Every decision we've summarized from United States Court of Appeals for the Sixth Circuit.
The Sixth Circuit affirmed the dismissal of ERISA claims alleging that union benefit funds violated fiduciary duties by refusing contributions. The court held that the Garmon doctrine preempted the claims because resolving them required determining whether the funds violated the National Labor Relations Act.
The Sixth Circuit affirmed Mario Delaine's fifteen-year mandatory minimum sentence under the Armed Career Criminal Act, holding that his prior convictions qualified as violent felonies. The court clarified that state-law offenses satisfy the federal definition when they require intentional force, regardless of whether the defendant intended to cause specific injury.
The Sixth Circuit reversed the district court's grant of habeas relief, holding that the state court's refusal to provide a defense-of-others jury instruction was not objectively unreasonable under AEDPA standards. The court concluded that the evidence did not support a reasonable inference that the petitioner acted to protect others from imminent harm, rendering the instructional error harmless beyond a reasonable doubt.
The Sixth Circuit reversed the district court's grant of habeas relief, holding that the state court's refusal to provide a defense-of-others jury instruction was not objectively unreasonable under AEDPA standards. The court found no constitutional violation in the trial proceedings regarding the jury instructions or other claims, thereby reinstating Mercer's conviction and denying her federal relief.
The Sixth Circuit affirmed the dismissal of a federal lawsuit seeking financial support under an Affidavit of Support, ruling that a prior state divorce judgment precluded the claim. The court held that the federal statute does not override the preclusive effect of a final state court order that explicitly resolved all spousal support issues between the parties.
The Sixth Circuit affirmed Michael Williams's within-Guidelines sentence for violating his supervised release, rejecting his claim that the district court impermissibly relied on retributive factors. The court held that the district court properly considered the breach of trust and the need for deterrence when imposing consecutive sentences for the new offense and the revocation.
The Sixth Circuit reversed the denial of qualified immunity for officers who used force to handcuff a large suspect actively resisting arrest for violent felonies. The court held that no clearly established law prohibited the officers' actions because the suspect's physical defiance created a unique factual context not covered by prior precedent.
The Sixth Circuit affirmed summary judgment for the Department of Labor, holding that the 2013 regulation validly exercises the Secretary's expressly delegated authority to exclude third-party home care employers from the FLSA's exemptions. The court further ruled that the challengers lack standing to contest the narrowed definition of 'companionship services' because the regulation excluding them from the exemption already causes their injury.
The Sixth Circuit vacated the district court's denial of early termination of supervised release, ruling that a rigid fifty-percent completion custom violates statutory requirements. The court held that judges must conduct an individualized assessment of statutory factors rather than relying on a blanket time-served rule.
The Sixth Circuit vacated the district court's denial of early termination of supervised release, ruling that a rigid fifty-percent completion rule constitutes an abuse of discretion. The court held that 18 U.S.C. § 3583(e)(1) requires an individualized assessment of statutory factors rather than a mechanical time threshold.