The U.S. Court of Appeals for the Sixth Circuit affirmed a district court's dismissal of a civil rights lawsuit filed by William Shelton, a former officer with the Cuyahoga Metropolitan Housing Authority police department, against his employer and supervisor.

In the January 14, 2026 opinion in *Shelton v. CMHA*, the three-judge panel unanimously upheld the U.S. District Court for the Northern District of Ohio's decision to dismiss Shelton's First Amendment claims as untimely and grant summary judgment in favor of CMHA on his Title VII discrimination claims.

Shelton began his career with the CMHA police department in 2016, working as a detective and occasionally participating in SWAT team operations. His responsibilities included responding to service calls, enforcing CMHA policies, and securing CMHA properties throughout the Cleveland area.

The case arose from Shelton's activities as what he described as a "rap artist." According to court documents, others within CMHA were aware of Shelton's musical pursuits, including Police Chief Andreas Gonzalez and his supervisor, Sergeant John Smiddy. Gonzalez had even reportedly invited Shelton to perform at an event, though Shelton warned the chief that his rap music was "vulgar."

The legal dispute centered on specific videos Shelton created, including one titled "Head Shot," which depicted Shelton in what the court described as mock execution scenarios. Court records indicate that Shelton provided no evidence that anyone at CMHA was aware of these particular videos at the time of their creation.

Shelton's lawsuit alleged violations of his First Amendment rights to free speech and expression, claiming that his employment was adversely affected because of his rap music and videos. He also brought Title VII claims alleging workplace discrimination based on protected characteristics.

The district court initially dismissed Shelton's First Amendment claims, finding that they were filed outside the applicable statute of limitations. Federal civil rights claims under Section 1983, which Shelton used to assert his First Amendment allegations, must generally be filed within the state's statute of limitations for personal injury claims, which in Ohio is two years.

Regarding the Title VII discrimination claims, the district court granted summary judgment in favor of CMHA. Title VII of the Civil Rights Act of 1964 prohibits employment discrimination based on race, color, religion, sex, or national origin. To succeed on a Title VII claim, plaintiffs must typically establish that they suffered an adverse employment action because of their membership in a protected class.

The Sixth Circuit's opinion, authored by Circuit Judge Helene White and joined by Circuit Judges Karen Nelson Moore and Danny Clay, found no error in the district court's handling of either set of claims. The appeals court determined that the statute of limitations analysis for the First Amendment claims was correct and that CMHA was entitled to summary judgment on the Title VII allegations.

The case highlights the intersection of employee speech rights and workplace policies, particularly in law enforcement contexts. While public employees retain some First Amendment protections for their speech, courts apply a balancing test that considers whether the speech addresses matters of public concern and whether the government employer's interests in workplace efficiency outweigh the employee's speech rights.

For the First Amendment analysis, courts typically examine whether the speech was made in the employee's capacity as a citizen on matters of public concern, and if so, whether the government employer's interest in promoting workplace efficiency justifies any restrictions on that speech. The *Pickering* balancing test, established by the Supreme Court, governs these determinations.

The Title VII analysis requires plaintiffs to demonstrate either direct evidence of discrimination or establish a prima facie case showing they were treated differently because of their protected status. Employers can then articulate legitimate, non-discriminatory reasons for their actions, which plaintiffs must prove were pretextual.

Shelton's case illustrates the challenges public employees face when pursuing civil rights claims against their employers. The strict timing requirements for federal civil rights lawsuits can bar otherwise valid claims if not filed promptly, while discrimination claims require substantial evidence linking adverse employment actions to protected characteristics.

The opinion was marked "NOT RECOMMENDED FOR PUBLICATION," indicating that while it resolves the dispute between the parties, it does not establish new legal precedent for future cases. Such opinions are common in federal appeals courts for cases that apply established legal principles to specific factual situations.

CMHA operates public housing and provides housing assistance throughout Cuyahoga County, which includes Cleveland. The authority maintains its own police force to provide security and law enforcement services at housing properties and facilities.

Neither Shelton nor his legal representatives could be reached for comment following the Sixth Circuit's decision. CMHA also did not respond to requests for comment about the ruling.

The case number is 24-3933, and the full opinion is available through the federal court system's electronic filing system. Appeals to the U.S. Supreme Court would require filing a petition for certiorari, though the high court accepts only a small fraction of such requests for review.