6th Circuit Case Commentaries

Total Disability for the BLBA Fifteen-Year Presumption Can Be Inferred from Severe Respiratory Failure Evidence—No “Chronic” Requirement

Date: Apr 20, 2026

Total Disability for the BLBA Fifteen-Year Presumption Can Be Inferred from Severe Respiratory Failure Evidence—No “Chronic” Requirement I. Introduction In Star Servs. Corp. v. OWCP (6th Cir. Apr....

Title-Insurance Exclusion 3(a) Bars Defense Coverage When the Insured Knowingly Permits a Title Reversion and Later Sells Into a Known Cloud

Date: Apr 20, 2026

Title-Insurance Exclusion 3(a) Bars Defense Coverage When the Insured Knowingly Permits a Title Reversion and Later Sells Into a Known Cloud Introduction In Triple Properties Detroit, LLC v. First...

Sixth Circuit Tightens FCA Relator Path: “Substantially the Same” Means No Mere Detail, and “Original Source” Requires Pre-Suit Government Disclosure; Novel Theories Still Must Meet Rule 9(b)

Date: Apr 20, 2026

Sixth Circuit Tightens FCA Relator Path: “Substantially the Same” Means No Mere Detail, and “Original Source” Requires Pre-Suit Government Disclosure; Novel Theories Still Must Meet Rule 9(b) Case:...

Actual Notice Can Satisfy Rule 902(11) and a Large Guidelines Variance Requires a Reasoned Basis to Accept an 11(c)(1)(C) Plea

Date: Apr 20, 2026

Actual Notice Can Satisfy Rule 902(11) and a Large Guidelines Variance Requires a Reasoned Basis to Accept an 11(c)(1)(C) Plea I. Introduction In United States v. Reginald DeWayne Brown (Sixth...

Harmless Error in Withholding-of-Removal Nexus: Misuse of “One Central Reason” Does Not Require Remand Where Record Shows No Protected-Ground Motive

Date: Apr 20, 2026

Harmless Error in Withholding-of-Removal Nexus: Misuse of “One Central Reason” Does Not Require Remand Where Record Shows No Protected-Ground Motive I. Introduction In Fermin Pablo-Diaz v. Todd W....

Post-Revocation Supervised Release Must Be Reduced by All Revocation Imprisonment; No Advance Notice Required for Upward Variances Based on the Record

Date: Apr 20, 2026

Post-Revocation Supervised Release Must Be Reduced by All Revocation Imprisonment; No Advance Notice Required for Upward Variances Based on the Record 1. Introduction In United States v. Jamel...

United States v. Jorge Flores (6th Cir. Apr. 15, 2026) — Commentary

Date: Apr 20, 2026

Protective Sweeps Require Articulable Facts of Dangerous Others (Not Just the Arrestee), While General MS-13 Expert “Background” Testimony and Curative Voir Dire Instructions Are Typically Sufficient...

General Gang-Structure Expert Testimony Survives Rule 704(b) (Post-Diaz) and Curative Instructions Defeat “Fear” and Co-Defendant-Plea Prejudice in MS-13 RICO/VICAR Trials

Date: Apr 20, 2026

General Gang-Structure Expert Testimony Survives Rule 704(b) (Post-Diaz) and Curative Instructions Defeat “Fear” and Co-Defendant-Plea Prejudice in MS-13 RICO/VICAR Trials 1. Introduction In United...

Protective Sweep Scope, Gang-Trial Voir Dire Fear, and Limits on Gang Expert/Impeachment Evidence in RICO/VICAR Prosecutions (Sixth Cir.)

Date: Apr 20, 2026

Protective Sweep Scope, Gang-Trial Voir Dire Fear, and Limits on Gang Expert/Impeachment Evidence in RICO/VICAR Prosecutions (Sixth Cir.) 1. Introduction In United States v. Jorge Flores (24-5610);...

Pleading Fraud-Based Tortious Interference When a Manufacturer Induces Disclosure of Dealer Network Information; “Agreement” Under Michigan Farm Equipment Act Requires Mutual Assent Beyond Transitional Emails

Date: Apr 17, 2026

Pleading Fraud-Based Tortious Interference When a Manufacturer Induces Disclosure of Dealer Network Information; “Agreement” Under Michigan Farm Equipment Act Requires Mutual Assent Beyond...

