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

A man was convicted by a Michigan state jury for delivering oxycodone to a friend, resulting in her death from a drug overdose. The evidence showed that the man and the deceased had a longstanding relationship, and after her release from jail, he purchased 40 Percocet pills—containing oxycodone and acetaminophen—and spent time with her at a hotel where she died. Medical experts found oxycodone in her blood and acetaminophen in her urine, both components of Percocet, and testified that oxycodone was a substantial factor in causing her death.After his conviction, the defendant sought a new trial in the Michigan courts, arguing that his trial counsel was ineffective for two reasons: failing to investigate an “acetaminophen-based” defense (that the absence of acetaminophen in the blood meant the deceased had not consumed Percocet), and failing to call an expert witness to challenge the prosecution’s case on causation. The trial court held a hearing and ultimately rejected these claims. The Michigan Court of Appeals affirmed, and the Michigan Supreme Court denied further review.The United States District Court for the Eastern District of Michigan then denied the defendant’s petition for habeas corpus, and the case was appealed to the United States Court of Appeals for the Sixth Circuit. The Sixth Circuit held that, under the highly deferential standards of the Antiterrorism and Effective Death Penalty Act (AEDPA), the state courts did not unreasonably apply clearly established Supreme Court law or make unreasonable determinations of fact in rejecting the ineffective assistance claims. The court further held that counsel’s strategic decisions were not objectively unreasonable and that the alleged failures did not prejudice the outcome of the trial. The Sixth Circuit affirmed the denial of habeas relief. View "DeBruyn v. Douglas" on Justia Law

In this case, the petitioner was convicted and sentenced to death for the murder and robbery of two men in a Kentucky convenience store in 1987. After being identified as a suspect, he confessed to the crimes but later asserted an insanity defense at trial. His mental health was evaluated by state experts, who found him competent and not suffering from a mental illness that would have excused his conduct. At trial, the defense presented testimony from the petitioner and a psychologist, but the jury found him guilty on all counts and recommended the death penalty. The penalty phase included limited mitigation evidence and testimony.Following his conviction and sentencing, the petitioner pursued direct appeals and post-conviction relief in Kentucky state courts, including before the Kentucky Supreme Court, and sought certiorari from the United States Supreme Court, which was denied multiple times. He then filed a federal habeas corpus petition in the United States District Court for the Eastern District of Kentucky, asserting several constitutional claims, including ineffective assistance of counsel, improper jury instructions on the insanity defense, and cumulative error. The district court denied relief, but granted certificates of appealability on several issues.On appeal, the United States Court of Appeals for the Sixth Circuit first held that the Antiterrorism and Effective Death Penalty Act (AEDPA) is constitutional, rejecting the argument that it unconstitutionally restricts federal habeas review. Applying AEDPA deference, the court found that the Kentucky Supreme Court’s decisions regarding the jury instructions and most of the ineffective assistance of counsel claims were neither contrary to nor unreasonable applications of clearly established federal law. Claims not subject to AEDPA deference failed under de novo review because the petitioner could not show prejudice. The cumulative error claim was found to be procedurally defaulted. Accordingly, the Sixth Circuit affirmed the denial of the habeas petition in full. View "Sanders v. Plappert" on Justia Law

