Helene N. White

Savannah Moton sued her former employer, Amer Sports Winter & Outdoor Company, alleging she was fired because of her race and in retaliation for an internal complaint she filed claiming racial discrimination by her manager. The district court granted summary judgment to the employer on both claims, and the Sixth Circuit affirmed. The court held that Moton failed to establish a prima facie case of race discrimination because she provided no evidence of a similarly situated non-Black employee who was treated more favorably. It also ruled that her retaliation claim failed because the employer had already documented performance issues and contemplated termination before her complaint, so the five-week gap between the complaint and firing did not prove causation. Inconsistencies about who made the final termination decision and the timing of events did not substitute for the required evidence on either claim.

civil rightslabor & employment

In United States v. Quantavious O’Bannon, the defendant, who had multiple prior felony convictions including fleeing and evading police, burglary, and escape, was arrested pursuant to an outstanding warrant and found in possession of a loaded handgun with an extended magazine; he was indicted under 18 U.S.C. § 922(g)(1) and moved to dismiss on Second Amendment grounds. The district court denied the motion, O’Bannon pled guilty while preserving his challenge, and the Sixth Circuit affirmed. The court held that O’Bannon could constitutionally be disarmed because his record demonstrated dangerousness, as his repeated fleeing-and-evading offenses—such as leading police on chases in stolen vehicles that nearly struck pedestrians, caused crashes, and risked serious injury to officers and bystanders—fell within categories of conduct that endanger the public and justify restrictions under the Second Amendment.

gunscriminal lawcivil rights

In early 2021, Hamtramck Investment Group sought to open a marijuana dispensary in the City of Hamtramck and met with the city clerk, who signed an attestation form and allegedly assured the company it would be grandfathered in despite an impending ordinance banning new retailers. After the City enacted the ban and notified the State that HIG’s proposed site violated the new ordinance, the State denied the license, prompting HIG to sue the City under 42 U.S.C. § 1983 for a substantive due process violation. The district court granted summary judgment to the City, and the Sixth Circuit affirmed. The court held that HIG had no constitutionally protected property interest in the license because, under Michigan law, the city clerk lacked authority to bind the municipality or override ordinances, and any statements or permits created no legitimate entitlement. The company’s business license application also contained disclaimers confirming that approvals from one department did not guarantee others.

business & regulatorycivil rightsproperty

In United States v. Derrion Turner, the defendant appealed his within-guidelines sentence of 246 months in prison after pleading guilty to five counts arising from three armed carjackings committed over ten days when he was 18. Turner argued that the district court gave unreasonable weight to his juvenile criminal history in determining the sentence. The Sixth Circuit affirmed the sentence, holding that the district court did not abuse its discretion. The court reasoned that 18 U.S.C. § 3553(a) required consideration of Turner’s history and characteristics, including his prior juvenile conduct, to assess deterrence and recidivism risk, and that within-guidelines sentences carry a presumption of reasonableness. Although the court noted Turner’s youth and the impact of mandatory minimum sentences under 18 U.S.C. § 924(c), it concluded that the district court retained discretion to weigh these factors and impose the sentence.

criminal lawguns