RONALD LEE GILMAN, Circuit Judge. C. Sue Schwamberger, a former deputy director of the Marion County Board of Elections (the Board), brought suit against the Board and its former director, F. John Meyer. She asserted 12 causes of action in connection with her termination, only 3 of which involve federal constitutional claims. These three claims, brought under 42 U.S.C. § 1983, allege that the defendants’ actions constituted (1) First Amendment retaliation, (2) a violation of the Fourteenth Amendment’s Due Process Clause, and (3) a violation of the Fourteenth Amendment’s Equal Protection Clause.

The defendants moved to dismiss Schwamberger’s complaint. After dismissing the federal causes of action, the district court declined to exercise supplemental jurisdiction over the state-law claims. For the reasons set forth below, we AFFIRM the judgment of the district court.

THAPAR, Circuit Judge. When you skip over the basics, things get complicated. At its core, this is a straightforward case of contract interpretation. But rather than address the operative text, the Federal Energy Regulatory Commission began with other portions of the contract and treated the matter as an invitation to make complex policy choices. The Commission’s resulting order cannot withstand arbitrary-and-capricious review, so we grant the petition for review, vacate the order, and remand for another go.

McKEAGUE, Circuit Judge. Blake Cretacci sued Coffee County and Coffee County Jail Deputies Joe Call, Brian Keith, Jared Nelson, Jesse Harden, and Cody Faust (“Appellees”) pursuant to 42 U.S.C. § 1983 for constitutional violations that occurred while Cretacci was a pretrial detainee at Coffee County Jail. The district court granted summary judgment in favor of Appellees, finding that two claims were barred by the statute of limitations and that there were no constitutional violations underlying the remaining two claims.

The untimely claims implicate the issue of whether the prison mailbox rule applies to prisoners who are represented by counsel, an issue of first impression in the Sixth Circuit. A majority of circuits have declined to extend the rule to represented prisoners, finding that the rule established in Houston v. Lack, 487 U.S. 266 (1988), is premised on the relaxed procedural requirements traditionally afforded to pro se prisoners who have no choice but to rely on the prison authorities to file their pleadings. We agree and hold that, in the context of filing civil complaints in federal court, the prison mailbox rule applies only to prisoners who are not represented by counsel.

Finding no error in the district court’s judgment, we AFFIRM.

For Week of February 8, 2021 - February 12, 2021

SUTTON, Circuit Judge. Lion’s Den displays a billboard, affixed to a tractor-trailer, on a neighbor’s property that advertises its nearby adult bookstore. Kentucky’s Billboard Act prohibits such off-site billboards when, as in this case, the advertisement is not securely affixed to the ground, the sign is attached to a mobile structure, and no permit has been obtained. None of these requirements applies to an on-site billboard advertisement, and the Act applies equally to commercial and non-commercial speech on billboards. In response to a First (and Fourteenth) Amendment challenge to the Act, the district court prohibited the Commonwealth from enforcing its law. We affirm, as the Billboard Act regulates commercial and non-commercial speech on content-based grounds and is not tailored to achieve Kentucky’s purported interests.

The employee suffered compensable injuries to her right shoulder, and the employer initiated workers’ compensation benefits for those injuries, including the surgical repair of the employee’s rotator cuff and biceps tendon. The employee’s treating physician subsequently recommended a shoulder replacement due to the employee’s preexisting osteoarthritis, but the employer declined to pay for the shoulder replacement. After an expedited hearing, the trial court denied the employee’s request that the employer be compelled to pay for the shoulder replacement, finding the employee had not established that she would likely prevail at trial in proving the need for shoulder replacement surgery was reasonable and necessary treatment causally related to her workplace injury. The employee has appealed. After careful consideration, we affirm the trial court’s order denying the requested medical benefits and remand the case.

The parties dispute the meaning of a one-page written agreement. Appellee asserts the agreement entitled her to purchase a piece of real property over a four-and-a-half-year lease term, with her rental payments and a non-refundable down payment going toward the purchase price. In contrast, Appellant asserts that Appellee was entitled to purchase the property after the four-and-a-half-year lease term, with credit for her down payment but not her monthly rental payments. Given the ambiguity of the agreement, we defer to the trial court’s interpretation and affirm its holding that Appellee purchased the property by the conclusion of the contract’s term.

This appeal arises from a petition for judicial review of a decision of the City of Memphis Civil Service Commission. The appellant was terminated from his employment with the City after he was found to have violated two sections of the city’s disciplinary policy. The Civil Service Commission upheld his termination. The appellant then sought judicial review in chancery court. After reviewing the record, the chancery court likewise upheld termination. The appellant appealed to this Court. Discerning no error, we affirm and remand for further proceedings.

This is a defamation case that was dismissed by the trial court on a motion to dismiss. Plaintiff, a former riverboat captain, predicated his defamation claim on a letter sent by a lawyer for the owner of a drawbridge to the riverboat captain’s former employer. The purpose of the letter was to put the employer on notice that damage had been caused to the drawbridge by one of the employer’s towboats. In its oral ruling, which was incorporated into its dismissal order, the trial court identified several grounds which it concluded supported dismissal. Not addressed by the trial court were several procedural defenses raised by the defendant, including a defense based on an alleged lack of personal jurisdiction. Notably, the defendant has not waived its personal jurisdiction defense on appeal. Because jurisdiction is a prerequisite to an adjudication on the merits of the case, we vacate the trial court’s dismissal order and remand the matter for a consideration of the defendant’s personal jurisdiction defense.

SUTTON, Circuit Judge. When International Digital Publishing Forum decided to license and potentially transfer its intellectual property to the World Wide Web Consortium, one of its members sued. OverDrive claimed that the arrangement violated its rights under the Copyright Act. The district court granted summary judgment to International Digital because it validly licensed its intellectual property and because it would be premature to resolve any claim about future transfers. We affirm.

One loose part of this conversation dangles. OverDrive separately argues that the district court erred by failing to decide whether International Digital has an independent copyright interest in EPUB as its “collective-work author.” In its view, we need to decide whether International Digital has a copyright in EPUB before we can know whether transferring its intellectual property to the Consortium would infringe OverDrive’s copyrights. But settling that issue will not get us any closer to a ripe dispute. We do not need to know the precise scope of International Digital’s intellectual property to determine that evaluating its transfer today would be premature.

We affirm.