Federal and local law enforcement investigated an individual as part of a drug trafficking organization operating in Tennessee. Over ten months, agents used various investigative techniques, including wiretaps, confidential informants, controlled narcotics buys, and electronic surveillance. Based on the evidence, a grand jury indicted the defendant on multiple counts, including conspiracy to distribute cocaine and heroin, drug distribution, money laundering, and related offenses. The defendant was arrested at his home, questioned by agents, and, after receiving Miranda warnings, confessed to involvement in drug trafficking. Agents also seized and searched his cellphones with his verbal and written consent.Before trial in the United States District Court for the Middle District of Tennessee, the defendant filed motions to suppress his post-arrest statements and evidence from the cellphone searches, arguing violations of his Fifth, Sixth, and Fourth Amendment rights. The district court denied these motions after evidentiary hearings. At trial, a jury convicted the defendant on all counts, and the district court imposed a prison sentence and supervised release.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the denial of the suppression motions. The appellate court held that the defendant’s post-Miranda confession was not coerced, the warnings given reasonably conveyed his rights, and even if there were deficiencies, any error was harmless due to overwhelming other evidence of guilt. The court further found that the defendant voluntarily consented to the cellphone searches, and there was no Fourth Amendment violation. The court noted that no evidence from the cellphones was introduced at trial. Accordingly, the Sixth Circuit affirmed the district court’s denial of the suppression motions and upheld the convictions. View "United States v. Magallon Guerrero" on Justia Law

The defendant was previously convicted under Florida law for lewd and lascivious battery and transmission of harmful materials to a minor. After relocating from Florida to Tennessee in 2023, she knowingly failed to register as a sex offender in Tennessee and to notify Florida of her move, as required by federal law. She pleaded guilty to failure to register as a sex offender under 18 U.S.C. § 2250(a). The probation office classified her as a Tier II sex offender under the Sex Offender Registration and Notification Act (SORNA), which affected her sentencing guidelines.The United States District Court for the Eastern District of Tennessee overruled her objection to the Tier II classification and sentenced her to 24 months of imprisonment followed by twenty years of supervised release. The calculated guidelines range for supervised release was five years, but the district court imposed a sentence significantly above this recommendation. The defendant subsequently appealed the classification and the length of her supervised release.The United States Court of Appeals for the Sixth Circuit reviewed the case. It held that the district court erred in classifying the defendant as a Tier II sex offender. Applying the categorical approach, the appellate court determined that Florida’s lewd and lascivious battery statute does not require knowledge of the victim’s age, while the federal comparator offense under 18 U.S.C. § 2422(b) does require such knowledge. Therefore, the state offense was not “comparable to or more severe than” the Tier II offense, and the defendant should have been classified as a Tier I offender. The appellate court also found that the district court procedurally erred in imposing a twenty-year term of supervised release based on a misunderstanding of the applicable guidelines. As a result, the Sixth Circuit reversed the SORNA classification ruling, vacated the supervised release sentence, and remanded for resentencing. View "United States v. Buddi" on Justia Law

Dr. Lawrence Sherman, a physician, was employed one day per week at Tranquility Wellness Center in Southeastern Michigan, a clinic operated by individuals later convicted for their roles in an illegal prescription scheme. The clinic accepted only cash, did not bill insurance, and routinely provided opioid prescriptions, often based on questionable or fake medical records. Dr. Sherman prescribed large quantities of Schedule II controlled substances, sometimes without adequate patient evaluation or verification of medical histories, and was paid per prescription. After an investigation, Sherman was indicted for conspiracy to possess with intent to distribute and to distribute controlled substances, along with multiple counts of unlawful distribution.In the United States District Court for the Eastern District of Michigan, Sherman went to trial while his co-defendants pleaded guilty and testified against him. The jury found Sherman guilty on all counts, and he was sentenced to 144 months in prison. Sherman subsequently moved for a judgment of acquittal and a new trial, both of which the district court denied.The United States Court of Appeals for the Sixth Circuit reviewed Sherman’s conviction and the denial of his post-trial motions. The court held that sufficient evidence supported the convictions, as a rational jury could find Sherman knowingly issued unauthorized prescriptions based on circumstantial evidence, including expert testimony on deviations from standard medical practice. The appellate court also found no reversible error in the district court’s jury instructions, evidentiary rulings, admission of summary charts, or handling of alleged judicial bias. Any errors identified were deemed harmless in light of overwhelming evidence. The court affirmed both Sherman’s conviction and the denial of his motion for a new trial. View "United States v. Sherman" on Justia Law

