Justia U.S. 6th Circuit Court of Appeals Opinion Summaries

The case revolves around Joshua Aldridge, who was found guilty of conspiracy to sex traffic an adult by force, threats of force, fraud, or coercion, among other charges. Aldridge and his girlfriend, Kathy, were both addicted to painkillers and sought out higher-dosage pills from Larry Dean Porter. When they could not afford to purchase pills with money, Porter would allow them to have the pills as long as they agreed to pay him later. Eventually, Kathy was informed that she could “work off” the debt by “cleaning and doing sexual favors.” Aldridge would regularly drive Kathy to Porter’s house, take his pill, leave Kathy at the house, and return to pick her up when she was finished.The district court denied Aldridge's Rule 29 motion for judgment of acquittal on the adult-sex-trafficking-by-force conspiracy charge. The court reasoned that a jury could find that Aldridge had personally coerced Kathy to buy pills in exchange for sex acts. The jury found Aldridge guilty on all three counts. At sentencing, the district judge applied two enhancements over Aldridge’s objections: the enhancement for use of a computer to entice or offer and the vulnerable-victim enhancement.In the United States Court of Appeals for the Sixth Circuit, Aldridge challenged the district court’s denial of his Rule 29 motion and the district court’s application of two sentencing enhancements. The court affirmed the district court's decision, stating that there was sufficient evidence for the jury to find that Aldridge knowingly and voluntarily joined the conspiracy with intent to further its objective. The court also found that the district court properly applied the sentencing enhancements. View "United States v. Aldridge" on Justia Law

The case involves Katrina Robinson, founder and director of The Healthcare Institute (THI), a for-profit company in Memphis, Tennessee, that provided certified nursing assistant training. THI received a federal grant from the Geriatrics Workforce Enhancement Program (GWEP), administered by the Health Resources and Services Administration (HRSA), from 2015 to 2019. The grant provided scholarships for eligible THI students. Robinson was convicted of four counts of wire fraud for actions she took in administering the grant. The district court granted Robinson's post-verdict motion for a judgment of acquittal on two of the counts, and Robinson appealed the denial of acquittal on the remaining two counts.The district court's decision was based on a federal investigation that raised concerns about Robinson's use of HRSA grant funds for personal expenses and discrepancies in Annual Performance Reports (APRs) that Robinson had submitted on THI’s behalf. The APRs contained inaccurate information on the number of students who graduated from the program, the number of students who received grant-funded scholarships, and the unique numerical identifiers assigned to students. The government argued that these "errors" were intentional manipulations by Robinson to ensure THI’s continued receipt of grant funds.The United States Court of Appeals for the Sixth Circuit affirmed in part, reversed in part, and remanded for further proceedings. The court found that there was sufficient evidence to prove that Robinson's submission of false information in the APRs constituted a course of conduct intended to deprive the government of money. The court also found that Robinson's intent to defraud was demonstrated by her direct involvement in preparing and submitting the APRs, and her direction to charge personal wedding expenses to the grant. The court reversed the district court's grant of acquittal on one of the counts, finding that a rational juror could conclude that Robinson's transmission of materially false information was done to induce HRSA to continue funding the grant. The court affirmed the district court's denial of acquittal on the remaining two counts. View "United States v. Robinson" on Justia Law

Travis Lester, a convicted felon, was arrested and charged with possession of a firearm after law enforcement officers found a stolen .40 caliber pistol in his motel room. The arrest occurred after Lester violated the terms of his supervised release from a previous conviction for possessing ammunition as a felon. During the arrest, officers found a baggie of crack cocaine and $869 in cash on Lester's person. Lester admitted to having marijuana in his motel room. Based on this information, officers obtained a search warrant for the room, where they found the pistol, a digital scale, and a small bag of marijuana.Prior to his trial, Lester filed a motion to suppress the evidence obtained from the officers' protective sweep of his motel room and his admission about the marijuana, arguing that these violated his Fourth Amendment and Miranda rights. The district court denied this motion, finding that the officers had not violated Lester's rights. At trial, the jury convicted Lester, and the district court sentenced him to 120 months in prison. The court also imposed an additional seventeen-month prison sentence to be served consecutively due to Lester's violation of the supervised-release conditions from his earlier conviction.On appeal to the United States Court of Appeals for the Sixth Circuit, Lester argued that his Miranda and Fourth Amendment rights were violated, that there were evidentiary errors, and that there were mistakes in his sentencing. The appellate court disagreed with Lester's claims and affirmed the district court's decision. The court held that the officer's question during Lester's arrest was not an interrogation under Miranda, and that the protective sweep of Lester's motel room did not violate his Fourth Amendment rights. The court also found no error in the district court's evidentiary rulings or in its sentencing of Lester. View "United States v. Lester" on Justia Law

