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

Daniel Jackson was stopped by sheriff’s deputies in Kentucky after they observed his truck with an obscured license plate and learned he was driving without a valid license or registration. After arresting Jackson, deputies searched his truck and found methamphetamine, marijuana, syringes, and digital scales. A subsequent search of the police cruiser’s back seat, where Jackson had been placed, revealed a bag containing fentanyl. Jackson was charged with possession of fentanyl and methamphetamine with intent to distribute.The United States District Court for the Eastern District of Kentucky presided over Jackson’s trial. At trial, Jackson testified that he had been framed by a deputy who allegedly planted the drugs in both his truck and the police cruiser. The jury rejected Jackson’s account and convicted him. At sentencing, the district court found that Jackson’s testimony constituted perjury and applied a two-level obstruction-of-justice enhancement under the Sentencing Guidelines. The court also imposed a five-year term of supervised release, including a condition permitting searches of Jackson’s electronic devices by the probation office. Jackson did not object to this condition at sentencing.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed Jackson’s challenges to both the obstruction-of-justice enhancement and the supervised-release search condition. The court held that the district court’s findings of perjury—falsity, willfulness, and materiality—were not clearly erroneous and that the enhancement was mandatory under the Guidelines. The appellate court also found no plain error in the imposition or explanation of the electronic-device search condition, given the district court’s stated concerns about officer safety and recidivism. Accordingly, the Sixth Circuit affirmed the judgment of the district court. View "United States v. Jackson" on Justia Law

After being released from federal prison, an individual began a term of supervised release that required him to comply with several conditions, including avoiding new criminal conduct, truthfully answering his probation officer’s questions, and participating in mental health and substance abuse treatment programs. Within two months, the probation office alleged that he violated four conditions: failing to enroll in required treatment, lying to his probation officer about receiving services, missing a scheduled drug test, and committing a new state misdemeanor offense involving assault and stalking.The United States District Court for the Eastern District of Tennessee held a revocation hearing. The individual admitted to three of the violations—lying to his probation officer, failing to enroll in treatment, and missing the drug test—and contested only the allegation that he committed a new state crime. After hearing testimony and reviewing evidence, the district court found by a preponderance of the evidence that he had committed the misdemeanor, in addition to the three admitted violations. The court revoked his supervised release and imposed a 14-month prison sentence, at the top of the applicable guidelines range. The individual appealed, challenging only the finding that he committed the new state offense.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s factual findings for clear error. The appellate court concluded that even if the district court erred in finding the new state offense, any such error was harmless because the three uncontested violations independently justified revocation and the sentence imposed. The court held that a single violation is sufficient to support revocation, and the guidelines range and sentence would have been the same regardless of the contested finding. Accordingly, the Sixth Circuit affirmed the district court’s judgment. View "United States v. Kidd" on Justia Law

In this case, the defendant was found in possession of a firearm after having previously been convicted of multiple felonies, including several burglaries. When law enforcement approached his girlfriend’s home, he cooperated and led them to a pistol hidden in the woods, which bore his fingerprints. He was indicted on one count of being a felon in possession of a firearm. The presentence report listed twenty-two prior felony convictions, eleven of which were for burglary, with the offenses occurring over several years and involving different victims.The United States District Court for the Eastern District of Tennessee accepted the defendant’s guilty plea. At sentencing, the court determined, based on the presentence report, that the defendant qualified as an Armed Career Criminal under the Armed Career Criminal Act (ACCA), which mandates a minimum sentence for those with three prior violent felony convictions committed on different occasions. The court imposed a 180-month sentence. The defendant did not object to the factual accuracy of the presentence report but later challenged the application of the ACCA enhancement, arguing that the determination of whether his prior offenses were committed on different occasions should have been made by a jury, as clarified by the Supreme Court in Erlinger v. United States.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the failure to submit the “different occasions” question to a jury was not structural error and that, under harmless error review, no reasonable jury could have found that the defendant’s predicate burglaries occurred on the same occasion, given the significant gaps in time and different victims. The court also rejected the defendant’s double jeopardy argument, finding no plain error. The Sixth Circuit affirmed the enhanced sentence under the ACCA. View "United States v. Ballinger" on Justia Law

