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

Christopher Goins challenged the constitutionality of 18 U.S.C. § 922(g)(1), which prohibits firearm possession by individuals convicted of crimes punishable by imprisonment for over a year. Goins, with multiple felony convictions, argued that the Supreme Court's decision in New York State Rifle and Pistol Association, Inc. v. Bruen rendered this statute unconstitutional as applied to him. In December 2021, Goins had an associate purchase a firearm for him, which he then took possession of, despite being on probation with a condition prohibiting firearm possession.The United States District Court for the Eastern District of Kentucky denied Goins's motion to dismiss the indictment, holding that § 922(g)(1) was constitutional as applied to him. Goins pled guilty but reserved the right to appeal the district court's decision.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo and upheld the district court's decision. The court found that Goins's probation condition, his relatively short probation sentence for a dangerous crime, and his repeated dangerous conduct justified his disarmament under the Second Amendment. The court emphasized that historical traditions support the temporary disarmament of individuals who have engaged in dangerous conduct, such as Goins. Therefore, the court held that 18 U.S.C. § 922(g)(1) is constitutional as applied to Goins and affirmed the district court's judgment. View "United States v. Goins" on Justia Law

In this case, the defendant was charged with possessing a stolen firearm and receiving a firearm while under felony indictment. Law enforcement found the stolen firearm in a vehicle owned by another individual, who later revealed that the defendant had left the gun in his car. The defendant admitted to touching the gun and knowing it was stolen. He was under felony indictment for other firearms offenses at the time.The United States District Court for the Southern District of Ohio denied the defendant's motion to dismiss the indictment, which argued that the statutes under which he was charged violated the Second Amendment. During jury selection, the defendant raised a Batson challenge against the prosecutor's peremptory strike of the last black juror on the panel. The district court found the prosecutor's reasons for the strike to be race-neutral and allowed it. The jury convicted the defendant on both counts, and he was sentenced to 18 months' imprisonment.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court upheld the district court's denial of the motion to dismiss, finding that the statutes in question were consistent with historical firearm regulations and did not violate the Second Amendment. The court also affirmed the district court's rejection of the Batson challenge, concluding that the prosecutor's race-neutral explanation for the peremptory strike was credible and not pretextual. The Sixth Circuit affirmed the defendant's conviction and sentence. View "United States v. Gore" on Justia Law

Johnathan Holt, just weeks before his eighteenth birthday, shot and killed a drug dealer, Quincy Battle, on behalf of the Short North Posse gang. Holt was later paralyzed from the chest down due to gun violence. A federal jury convicted him of murder in aid of racketeering and murder with a firearm during a drug-trafficking crime. The district court initially sentenced him to life imprisonment, but this was later vacated as it violated the Eighth Amendment under Miller v. Alabama, which prohibits mandatory life sentences for juveniles. Holt was resentenced to 900 months in prison.The United States District Court for the Southern District of Ohio initially sentenced Holt to life imprisonment, which was later vacated due to the Eighth Amendment violation. The district court then resentenced him to 900 months in prison. Holt appealed, arguing that his new sentence still violated the Eighth Amendment and was procedurally and substantively unreasonable.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the district court had adequately considered Holt’s youth, as required by Miller v. Alabama, and that the Eighth Amendment did not require a more lenient sentence based on his medical condition. The court also found that Holt’s procedural claims, including the district court’s handling of the presentence report and his right to allocute, did not demonstrate plain error. Finally, the court held that the 900-month sentence was substantively reasonable given the severity of Holt’s crime and the district court’s consideration of the relevant sentencing factors. The Sixth Circuit affirmed the district court’s decision. View "United States v. Holt" on Justia Law

Chadrick Perry was indicted for being a felon in possession of a firearm and ammunition. After pleading not guilty, he was detained pending trial. Concerns about his competency led to evaluations by two forensic psychologists, who reached different conclusions. The district court committed Perry to the custody of the Attorney General for competency restoration. Perry experienced significant delays in being transported to a federal facility for treatment. Eventually, he was deemed competent, pleaded guilty to being a felon in possession of ammunition, and was sentenced to 57 months in prison.The United States District Court for the Western District of Michigan denied Perry's motion to dismiss the indictment based on alleged violations of the Speedy Trial Act. Perry argued that the 152-day delay between his designation for treatment and his arrival at the facility should count against the Act's 70-day clock. The district court ruled that the entire period from when Perry was deemed incompetent until his competency was restored was excludable under the Act.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the entire period of delay resulting from Perry's mental incompetence was excludable under 18 U.S.C. § 3161(h)(4). This exclusion applied even during the transportation delay, thus not violating the Speedy Trial Act. Additionally, the court upheld Perry's sentence, determining that his prior conviction for aggravated domestic violence qualified as a "crime of violence" under U.S.S.G. § 4B1.2(a), justifying the increased Guidelines range. The court affirmed both the conviction and the sentence. View "United States v. Perry" on Justia Law