Three individuals were prosecuted for their roles in a murder-for-hire scheme that resulted in the deaths of Holly Williams and William Lanway in Nashville. After one of the defendants, Maund, was blackmailed by Lanway following an affair with Williams, he hired Peled to address the situation. Peled then recruited Brockway, Carey, and others to surveil the victims, ultimately leading to their murders in March 2020. Substantial evidence was presented at trial, including recorded conversations, testimony from co-conspirators, financial records, and surveillance footage linking the defendants to the crimes.The United States District Court for the Middle District of Tennessee presided over the joint trial. The jury convicted all three defendants on various counts, including murder-for-hire conspiracy, and convicted Brockway and Carey on kidnapping-related charges. After the verdict, the district court discovered a critical error: the jury had received ten unadmitted exhibits—including recordings and transcripts not presented at trial—and had not received three admitted exhibits. Notably, among the unadmitted exhibits were statements concerning Carey’s knowledge of the crimes that had been excluded at trial. Following a post-verdict hearing, the district court concluded that this error was structural and required a new trial for all defendants, reasoning that the effects of the error were too difficult to measure.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s grant of a new trial. The appellate court held that the erroneous jury exposure to unadmitted exhibits was not a structural error and was subject to harmless-error analysis. Applying the strictest harmless-error standard, the court found the error harmless beyond a reasonable doubt given the overwhelming evidence of guilt and the minimal prejudice to the defendants. The Sixth Circuit reversed the district court’s order granting a new trial and remanded for further proceedings. View "United States v. Maund" on Justia Law

The defendant, while on supervised release following a federal conviction for being a felon in possession of a firearm, was arrested in May 2023 for new state charges involving drug trafficking, possession of marijuana and drug paraphernalia, and being a felon in possession of a handgun. These events occurred after violations that led to his second supervised release revocation but before the hearing for those violations, and were not discovered by the federal probation office until several months later. Upon learning of the May 2023 incident, after the defendant had completed his sentence and was again on supervised release, the probation office initiated the proceedings at issue, seeking a third revocation based on the new conduct.The United States District Court for the Eastern District of Kentucky held a hearing to determine if the defendant could knowingly and voluntarily waive his right to counsel in the revocation proceeding, ultimately allowing him to represent himself. After a subsequent hearing, the district court found violations of supervised release, classified the new conduct as a Grade A violation, and imposed a 24-month term of imprisonment, the statutory maximum. The defendant timely appealed, challenging the validity of his waiver of counsel, the sentencing procedure, and the constitutionality of his underlying conviction.The United States Court of Appeals for the Sixth Circuit reviewed the case. It held that the right to counsel in a supervised release revocation is not derived from the Sixth Amendment but is governed by statutory and due process considerations. The court reviewed the waiver of counsel for abuse of discretion and found the district court’s inquiry sufficient under the totality of the circumstances. The court also found no procedural error in sentencing, concluding that the district court did not improperly rely on prohibited factors. Finally, the court declined to consider the challenge to the underlying conviction, holding that such arguments must be raised on direct appeal or collateral review. The Sixth Circuit affirmed the district court’s judgment. View "United States v. Spence" on Justia Law

