Case Explained: 26a0183p.06

Court: United States Court of Appeals for the Sixth Circuit Filed: 2026-06-25 The Sixth Circuit affirmed the district court’s grant of summary judgment in favor of the defendants, dismissing Jenna Amacher’s First Amendment retaliation claim under 42 U.S.C. § 1983 and her state law malicious prosecution claim. The court held that a plaintiff alleging retaliation based on a legal action taken against them must prove the absence of probable cause as an element of their claim. Applying this standard to the quo warranto petition filed against Amacher, the court reasoned that such civil proceedings are most analogous to common law malicious prosecution and wrongful civil proceedings, both of which require a showing that the underlying lawsuit lacked probable cause. The court determined that probable cause existed for the quo warranto petition because the defendants had a reasonable belief that Amacher’s eligibility for office was questionable given her failure to maintain residency within Tullahoma for six months and her delayed construction efforts on a new home. The court emphasized that even if the petition was ultimately unsuccessful, it presented a fair ground for challenging her tenure as an alderman. Consequently, the existence of probable cause barred the First Amendment retaliation claim regardless of any alleged retaliatory motive. Additionally, the court affirmed the district court’s denial of Amacher’s request to extend discovery, ruling that the trial judge did not abuse their discretion in rejecting the motion because Amacher failed to demonstrate “good cause” and was not sufficiently diligent in pursuing depositions within the allotted timeframes. The practical consequence is that the judgment for the defendants stands, and Amacher’s claims are dismissed without further litigation on the merits. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.