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

Leonel Hinojosa was originally sentenced to 240 months in prison for shooting a man during a robbery. The sentence was vacated by the United States Court of Appeals for the Sixth Circuit because it was unclear whether the district court properly used one of Hinojosa’s prior convictions to calculate his guidelines range. The court could only rely on this prior conviction if it resulted in Hinojosa’s incarceration during any time in the 15 years before he committed his current offenses.On remand, the government presented additional evidence about Hinojosa’s criminal history. The district court found that the prior conviction met the guideline’s standards for inclusion in the criminal history score. This resulted in a guidelines range of 120 to 150 months for his robbery and felon-in-possession offenses, plus a consecutive 120-month minimum sentence for discharging a firearm during a crime of violence. The district court reimposed the same 240-month sentence.The United States Court of Appeals for the Sixth Circuit reviewed the case and held that the “but for” causal connection between the prior conviction and the extra incarceration satisfied the guideline’s “resulted in” language. The court also found that the district court reasonably sentenced Hinojosa to 240 months due to his history of violence. The Sixth Circuit affirmed the sentence, rejecting Hinojosa’s procedural and substantive challenges. The court concluded that the district court properly calculated the guidelines range and reasonably balanced the sentencing factors, including the seriousness of the offense and Hinojosa’s history of violent behavior. View "United States v. Hinojosa" on Justia Law

In this case, Kelli Prather was convicted by a jury of bank fraud, wire fraud, aggravated identity theft, and making a false statement on a loan application. The charges stemmed from her fraudulent applications for Paycheck Protection Program (PPP) and Economic Injury Disaster Loan (EIDL) funds under the CARES Act, which were intended to provide financial relief during the COVID-19 pandemic. Prather submitted multiple fraudulent loan applications for non-operational businesses and used the identity of her mentally disabled nephew, D.P., to apply for additional loans.The United States District Court for the Southern District of Ohio sentenced Prather to 84 months in prison. Prather appealed her conviction and sentence, arguing insufficient evidence for her aggravated identity theft conviction, improper admission of certain testimonies, and errors in the jury instructions and sentencing enhancements.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found that there was ample evidence to support Prather's aggravated identity theft conviction, including testimony that D.P. did not understand the loan application process and that Prather used his identity without lawful authority. The court also determined that the testimonies of Special Agent Reier and Prather's ex-fiancé, Darrell Willis, did not constitute plain error and were cumulative of other evidence presented at trial.Regarding the jury instructions, the court held that the district court correctly informed the jury that Prather did not need to know the interstate nature of her acts to be convicted of wire fraud. Finally, the court upheld the district court's application of the vulnerable victim enhancement, finding that D.P. was indeed a victim of Prather's fraudulent scheme.The Sixth Circuit affirmed Prather's conviction and sentence, concluding that there were no reversible errors in the district court's proceedings. View "United States v. Prather" on Justia Law

Jermaine Kimbrough pleaded guilty in 2022 to four criminal offenses related to carjacking and firearms. At sentencing, the district court determined that Kimbrough had three prior violent felonies committed on different occasions, making him subject to an enhanced sentence under the Armed Career Criminal Act (ACCA). This enhancement increased his statutory penalty range for being a felon in possession of a firearm from a maximum of 10 years to a minimum of 15 years.The district court, following then-controlling Sixth Circuit precedent, decided that Kimbrough's two 2016 aggravated burglary offenses occurred on different occasions, thus applying the ACCA enhancement. Kimbrough objected, arguing that a jury should make this determination. The district court overruled his objection and sentenced him to 148 months for Counts One, Two, and Four, to be served concurrently, and 84 months for Count Three, to be served consecutively.The United States Court of Appeals for the Sixth Circuit reviewed the case. The Supreme Court's decision in Erlinger v. United States established that it is an error for a judge, rather than a jury, to determine whether prior offenses occurred on different occasions for ACCA purposes. The Sixth Circuit found that this error was not harmless in Kimbrough's case. The court noted that a reasonable jury could find that Kimbrough's two 2016 burglaries were part of a single criminal event, given their close proximity and similar nature.The Sixth Circuit vacated Kimbrough's sentence on Counts One, Two, and Four and remanded for further proceedings consistent with its opinion. The court also noted that the sentence for Count One exceeded the statutory maximum and must be corrected on remand. Additionally, the court left Kimbrough's Double Jeopardy argument for the district court to address if the government seeks an ACCA-enhanced sentence on remand. View "United States v. Kimbrough" on Justia Law

