged false statements from the affidavit. The court also affirmed dismissal of the Fourteenth Amendment claim as duplicative of the Fourth Amendment unreasonable seizure claim. However, the appeals court reversed the dismissal of the unreasonable seizure claim against the officer who denied restroom access, holding that, under the totality of the circumstances, the plaintiff plausibly alleged a violation of a clearly established Fourth Amendment right. The case was remanded for further proceedings on this claim. View "Antol v. English" on Justia Law

Washington v. City of Cincinnati

2026-08-13T10:30:38-08:00

A former Fire Chief of the Cincinnati Fire Department, who had worked for the department since 1993 and was promoted to Fire Chief in 2021, was terminated by the City Manager in 2023 without being given a pre-termination hearing. The City Charter provided that, after serving six months as Fire Chief, the individual could only be removed for cause. When promoted, the Fire Chief signed a memorandum stating the position was “unclassified” and subject to dismissal without cause, but the Charter’s language provided for-cause protection after the first six months. The City Manager provided the Fire Chief with a termination letter listing reasons for the firing and publicized the termination, including to the media, citing the reasons as “for cause.” The Fire Chief did not receive a pre-termination or post-termination hearing before a neutral decisionmaker. The United States District Court for the Southern District of Ohio denied summary judgment to the City Manager and the City, holding that the City Manager was not entitled to qualified immunity regarding pre-termination due process violations. The court found that, under the Charter, the Fire Chief had a property interest in continued employment after six months and that there were unresolved factual disputes regarding waiver of those rights. The district court also denied statutory immunity to the City Manager on the Fire Chief’s state law defamation claim, finding triable issues regarding whether her statements were knowingly false or made with malice. On interlocutory appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s rulings. The Sixth Circuit held that the City Charter unambiguously gave the Fire Chief for-cause removal protection after six months, creating a property interest protected by procedural due process. It found that no “clear and unmistakable” waiver of those rights was effected by the memorandum. The court also held that sufficient evidence existed for a jury to decide whether the City Manager acted with malice or bad faith in making allegedly defamatory statements. The matter was remanded for further proceedings. View "Washington v. City of Cincinnati" on Justia Law

United States v. Wagner

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

Kyle Wagner was indicted for cyberstalking and transmitting interstate threats after a series of online communications in which he threatened federal law enforcement officers and their supporters, solicited resources to evade detection, and entertained an inquiry about killing a former government official. Wagner’s conduct included public social-media posts calling for violence against ICE agents, doxxing a pro-ICE individual and their family, and private messages discussing possible violent acts. He also sought monetary support from followers and evaded social-media bans by creating new accounts. Upon arrest, he physically resisted law enforcement and made hostile statements. A magistrate judge in the District of Minnesota initially ordered Wagner detained pretrial under the Bail Reform Act, citing dangerousness and flight risk. Wagner’s case was then transferred to the United States District Court for the Eastern District of Michigan, where a grand jury indicted him on cyberstalking and transmitting threats. The district court, after a hearing, reversed the magistrate judge’s decision and ordered Wagner’s release subject to strict conditions, including GPS monitoring, internet and social-media restrictions, and home detention at his mother’s residence. The government appealed and obtained a stay of the release order. The United States Court of Appeals for the Sixth Circuit reviewed the case de novo and concluded that the government had proven Wagner’s dangerousness by clear and convincing evidence. The court held that no condition or combination of conditions would reasonably assure the safety of the victim, J.S., or the community, given Wagner’s conduct, history of noncompliance, and the ease with which he could circumvent internet restrictions. The court reversed the district court’s release order and required Wagner’s pretrial detention under the Bail Reform Act. View "United States v. Wagner" on Justia Law

Arthur v. Krause

2026-08-11T12:30:38-08:00

A mental-health professional employed at a Michigan correctional facility participated in a voluntary hostage training exercise in April 2023, at the request of her supervisor and an assistant deputy warden. During the exercise, she acted as a hostage while corrections officers, outfitted in cell-extraction gear, conducted a simulated rescue. As the officers entered the office, the plaintiff was inadvertently pinned against an armchair during the attempt to subdue the mock hostage-taker, resulting in significant injury to her leg. An internal investigation by the prison concluded that any physical contact was accidental and not a violation of policy. The plaintiff initiated a lawsuit in the United States District Court for the Western District of Michigan against the participants in the exercise, alleging excessive force in violation of her Fourth Amendment rights. After various claims and defendants were dismissed, the sole remaining claim was a 42 U.S.C. § 1983 action against two corrections officers, asserting that their conduct amounted to a seizure by excessive force. The district court granted summary judgment in favor of the defendants, holding that the plaintiff had not been subjected to a “seizure” within the meaning of the Fourth Amendment. The court entered final judgment without ruling on the plaintiff’s pending motion for sanctions related to alleged evidentiary misconduct by one defendant. The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court affirmed the district court’s judgment, holding that the plaintiff was not seized under the Fourth Amendment because the force used during the training exercise lacked the requisite intent to restrain her, and she was a voluntary participant. The court also held that any error in failing to rule on the sanctions motion before granting summary judgment was harmless, as it would not have altered the outcome. View "Arthur v. Krause" on Justia Law

Henderson v. Village of New Holland

2026-08-07T09:01:27-08:00

Cody Henderson, a resident of New Holland, Ohio, was stopped and cited by police officers on multiple occasions while driving his black Prius. On September 13, 2022, he was stopped for speeding, and later cited for several infractions including expired registration. On September 22, officers again stopped him for driving with expired tags, impounded his car, and conducted an inventory search. Henderson objected, refused to comply with officer instructions, and was arrested for obstruction of official business. The search revealed hemp-related substances, which were later determined to be legal, and all charges were dismissed. Henderson subsequently filed a federal lawsuit alleging violations of his constitutional rights and state-law claims. The United States District Court for the Southern District of Ohio dismissed the claims against Officer Pate (who had died prior to the suit) and against the Village of New Holland. Most claims against Officer Lawless were also dismissed, except for Henderson’s Fourth Amendment and malicious prosecution claims. The district court denied qualified immunity to Officer Lawless on these remaining claims, allowing them to proceed. The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial of qualified immunity. The appellate court held that Officer Lawless had probable cause for the traffic stop, inventory search, and subsequent arrest for obstruction of official business. The inventory search was found lawful under the Fourth Amendment, as it followed standardized procedures and was not pretextual. The court also determined that the state-law malicious prosecution claim failed because probable cause existed for the arrest. Accordingly, the Sixth Circuit reversed the district court’s denial of qualified immunity and dismissed the remaining claims against Officer Lawless. View "Henderson v. Village of New Holland" on Justia Law

