6th Circuit Case Commentaries

Habeas Courts Retain Jurisdiction to Sanction Pre‑Compliance Violations of Conditional and Unconditional Writs, Even After Belated State Compliance; “Penalty Bar” Reserved for Substantial Inequitable Conduct

Date: Oct 11, 2025

Habeas Courts Retain Jurisdiction to Sanction Pre‑Compliance Violations of Conditional and Unconditional Writs, Even After Belated State Compliance; “Penalty Bar” Reserved for Substantial Inequitable...

United States v. Riley: Pro se allegations that counsel entered a sentencing stipulation without client consent trigger a mandatory judicial inquiry; the hybrid-representation bar does not apply

Date: Oct 11, 2025

United States v. Riley: Pro se allegations that counsel entered a sentencing stipulation without client consent trigger a mandatory judicial inquiry; the hybrid-representation bar does not apply...

No Posthumous Payments Under IRA § 22007(e): Sixth Circuit Holds “Financial Assistance” Is Forward‑Looking and Limited to Living Farmers

Date: Oct 10, 2025

No Posthumous Payments Under IRA § 22007(e): Sixth Circuit Holds “Financial Assistance” Is Forward‑Looking and Limited to Living Farmers Introduction In Black Farmers & Agriculturalists Association...

Political Facebook Posts Framed as Opinions with Disclosed Basis Are Not Actionable as Defamation under Michigan Law: Lento Law Group, P.C. v. Lewis (6th Cir. 2025)

Date: Oct 10, 2025

Political Facebook Posts Framed as Opinions with Disclosed Basis Are Not Actionable as Defamation under Michigan Law: Lento Law Group, P.C. v. Lewis (6th Cir. 2025) Note: The opinion is “Not...

Issue Preclusion, Not Claim Preclusion, Controls Prior Standing Dismissals; New Self‑Censorship Facts Confer Standing to Challenge Discretionary Billboard Variances

Date: Oct 10, 2025

Issue Preclusion, Not Claim Preclusion, Controls Prior Standing Dismissals; New Self‑Censorship Facts Confer Standing to Challenge Discretionary Billboard Variances Introduction This Sixth Circuit...

No Nexus for Intrafamilial Land Disputes: Sixth Circuit Reaffirms Personal-Motive Bar and Treats Nexus as a Factual Finding in Asylum Claims

Date: Oct 10, 2025

No Nexus for Intrafamilial Land Disputes: Sixth Circuit Reaffirms Personal-Motive Bar and Treats Nexus as a Factual Finding in Asylum Claims Introduction In Masud Ahmed v. Pamela Bondi, the United...

Acceptance Means More Than a Plea: Sixth Circuit Authorizes Use of Post‑Indictment Jailhouse Drug Misconduct and False Denials to Defeat §3E1.1—Even If Not §1B1.3 Relevant Conduct; Explicit Bostic Concurrence Invokes Invited Error

Date: Oct 10, 2025

Acceptance Means More Than a Plea: Sixth Circuit Authorizes Use of Post‑Indictment Jailhouse Drug Misconduct and False Denials to Defeat §3E1.1—Even If Not §1B1.3 Relevant Conduct; Explicit Bostic...

Honest-Belief, Not Exhaustive Investigation: Sixth Circuit Clarifies Pretext Analysis and Comparator Severity in ADA/PWDCRA and Michigan WDCA Retaliation Cases

Date: Oct 10, 2025

Honest-Belief, Not Exhaustive Investigation: Sixth Circuit Clarifies Pretext Analysis and Comparator Severity in ADA/PWDCRA and Michigan WDCA Retaliation Cases Case: Daniel Welch v. Heart Truss &...

Safety-Based Union Discretion: Sixth Circuit Affirms No DFR Breach When Union Declines to Grieve Termination Based on Credible Workplace-Safety Concerns

Date: Oct 10, 2025

Safety-Based Union Discretion: Sixth Circuit Affirms No DFR Breach When Union Declines to Grieve Termination Based on Credible Workplace-Safety Concerns Case: Thomas Schramm v. Neenah Paper Michigan,...

Sixth Circuit Confirms District Courts May Deny Amendment 821 Reductions and Maintain Above-Amended-Guidelines Sentences with an Adequate § 3553(a) Explanation

Date: Oct 10, 2025

Sixth Circuit Confirms District Courts May Deny Amendment 821 Reductions and Maintain Above-Amended-Guidelines Sentences with an Adequate § 3553(a) Explanation Introduction United States v. Luster is...