Federal and local law enforcement officers in Toledo, Ohio, uncovered a large-scale drug distribution scheme involving cocaine, cocaine base, and fentanyl. Christopher Simpson, Marquise Figures, and Antuan Wynn were charged with various federal crimes related to this scheme. They were tried together, and the jury found them guilty on all charges except one against Wynn.The United States District Court for the Northern District of Ohio sentenced Simpson to 300 months, Wynn to 224 months, and Figures to 70 months. All three defendants appealed their convictions and sentences.The United States Court of Appeals for the Sixth Circuit reviewed the case. Simpson challenged the seizure and search of a vehicle, arguing Fourth Amendment violations, but the court found the actions lawful. Simpson also contested his sentence, particularly the drug quantity calculation and an obstruction of justice enhancement, but the court upheld the district court's findings.Figures argued that evidence from a traffic stop was improperly admitted and that there was insufficient evidence for his conspiracy conviction. The court found the evidence intrinsic to the charged conspiracy and sufficient to support the conviction. Figures also challenged his sentence, but the court found no error in the drug quantity calculation or the denial of a minor participant reduction.Wynn contended there was a variance between the indictment and the trial evidence, but the court found no prejudicial variance. He also challenged a jury instruction and the admission of pre-conspiracy evidence, but the court found no error. Wynn's sentence challenges, including the drug quantity calculation and enhancements for firearm possession and maintaining a drug premises, were also rejected.The Sixth Circuit affirmed the judgments of the district court for all three defendants. View "United States v. Simpson" on Justia Law

Malgum Whiteside, Jr. was charged with being a felon in possession of firearms after police found the weapons during a search of his residence. The search was conducted while officers were looking for evidence related to stalking charges against Whiteside. Whiteside moved to suppress the firearms, arguing that the search warrant was invalid and no warrant exception applied. The district court denied the motion, and Whiteside pleaded guilty while reserving the right to appeal the suppression ruling.The United States District Court for the Western District of Michigan denied Whiteside's motion to suppress, finding that the warrant was valid despite the judge not signing the warrant itself, only the affidavit. The court also found that there was a sufficient nexus between the place to be searched and the evidence sought. Additionally, the court ruled that even if the warrant was invalid, the good-faith exception to the warrant requirement would apply, and the firearms were in plain view.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The Sixth Circuit held that the warrant was validly issued despite the lack of a signature on the warrant itself, as there was clear and contemporaneous evidence that the judge made the necessary probable cause determination. The court also found that the warrant affidavit established a sufficient nexus between Whiteside's residence and the evidence of stalking. Furthermore, the court concluded that the plain-view doctrine applied to the seizure of the firearms, as the incriminating character of the firearms was immediately apparent to the officers, who knew Whiteside was a felon. Therefore, the seizure of the firearms was valid, and the district court's denial of the motion to suppress was affirmed. View "United States v. Whiteside" on Justia Law

Freddie Knipp, Jr. was convicted of two counts of distributing methamphetamine and one count of knowingly selling a firearm to a felon. The convictions stemmed from controlled drug buys and a firearm purchase facilitated by law enforcement, with Knipp selling methamphetamine to Larry Eldridge and purchasing a firearm for him, knowing Eldridge was a felon. Eldridge cooperated with law enforcement, leading to Knipp's arrest and subsequent trial.The United States District Court for the Eastern District of Kentucky denied Knipp's motion to dismiss the firearm charge, which he argued violated the Second Amendment. Knipp was found guilty on all counts by a jury and sentenced to 138 months in prison for the drug charges and 120 months for the firearm charge, to be served concurrently.The United States Court of Appeals for the Sixth Circuit reviewed the case. Knipp challenged the constitutionality of 18 U.S.C. § 922(d)(1), which prohibits selling firearms to felons, arguing it violated the Second Amendment. The court applied the two-step framework from N.Y. State Rifle & Pistol Ass’n, Inc. v. Bruen and found that while the Second Amendment covers the right to acquire firearms, historical precedent supports disarming dangerous individuals, including felons. Thus, the court upheld the statute's constitutionality.Knipp also contested the admission of Eldridge's testimony about prior drug transactions, arguing it was impermissible propensity evidence. The court found any potential error in admitting this evidence to be harmless, given the substantial other evidence of Knipp's guilt.Finally, Knipp argued that the district court erred in calculating his sentence by including drug quantities from prior transactions based on Eldridge's testimony. The appellate court found no clear error in the district court's credibility determination and upheld the sentence.The Sixth Circuit affirmed Knipp's conviction and sentence. View "United States v. Knipp" on Justia Law

In September 2020, Jesse Fairley was observed by law enforcement conducting hand-to-hand drug transactions in a convenience store parking lot. When officers approached and searched the vehicle Fairley had been using, they found crack cocaine, marijuana, cash, and two loaded firearms. Fairley was charged and convicted of possessing with intent to distribute crack cocaine, being a felon in possession of firearms, and possessing a firearm in furtherance of a drug trafficking crime. He received a thirty-year sentence and appealed his conviction.The United States District Court for the Northern District of Ohio denied Fairley's motions for acquittal, finding sufficient evidence for the jury to convict him. Fairley raised five issues on appeal, including the sufficiency of the evidence, the jury instructions on third-party guilt, the cumulative effect of evidentiary rulings, alleged improper communications with a defense witness, and improper closing remarks by the prosecution.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the lower court's decision. The court found that there was substantial evidence to support Fairley's convictions, including his proximity to the drugs and firearms, his observed drug transactions, and his evasive behavior. The court also determined that the jury instructions were not misleading, the evidentiary rulings were within the court's discretion, and there was no substantial interference with the witness's decision to testify. Additionally, the court found that the prosecution's closing remarks did not constitute plain error or prosecutorial misconduct. View "United States v. Fairley" on Justia Law