Pannek v. U.S. Bank Nat'l Ass'n

2026-08-07T09:01:27-08:00

Mark Pannek and Thomas Strotman, both former vice presidents at U.S. Bank, alleged the bank retaliated against them after Pannek filed an ethics complaint against their supervisor, Gemrich, who had made inappropriate sexual comments and engaged in other unprofessional conduct. Pannek also claimed age discrimination after his termination, asserting he was replaced by a younger employee. Following internal investigations, U.S. Bank issued a written warning to Gemrich and eventually terminated him, but before that, Pannek and Strotman were terminated as part of a departmental reorganization. Their responsibilities were redistributed among other employees. The United States District Court for the Southern District of Ohio granted summary judgment in favor of U.S. Bank on all claims. The court found insufficient evidence for the retaliation, hostile work environment, and age discrimination claims, concluding that the bank’s actions were justified by a neutral workforce reduction and that Pannek and Strotman failed to establish a causal link between the ethics complaint and their terminations. The district court also determined the hostile work environment claims did not meet the necessary legal standards, and that Pannek was not replaced in a manner that would support his age discrimination claim. The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court held that summary judgment was improper for the Title VII retaliation claims, finding genuine disputes of material fact about whether the terminations were motivated by retaliation for the ethics complaint. It affirmed summary judgment for the Title VII hostile-work-environment claims, ruling U.S. Bank was entitled to the Faragher/Ellerth affirmative defense because it had a reasonable harassment policy and Pannek and Strotman failed to promptly and fully utilize corrective measures. The court also affirmed summary judgment on Pannek’s ADEA claim, finding he was not replaced in a manner supporting age discrimination and presented no additional evidence of discriminatory motive. The retaliation claims were remanded for further proceedings. View "Pannek v. U.S. Bank Nat'l Ass'n" on Justia Law

Klein v. USPS

2026-08-07T09:01:26-08:00

The plaintiffs in this case are residents of Hillman Ridge Road in Brown County, Ohio. They experienced a cessation of direct mail delivery to their homes after 2017, following an incident involving a neighbor and a mail carrier. As a result, they were required to retrieve their mail from a distant location and travel to a nearby town for parcels. Other delivery services continued to serve their properties, and the Postal Service continued direct delivery on similar roads in the area. The plaintiffs argued that the Postal Service’s refusal to deliver directly to their homes constituted unconstitutional, unreasonable discrimination. The plaintiffs filed suit in the United States District Court for the Southern District of Ohio, naming the United States Postal Service and two officials as defendants. They asserted a “class of one” equal protection claim, alleging that the Postal Service’s actions violated their constitutional rights. The defendants moved to dismiss the complaint for lack of subject matter jurisdiction. The district court held that the plaintiffs’ dispute belonged exclusively before the Postal Regulatory Commission, not in federal district court, and granted the dismissal. Plaintiffs then appealed. The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision de novo. It held that Congress intended for claims concerning unreasonable discrimination in mail service—such as those under 39 U.S.C. § 403(c)—to be addressed first by the Postal Regulatory Commission under the administrative procedures of the Postal Accountability and Enhancement Act. The court found that the statutory scheme precludes district court jurisdiction over such claims, even those framed as constitutional issues. The court affirmed the district court’s dismissal for lack of jurisdiction, holding that plaintiffs must pursue their claim through the Commission before seeking judicial review. View "Klein v. USPS" on Justia Law

Spindola v. Blanche

2026-08-07T09:01:26-08:00

A Brazilian citizen, along with his wife and children, became embroiled in a violent family dispute following the sale of inherited real estate and subsequent disagreements over payment and property. Tensions escalated over several years, culminating in a series of confrontations, including assaults, threats, and a civil lawsuit. The most serious incident occurred in August 2022, when the petitioner, believing his son had been kidnapped by a relative, chased the relative by car and fired multiple shots at his vehicle, ultimately injuring him. After discovering the son was not kidnapped, the petitioner reported himself to the police and fled to the United States. He was later charged with attempted murder in Brazil. The Department of Homeland Security initiated removal proceedings, and the petitioner applied for asylum, withholding of removal, and relief under the Convention Against Torture (CAT). An Immigration Judge denied his requests, finding him barred from asylum and withholding due to the serious-nonpolitical-crime bar and concluding he did not establish a likelihood of torture with official consent or acquiescence needed for CAT relief. The Board of Immigration Appeals (BIA) affirmed, reasoning that the facts supported the probable cause standard for the bar and that the petitioner’s self-defense and intent arguments were not persuasive. The United States Court of Appeals for the Sixth Circuit reviewed the BIA’s decision. It adopted the probable cause standard for the “serious reasons to believe” language of the bar, joining other circuits. The court held that substantial evidence supported the BIA’s application of the bar, rejected the petitioner’s self-defense and intent arguments, and found substantial evidence for the BIA’s denial of CAT relief. The court denied the petition for review. View "Spindola v. Blanche" on Justia Law

Sullivan v. Miller

2026-08-06T11:30:38-08:00

Jason Wylie, a farmer and business owner, experienced significant financial distress following a serious illness in 2018 that left him unable to manage his farm and businesses. Over the preceding years, Wylie and his mother, Kathleen Sullivan, engaged in several financial transactions, including property transfers and loans. In August 2019, Wylie transferred three pieces of real property back to Sullivan by quitclaim deed, with two properties still subject to mortgages. The parties executed a “Mutual Release in Full” to settle the debt. In August 2020, Wylie filed for Chapter 7 bankruptcy, seeking to discharge nearly $2 million in debt. The bankruptcy trustee filed an adversary proceeding against Sullivan to avoid one of the property transfers, alleging it was constructively fraudulent and intended to shield assets from creditors. The United States Bankruptcy Court for the Eastern District of Michigan found that Wylie received less than reasonably equivalent value in exchange for the property transferred to Sullivan, determining the transfer was constructively fraudulent under 11 U.S.C. § 548(a)(1)(B)(i). The court ordered Sullivan to return one of the properties to the estate. Sullivan appealed to the United States District Court for the Eastern District of Michigan, which affirmed the bankruptcy court’s decision. On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the bankruptcy court’s legal conclusions de novo and factual findings for clear error, with no deference to the district court’s decision. The Sixth Circuit held that Wylie did not personally guarantee the business loan to Sullivan, the Mutual Release did not cover damages from a prior conversion of funds, and the bankruptcy court did not abuse its discretion by ordering recovery of the transferred property rather than its value. The court affirmed the district court’s judgment. View "Sullivan v. Miller" on Justia Law

Richardson v. Falk

2026-08-06T11:30:37-08:00

An inmate with a history of heart issues experienced unusually severe chest pain while incarcerated and took medication without relief. He promptly reported his symptoms to a corrections officer, expressing the need for immediate medical attention and warning of his medical vulnerability. The officer dismissed the complaint, ordering the inmate back to his cell, and allegedly threatened further discipline. Instead, the inmate sat in a nearby wheelchair. Another prison official later intervened and arranged for the inmate to be transported to the medical wing, resulting in an eight-minute delay from the initial complaint. After waiting about an hour in the medical wing without treatment, the inmate suffered a heart attack but ultimately recovered. The inmate initiated a lawsuit in the United States District Court for the Eastern District of Michigan, asserting that the officer’s conduct constituted deliberate indifference to his serious medical needs in violation of the Eighth Amendment and also violated his Fourteenth Amendment rights. The officer sought summary judgment on qualified immunity grounds. A magistrate judge recommended dismissing the Fourteenth Amendment claim but found that a reasonable jury could determine that the officer was deliberately indifferent and thus denied qualified immunity. The district court adopted this recommendation, concluding that there was sufficient evidence for the Eighth Amendment claim to proceed to trial. On appeal, the United States Court of Appeals for the Sixth Circuit reviewed whether the officer was entitled to qualified immunity as a matter of law. The Sixth Circuit held that the officer did not violate a clearly established constitutional right because existing precedent did not put a reasonable officer on notice that failing to immediately respond to a prisoner’s oral complaint of chest pain, absent visible signs of medical distress, violated the Eighth Amendment. The court reversed the district court’s denial of summary judgment and remanded the case for entry of judgment in favor of the officer. View "Richardson v. Falk" on Justia Law