No-Hindsight Review and the Alignment of Rule 23(a) and Rule 23(e): The Sixth Circuit Affirms a Global Settlement of Michigan “Home-Equity Theft” Claims

Date: Oct 10, 2025

No-Hindsight Review and the Alignment of Rule 23(a) and Rule 23(e): The Sixth Circuit Affirms a Global Settlement of Michigan “Home-Equity Theft” Claims Introduction This appeal arises from a...

"Fairness Is Judged at the Time of Settlement": Sixth Circuit Affirms Arm’s‑Length, Pro Rata Class Settlement and Rejects Unproven “Reverse Auction” Allegations in Michigan Surplus‑Proceeds Takings Litigation

Date: Oct 10, 2025

"Fairness Is Judged at the Time of Settlement": Sixth Circuit Affirms Arm’s‑Length, Pro Rata Class Settlement and Rejects Unproven “Reverse Auction” Allegations in Michigan Surplus‑Proceeds Takings...

No Indictment Presumption for Probable Cause; Body‑Weight Pressure on Restrained Suspects and “Small‑Group” Identification: Sixth Circuit Partially Revives Claims in English v. Kral

Date: Oct 9, 2025

No Indictment Presumption for Probable Cause; Body‑Weight Pressure on Restrained Suspects and “Small‑Group” Identification: Sixth Circuit Partially Revives Claims in English v. Kral Court: U.S. Court...

Mandamus as Safety Valve: Sixth Circuit Reaffirms Privilege and Work-Product Protection for Corporate Internal Investigations Triggered by Government Probes

Date: Oct 9, 2025

Mandamus as Safety Valve: Sixth Circuit Reaffirms Privilege and Work-Product Protection for Corporate Internal Investigations Triggered by Government Probes Case: In re FirstEnergy Corp., No. 24-3654...

First-to-File Is Not an Independent Transfer Power: Sixth Circuit Authorizes Mandamus to Vacate Unauthorized Inter‑Circuit Transfers

Date: Oct 9, 2025

First-to-File Is Not an Independent Transfer Power: Sixth Circuit Authorizes Mandamus to Vacate Unauthorized Inter‑Circuit Transfers Introduction This published Sixth Circuit decision addresses when...

Yoder v. Bowen: Sixth Circuit Leaves Drone-Hunting Ban Intact and Narrows the Speech-Inputs Doctrine—For Now

Date: Oct 9, 2025

Yoder v. Bowen: Sixth Circuit Leaves Drone-Hunting Ban Intact and Narrows the Speech-Inputs Doctrine—For Now Introduction In Mike Yoder v. Scott Bowen, the U.S. Court of Appeals for the Sixth Circuit...

Misdesignated Notices Saved by FRAP 3(c)(7), “Some Day Intentions” Do Not Confer Equitable Standing, and Neutral Single‑Family Zoning Is Not Facially Discriminatory: Commentary on Be the Bush Recovery Ministries v. Coffee County

Date: Oct 9, 2025

Misdesignated Notices Saved by FRAP 3(c)(7), “Some Day Intentions” Do Not Confer Equitable Standing, and Neutral Single‑Family Zoning Is Not Facially Discriminatory: Commentary on Be the Bush...

Waiver-Induced Mootness on Appeal: Sixth Circuit Dismisses NCAA’s Preliminary-Injunction Appeal and Declines Munsingwear Vacatur

Date: Oct 2, 2025

Waiver-Induced Mootness on Appeal: Sixth Circuit Dismisses NCAA’s Preliminary-Injunction Appeal and Declines Munsingwear Vacatur Introduction This published Sixth Circuit decision arises from a...

Clear-Error, Not De Novo: Sixth Circuit Clarifies Appellate Review for Perjury-Based §3C1.1 Enhancements and Upholds Digital-Device Search Condition Under Plain Error

Date: Oct 2, 2025

Clear-Error, Not De Novo: Sixth Circuit Clarifies Appellate Review for Perjury-Based §3C1.1 Enhancements and Upholds Digital-Device Search Condition Under Plain Error Introduction In United States v....

Upward Variances May Rest on Pretrial-Compliance Failures Revealed After a Bostic Objection: Sixth Circuit Affirms 21% Variance in United States v. Ellington

Date: Oct 2, 2025

Upward Variances May Rest on Pretrial-Compliance Failures Revealed After a Bostic Objection: Sixth Circuit Affirms 21% Variance in United States v. Ellington Introduction This commentary analyzes the...