In Elizabeth Ferguson v. MetLife Investors USA Insurance Company, the dispute centered on Brighthouse Life Insurance Company’s rescission of a $1 million life insurance policy it had issued to Ewanda Ferguson after discovering material misrepresentations in her 2020 reinstatement application about her driving record, including two operating-while-impaired convictions and a license revocation. Brighthouse denied the death benefit to the named beneficiary, Ewanda’s daughter Elizabeth Ferguson, who then sued for breach of contract and argued she was an innocent third party entitled to equitable balancing under Michigan law before rescission. The district court granted summary judgment to Brighthouse, ordering rescission, and the Sixth Circuit affirmed. The court held that Michigan’s third-party beneficiary statute gives Ferguson the same rights and limitations as the original insured, so she stood in Ewanda’s shoes with no right to equitable balancing; the policy’s terms expressly allowed rescission for material misrepresentations, and the distinct “innocent third party” balancing rule from auto-insurance cases did not apply.
In United States v. Steven Tilden Fellmy, police stopped the defendant's silver Mustang after receiving an anonymous tip about drug trafficking and observing traffic violations, then used a drug-sniffing dog named Tyra to examine the vehicle after Fellmy refused consent to a search. Tyra jumped onto the car door and alerted to drugs through an open window, leading officers to discover methamphetamine and heroin inside. The district court denied Fellmy's motion to suppress the evidence, and a jury convicted him of methamphetamine trafficking. The Sixth Circuit affirmed, holding that the traffic stop was justified, officers could lawfully order Fellmy out of the car, and the dog sniff did not constitute an unreasonable search because officers did not encourage or facilitate the dog's contact with the vehicle. The court rejected the argument that the dog's paws on the door or nose through the window transformed the open-air sniff into an unlawful trespass requiring probable cause.
T.E. sued Anthem Blue Cross Blue Shield after the insurer initially covered but then denied further payment for his minor son's long-term residential mental-health treatment at Elevations, asserting the treatment was no longer medically necessary under the plan's MCG guidelines. The district court granted summary judgment to Anthem on both the ERISA claim that the denial was arbitrary and capricious and the claim that the denial violated the Mental Health Parity and Addiction Equity Act. The Sixth Circuit held that Anthem's coverage decision was arbitrary and capricious under ERISA because the record showed the insurer failed to properly apply its own continued-stay criteria to C.E.'s documented symptoms and treatment needs. On the Parity Act claim, however, the court found T.E. offered no evidence comparing Anthem's application of treatment limitations for mental-health care versus medical or surgical care, so that claim failed as a matter of law. The court therefore affirmed in part, vacated in part, and remanded with instructions for Anthem to reassess the coverage request.
The case concerned HRT Enterprises’ claim that the City of Detroit effected a de facto taking of its industrial property near Coleman A. Young Airport by failing to acquire it or mitigate conditions that rendered the land unusable after 2008, following earlier state-court litigation in which a jury rejected HRT’s inverse-condemnation claim. The district court held that res judicata did not bar the federal suit, ruled as a matter of law that a taking had occurred, and, after two jury trials on damages, entered judgment for HRT in the amount of approximately $1.97 million. On appeal, the Sixth Circuit affirmed, concluding that the federal action was ripe, that the prior state-court judgments did not preclude the claim because they rested on different facts and on the since-overruled Williamson County exhaustion requirement, and that the City’s conduct constituted a compensable taking under the Fifth Amendment.
In HRT Enterprises v. City of Detroit, HRT prevailed on a federal takings claim under 42 U.S.C. § 1983 after years of state-court and bankruptcy proceedings, and then sought attorney fees as the prevailing party under 42 U.S.C. § 1988. The district court awarded fees but ruled it lacked discretion to compensate work performed in the related state-court and bankruptcy matters and also granted expert witness fees. On cross-appeals, the Sixth Circuit held that the district court erred by treating fees from those separate proceedings as categorically unavailable and by awarding expert fees under § 1988(c), which by its plain terms applies only to actions enforcing §§ 1981 or 1981a, not § 1983. The court therefore vacated the fee award and remanded for recalculation consistent with its interpretation of the statute.
In United States v. Neal Harris, Kelly and Neal Harris were convicted by a jury of multiple counts of wire fraud under 18 U.S.C. § 1343 after submitting numerous fraudulent applications to the federal COVID-19 Economic Injury Disaster Loan program administered by the SBA, through which they obtained over $300,000 for purported businesses that had little or no actual revenue, employees, or operations. On appeal, the Harrises challenged the sufficiency of the evidence supporting their convictions, the procedural and substantive reasonableness of their sentences, and Kelly additionally raised an ineffective-assistance-of-counsel claim. The Sixth Circuit affirmed the convictions, holding that the trial evidence—including the submission of false information about revenues, employee counts, and industry sectors to secure approvals—permitted a rational jury to find the defendants knowingly made material misrepresentations. The court also upheld the sentences as reasonable, concluding that the district court adequately considered the § 3553(a) factors and did not abuse its discretion, and rejected the ineffective-assistance claim as unsupported by the record and better suited for collateral review.