Liles v. Fisher

2026-08-06T11:30:37-08:00

After being arrested for multiple instances of cocaine trafficking in Ohio, the petitioner entered a plea agreement with the state. Under this agreement, he pleaded guilty to four counts and admitted to being a major drug offender, while the state agreed to drop eleven other counts and, importantly, not to make a sentencing recommendation. At sentencing, however, the prosecutor urged the court to impose a lengthy prison term, despite the agreement. The petitioner’s attorney did not object, and the trial court imposed a 25-year sentence within the applicable guidelines. The petitioner appealed his sentence to the Ohio Court of Appeals, arguing that the prosecutor’s comments violated the plea agreement and that his attorney was ineffective for failing to object. The appellate court reviewed for plain error due to the lack of a contemporaneous objection and found that, while the prosecutor had breached the plea agreement, there was no evidence this breach influenced the sentencing court’s decision. The Ohio Supreme Court declined jurisdiction. The petitioner also pursued post-conviction and habeas relief in state court, raising additional claims about newly discovered evidence and alleged misconduct by public officials, but these efforts were unsuccessful. Subsequently, the petitioner filed for federal habeas relief in the United States District Court for the Northern District of Ohio, which denied his petition based on procedural default, finding he had not shown prejudice resulting from his counsel’s failure to object. The United States Court of Appeals for the Sixth Circuit reviewed the case de novo and held that the petitioner failed to establish prejudice under Strickland v. Washington, as there was no reasonable probability that the outcome would have been different absent counsel’s error. The court thus affirmed the district court’s denial of habeas relief. View "Liles v. Fisher" on Justia Law

Charlton-Perkins v. Univ. of Cincinnati

2026-08-05T11:30:38-08:00

A United States citizen residing in the United Kingdom applied for an assistant professor position at a university in Ohio. The search committee recommended him as their top candidate, but concerns arose regarding a potential conflict of interest due to a preexisting professional relationship between the applicant and the committee chair, as well as faculty comments about the candidate's gender and diversity. After discussions weighing these issues, the Dean ultimately canceled the job search instead of proceeding with any candidate, citing factors including gender balance, conflict of interest, and the risk of litigation. The canceled position was never reposted. The applicant filed suit in the United States District Court for the Southern District of Ohio, asserting Title IX claims against the university and equal protection claims against two administrators, seeking both injunctive and monetary relief. The district court granted summary judgment to the university on the Title IX claim and dismissed the equal protection claims with prejudice, holding that the Eleventh Amendment barred the official-capacity claims and that qualified immunity protected the administrators in their personal capacities. The court also found the applicant had not shown that the university's stated reason for canceling the search was pretextual. On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court held that Title IX only protects persons physically present in the United States, and the plaintiff, residing abroad when the discriminatory acts occurred and learned of them, was not covered. It further held that Eleventh Amendment sovereign immunity barred official-capacity equal protection claims because the requested relief would impermissibly burden the state treasury and lacked sufficient historical analogues. Finally, the court determined the administrators were entitled to qualified immunity on the individual-capacity equal protection claims, as no clearly established right was violated. View "Charlton-Perkins v. Univ. of Cincinnati" on Justia Law

Sinclair v. Meisner

2026-08-05T11:30:37-08:00

Several homeowners lost their properties through foreclosure after failing to pay property taxes to Oakland County, Michigan. Although the properties’ values exceeded the tax debts, the County retained all surplus equity rather than refunding the difference to the owners. The affected individuals, represented by attorney Scott Smith and later the McAlpine PC firm, brought suit alleging that this retention violated the Takings Clause of the U.S. Constitution. Both cases were initially dismissed by the United States District Court for the Eastern District of Michigan for failure to state a claim. The plaintiffs appealed. In the Hall case, the Pacific Legal Foundation represented the plaintiffs pro bono. The United States Court of Appeals for the Sixth Circuit reversed, holding that the County’s actions constituted a violation of the Takings Clause. The district court subsequently denied motions for class certification and the parties settled for $500,000. Plaintiffs then sought attorney fees totaling over $4.2 million, including hours spent on failed class certification and appeals largely handled by other counsel. The district court reduced the fee request by 40% and applied a 1.1 multiplier, awarding $1,361,476.51. The United States Court of Appeals for the Sixth Circuit reviewed the fee award for abuse of discretion and determined that the district court erred in several respects. The appellate court held that hours spent on failed class certification, litigation against other defendants, and certain other tasks were not properly billable and should have been categorically excluded. The court also found that the hours claimed for appellate work and by Mark McAlpine were grossly excessive, and that the district court failed to address the reasonableness of the hourly rates. The Sixth Circuit vacated the fee award and remanded, instructing the district court to recalculate fees with specific exclusions, a blended $325 hourly rate, and a 1.1 multiplier. No fees were awarded for the present appeal. View "Sinclair v. Meisner" on Justia Law

Lovell v. Clermont Cnty. Sheriff's Office

2026-08-04T12:30:40-08:00

Mark Lovell, after a night of heavy drinking, was arrested and taken to the Clermont County Jail. Multiple correctional officers were involved in his booking, during which Lovell complained about the grip on his arm and made several comments. Video footage documented the booking and subsequent altercations. Two distinct uses of force occurred: first, Lovell was taken to the floor and subjected to pepper spray and multiple strikes by officers; second, after being moved to a shower room, Lovell was again taken down, pepper-sprayed, and struck multiple times. Lovell suffered significant injuries, including fractured ribs and a pneumothorax, requiring hospitalization. Lovell filed a complaint under 42 U.S.C. § 1983, alleging excessive force in violation of his Fourth and Fourteenth Amendment rights against several officers. The United States District Court for the Southern District of Ohio granted summary judgment to some officers for specific counts on the basis of qualified immunity, but denied summary judgment for the remaining excessive force claims, finding genuine issues of material fact regarding whether constitutional violations occurred. The officers appealed, seeking reversal of the denial of qualified immunity. The United States Court of Appeals for the Sixth Circuit reviewed the interlocutory appeal. It determined that it lacked jurisdiction because the officers’ arguments contested the district court’s factual findings, rather than raising purely legal issues. The Sixth Circuit found that the video evidence did not blatantly contradict Lovell’s version of events or the district court’s findings, and the officers failed to concede the facts in the light most favorable to Lovell. Therefore, the court granted Lovell’s motion to dismiss and dismissed the appeal for lack of jurisdiction, leaving the district court’s denial of qualified immunity intact. View "Lovell v. Clermont Cnty. Sheriff's Office" on Justia Law

