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

In January 2019, Ashley Franklin, an inmate at the Franklin County Regional Jail, was transported to a hospital by Jail Sergeant Brandon Price due to illness. During the transport, Price sexually assaulted Franklin. Franklin filed a lawsuit against Price, Franklin County, and two other Jail employees, asserting constitutional claims under 42 U.S.C. § 1983 and related state law claims. She alleged that Price and his superior, Captain Wes Culbertson, were deliberately indifferent to her safety and that Franklin County had inadequate policies and training to prevent such assaults.The United States District Court for the Eastern District of Kentucky granted Franklin’s motion for summary judgment on her Eighth Amendment claim against Price but denied her other claims. The court granted summary judgment in favor of the other defendants, finding no evidence that Culbertson or Franklin County were deliberately indifferent or that the County’s policies were inadequate. The court also found that the County’s previous incidents of misconduct did not establish a pattern of unconstitutional behavior. Franklin’s negligence claims against Culbertson and Jailer Rick Rogers were dismissed, with the court ruling that they were entitled to qualified immunity under Kentucky law.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s judgment. The appellate court held that Franklin County was not liable under § 1983 because Franklin failed to show a direct causal link between the County’s policies and her assault. The court also found that Culbertson and Rogers were entitled to qualified immunity, as their actions were discretionary and performed in good faith. Franklin’s claims of gross negligence were deemed forfeited due to lack of development in her arguments. The court concluded that Franklin had not established that the County’s policies or training were constitutionally inadequate or that there was a pattern of similar constitutional violations. View "Franklin v. Franklin County" on Justia Law

In this case, DEA agents, acting on an anonymous tip, conducted a four-month investigation into Robert Cortez Burrell's alleged drug trafficking activities. They surveilled Burrell, observed suspicious behavior consistent with drug transactions, and corroborated the tip with additional evidence, including Burrell's criminal history and interactions with known drug dealers. Based on this information, they obtained and executed search warrants for four residences associated with Burrell, recovering significant quantities of illegal narcotics, firearms, and drug-manufacturing equipment. Burrell was subsequently convicted by a jury of multiple drug-related offenses and being a felon in possession of firearms and ammunition, resulting in a 180-month prison sentence.The United States District Court for the Eastern District of Michigan denied Burrell's motion to suppress the evidence obtained from the searches, as well as his motion to dismiss the firearms and ammunition charges on Second Amendment grounds. The court found that the search warrants were supported by probable cause and that Burrell's motion to dismiss was untimely. Additionally, the court admitted testimony that Burrell argued violated the Confrontation Clause and the Federal Rules of Evidence.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's judgment. The appellate court held that the search warrants were supported by probable cause, as the DEA agents had sufficiently corroborated the anonymous tip through extensive surveillance and other investigative methods. The court also found that the district court did not abuse its discretion in denying Burrell's motion to dismiss as untimely and that Burrell's constitutional challenges to the firearms and ammunition charges failed under the plain-error standard. Furthermore, the court ruled that the admission of the contested testimony did not violate the Confrontation Clause or the Federal Rules of Evidence, as the statements were not offered for their truth but to explain the DEA's actions. View "United States v. Burrell" on Justia Law

The case involves Joseph Betro, Mohammed Zahoor, Tariq Omar, and Spilios Pappas, who conspired to defraud Medicare by administering medically unnecessary back injections and bribing patients with opioid prescriptions. They fraudulently billed these injections as “facet injections” to receive higher reimbursements. Additionally, they ordered unnecessary urine drug tests and referred patients to ancillary services in exchange for kickbacks. Despite patient complaints about the ineffectiveness and pain of the injections, the defendants continued their fraudulent practices.A jury in the United States District Court for the Eastern District of Michigan convicted the defendants of conspiracy to commit healthcare fraud and wire fraud under 18 U.S.C. § 1349 and healthcare fraud under 18 U.S.C. § 1347. The defendants filed motions for a new trial, which the district court denied. They then appealed their convictions and sentences, raising various challenges related to the prosecution, evidence admission, jury instructions, and sentencing calculations.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s judgments. The court found sufficient evidence to support the jury’s findings that the defendants knowingly participated in the fraudulent scheme. The court also held that the district court did not abuse its discretion in denying the motions for a new trial, admitting evidence, or instructing the jury. The sentences imposed were deemed procedurally and substantively reasonable, with the court noting that the district court had appropriately calculated the loss amounts and applied relevant sentencing enhancements. View "United States v. Betro" on Justia Law