Michael Harvel, a county official, was convicted by a jury for sexually assaulting seven women he supervised, violating their constitutional rights under 18 U.S.C. § 242. Harvel appealed, raising issues about the timeliness of the charges, the indictment's sufficiency, and the admission of certain evidence.The United States District Court for the Middle District of Tennessee initially handled the case. Harvel argued that the most serious charges were not brought within the five-year statute of limitations under 18 U.S.C. § 3282(a). However, the court found that these charges were "punishable by death" under 18 U.S.C. § 3281, thus not subject to the five-year limit. Harvel also claimed that the introduction of "other crimes" evidence violated the Due Process Clause and Federal Rule of Evidence 403. The district court allowed this evidence, finding it relevant and not overly prejudicial.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's rulings, holding that the charges were timely under § 3281 because the crimes included kidnapping and aggravated sexual abuse, which are punishable by death under § 242. The court also rejected Harvel's due process challenge to Rule 413, which allows the admission of other sexual assaults to show propensity, and found no abuse of discretion in the district court's Rule 403 balancing. Additionally, the court upheld the denial of Harvel's motion for a mistrial, concluding that the district court's limiting instructions were sufficient to mitigate any potential prejudice from the inadmissible testimony.In conclusion, the Sixth Circuit affirmed Harvel's convictions and the 204-month sentence, finding no merit in his arguments regarding the statute of limitations, the indictment's sufficiency, or the evidentiary rulings. View "United States v. Harvel" on Justia Law

In 2012, Kayla Ayers was convicted by an Ohio jury of aggravated arson and child endangerment following a fire in her basement. In 2019, Ayers obtained an expert report suggesting that the prosecution's key witness, a fire inspector, was unqualified. Ayers argued that her trial counsel was ineffective for not investigating the fire inspector's qualifications or retaining an arson expert to challenge his testimony.The United States District Court for the Northern District of Ohio dismissed Ayers's habeas corpus petition as time-barred, concluding that she failed to exercise due diligence in obtaining the expert report sooner. The court found that Ayers could have discovered the factual basis for her claim within the statutory period.The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court's decision. The appellate court held that the expert report, which questioned the fire inspector's qualifications and methods, constituted the factual predicate for Ayers's ineffective-assistance claim. The court determined that Ayers, an indigent prisoner, could not have discovered this information without the assistance of the Ohio Innocence Project, which secured the expert report in 2019. The court concluded that Ayers exercised due diligence under the circumstances and filed her habeas petition within one year of obtaining the report. The case was remanded for further proceedings consistent with this opinion. View "Ayers v. Ohio Department of Rehabilitation and Correction" on Justia Law

Erick Williams was stopped by Memphis police for speeding and erratic driving. Officers smelled marijuana and saw an open beer can, leading them to search the car after a canine alert. They found a loaded pistol in the trunk. Williams, a convicted felon for aggravated robbery, was indicted for being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1). He moved to dismiss the indictment, arguing that the statute violated the Second Amendment. The district court denied his motion, and Williams pled guilty while reserving the right to appeal.The United States District Court for the Western District of Tennessee denied Williams's motion to dismiss the indictment. Williams then appealed to the United States Court of Appeals for the Sixth Circuit, arguing that § 922(g)(1) was unconstitutional both on its face and as applied to him.The United States Court of Appeals for the Sixth Circuit reviewed the case and upheld the district court's decision. The court held that § 922(g)(1) does not violate the Second Amendment. The court reasoned that historical precedent supports the disarmament of individuals deemed dangerous, and Williams's criminal record, including convictions for aggravated robbery and attempted murder, demonstrated that he was dangerous. Therefore, the statute was constitutional as applied to him. The court also noted that while individuals must have an opportunity to show they are not dangerous, Williams failed to do so. The court affirmed the district court's decision, maintaining Williams's conviction under § 922(g)(1). View "United States v. Williams" on Justia Law