United States v. Benavides

2026-08-04T12:30:39-08:00

Federal authorities investigated a cocaine distribution conspiracy involving three individuals. One participant ordered cocaine from a supplier near the U.S.-Mexico border, while another, acting for the supplier, mailed the cocaine to the recipient. A third participant, a postal worker, was paid to deliver the packages along his mail route. Investigators intercepted two packages containing kilograms of cocaine and suspected that one conspirator used his mother’s home as a stash house. When confronted at the residence, the individual admitted possessing cocaine and allowed a search, which led to the seizure of drugs and three firearms. He took responsibility for both the drugs and the firearms. A grand jury indicted the three for their roles in the conspiracy. The United States District Court for the Western District of Michigan accepted a guilty plea from the defendant for conspiracy to distribute and possess cocaine with intent to distribute. At sentencing, the court applied a two-level enhancement for possession of firearms under U.S.S.G. § 2D1.1(b)(1) and declined to apply a two-level reduction under U.S.S.G. § 4C1.1(a), known as the “zero-point offender” reduction. The court imposed a 96-month sentence, which fell within the applicable Guidelines range. The defendant appealed, challenging both the enhancements and the reasonableness of the sentence. The United States Court of Appeals for the Sixth Circuit reviewed the case. It held that the district court did not err in applying the firearm enhancement because the conspiracy continued beyond the last drug shipment, and the defendant had not proven withdrawal. It also held that the defendant bore the burden of proving entitlement to the zero-point offender reduction and failed to show that his firearm possession was not connected to the offense. Finally, the appellate court found the sentence substantively reasonable and affirmed the district court’s judgment. View "United States v. Benavides" on Justia Law

Henry v. City of Detroit

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

A former Detroit Police Department officer, after sustaining injuries in car accidents, was placed on restricted duty due to permanent physical limitations. Over several years, she raised various grievances related to her employment status, overtime, and accommodations for her disabilities. In 2021, following additional injuries and extended sick leave, she failed to report for duty or provide updated medical documentation as requested by her employer, leading to her termination. Shortly after her termination, her physician sent documentation indicating she was unable to perform most police functions. She filed two lawsuits in the United States District Court for the Eastern District of Michigan, both under the Americans with Disabilities Act (ADA), alleging intentional discrimination, failure to accommodate, and retaliation for engaging in ADA-protected activity. The district court consolidated the cases and granted summary judgment to the City on her retaliation claim, finding the City had a legitimate, non-discriminatory reason for her termination—her repeated failure to report for duty or supply requested medical forms. The remaining claims for intentional discrimination and failure to accommodate proceeded to trial, where the jury found in favor of the City. On appeal to the United States Court of Appeals for the Sixth Circuit, the plaintiff argued the district court erred in granting summary judgment, that no reasonable jury could have sided with the City, that jury instructions were incorrect, and that the City engaged in fraud at trial. The Sixth Circuit affirmed the district court’s decisions. It held that the City’s actions were supported by legitimate reasons, the jury’s verdict was reasonable, the instructions accurately stated the law, and the fraud claims were unpreserved and insufficient for relief. The disposition was affirmed. View "Henry v. City of Detroit" on Justia Law

United States v. Starling

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

The defendant, Joshua Starling, was convicted after a bench trial of being a felon in possession of a firearm. Starling worked for a mattress delivery business and was arrested during a delivery when police found him carrying a firearm. He had previous convictions, including drug offenses and burglary. The government sought an enhanced sentence under the Armed Career Criminal Act (ACCA) based on Starling's prior convictions, although the indictment did not explicitly mention ACCA or allege that the enhancement would apply. The United States District Court for the Middle District of Tennessee conducted the bench trial and found Starling guilty. At sentencing, the court considered whether Starling's prior drug convictions under Tennessee law qualified as ACCA predicate offenses. Starling argued that Tennessee law criminalized a broader range of cocaine-related conduct than federal law, so his convictions should not count as ACCA predicates. He also argued that the government's failure to allege ACCA in the indictment violated his rights, citing Erlinger v. United States, 602 U.S. 821 (2024). The district court rejected both arguments, finding that the Tennessee statute was divisible and that Starling's convictions specifically involved cocaine, matching the federal definition. The court also concluded that the indictment’s omission of ACCA did not warrant relief because Starling failed to timely object. The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court’s decision. It held that Starling’s Tennessee drug convictions qualify as ACCA predicates under the modified categorical approach because the relevant statute is divisible and his convictions involved cocaine itself. The court further held that Starling’s argument regarding the indictment was subject to plain-error review and failed that standard, as there was overwhelming evidence and adequate notice regarding ACCA’s application. The judgment was affirmed. View "United States v. Starling" on Justia Law

Bonfiglioli USA, Inc. v. Midwest Engineered Components, Inc.

2026-07-29T12:30:40-08:00

A Kentucky-based manufacturer entered into a sales representative agreement with a Minnesota-based company to facilitate sales of industrial parts in several Midwestern states. The contract included a choice of law clause specifying Kentucky law would govern disputes and permitted the manufacturer to terminate the relationship at its discretion. However, a pre-contract email from Minnesota’s representatives revealed their intent to disregard the Kentucky choice of law, planning instead to invoke the Minnesota Termination of Sales Representatives Act (MTSRA), which restricts termination and invalidates conflicting contract terms. After several years, the manufacturer issued a termination notice in line with the contract. The Minnesota company, shortly before the contract’s automatic renewal, claimed protection under the MTSRA and demanded $165,000, threatening litigation. The manufacturer responded by filing suit in the United States District Court for the Eastern District of Kentucky, seeking declaratory judgment that Kentucky law governed and asserting fraudulent inducement based on the Minnesota company’s misrepresentation of its intent to abide by the choice of law provision. The district court held that Kentucky law applied, rendering the MTSRA inapplicable, and granted declaratory judgment for the manufacturer. It permitted the fraudulent inducement claim to proceed to a jury, which found the Minnesota company liable, awarding nominal actual damages and $280,000 in punitive damages. The court denied post-trial motions challenging the verdict, jury instructions, evidentiary rulings, and the punitive damages award. On appeal, the United States Court of Appeals for the Sixth Circuit affirmed. The Sixth Circuit held that Kentucky’s choice of law rules applied and that Kentucky had the most significant relationship to the contract, making the MTSRA inapplicable. The court upheld the jury’s finding of fraudulent inducement and found no abuse of discretion in the district court’s management of trial issues. The punitive damages award was found not to violate due process. View "Bonfiglioli USA, Inc. v. Midwest Engineered Components, Inc." on Justia Law