Timothy Baker, a registered sex offender, was in a relationship with Shaelyn Fann and expressed sexual interest in Fann’s eleven-year-old daughter, S.H. Over several months, Baker and Fann groomed S.H. for sexual activity, with Fann sending Baker sexually explicit photographs of S.H. at his request. Baker provided detailed instructions to Fann on how to obtain these images and discussed plans to sexually abuse S.H. Law enforcement discovered Baker’s activities while investigating him for another alleged sexual assault involving a minor.A grand jury in the United States District Court for the Western District of Michigan indicted Baker on three counts: conspiracy to sexually exploit a minor, coercion and enticement of a minor, and committing these offenses while required to register as a sex offender. The indictment also alleged that Baker had two prior convictions for sexually exploiting minors under Michigan law. Before trial, Baker moved to strike the sentencing enhancement based on his prior convictions, arguing they were juvenile adjudications, not convictions. He also sought to sever the count related to his sex offender status and to exclude testimony from two other minors, L.H. and I.B., who alleged prior sexual assaults by Baker. The district court denied all these motions, admitted the testimony under Federal Rule of Evidence 413, and the jury convicted Baker on all counts. The court imposed a total sentence of 600 months’ imprisonment.On appeal, the United States Court of Appeals for the Sixth Circuit held that Baker’s prior Michigan offenses constituted convictions under federal law, supporting the enhanced sentence. The court also found that cumulative punishments under 18 U.S.C. §§ 2251(e) and 2260A did not violate the Double Jeopardy Clause, as Congress clearly intended such cumulative sentences. Finally, the court concluded that the district court did not abuse its discretion in admitting the testimony of L.H. and I.B. The Sixth Circuit affirmed the district court’s judgment. View "United States v. Baker" on Justia Law

The case concerns an individual who was sentenced in 2006 to a term of imprisonment and supervised release for drug trafficking offenses. After his initial release, his supervised release was revoked due to a new drug offense, resulting in additional imprisonment and a new term of supervised release. While incarcerated, he sought to earn and apply time credits under the First Step Act, arguing that the Bureau of Prisons (BOP) unlawfully denied him these credits despite his eligibility.The United States District Court for the Northern District of Ohio reviewed his habeas corpus petition under 28 U.S.C. § 2241. The warden moved to dismiss, contending that the petitioner had not exhausted administrative remedies and was ineligible for time credits due to a disqualifying offense. The district court agreed, finding both a failure to exhaust and statutory ineligibility, and denied the petition. The petitioner appealed to the United States Court of Appeals for the Sixth Circuit. While the appeal was pending, he was released from BOP custody and began serving his supervised release.The United States Court of Appeals for the Sixth Circuit addressed whether First Step Act time credits could be used to reduce a term of supervised release, as opposed to only reducing a term of imprisonment. The court held that such credits may only be applied to reduce a prison term, not a supervised-release term. Because the petitioner was no longer incarcerated and the credits could not affect his supervised release, the court determined that the case was moot and dismissed the appeal. The court did not address other arguments regarding exhaustion or the merits of the underlying claim. View "Hargrove v. Healy" on Justia Law

Between 1994 and 2018, the defendant sexually abused three boys, beginning with C.C. in 1994, followed by B.A. around 2005–06, and J.G. in 2017. The abuse included interstate travel with C.C., during which the defendant filmed some of the acts, and the creation of sexually explicit images and videos of all three victims. In 2021, law enforcement recovered thumb drives containing thousands of images of child pornography, including depictions of the three boys. The defendant was indicted on five federal counts: transportation of a minor for criminal sexual activity, two counts of child exploitation, possession of child pornography, and committing sexual exploitation while a registered sex offender.The United States District Court for the Eastern District of Tennessee denied the defendant’s pretrial motion to dismiss the first three counts, rejecting arguments that Count One was time-barred and that the indictment was insufficient. After the defendant waived his right to a jury trial, the court convicted him on all counts and sentenced him to life plus ten years’ imprisonment. The defendant appealed, challenging the statute of limitations, the sufficiency of the indictment, the sufficiency of the evidence, and the application of a sentencing enhancement based on prior convictions.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s judgment. The court held that the extended statute of limitations in 18 U.S.C. § 3283 applied to Count One, making the prosecution timely. It found the indictment sufficient for all challenged counts, concluded that the evidence was sufficient to support each conviction, and upheld the sentencing enhancement, determining that the defendant’s prior Tennessee convictions related to the sexual exploitation of children as required by federal law. The court affirmed the conviction and sentence in all respects. View "United States v. Deakins" on Justia Law

Federal agents began investigating an individual due to his connections with a known drug dealer. Over several months, agents conducted multiple controlled purchases of fentanyl and cocaine from him, using an undercover officer. During the final controlled buy, agents tracked the individual’s cell phone to a specific residence, observed him leave that house, conduct the drug sale, and return immediately afterward. Based on these observations, agents obtained a search warrant for the residence, where they found large quantities of drugs, cash, firearms, and drug paraphernalia. The individual and his aunt were present during the search.A grand jury indicted the individual on multiple drug and firearm charges. He moved to suppress the evidence obtained from the search, arguing that the warrant lacked probable cause. The United States District Court for the Northern District of Ohio denied the suppression motion. The defendant then pleaded guilty to several counts but reserved his right to appeal the suppression ruling. At sentencing, the district court applied a two-level enhancement for maintaining a premises for drug distribution, resulting in a 106-month prison sentence.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the search warrant was supported by probable cause, relying on precedent that observing a suspect leave a residence, conduct a drug sale, and return provides a sufficient nexus to justify a search. The court also upheld the sentencing enhancement, finding no clear error in the district court’s determination that the defendant exercised de facto control over the premises, given the evidence found and his admitted possession of the contraband. The Sixth Circuit affirmed the district court’s rulings in all respects. View "United States v. Florence" on Justia Law

