6th Circuit Case Commentaries

Administrative-Agent Standing Without a Financial Stake; Judicial Sales Must Maximize Competition

Date: Jun 17, 2026

Administrative-Agent Standing Without a Financial Stake; Judicial Sales Must Maximize Competition I. Introduction Case: JPMorgan Chase Bank, N.A. v. Larry Winget (Sixth Circuit, 2026-06-15). Parties:...

Ahmed v. Hamtramck Public Schools: Pleading-Stage Rules for Futility—Paid Administrative Leave Can Be an Adverse Action for FMLA Retaliation and Title IX Employment Discrimination (Post-Muldrow)

Date: Jun 17, 2026

Ahmed v. Hamtramck Public Schools: Pleading-Stage Rules for Futility—Paid Administrative Leave Can Be an Adverse Action for FMLA Retaliation and Title IX Employment Discrimination (Post-Muldrow) I....

Sixth Circuit Clarifies Confrontation Limits for Data-Driven Expert Testimony in Healthcare-Fraud Prosecutions

Date: Jun 14, 2026

Sixth Circuit Clarifies Confrontation Limits for Data-Driven Expert Testimony in Healthcare-Fraud Prosecutions I. Introduction In United States v. Kindy Ghussin (Nos. 25-1056/1099/1104/1157/1353, 6th...

Independent Expert Interpretation of Fraud Analytics Does Not Trigger Confrontation Rights Absent Relayed Testimonial Hearsay

Date: Jun 14, 2026

Independent Expert Interpretation of Fraud Analytics Does Not Trigger Confrontation Rights Absent Relayed Testimonial Hearsay I. Introduction United States v. Ali Abdelrazzaq (6th Cir. June 12, 2026)...

Sixth Circuit: Confrontation Clause Permits Expert’s Independent Interpretation of Team-Processed Data (No Right to Cross-Examine Data Validators)

Date: Jun 14, 2026

Sixth Circuit: Confrontation Clause Permits Expert’s Independent Interpretation of Team-Processed Data (No Right to Cross-Examine Data Validators) Introduction United States v. Raef Hamaed (6th Cir....

Independent Expert Interpretation of Third-Party-Processed Data Does Not Violate the Confrontation Clause (Sixth Cir.)

Date: Jun 14, 2026

Independent Expert Interpretation of Third-Party-Processed Data Does Not Violate the Confrontation Clause (Sixth Cir.) I. Introduction In United States v. Raef Hamaed (6th Cir. June 12, 2026)...

Independent Expert Interpretation of Third-Party Verified Data Does Not Trigger the Confrontation Clause

Date: Jun 14, 2026

Independent Expert Interpretation of Third-Party Verified Data Does Not Trigger the Confrontation Clause Case: United States v. Tarek Fakhuri (with consolidated appeals of Hamaed, Ghussin,...

Torres Limits “Missed-Shot” Seizure: No Fourth Amendment Seizure Without Physical Contact or Actual Control Over a Fleeing Suspect

Date: Jun 14, 2026

Torres Limits “Missed-Shot” Seizure: No Fourth Amendment Seizure Without Physical Contact or Actual Control Over a Fleeing Suspect Introduction In Jamal Ward v. Charles Brotzke (6th Cir. June 12,...

Westfall Act Immunity Is Claim-by-Claim (Not Suit-Wide) and Civil Fifth-Amendment Silence May Support Adverse Inferences in Scope-of-Employment Hearings

Date: Jun 12, 2026

Westfall Act Immunity Is Claim-by-Claim (Not Suit-Wide) and Civil Fifth-Amendment Silence May Support Adverse Inferences in Scope-of-Employment Hearings I. Introduction Trey Cholewa v. United States...

Pre-Chiaverini Qualified Immunity in the Sixth Circuit: If Any One Charge Had Probable Cause, a § 1983 Malicious-Prosecution Claim Fails

Date: Jun 12, 2026

Pre-Chiaverini Qualified Immunity in the Sixth Circuit: If Any One Charge Had Probable Cause, a § 1983 Malicious-Prosecution Claim Fails 1. Introduction In Phillip Atsas v. Matthew Bowen (6th Cir....

