Every decision we've summarized from United States Court of Appeals for the Sixth Circuit.
The Sixth Circuit affirmed the dismissal of property owners' takings and conversion claims against a county treasurer, ruling that the official was entitled to sovereign immunity. The court held that because Michigan law compelled the treasurer's actions regarding tax foreclosures and surplus proceeds, he acted as an arm of the State.
The Sixth Circuit affirmed the denial of sovereign immunity, clarifying that the proper defendant in this tax foreclosure dispute is Wayne County, not its Treasurer. Because the plaintiffs sued the county itself, the Treasurer's Eleventh Amendment immunity was irrelevant to the outcome.
The Sixth Circuit affirmed Mohammed Al-Abadi's twenty-four-month prison sentence for trafficking in counterfeit airbags and recklessly transporting hazardous materials. The court rejected Al-Abadi's challenge to the sentence's reasonableness, finding the district court properly calculated the Guidelines range and applied special supervised release conditions.
The Sixth Circuit affirmed the denial of Robert Smith's motion to suppress evidence found during a search of his home, ruling that the warrant affidavit contained sufficient probable cause. The court held that detailed, first-hand accounts from non-anonymous informants, who admitted to purchasing drugs from Smith, provided a substantial basis for the magistrate judge to issue the warrant.
The Sixth Circuit affirmed the denial of a preliminary injunction against Ohio House Bill 96, ruling that the state's escheat of unclaimed funds does not cause irreparable harm. The court held that property owners retain a ten-year window to recover their funds plus interest, negating the need for injunctive relief.
The Sixth Circuit denied a petition for review of a BIA decision rejecting an asylum claim because the petitioner failed to prove her abuse was motivated by her membership in a protected social group. The court held that the harm suffered was the result of private crimes rather than persecution on account of her identity as an indigenous Mayan Quiche woman.
The Sixth Circuit reversed the district court's denial of intervention of right for agricultural industry groups challenging the EPA's approval of a phosphorus pollution limit for Lake Erie. The court held that these groups have a distinct legal interest in defending the TMDL that the EPA may not adequately represent, while affirming the denial of intervention for a local coalition that failed to show unique arguments.
The Sixth Circuit reversed a district court dismissal of a federal habeas petition, holding that a prisoner's motion for a belated appeal under Kentucky law tolls the federal statute of limitations. The court ruled that because the state appeal remained pending under a recognized exception for ineffective assistance of counsel, the one-year federal clock did not run during that period.
The Sixth Circuit affirmed a 21-month prison sentence for Phillip Gray, who violated supervised release conditions through repeated drug use and combative behavior. The court found no procedural or substantive error, noting the district court adequately considered Gray's psychiatric history while prioritizing public safety and the need for custodial monitoring.
The Sixth Circuit affirmed a defendant's sentence for child pornography possession, rejecting claims that a mandatory victim assessment was improper due to indigency. The court also upheld a five-year term of supervised release as a statutory minimum that is inherently reasonable.