United States v. Smith

2026-07-29T12:30:39-08:00

Three individuals—Khari, Logan, and Saruba—became involved in a drug distribution scheme. While incarcerated, Khari connected his cellmate (who was cooperating with law enforcement) with Logan, a drug dealer based in Detroit but residing in Lexington, Kentucky. Logan, guided by Khari, communicated with an undercover officer and arranged to sell fentanyl and methamphetamine. Saruba, Logan’s girlfriend, accompanied Logan to a drug deal and participated in the exchange. Law enforcement recorded and monitored the transactions, conducted controlled buys, and eventually arrested the trio after seizing large quantities of drugs and drug paraphernalia. The United States District Court for the Eastern District of Kentucky presided over the proceedings. Logan pleaded guilty to conspiracy and possession with intent to distribute, receiving a 360-month sentence. Khari and Saruba proceeded to trial. The jury convicted both of aiding and abetting drug distribution; Khari was also convicted of using a telephone to facilitate a drug offense, while Saruba was acquitted of conspiracy. The district court sentenced Khari to 150 months, consecutive to a prior sentence, and Saruba to 92 months. On appeal, the United States Court of Appeals for the Sixth Circuit reviewed multiple challenges. The court rejected Logan’s claims of procedural and substantive sentencing error and affirmed her conviction and sentence. Khari’s sufficiency-of-the-evidence and sentencing arguments were also rejected, with the court upholding his conviction and sentence. For Saruba, the court affirmed her conviction, finding no reversible error in her trial or in the sufficiency of evidence. However, the appellate court determined that the district court erred by failing to apply a two-level reduction to her offense level under the Sentencing Guidelines. As a result, the Sixth Circuit vacated Saruba’s sentence and remanded her case for resentencing. View "United States v. Smith" on Justia Law

Perez-Hernandez v. Blanche

2026-07-28T13:00:38-08:00

A native and citizen of Guatemala, the petitioner entered the United States in 2007 after fleeing an intrafamilial land dispute in which his great uncle, motivated by a conflict over inheritance and, to a lesser extent, political differences, threatened his family. In 2011, he was stopped by an Ohio police officer for littering. The officer suspected him of possessing false identification and obstructing official business, leading the Department of Homeland Security to initiate removal proceedings. The petitioner conceded removability but sought relief on several grounds, arguing that his stop was racially motivated, and that his removal would expose him to persecution or torture in Guatemala due to his membership in particular social groups or political opinions. An Immigration Judge denied the petitioner’s motion to suppress evidence, finding no constitutional or regulatory violations, and rejected his applications for asylum, withholding of removal, and protection under the Convention Against Torture (CAT). The judge determined the asylum application was time-barred and, on the merits, found no nexus between the alleged harm and any protected ground. The judge also found insufficient evidence of likely torture upon return to Guatemala. The petitioner appealed to the Board of Immigration Appeals (BIA), which affirmed the Immigration Judge’s decisions and denied as untimely his later motion to terminate or remand the proceedings based on alleged defects in his notice to appear. The United States Court of Appeals for the Sixth Circuit reviewed the BIA’s final order. The court held that the denial of the motion to suppress was proper because the initial stop was supported by reasonable suspicion, and no egregious Fourth Amendment violation occurred. The court further held that the petitioner’s claims-processing challenge to the notice to appear was untimely, and substantial evidence supported the findings that there was no nexus for withholding of removal and no likelihood of torture for CAT relief. The petition for review was denied. View "Perez-Hernandez v. Blanche" on Justia Law

United States v. King

2026-07-28T13:00:37-08:00

The defendant was arrested in 2023 after police discovered evidence linking him to significant drug trafficking, including large quantities of fentanyl and methamphetamine, as well as a firearm. He confessed to both personal use and substantial sales of fentanyl. Previously, he had two state felony convictions for possessing meth for resale, served five years in prison, and was paroled before committing the new offense. A federal grand jury charged him with several offenses, but he ultimately pleaded guilty to possessing with intent to distribute at least 40 grams of a fentanyl mixture. The government dismissed other charges and did not pursue enhanced penalties. The United States District Court for the Eastern District of Tennessee sentenced the defendant as a career offender, calculating a Guidelines range of 188 to 235 months and imposing a sentence at the lower end. The defendant moved for a downward variance, arguing that his prior state convictions should not qualify him as a career offender under the guidelines, citing his upbringing and the time gap between convictions as mitigating factors. He also challenged the inclusion of state-law convictions as career-offender predicates, suggesting the Sentencing Commission exceeded its statutory authority. The district court considered his mitigating arguments but denied the variance and applied the guideline. The United States Court of Appeals for the Sixth Circuit reviewed the sentence. It held that the career-offender guideline validly includes state-law convictions, interpreting the statute to cover offenses “described in” federal drug statutes, regardless of whether the convictions were under federal or state law. The court found no procedural error, as the district court adequately considered the relevant factors and explained its reasoning. The court also found the sentence substantively reasonable, especially as it was within the Guidelines range, and rejected the defendant’s challenges. Accordingly, the Sixth Circuit affirmed the sentence. View "United States v. King" on Justia Law

Taylor v. Hooven

2026-07-27T09:00:55-08:00

A dispute arose between two former spouses involving child custody and related issues in Ohio state court. After their 2019 divorce, they shared parenting responsibilities for their two children. In 2023, the ex-husband, a police officer, allegedly enlisted a county employee to access confidential information about his ex-wife’s fiancé, and this information was subsequently shared. Complaints about this conduct were filed with municipal and county authorities. Amid these events, the ex-wife and her fiancé filed a federal lawsuit alleging violations of federal civil rights statutes and state law, and sought relief against municipal and county entities. In the United States District Court for the Southern District of Ohio, the plaintiffs amended their complaint and the City of Cincinnati moved to dismiss the claims against it. The district court dismissed these claims under Monell v. Department of Social Services. The plaintiffs sought reconsideration or, alternatively, certification to appeal the dismissal, but the district court declined to certify the order as final. Separately, the ex-wife moved for a temporary restraining order and preliminary injunction to prevent enforcement of an Ohio state court’s contempt order, which sanctioned her for disclosing the ex-husband’s address in federal filings. The district court denied injunctive relief, citing Younger v. Harris abstention, to avoid interference with ongoing state court proceedings. The United States Court of Appeals for the Sixth Circuit reviewed two issues: the district court’s abstention from granting injunctive relief and the dismissal of the Monell claim. The Sixth Circuit held that Younger abstention was appropriate because the contempt proceeding was an ongoing state judicial process implicating important state interests, and the plaintiff had an adequate opportunity to raise constitutional challenges in state court. The court also determined it lacked appellate jurisdiction over the Monell dismissal, as the district court’s order was not final and had not been certified for interlocutory appeal. The court affirmed the abstention and dismissed the Monell appeal for lack of jurisdiction. View "Taylor v. Hooven" on Justia Law