Dodaj v. Blanche: Discretionary Reweighing Is Unreviewable and Unappealed Removability Is Waived

Date: Jun 12, 2026

Dodaj v. Blanche: Discretionary Reweighing Is Unreviewable and Unappealed Removability Is Waived I. Introduction In Leke Dodaj v. Todd W. Blanche, Acting U.S. Attorney General (6th Cir. June 8,...

Post-Judgment Pleading Lock-In: Rule 59(e) Is Not a Do-Over, and Rule 15 Amendment Requires First Reopening the Judgment

Date: Jun 12, 2026

Post-Judgment Pleading Lock-In: Rule 59(e) Is Not a Do-Over, and Rule 15 Amendment Requires First Reopening the Judgment 1. Introduction In Jimmy Bryson; LaTonya Bryson v. Specialized Loan Servicing,...

Section 115 “True Threats” After Counterman: Specific Intent to Intimidate or Retaliate Satisfies the Constitution; “Consciously Disregarded a Substantial Risk” Instruction Not Plain Error

Date: Jun 12, 2026

Section 115 “True Threats” After Counterman: Specific Intent to Intimidate or Retaliate Satisfies the Constitution; “Consciously Disregarded a Substantial Risk” Instruction Not Plain Error I....

Title VII: No Pretext Where Employer’s Conduct-Based Rationale Is Consistent; Retaliation Claim Barred Absent a Proper EEOC Charge

Date: Jun 12, 2026

Title VII: No Pretext Where Employer’s Conduct-Based Rationale Is Consistent; Retaliation Claim Barred Absent a Proper EEOC Charge I. Introduction In Renete Barnett-Morgan v. Inverness Techs., Inc....

Corroborated Testimony and Digital/Forensic Evidence Suffice to Prove § 841 “Distribution Resulting in Death”

Date: Jun 12, 2026

Corroborated Testimony and Digital/Forensic Evidence Suffice to Prove § 841 “Distribution Resulting in Death” I. Introduction In United States v. Melvin Lamar Triplett (6th Cir. June 8, 2026)...

Extending the Heckler’s Veto Doctrine to School-Board Limited Public Forums

Date: Jun 12, 2026

Extending the Heckler’s Veto Doctrine to School-Board Limited Public Forums I. Introduction Darbi Boddy v. Mary Grech (Sixth Cir. June 10, 2026) arises from a public-comment period at a Xenia...

Rule 9(b) Pleading Defects Establish Fraudulent Joinder, and Ohio’s Uniform Fiduciary Act Shields Banks Absent “Actual Knowledge” or “Bad Faith”

Date: Jun 12, 2026

Rule 9(b) Pleading Defects Establish Fraudulent Joinder, and Ohio’s Uniform Fiduciary Act Shields Banks Absent “Actual Knowledge” or “Bad Faith” Case: Vivy Voutsiotis v. PNC Bank, NA (6th Cir. June...

Dodaj v. Blanche: Waiver of Removability Challenges and Limited Judicial Review of Discretionary Cancellation

Date: Jun 12, 2026

Dodaj v. Blanche (6th Cir. 2026): No Duty for the BIA to Revisit Unappealed Removability, and No Judicial Review of Pure Discretionary Reweighing in Cancellation Introduction In Leke Dodaj v. Todd W....

Conditional Habeas Writs: “No Utilizing” an Identification Bars Implicit In‑Court Identification at Retrial; Jurisdiction Persists Absent Clear Vacatur, and CVRA Rights Must Be Asserted by the Victim via Statutory Procedure

Date: Jun 6, 2026

Conditional Habeas Writs: “No Utilizing” an Identification Bars Implicit In‑Court Identification at Retrial; Jurisdiction Persists Absent Clear Vacatur, and CVRA Rights Must Be Asserted by the Victim...

High Dissimilarity Defeats Preliminary-Injunction Dilution Claims (Even Post-TDRA) and Conceptual Weakness Tempers Commercial Strength in Trade Dress

Date: Jun 6, 2026

High Dissimilarity Defeats Preliminary-Injunction Dilution Claims (Even Post-TDRA) and Conceptual Weakness Tempers Commercial Strength in Trade Dress 1. Introduction The Scotts Co. LLC v. The Procter...