The case involves Carl Hubbard, who was convicted of first-degree murder in Michigan state court in 1992. Over two decades later, Hubbard filed a petition for a writ of habeas corpus in the United States District Court for the Eastern District of Michigan, arguing that he is entitled to an equitable exception to the Antiterrorism and Effective Death Penalty Act of 1996’s (AEDPA) time bar based on a credible showing of actual innocence. The district court dismissed the petition as untimely.The district court's decision was appealed to the United States Court of Appeals for the Sixth Circuit. Hubbard argued that he had new evidence that impeached the State’s case against him, but he failed to present evidence affirmatively demonstrating his actual innocence. The court held that AEDPA does not permit him to file an untimely habeas petition. The court affirmed the district court's decision, stating that Hubbard's new evidence did not meet the burden of showing that the State had imprisoned an innocent person. Therefore, Hubbard must comply with the same law with which all other habeas petitioners must comply. View "Hubbard v. Rewerts" on Justia Law

The case involves Hattie Tanner, who was convicted of murder and served seventeen years in prison before her conviction was set aside due to insufficient evidentiary support. After her release, Tanner filed a lawsuit against David Walters, a retired police detective, alleging that he violated her constitutional rights by falsifying investigation reports and providing false testimony, leading to her wrongful conviction. Walters sought summary judgment based on qualified immunity, which the district court partially granted and partially denied. The court allowed Tanner's claims for fabrication of evidence and malicious prosecution to proceed to trial. Walters appealed this decision.Previously, the district court found that Tanner's claims for fabrication of evidence and malicious prosecution should proceed to trial. Walters appealed this decision, arguing that he was entitled to qualified immunity.The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court found that a reasonable jury could conclude that Walters knowingly fabricated evidence against Tanner, and thus he was not entitled to qualified immunity on Tanner's fabrication-of-evidence claim. The court also found that a reasonable jury could find that Walters's false statements influenced the decision to charge Tanner, and that without these false statements, there would not have been probable cause to prosecute Tanner. Therefore, Walters was not entitled to qualified immunity on Tanner's malicious prosecution claim. View "Tanner v. Walters" on Justia Law

The case revolves around Gregory Rogers, who was convicted of various drug and firearm-related crimes. The evidence leading to his conviction was obtained from his girlfriend's car, where he was found alone in the passenger seat. Rogers claimed that the evidence was collected in violation of his Fourth Amendment rights, arguing that he had a legitimate expectation of privacy in the vehicle.Previously, the trial court had denied Rogers' motion to suppress the evidence. The court ruled that Rogers lacked a legitimate expectation of privacy in the vehicle as he was neither the owner nor the driver of the car and failed to show that he had permission to occupy it. The court also determined that the search was a valid inventory search. After trial, a jury convicted Rogers on all six counts.The United States Court of Appeals for the Sixth Circuit affirmed the trial court's decision. The court agreed with the trial court that Rogers had no legitimate expectation of privacy in the vehicle. The court noted that Rogers had not exhibited a subjective expectation of privacy. He was neither the owner nor the driver of the vehicle, and he had not shown that he had "complete dominion and control" over the car. The court also noted that Rogers had twice informed the police that the car was not his and had loudly disclaimed his authority over the vehicle. Therefore, the court concluded that Rogers could not establish that the police had violated his Fourth Amendment rights. View "United States v. Rogers" on Justia Law