Federal and state authorities initially suspected Luz Jiminez of involvement in a drug-trafficking organization based in Phoenix, Arizona. Investigators obtained a wiretap order to intercept communications from Jiminez and her associates. Through intercepted calls, they learned Jiminez planned to pick up luggage for someone named “Rondo,” later identified as Liggins. Using a “check and miss” scheme, Liggins sent a bag containing nearly $37,000 from Detroit to Phoenix, which Jiminez retrieved but abandoned after noticing surveillance. A police dog alerted to drugs, and a warrant led to the discovery of the money. Separately, Detroit authorities arrested DeHaven Murphy, who possessed heroin and later implicated Liggins. Murphy arranged recorded calls with Liggins, but Detroit officers testified their investigation was independent of the Arizona wiretap.The United States District Court for the Eastern District of Michigan presided over Liggins’s trial, where a jury convicted him on drug charges. The United States Court of Appeals for the Sixth Circuit vacated the conviction due to judicial bias and remanded for a new trial. On remand, Liggins moved to suppress evidence derived from the Arizona wiretap, arguing violations of federal wiretap laws. The district court denied the motion, finding Liggins lacked standing as an “aggrieved person” under Title III and that the Detroit evidence was untainted by the Arizona wiretap. Liggins entered a conditional guilty plea to preserve his right to appeal.The United States Court of Appeals for the Sixth Circuit reviewed whether Liggins qualified as an “aggrieved person” entitled to move for suppression under Title III. The court held that regardless of the interpretation, Liggins was not an “aggrieved person”: he did not participate in intercepted calls, the calls did not use his property, and he was not named or targeted in the wiretap application. The court affirmed the district court’s denial of the motion to suppress. View "United States v. Liggins" on Justia Law

The defendant participated in the robbery of a business known as Cash Express, which offers check cashing, short-term loans, and related financial services. With assistance from his then-girlfriend, the defendant orchestrated the robbery, during which he physically restrained the clerk, brandished a firearm, and escaped with $2,680. Shortly after his arrest, the defendant pleaded guilty to Hobbs Act robbery as part of a plea agreement. Eleven days after signing the agreement, an image implying retaliation against informants was posted on his Facebook profile, which became relevant at sentencing.The United States District Court for the Eastern District of Tennessee sentenced the defendant. The court applied several sentence enhancements: it determined Cash Express was a "financial institution" under the Sentencing Guidelines, imposed a leadership role enhancement, and declined to grant a reduction for acceptance of responsibility due to the defendant's conduct after the plea. The court rejected certain enhancements related to obstruction of justice and reckless endangerment, resulting in a Guidelines range of 151 to 188 months, and sentenced the defendant to 188 months' imprisonment. The defendant appealed, challenging the application of the financial institution and leadership enhancements, the denial of the acceptance of responsibility reduction, and the reasonableness of his sentence.The United States Court of Appeals for the Sixth Circuit reviewed the case. It held that Cash Express qualifies as a "financial institution" under the plain meaning of the term in the Guidelines, affirmed the district court's finding that the defendant acted in a leadership role, and upheld the denial of the acceptance of responsibility reduction due to conduct inconsistent with remorse. The court also found that the sentence was procedurally and substantively reasonable and that the government did not breach the plea agreement. The judgment of the district court was affirmed. View "United States v. Glover" on Justia Law

The case centers on an individual who immigrated to the United States and became involved in a transnational drug trafficking and money laundering conspiracy. His role was to travel across the country collecting large sums of drug proceeds, which he then laundered through a business that purchased used cell phones. These phones were sent to a contact in China as payment for precursor chemicals vital to the drug operation. During one such trip, law enforcement observed him receiving nearly $200,000 in cash and, upon stopping his vehicle, discovered an unloaded firearm and loaded magazine in the van. He admitted to bringing the gun for protection due to the large sums of money he was transporting.He was convicted of money laundering and conspiracy to launder money in the United States District Court for the Eastern District of Kentucky, receiving a 90-month prison sentence and three years of supervised release. His conviction and sentence were affirmed on appeal. While his appeal was pending, the U.S. Sentencing Commission amended the Guidelines to allow certain first-time offenders a two-level reduction in offense level, with exceptions including possession of a firearm “in connection with” the offense. He moved for a sentence reduction under the new provision, but the district court denied the request, finding his possession of the firearm during the offense made him ineligible.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial. The appellate court held that the “in connection with” language should be interpreted broadly and that the close proximity of the firearm to the drug proceeds, along with the defendant’s own admission that the gun was for protection during his criminal activity, established the necessary nexus. The court affirmed the district court’s decision, finding no error in deeming him ineligible for the reduced sentence. View "United States v. Tajwar" on Justia Law