CINCINNATI - A Michigan county employee who was involuntarily transferred to a position that he had applied for a short time before may proceed with his bias complaint, the Sixth Circuit U.S. Court of Appeals ruled Jan. 14 (Robert Deleon, et al. v. Kalamazoo County Road Commission, et al., No. 12-2377, 6th Cir.; 2014 U.S. App. LEXIS 681).