The case involves two separate appeals by Brian Witham and Michael Savage, both of whom pleaded guilty to various federal crimes, including one count each of using, carrying, and brandishing a firearm in relation to a crime of violence under 18 U.S.C. § 924(c). As part of their plea deals, the government dismissed additional charges under the same statute. Later, both Witham and Savage sought to vacate their § 924(c) convictions, arguing that their offenses did not constitute "crimes of violence" in light of a subsequent Supreme Court ruling in United States v. Davis.In the lower courts, both Witham and Savage's motions to vacate their § 924(c) convictions were rejected. The courts reasoned that they had procedurally defaulted their claims by failing to raise them on direct appeal. The courts also held that their claims of actual innocence of the attempted bank extortion/firearm charge did not excuse the default because they could not show their innocence with respect to the other dismissed firearms charges.The United States Court of Appeals for the Sixth Circuit affirmed the lower courts' decisions. The court held that a defendant who has accepted a plea bargain may not collaterally attack his conviction unless he can show that he is actually innocent of equally or more serious charges dismissed as part of the bargain. Because Witham and Savage's plea agreements both involved the dismissal of § 924(c) charges, and because neither of them has shown actual innocence of the dismissed charges, the court ruled that their procedural defaults could not be excused. View "Witham v. United States" on Justia Law

The case involves two separate appeals by Brian Witham and Michael Savage, who pleaded guilty to various federal crimes, including using a firearm during a crime of violence. Both appellants later sought to vacate their convictions under 28 U.S.C. § 2255, arguing that their offenses no longer qualified as crimes of violence under United States v. Davis. The district courts rejected their motions, reasoning that they had procedurally defaulted their claims by failing to raise them on direct appeal. The courts also held that the appellants could not demonstrate their "actual innocence" of other serious charges that the government had dismissed as part of their plea deals.The United States Court of Appeals for the Sixth Circuit affirmed the lower courts' decisions. The court held that a defendant who secures the dismissal of equally serious charges through a plea bargain must demonstrate his "actual innocence" of those charges to avoid procedural default. The court rejected the appellants' arguments that the rule should only apply to more serious charges and that a statute enacted after the Supreme Court's decision in Bousley v. United States had changed the landscape. The court concluded that the statute, 18 U.S.C. § 3296, did not speak to the issue at hand and did not undermine the rationale of Bousley. View "Savage v. United States" on Justia Law

In the case before the United States Court of Appeals for the Sixth Circuit, the defendant, Jyoti Agrawal, was convicted of three financial crimes. Agrawal had obtained over $1.5 million in federal and state grants to research and develop a scanning electron microscope. However, she forged a letter in her company’s application to the Department of Energy, and later lied about how the funds were spent. She diverted a portion of the grant funds for personal expenses, including her MBA. The district court found that Agrawal's conduct caused a loss of $1,548,255, which was used to calculate her sentencing guidelines range. She was also ordered to pay restitution of the same amount.On appeal, Agrawal challenged the district court’s evidentiary and instructional rulings at trial, its estimate of the amount of loss from her fraud, and its decision to find her personal property forfeitable due to the fraud. However, the Court of Appeals found that the alleged evidentiary and instructional errors were harmless, the district court properly refused to offset its loss amount by her project expenses, and the court properly subjected her personal property to forfeiture because she commingled that property with grant funds.Furthermore, the court rejected Agrawal's challenges to her sentence, including her claim that the court identified an incorrect guidelines range, miscalculated the restitution amounts, and entered an illegal forfeiture judgment. The court affirmed the lower court's decision. View "United States v. Agrawal" on Justia Law

In the case under review, the appellant, Lafayette Deshawn Upshaw, was convicted of crimes associated with two separate incidents occurring on the same day: a gas station robbery and a home invasion. Following exhaustion of state court remedies, Upshaw sought habeas relief in federal court, upon which the district court granted relief on claims of ineffective assistance of counsel and violation of the Batson rule.The ineffective assistance of counsel claim was based on trial counsel's failure to investigate potential alibi witnesses. The Batson rule violation claim was derived from the State’s use of peremptory challenges to strike six Black jurors. The Warden appealed the district court's decision, but the United States Court of Appeals for the Sixth Circuit affirmed the lower court's ruling.The court found that the trial counsel's failure to investigate potential alibi witnesses and to request an adjournment to rectify the situation was unreasonable and prejudicial to Upshaw, constituting ineffective assistance of counsel. The court also found that the State's failure to provide race-neutral reasons for striking certain jurors, coupled with the trial court's failure to properly evaluate the State's justifications, constituted a violation of the Batson rule. The court held that even a single racially motivated peremptory strike requires relief. The court concluded that both of these errors entitled Upshaw to habeas relief. View "Upshaw v. Stephenson" on Justia Law