In Home Health, LLC v. Kennedy

2026-07-27T09:00:54-08:00

A hospice provider participated in the Medicare program and sought reimbursement for hospice services provided to several patients. Medicare, through its contractor, conducted a review and determined that a substantial number of the provider's claims did not meet the required coverage criteria, resulting in a demand for repayment of nearly $1 million. The contractor’s decision was partially reversed at the next level of administrative review for some claims, but a significant number were still denied. The provider pursued further administrative appeals, including a hearing before an administrative law judge (ALJ), where testimony and medical records were considered. The ALJ ultimately found that some additional claims were covered but upheld the denial of coverage for others, concluding that the provider was financially responsible for those denied claims and could not benefit from the statutory safe harbor. After the Medicare Appeals Council failed to resolve the provider’s appeal within the prescribed time, the provider sought judicial review in the United States District Court for the Northern District of Ohio. The district court affirmed the ALJ’s decision, agreeing with the denial of coverage for the disputed claims and with the determination that the provider was not entitled to the safe harbor protection. On appeal, the United States Court of Appeals for the Sixth Circuit reviewed two issues: whether substantial evidence supported the ALJ’s denial of Medicare coverage for the claims, and whether the ALJ properly applied the Medicare statute’s safe harbor provision. The appellate court held that substantial evidence did support the denial of coverage. However, it determined that the ALJ had applied the wrong legal standard to the safe harbor inquiry. The Sixth Circuit clarified that the correct standard requires assessment of whether the provider reasonably interpreted the relevant Medicare guidance as covering the disputed claims. The court vacated the district court’s judgment as to the safe harbor issue and remanded with instructions to return the case to the ALJ for application of the correct safe harbor standard to each disputed claim. View "In Home Health, LLC v. Kennedy" on Justia Law

Hemwall v. Douglas

2026-07-24T07:30:38-08:00

Christopher Hemwall was convicted by a jury in Michigan of multiple counts of criminal sexual conduct involving his twin half-sisters, with the incidents occurring when the victims were between four and six years old. The offenses took place from 2005 to 2008 and were reported to authorities roughly a decade later. Following his conviction, Hemwall received a lengthy prison sentence. He exhausted his appellate rights, with the Michigan Court of Appeals affirming his conviction and the Michigan Supreme Court denying leave to appeal. Hemwall did not pursue review by the U.S. Supreme Court, and his convictions became final in August 2021. Hemwall sought post-conviction relief in Michigan courts, alleging ineffective assistance of counsel. The Monroe County Circuit Court denied his motion, the Michigan Court of Appeals declined leave to appeal, and the Michigan Supreme Court denied leave in January 2024. Hemwall then filed a federal habeas petition under 28 U.S.C. § 2254 in the United States District Court for the Eastern District of Michigan, but it was filed nearly three months after the statutory deadline. Hemwall requested equitable tolling of the one-year statute of limitations, citing his attorney’s health issues and those of the attorney’s child, as well as COVID-19-related disruptions. The district court dismissed the petition, finding Hemwall failed to establish that these circumstances caused the late filing, but granted a certificate of appealability due to unsettled precedent. The United States Court of Appeals for the Sixth Circuit reviewed the case. It assumed for argument’s sake that the attorney’s health difficulties could qualify as extraordinary circumstances but held that Hemwall did not prove these difficulties caused the late filing. The Sixth Circuit found no clear error in the district court’s factual finding that the attorney’s personal issues did not prevent timely filing, especially given evidence that the attorney was able to continue practicing law and that the federal petition was largely copied from prior state filings. The court affirmed the district court’s dismissal of Hemwall’s habeas petition. View "Hemwall v. Douglas" on Justia Law

United States v. Williams

2026-07-24T07:30:38-08:00

The case concerns a defendant who was arrested after his girlfriend reported to police that he had struck her, taken her handgun, chambered a round, and threatened her with it. Forensic evidence later confirmed his DNA on the weapon. The defendant gave conflicting accounts, initially denying knowledge of the gun, then claiming he took it from his girlfriend to protect himself. Officers arrested him, and he was charged in state court with domestic violence and illegal firearm possession. While out on bond, federal prosecutors indicted him for being a felon in possession of a firearm after an earlier felony conviction. During execution of a federal arrest warrant, officers found a stolen rifle in the home. The government offered a plea deal involving a single count, which the defendant declined, resulting in a superseding indictment on two counts. The United States District Court for the Northern District of Ohio denied the defendant’s motion to suppress the rifle and his motion to dismiss on Second Amendment grounds. The defendant ultimately pleaded guilty to both counts without a written plea agreement. At sentencing, the district court applied an enhancement for possessing a firearm in connection with a felony offense, based on evidence that he had threatened his girlfriend with the handgun, and imposed a 100-month prison sentence. The defendant appealed, raising constitutional arguments and challenging the sentencing enhancement. The United States Court of Appeals for the Sixth Circuit held that, because the defendant pleaded guilty unconditionally and did not comply with Federal Rule of Criminal Procedure 11(a)(2), he waived his right to appeal pre-plea constitutional issues. The court declined to address his ineffective assistance of counsel claim on direct appeal, finding the record undeveloped. Reviewing the sentencing enhancement for clear error, the court found ample evidence to support the district court’s application of the enhancement and affirmed the sentence. View "United States v. Williams" on Justia Law

United States v. Fordham

2026-07-22T11:00:58-08:00

Three defendants, who held leadership positions in a nationwide gang operating in Michigan and Chicago, were charged after a lengthy federal investigation uncovered extensive drug distribution, violent acts, and strict internal codes of silence within the organization. Law enforcement used confidential informants, monitored communications, conducted controlled purchases, and executed search warrants on social media and personal devices to gather evidence. The defendants were indicted for racketeering conspiracy, drug conspiracies, and related offenses. While many co-defendants pled guilty, these three proceeded to trial. The United States District Court for the Eastern District of Michigan conducted a month-long trial, after which a jury convicted all three defendants on most counts. One defendant was acquitted of certain drug trafficking and firearm possession charges but convicted on racketeering, drug conspiracy, and possession with intent to distribute marijuana. At sentencing, the district court imposed lengthy prison terms for each defendant. The defendants appealed, raising suppression issues concerning wiretap evidence, social media searches, and cell phone searches; Sixth Amendment claims regarding prison mail policies and cross-examination limitations; sufficiency-of-the-evidence challenges; and a sentencing dispute. The United States Court of Appeals for the Sixth Circuit reviewed the case. It rejected all suppression arguments except for a procedural sentencing challenge raised by one defendant, finding that the district court failed to adequately address his objection to a sentencing enhancement based on acquitted conduct. The Court affirmed the convictions for all three defendants and rejected their constitutional and evidentiary claims, holding that the evidence and trial procedures met legal standards. However, it vacated the sentence for the one defendant on procedural grounds and remanded for resentencing, while affirming all other aspects of the district court’s judgment. View "United States v. Fordham" on Justia Law

Steger v. Willis

2026-07-21T12:30:39-08:00

A woman called police to report that her neighbor, Melvin Steger, had stolen her insulin pump after she accidentally dropped it outside her home. Officers responded and spoke to the woman, then approached Steger, who was standing on his own porch behind an iron gate. During the encounter, Steger grew agitated, refused to provide identification, told the officers to get a warrant, and used profanity. After he shouted an obscenity at Officer Willis, Willis immediately slammed the gate into Steger, knocked him down, and punched him twice before handcuffing him. Steger was arrested and charged with several offenses, including disorderly conduct and theft, and was later convicted of theft. Steger subsequently filed a lawsuit under 42 U.S.C. § 1983 in the United States District Court for the Eastern District of Kentucky, alleging that Officers Willis and Appleman used excessive force in violation of the Fourth Amendment. The officers moved for summary judgment on the basis of qualified immunity. The district court denied the motion as to Willis, finding that, based on the record, a reasonable jury could find that Willis’s actions constituted excessive force, which was clearly prohibited by established case law. The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial of qualified immunity de novo. The appellate court agreed that, accepting the facts in the light most favorable to Steger, Willis’s use of physical force—slamming the gate, knocking Steger down, and punching him twice—against a non-resisting individual on his own porch, without warning and without announcing an arrest, violated clearly established Fourth Amendment rights. The Sixth Circuit affirmed the district court’s denial of qualified immunity to Willis. View "Steger v. Willis" on Justia Law