John O’Hara pleaded guilty to wire fraud and bank fraud for misappropriating funds from his mother, Sally Thrush. Thrush passed away shortly after his plea, leaving O’Hara as the sole beneficiary of her estate. At sentencing, the district court ordered O’Hara to pay over $300,000 in restitution to Thrush’s estate, despite knowing that O’Hara would likely receive the restitution as the estate’s beneficiary. Four years later, the district court amended the judgment to direct O’Hara to pay the federal Crime Victims Fund instead of the estate.The United States District Court for the Eastern District of Kentucky initially sentenced O’Hara to twenty-six months in prison and ordered him to pay restitution to his mother’s estate. After O’Hara’s release from prison, the district court, prompted by the government, amended the judgment to substitute the Crime Victims Fund as the payee, reasoning that allowing O’Hara to receive his own restitution would be contrary to the intent of the Mandatory Victims Restitution Act (MVRA).The United States Court of Appeals for the Sixth Circuit reviewed the case and determined that the district court did not have the authority to modify the final judgment to substitute a new payee. The appellate court held that the MVRA, specifically 18 U.S.C. § 3663A(a)(2), does not provide the statutory authority to amend a restitution order post-judgment. The court emphasized that a final restitution order can only be modified under specific statutory provisions, none of which applied in this case. Consequently, the Sixth Circuit reversed the district court’s decision and remanded the case. View "United States v. O'Hara" on Justia Law

Joel M. Guy, Jr. murdered his parents in 2016 with the intent to collect the proceeds from his mother’s insurance plans. His mother had life insurance and accidental death and dismemberment insurance through her employer, naming Guy and his father as beneficiaries. Guy was convicted of first-degree premeditated murder, felony murder, and abuse of a corpse by a Tennessee jury.The United States District Court for the Eastern District of Tennessee determined that Guy would be entitled to the insurance proceeds if not disqualified. However, the court ruled that Guy was disqualified under Tennessee’s slayer statute or federal common law, which prevents a murderer from benefiting from their crime. The court granted summary judgment in favor of Guy’s family members, who argued that Guy was not entitled to the benefits. Guy appealed, arguing that ERISA preempts Tennessee’s slayer statute and that no federal common-law slayer rule applies.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court held that ERISA does not explicitly address the issue of a beneficiary who murders the insured, and thus, either Tennessee law or federal common law must apply. The court found that both Tennessee’s slayer statute and federal common law would disqualify Guy from receiving the insurance proceeds. The court affirmed the district court’s decision, concluding that Guy’s actions disqualified him from benefiting from his mother’s insurance plans under both state and federal law. View "Standard Insurance Co. v. Guy" on Justia Law

Don Ellis committed a carjacking and bank robbery in Toledo, Ohio, on August 13, 2018. He threatened a gas station customer with a gun, stole a car and $200, and later robbed a Fifth Third Bank. The police tracked him using a GPS device hidden in the stolen money, leading to a high-speed chase and his arrest. Ellis escaped from jail two days later but was recaptured five days after that. A federal grand jury indicted him on six counts, including carjacking, bank robbery, escape, unlawful firearm possession, and two counts of using or carrying a firearm during a crime of violence.The United States District Court for the Northern District of Ohio accepted Ellis's guilty plea to all six counts under a plea agreement, which included a waiver of his right to appeal except under specific circumstances. Ellis later moved to withdraw his plea, arguing he did not understand the appeal waiver's implications. The district court denied his motion, finding that he had been adequately informed of his rights and the plea agreement's terms. At sentencing, the court rejected Ellis's argument that the indictment failed to state a § 924(c) offense and sentenced him to 201 months in prison, as agreed in the plea deal.The United States Court of Appeals for the Sixth Circuit reviewed the case. Ellis argued that he should have been allowed to withdraw his plea and that the indictment was flawed. However, the court found that Ellis had knowingly and voluntarily waived his right to appeal as part of his plea agreement. The court also held that the alleged indictment error did not affect the district court's jurisdiction and could be waived. Consequently, the Sixth Circuit granted the government's motion to dismiss Ellis's appeal. View "United States v. Ellis" on Justia Law