Sixth Circuit: “Excusable Neglect” Under FRAP 4(a)(5) Requires an Extraordinary Reason—Lead Counsel’s Pregnancy Does Not Excuse a Missed Appeal Deadline Where Co-Counsel Also Received Notice

Date: Apr 17, 2026

Sixth Circuit: “Excusable Neglect” Under FRAP 4(a)(5) Requires an Extraordinary Reason—Lead Counsel’s Pregnancy Does Not Excuse a Missed Appeal Deadline Where Co-Counsel Also Received Notice I....

Rehabilitation Act Rule: No Failure-to-Accommodate Liability Absent an Accommodation Request—and No Accommodation Duty for “Regarded As” Disability

Date: Apr 17, 2026

Rehabilitation Act Rule: No Failure-to-Accommodate Liability Absent an Accommodation Request—and No Accommodation Duty for “Regarded As” Disability I. Introduction In Traniece Morgan v. Ohio Dep't of...

Qualified Immunity for “Compromise” Suicide-Prevention Decisions in Jail: No Clearly Established Deliberate Indifference Absent Factually Analogous Precedent

Date: Apr 17, 2026

Qualified Immunity for “Compromise” Suicide-Prevention Decisions in Jail: No Clearly Established Deliberate Indifference Absent Factually Analogous Precedent I. Introduction In David Lovell v. Cnty....

Technical Refusal to Bargain Does Not Confer § 9(d) Review of Decertification-Petition Dismissals That Preserve the Status Quo

Date: Apr 16, 2026

Technical Refusal to Bargain Does Not Confer § 9(d) Review of Decertification-Petition Dismissals That Preserve the Status Quo 1. Introduction Case: Rieth-Riley Constr. Co., Inc. v. NLRB (6th Cir....

Technical Refusal to Bargain Cannot Create Appellate Jurisdiction to Review a Nonfinal Decertification-Petition Dismissal

Date: Apr 16, 2026

Technical Refusal to Bargain Cannot Create Appellate Jurisdiction to Review a Nonfinal Decertification-Petition Dismissal Case: Rieth-Riley Constr. Co., Inc. v. NLRB (6th Cir. Apr. 13, 2026) Court:...

FCA Express False-Certification Liability Does Not Arise from Forward-Looking “Agrees to Comply” FTA Certifications

Date: Apr 16, 2026

FCA Express False-Certification Liability Does Not Arise from Forward-Looking “Agrees to Comply” FTA Certifications Introduction In UNITED STATES OF AMERICA, ex rel. GREGORY LYNN and PAULETTE...

Inevitable Discovery via Mandatory Tow-Triggered Inventory Search Despite Incomplete Inventory Paperwork (Sixth Circuit)

Date: Apr 16, 2026

Inevitable Discovery via Mandatory Tow-Triggered Inventory Search Despite Incomplete Inventory Paperwork Case: United States v. Arsenio Clayton (6th Cir. Apr. 10, 2026) (not recommended for...

Claim-by-Claim Fee Shifting and § 1927 Sanctions for Persisting in Frivolous Civil-Rights Theories

Date: Apr 10, 2026

Claim-by-Claim Fee Shifting and § 1927 Sanctions for Persisting in Frivolous Civil-Rights Theories Case: Anthony Wynn v. City of Covington, Kentucky, et al. (6th Cir. Apr. 8, 2026) (unpublished)...

Withdrawal from Multiemployer Bargaining Is Timely If Made Before Negotiations Begin, Regardless of Contract-Modification Deadlines

Date: Apr 10, 2026

Withdrawal from Multiemployer Bargaining Is Timely If Made Before Negotiations Begin, Regardless of Contract-Modification Deadlines Introduction Rieth-Riley Constr. Co. v. NLRB (6th Cir. Apr. 8,...

Qualified Immunity for Legislator Speech: No Clearly Established First Amendment “Adverse Action” Rule for a Councilmember’s Defamatory Remark During a Council Meeting

Date: Apr 10, 2026

Qualified Immunity for Legislator Speech: No Clearly Established First Amendment “Adverse Action” Rule for a Councilmember’s Defamatory Remark During a Council Meeting Case: Brian Menge v. Khursheed...