Styla Carter v. Hickory Healthcare Inc., 905 F.3d 963

Background

Carter, a nursing assistant with asthma, was fired by Hickory Healthcare in July 2007 after refusing to supervise patients during smoke breaks; she filed an ADA charge with the Ohio Civil Rights Commission the same month.
The Ohio Commission later filed a parallel charge with the EEOC and told Carter the agencies would share information; the state process took six years, and in November 2013 the Ohio Commission ruled for Carter.
Carter requested a federal right-to-sue letter; the EEOC mailed it to her old address. Gilbert, her attorney, obtained a copy dated February 20, 2014; Carter sued in federal court on December 9, 2014—well past the 90-day filing period.
The district court held Carter’s ADA claim time-barred and imposed sanctions under 28 U.S.C. § 1927 against Gilbert for maintaining a clearly time-barred suit; the magistrate computed fees and the district court (improperly) reviewed for clear error but entered a final sanctions award of $25,995.32.
On appeal, the Sixth Circuit concluded it had jurisdiction despite the district court’s incorrect standard-of-review application, found the forfeiture of that objection, and affirmed the sanctions as within the district court’s discretion.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether appellate jurisdiction exists where the district court applied the wrong standard of review to a magistrate’s computation	Gilbert argued the district court’s incorrect clear-error review of the magistrate deprived the Court of Appeals of proper appellate jurisdiction (relying on prior precedent)	Hickory argued the standard-of-review error does not strip appellate jurisdiction and parties forfeited the objection	Court held appellate jurisdiction exists under 28 U.S.C. § 1291; the Magistrates Act rule is non-jurisdictional and the parties forfeited the objection
Whether § 1927 sanctions were appropriate for maintaining a time‑barred ADA suit	Gilbert argued he reasonably relied on equitable tolling and interagency cooperation to excuse lateness	Hickory argued the suit was plainly barred and Gilbert ignored clear law and notice from defense	Court held sanctions proper: maintaining a clearly time‑barred suit (and persisting after notice) falls within § 1927 sanctions standard
Whether equitable tolling or agency cooperation justified late filing	Gilbert argued possible equitable tolling and that the Ohio agency’s cooperation with the EEOC made reliance reasonable	Hickory argued regulations require claimant to notify EEOC of address changes and precedent bars tolling/assumption here	Court held tolling/unreasonable reliance arguments were insufficient; claimant had duty to notify EEOC and legal authority foreclosed equitable tolling here
Whether the fee computation and reductions were improper	Gilbert argued various procedural and substantive errors (need for individual affidavits, expert proof of rates, excessive hours, insufficient clerical deduction)	Hickory argued the magistrate used acceptable methods: lead counsel affidavit, market rates, small percentage clerical reduction, and reasonable judgment on billed hours	Court held the magistrate and district court did not abuse discretion in computing and trimming fees; evidentiary/formulaic objections lacked merit

Key Cases Cited

Arbaugh v. Y & H Corp., 546 U.S. 500 (distinguishing jurisdictional rules from claim-processing rules)
Henderson ex rel. Henderson v. Shinseki, 562 U.S. 428 (statutory procedures are jurisdictional only on clear congressional statement)
Holland v. Florida, 560 U.S. 631 (equitable tolling standards require case-by-case analysis but guided by precedent)
Fox v. Vice, 563 U.S. 826 (fee awards aim for rough justice, not auditing perfection)
Red Carpet Studios Div. of Source Advantage, Ltd. v. Sater, 465 F.3d 642 (6th Cir.) (§ 1927 sanctions require more than negligence; sanctions appropriate for abusive conduct)
Graham-Humphreys v. Memphis Brooks Museum of Art, Inc., 209 F.3d 552 (6th Cir.) (EEOC letter mailing rule and commencement of 90‑day period)
Bennett v. Gen. Caster Serv. of N. Gordon Co., 976 F.2d 995 (6th Cir.) (treating attorney‑sanctions as dispositive for review purposes)
Northcross v. Bd. of Educ. of Memphis City Schs., 611 F.2d 624 (6th Cir.) (approving small-percentage deductions for clerical tasks instead of line‑by‑line parsing)
Ne. Ohio Coal. for the Homeless v. Husted, 831 F.3d 686 (6th Cir.) (reasonableness of hourly rates may be established via multiple sources; expert testimony not always required)