Am. Ass'n of Nurse Anesthesiology v. Kennedy

2026-07-21T12:30:38-08:00

The plaintiff, an advocacy organization representing nurse anesthetists, filed suit against the Secretary and Department of Health and Human Services (HHS) after several private insurers reduced reimbursement rates for nurse anesthetists practicing independently, compared to physician anesthesiologists. The plaintiff alleged these lower rates violated a nondiscrimination provision in the Affordable Care Act (ACA), which prohibits insurers from discriminating against healthcare providers acting within the scope of their license. The ACA assigns primary enforcement of this provision to the states, but allows HHS to intervene if a state fails to enforce it. The plaintiff sought a writ of mandamus compelling HHS to enforce the provision and also asserted a claim under the Administrative Procedure Act for agency action unlawfully withheld or unreasonably delayed. The United States District Court for the Northern District of Ohio granted HHS’s motion to dismiss, concluding that the plaintiff lacked standing. The court found the plaintiff had not adequately established that its members had suffered a cognizable injury or that any alleged injury was traceable to HHS’s conduct. On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s dismissal de novo. The Sixth Circuit determined that even if the plaintiff’s members had experienced monetary harm, they failed to show that the harm was caused by HHS’s alleged nonenforcement, as it was the insurers—not HHS—that set the reimbursement rates. The court found the causal link between government inaction and insurers’ decisions too speculative. Additionally, the court held that any relief ordered by the court would not likely redress the alleged injuries, given the discretionary nature of enforcement and uncertainty about how insurers would respond. Therefore, the Sixth Circuit affirmed the district court’s dismissal for lack of standing. View "Am. Ass'n of Nurse Anesthesiology v. Kennedy" on Justia Law

Dyda v. Michigan Sec'y of State

2026-07-20T12:00:38-08:00

A Michigan resident, who does not have a Social Security Number due to a sincerely held religious belief and has received a religious exemption from the Social Security Administration, sought to obtain a Commercial Learner’s Permit (CLP), a necessary step toward a Commercial Driver’s License. Federal regulations and Michigan law generally require a Social Security Number for such applications. When the applicant provided her religious exemption letter in lieu of a Social Security Number, the Michigan Department of State denied her application. The applicant and the department disagreed on whether her application was otherwise complete. After the denial, the department sought guidance from the Federal Motor Carrier Safety Administration (FMCSA), which ultimately clarified that applicants with an SSA-granted religious exemption are not required to provide a Social Security Number. The department then changed its policy, allowing such exemptions and inviting the applicant to reapply. The applicant filed suit in the United States District Court for the Eastern District of Michigan against a department help desk worker and the Secretary of State under 42 U.S.C. § 1983, alleging violation of her First Amendment rights and seeking declaratory and injunctive relief. The defendants moved to dismiss, arguing the case was moot due to their change in policy and asserting qualified immunity. The district court agreed, finding no live controversy remained because the department was no longer requiring a Social Security Number from the applicant and was updating its policies accordingly. The court also granted the help desk worker qualified immunity, concluding there was no clearly established law prohibiting enforcement of the prior requirements. On appeal, the United States Court of Appeals for the Sixth Circuit affirmed. The court held that the applicant’s claims for declaratory and injunctive relief were moot, as the challenged conduct had ceased and there was no reasonable expectation it would recur. The court also affirmed that the help desk worker was entitled to qualified immunity. View "Dyda v. Michigan Sec'y of State" on Justia Law

Abbey v. Metro. Gov't of Nashville & Davidson Cnty.

2026-07-17T13:30:40-08:00

Naya Abbey and her minor son, D.H., lived in Nashville, Tennessee. In August 2019, Abbey was moving her belongings between homes when she was followed by an unmarked police car. Fearing for her safety, she did not immediately stop. When the car activated its sirens, Abbey pulled over. Officer Terrance Stuckey and another officer forcibly removed Abbey from her car at gunpoint, arrested her, and searched her vehicle. D.H., who is autistic and nonverbal, was with her during this incident. Abbey was charged with several crimes and her case was stayed in criminal court for three years. In 2022, prosecutors disclosed dispatch tapes contradicting Stuckey’s previous testimony, which led to the dismissal of charges against Abbey. The United States District Court for the Middle District of Tennessee dismissed Abbey and D.H.’s complaint against Stuckey and the Metropolitan Government of Nashville and Davidson County. The district court found Abbey’s Fourth Amendment claims untimely under Tennessee’s one-year statute of limitations, holding that her claims accrued on the date of the arrest and search. It also rejected her Brady claim, reasoning that the eventual disclosure of the tapes and lack of a municipal policy foreclosed municipal liability. The court dismissed D.H.’s claims against Stuckey sua sponte, without prior notice. The United States Court of Appeals for the Sixth Circuit reviewed the case. It agreed that Abbey’s Fourth Amendment claims were time-barred, concluding that the statute of limitations began when the traffic stop occurred because Abbey was aware of her injuries and their source at that time. The court held that Abbey’s Brady claim failed because the right established in Brady v. Maryland only applies to evidence suppression affecting a criminal trial, and Abbey’s charges were dismissed before trial. However, the Sixth Circuit reversed the dismissal of D.H.’s Fourth Amendment claims against Stuckey because the district court acted without notice and Tennessee law tolls the limitations period for minors. The judgment was thus affirmed in part, reversed in part, and remanded. View "Abbey v. Metro. Gov't of Nashville & Davidson Cnty." on Justia Law

Crisp v. Scioto Ambulance Dist.