In early 2021, United States postal inspectors in Cleveland became suspicious of two packages sent between Ohio and California, both exhibiting characteristics commonly associated with drug trafficking, such as high cash-paid postage, mismatched sender and recipient information, and declined delivery signatures. After a certified narcotics detection dog named Ciga alerted to both packages, inspectors obtained search warrants and discovered a large sum of cash in one package and over a kilogram of fentanyl in the other. Subsequent investigation and a sting operation led to the arrest of Jaavaid McCarley-Connin, who was indicted on federal drug and firearm charges.The United States District Court for the Northern District of Ohio reviewed McCarley-Connin’s motions to suppress the evidence obtained from the package searches. He argued that, under Florida v. Harris, he was entitled to an evidentiary hearing to challenge the reliability of the canine’s alert, having presented extrinsic evidence to that effect. The government responded that Harris applied only to warrantless searches and that, for searches conducted pursuant to a warrant, a defendant must meet the requirements of Franks v. Delaware to obtain such a hearing. The district court agreed with the government, denied the evidentiary hearing and suppression motions, and McCarley-Connin subsequently pleaded guilty while reserving his right to appeal the suppression ruling.On appeal, the United States Court of Appeals for the Sixth Circuit held that Florida v. Harris does not entitle a defendant to an evidentiary hearing or consideration of extrinsic evidence regarding a canine’s reliability when the search is conducted pursuant to a warrant. Instead, the Franks v. Delaware standard governs such challenges. Because McCarley-Connin did not request a Franks hearing, the appellate court affirmed the district court’s denial of his motions and concluded that the search warrants were supported by probable cause. View "United States v. McCarley-Connin" on Justia Law

A woman identified as E.J. was carjacked by two masked men in a Detroit store parking lot. She observed the men in the store, noting one was light-skinned and the other dark-skinned. After the incident, a store customer who knew the light-skinned man from school provided E.J. with his name and later sent both E.J. and the investigating officer photos and information from his Facebook profile. Before a police-arranged photo lineup, the customer sent E.J. a picture of the suspect, Kyrrah Radaker-Carter, despite police instructions not to do so. E.J. confirmed to the customer that the man in the photo was the carjacker. The next day, E.J. participated in a six-photo lineup and immediately identified Radaker-Carter, who was later arrested while driving the stolen car.The United States District Court for the Eastern District of Michigan denied Radaker-Carter’s motion to suppress E.J.’s identification, finding that due process did not require exclusion because the suggestive circumstances were not arranged by law enforcement and the photo array itself was not unduly suggestive. Radaker-Carter subsequently pleaded guilty and was sentenced to 122 months’ imprisonment, then appealed the suppression ruling.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s factual findings for clear error and its legal conclusions de novo. The appellate court held that E.J.’s identification was constitutionally admissible because the suggestive circumstances—E.J. seeing Radaker-Carter’s photo before the lineup—were not orchestrated by law enforcement. The court also found that the police-arranged photo lineup was not unduly suggestive, as the differences in the photos were minor and did not improperly single out Radaker-Carter. The court affirmed the district court’s denial of the motion to suppress. View "United States v. Radaker-Carter" on Justia Law

Two men were arrested in Louisville, Kentucky, in 2020 and charged with being felons in possession of firearms. Both had prior convictions for crimes punishable by more than a year in prison. One defendant pleaded guilty, while the other was convicted by a jury. At sentencing, the government sought to apply the Armed Career Criminal Act (ACCA), which imposes a mandatory minimum fifteen-year sentence for offenders with at least three prior convictions for violent felonies or serious drug offenses, provided those offenses were committed on different occasions.The United States District Court for the Western District of Kentucky, following then-binding Sixth Circuit precedent, determined that the judge—not a jury—should decide whether the prior offenses occurred on different occasions. The court found that both defendants qualified for the ACCA enhancement and sentenced each to fifteen years in prison. Both defendants appealed, arguing that, in light of the Supreme Court’s subsequent decision in Erlinger v. United States, the question of whether their offenses occurred on different occasions should have been decided by a jury.The United States Court of Appeals for the Sixth Circuit reviewed the cases. Applying a harmless error analysis as required by recent precedent, the court found that, for one defendant, the record established beyond a reasonable doubt that a jury would have found his offenses occurred on different occasions, so his sentence was affirmed. For the other defendant, the court concluded that the government had not met its burden to show the error was harmless, given similarities among the offenses and gaps in the record. As a result, the court vacated his sentence and remanded for further proceedings. The main holding is that failure to submit the ACCA “different occasions” question to a jury is subject to harmless error review, and the outcome depends on the specific facts of each case. View "United States v. Barnes" on Justia Law