Larry Householder, former Speaker of the Ohio House of Representatives, and lobbyist Matthew Borges were convicted of conspiring to solicit and receive nearly $60 million in exchange for passing a billion-dollar bailout for a failing nuclear energy company, FirstEnergy Corp. Householder used the funds to support his bid for the speakership and to recruit candidates who would vote for him. Borges played a role in the conspiracy by attempting to disrupt a referendum campaign against the bailout legislation.The United States District Court for the Southern District of Ohio at Cincinnati found both Householder and Borges guilty after a 26-day trial. Householder was convicted of multiple counts, including public-official bribery, private-citizen bribery, and money laundering. Borges was also found guilty of participating in the conspiracy.The United States Court of Appeals for the Sixth Circuit reviewed the case and found no reversible error, affirming the convictions. The court held that the evidence was sufficient to support the jury's findings that Householder and Borges engaged in a quid pro quo arrangement with FirstEnergy. The court also upheld the jury instructions, finding them consistent with applicable law, and rejected Householder's claims of insufficient evidence, right to counsel violations, and judicial bias. Additionally, the court found that the district court did not abuse its discretion in its evidentiary rulings or in admitting the guilty pleas of co-conspirators.Householder's sentence of twenty years, the statutory maximum under RICO, was deemed procedurally and substantively reasonable. The court emphasized the magnitude and severity of Householder's offense, referring to it as the "biggest corruption case in Ohio's history." Borges's arguments regarding the sufficiency of the evidence and the district court's evidentiary rulings were also rejected, and his conviction was affirmed. View "United States v. Householder" on Justia Law

In 2014, federal law enforcement began investigating a website known as "Playpen," used to distribute child pornography. The Department of Justice obtained a warrant to reveal the IP addresses of Playpen users, leading to the identification of Eric Schuster in Ohio. A search of Schuster's residence uncovered multiple devices containing thousands of images and videos of child pornography. In May 2016, Schuster was indicted on three felony child pornography counts and detained pretrial.The case experienced significant delays in the district court. Initially, Schuster requested several continuances to review discovery and prepare motions. Over the next three years, Schuster's litigation conduct, including filing and withdrawing motions and requesting new counsel, contributed to the delays. In April 2019, Schuster's motions were fully briefed, but the district court took no action for twenty months. In December 2020, Schuster requested a status conference, and the court stayed proceedings for additional discovery. Another eighteen months passed without action on Schuster's motions.Schuster moved to dismiss his indictment in August 2022, arguing the delay violated his Sixth Amendment right to a speedy trial. The district court initially denied the motion but later reconsidered and dismissed the indictment with prejudice, finding the delay attributable to the court and the impact of incarceration during the COVID-19 pandemic.The United States Court of Appeals for the Sixth Circuit reviewed the case and applied the Barker v. Wingo factors. The court found that Schuster was responsible for much of the delay and failed to assert his right to a speedy trial in a timely and consistent manner. Additionally, Schuster did not demonstrate substantial prejudice resulting from the delay. The court concluded that Schuster's Sixth Amendment right was not violated and reversed the district court's decision, allowing the prosecution to proceed. View "United States v. Schuster" on Justia Law

Amaury Villa participated in two significant burglaries in 2011, stealing $61 million worth of pharmaceuticals from an Eli Lilly warehouse in Connecticut and $1.5 million worth of cigarettes from a warehouse in Kentucky. He was indicted by federal grand juries in Florida, Connecticut, and Kentucky. Villa pled guilty in the Florida and Connecticut cases, receiving concurrent prison terms of 140 and 98 months, respectively. In January 2016, Kentucky prosecutor Joshua Judd emailed Villa’s attorney, Donald Meier, a proposed plea agreement that did not mention concurrent sentencing. Villa later pled guilty without a plea agreement and was sentenced to 77 months, to be served consecutively.Villa moved to set aside his Kentucky sentence under 28 U.S.C. § 2255 in January 2019, claiming ineffective assistance of counsel. He later sought to amend his motion to add a claim that Meier failed to inform him of a potential cooperation agreement. The district court initially denied the motion as untimely. On appeal, the Sixth Circuit remanded for an evidentiary hearing on the timeliness of the claim. The district court found the claim timely but denied it on the merits.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s decision. The court found that Judd’s January 21 email did not constitute a formal plea offer but was an invitation to negotiate. The court also found that Meier had informed Villa of the January 9 plea offer, which was discussed at Villa’s change-of-plea hearing. The court concluded that Meier’s performance was not deficient and that Villa himself impeded further negotiations by refusing to provide additional information about his co-conspirator. The district court’s judgment denying Villa’s motion to vacate, set aside, or correct his sentence was affirmed. View "Villa v. United States" on Justia Law