2026-07-17T13:30:39-08:00

Gertrude Crisp, an emergency medical technician, alleged that a co-worker, Joshua Gullett, sexually harassed her at their workplace, the Scioto Ambulance District. Crisp claimed that Gullett made inappropriate comments, touched her without consent, and engaged in other sexually charged behavior. After reporting one incident to a supervisor and showing him Gullett’s Fetlife profile, the employer separated Crisp and Gullett on future shifts but did not otherwise discipline Gullett. Years later, Crisp showed nude images, allegedly of Gullett and his wife, to several co-workers at work, purporting to warn them about Gullett’s behavior. Following an investigation, Scioto Ambulance District terminated Crisp for sharing the images while on duty. In the United States District Court for the Southern District of Ohio, Crisp sued Scioto, arguing that her termination was unlawful retaliation under federal and Ohio antidiscrimination laws. The district court granted summary judgment for the employer, finding that Crisp’s conduct in showing the images was not protected activity under the relevant statutes. Crisp appealed this decision. The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s judgment. The Sixth Circuit held that Title VII and the Ohio Civil Rights Act do not protect an employee who, in the course of opposing workplace discrimination, gratuitously shares nude or sexually explicit images of co-workers while on the job. The court reasoned that while some complaints of sexual harassment are protected, Crisp’s sharing of such images was not necessary to her complaint and extended beyond protected conduct. Therefore, Crisp’s firing did not constitute unlawful retaliation, and the district court’s decision was affirmed. View "Crisp v. Scioto Ambulance Dist." on Justia Law

United States v. Hernandez

2026-07-16T13:00:40-08:00

While serving a term of supervised release, the defendant was suspected by his probation officer of violating release conditions by spending significant time at an unapproved residence, the Mahlon House, rather than at his approved address. Location data, surveillance, inconsistent statements to his probation officer, and a police report from a domestic violence incident at the Mahlon House—where a witness claimed the defendant had firearms—contributed to the officer’s suspicions. The defendant had also previously tested positive for controlled substances. Based on these factors, probation officers searched the Mahlon House, discovering three firearms, various controlled substances, drug paraphernalia, and mail addressed to the defendant. The United States District Court for the Western District of Michigan reviewed the defendant’s motion to suppress the evidence, in which he contended that the search was unsupported by reasonable suspicion. The district court denied the motion, and the defendant entered a conditional guilty plea, preserving the right to appeal the suppression ruling. He was then sentenced to 78 months in prison, followed by three years of supervised release. The United States Court of Appeals for the Sixth Circuit considered two issues on appeal: whether the district court erred in denying the motion to suppress and whether 18 U.S.C. § 922(g)(1), under which the defendant was convicted as a felon in possession of a firearm, is unconstitutional. The court held that the officers had reasonable suspicion to search the Mahlon House due to the totality of the circumstances, including credible reports of firearms and drug activity, and the defendant’s attempts to conceal his activities. The Sixth Circuit also held that binding precedent foreclosed a facial challenge to § 922(g)(1) and that the statute was not clearly or obviously unconstitutional as applied to the defendant. The judgment of the district court was affirmed. View "United States v. Hernandez" on Justia Law

DiChiara v. Summit Medical Group, Inc.

2026-07-13T11:00:38-08:00

A physician was employed by a medical group and its affiliated healthcare organization when they implemented a COVID-19 vaccination policy requiring employees to either be vaccinated or obtain a medical or religious exemption. The physician objected to the policy on scientific and religious grounds and engaged in internal advocacy, including meetings with leadership and organizing a petition among medical staff. She also communicated with a disbarred attorney who was promoting litigation against the vaccine mandate, forwarding confidential internal emails and documents to him to build his case. Although she was granted a religious exemption, she was subsequently terminated for cause, with the employer citing misappropriation of company property, policy violations, disruptive conduct, and breach of loyalty. After exhausting administrative remedies, the physician filed suit in the United States District Court for the Eastern District of Kentucky, asserting federal claims for retaliation under Title VII and the ADA, and state claims for retaliation, discharge against public policy, breach of contract, tortious interference, and declaratory relief from her non-compete clause. Both parties moved for summary judgment. The district court granted summary judgment in favor of the defendants on all claims, finding no violation of state or federal law. The United States Court of Appeals for the Sixth Circuit reviewed the district court’s grant of summary judgment de novo. The court held that the physician did not engage in protected activity under Title VII or the ADA, as her conduct did not qualify under either the participation or opposition clauses. Her state retaliation claims failed for the same reasons. The court also ruled that Kentucky’s wrongful discharge tort applies only to at-will employees, and her contract employment precluded such a claim. Finally, it found no breach of contract, as her conduct violated company policies and justified termination for cause. The Sixth Circuit affirmed the district court’s judgment. View "DiChiara v. Summit Medical Group, Inc." on Justia Law

Gmeiner v. Kent

2026-07-10T10:31:23-08:00

Stephen and Deborah Gmeiner owned waterfront property in Michigan and sought a permit to construct a walking path through wetlands to the lake. The Michigan Department of Environment, Great Lakes, and Energy initially denied their permit application, citing environmental concerns and suggesting a boardwalk as a less damaging alternative. The Gmeiners appealed, and an administrative law judge found that township ordinances made a boardwalk infeasible without constructing a home, so the permit was granted. When the Department issued the permit, it included an indemnification clause requiring the Gmeiners to hold the State harmless for claims arising from their actions in connection with the permit. The Gmeiners objected, arguing that the clause was unauthorized under Michigan law and imposed an unconstitutional condition on their First Amendment right to petition by potentially barring lawsuits against the State for its own misconduct. The United States District Court for the Western District of Michigan denied the Gmeiners’ request for a preliminary injunction and dismissed their complaint. The court interpreted the indemnification clause narrowly, holding that it only required indemnification for claims resulting from the Gmeiners’ own actions, not for state misconduct. It concluded that the clause did not violate the First Amendment Petition Clause and that sovereign immunity barred the state-law claim in federal court. On appeal, the United States Court of Appeals for the Sixth Circuit affirmed. The court held that, even assuming the unconstitutional-conditions doctrine under the Takings Clause applied to the Petition Clause, the indemnification clause was limited to claims arising from the Gmeiners’ own conduct and did not bar them from suing the State for its own misconduct. The court also held that Michigan’s sovereign immunity barred the Gmeiners from seeking state-law relief against state officials in federal court. The district court’s judgment was affirmed. View "Gmeiner v. Kent" on Justia Law

Millis v. Rewerts

2026-07-09T12:30:46-08:00

The petitioner was convicted in a Michigan state court after pleading no contest to multiple counts of criminal sexual conduct and was sentenced to 35 to 65 years in prison. He alleged that before entering his plea, an unidentified substitute attorney told him about a 12-year plea offer, but his own attorney did not provide material advice regarding the offer. After exhausting his direct appeals, the petitioner filed for state postconviction relief, which tolled the federal habeas deadline. When his state postconviction motion was denied, he attempted to appeal pro se to the Michigan Supreme Court from prison, but due to mailing date discrepancies and conflicting correspondence from the court, he received inconsistent messages about whether his application was timely filed and accepted. The Kent County Circuit Court denied his postconviction motion, and the Michigan Court of Appeals denied his appeal. The petitioner then attempted to file an application for leave to appeal with the Michigan Supreme Court. He received a series of letters: some stated his application was untimely, while others indicated it had been accepted as timely. Ultimately, he was notified months later that his application had been dismissed as untimely, by which time his federal habeas filing window had closed. The United States District Court for the Western District of Michigan dismissed his federal habeas petition as untimely, finding it was plainly apparent that he was not entitled to equitable tolling, and reasoning that he had not acted diligently following the conflicting communications from the Michigan Supreme Court. Upon review, the United States Court of Appeals for the Sixth Circuit held that it was not plainly apparent from the petition that the petitioner was not entitled to equitable tolling, given the confusing and conflicting notices from the state court. The Sixth Circuit reversed the district court’s dismissal and remanded the case for further proceedings, allowing the government to respond and further develop the record. View "Millis v. Rewerts" on Justia Law

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

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