In 2022, Condarius Tripplet pleaded guilty to possession with intent to distribute controlled substances. The district court sentenced him to 188 months in prison, applying a drug-premises enhancement. This enhancement adds two levels to the base offense level when a defendant maintains a premises for drug manufacturing or distribution. Tripplet acknowledged maintaining an apartment but disputed that its primary use was for drug distribution, noting he lived there with his girlfriend and her two children.The United States District Court for the Western District of Michigan found that Tripplet had significant quantities of illegal drugs, cash, a firearm, and drug manufacturing tools in the apartment. The court also noted that he regularly distributed drugs from this residence. Based on these findings, the court applied the drug-premises enhancement, resulting in a higher offense level and a longer sentence. Tripplet appealed the application of this enhancement.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the drug-premises enhancement was correctly applied. The court noted that the enhancement does not require drug operations to be the sole purpose of the premises, only that it be one of the primary uses. Given the substantial quantities of drugs, cash, and drug-related tools found in the apartment, along with evidence of regular drug transactions, the court affirmed the district court's decision to apply the enhancement. The court concluded that the totality of the evidence supported the inference that Tripplet maintained the apartment for drug trafficking purposes, justifying the enhancement and the resulting sentence. View "United States v. Tripplet" on Justia Law

Gregory D. Ralston was found guilty by a jury of distributing and possessing with intent to distribute a fentanyl-containing substance. He was acquitted of causing serious bodily injury by distributing the fentanyl. Ralston challenged the district court’s denial of his motion to suppress evidence without an evidentiary hearing, the limitation of his cross-examination of two government witnesses, and the reasonableness of his 180-month sentence.The United States District Court for the Northern District of Ohio initially scheduled an evidentiary hearing on Ralston’s motion to suppress but later denied the motion without holding the hearing. Ralston proceeded to trial, where the court limited his cross-examination of witnesses regarding potential bias and prior convictions. The jury convicted Ralston on the drug charges but acquitted him of the enhancement for causing serious bodily injury. The district court then imposed a 180-month sentence, significantly above the Guidelines range of 27 to 33 months, citing Ralston’s prior conviction and the seriousness of the current offense.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found no abuse of discretion in the district court’s decision to deny the motion to suppress without an evidentiary hearing, as the issues raised were legal rather than factual. The appellate court also upheld the limitation on cross-examination, noting that Ralston had the opportunity to question the witnesses directly about potential bias. The court found the sentence procedurally reasonable, as the district court adequately explained the upward variance and considered the § 3553(a) factors. The court also found the sentence substantively reasonable, given the district court’s rationale and the evidence supporting the findings.The Sixth Circuit affirmed the district court’s judgment but remanded the case for consideration of a potential sentence reduction under 18 U.S.C. § 3582(c) due to an intervening amendment in the Sentencing Guidelines. View "United States v. Ralston" on Justia Law

Yanjun Xu, a Chinese citizen and member of China’s Ministry of State Security, was convicted of conspiracy to commit economic espionage and conspiracy to steal trade secrets from multiple aviation companies over a five-year period. Xu was also convicted of attempted economic espionage by theft or fraud and attempted theft of composite fan-blade technology from GE Aviation. He was sentenced to a combined 240 months’ imprisonment. Xu appealed, seeking to vacate the judgment and remand for a new trial, arguing that the district court erred in failing to dismiss Counts 1 and 2 as duplicitous and abused its discretion in admitting expert testimony in violation of Federal Rule of Evidence 704(b). Alternatively, Xu sought to have his sentence vacated, arguing it was both procedurally and substantively unreasonable.The United States District Court for the Southern District of Ohio denied Xu’s motion to dismiss the indictment, finding that the conspiracy counts were not duplicitous as they alleged a single overarching conspiracy. The court also admitted expert testimony from James Olson, a retired CIA officer, who testified about espionage techniques and tradecraft, which Xu argued violated Rule 704(b). The court overruled Xu’s objections, finding that Olson’s testimony did not directly opine on Xu’s intent but rather described common practices in espionage.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The appellate court held that the indictment was not duplicitous as it charged a single conspiracy with multiple overt acts. The court also found that Olson’s testimony did not violate Rule 704(b) and that any potential error was cured by the district court’s limiting instructions to the jury. Additionally, the appellate court found Xu’s sentence to be procedurally and substantively reasonable, noting that the district court properly calculated the intended loss and considered the § 3553(a) factors. The court concluded that Xu’s sentence was within the Guidelines range and not disparate compared to similarly situated defendants. View "United States v. Yanjun Xu" on Justia Law

Leon Hensley, a high school nurse, was found to have surreptitiously recorded minors using the bathroom. An investigation revealed that he had hidden a camera in the nurse’s office bathroom stall, capturing videos of 57 students. Additionally, officers found multiple "upskirt" recordings and photos from inside a tanning bed. Hensley was indicted on 25 counts of production and attempted production of child pornography and pleaded guilty to all counts.The United States District Court for the Middle District of Tennessee sentenced Hensley to 293 months of confinement. During sentencing, the probation office recommended a five-level adjustment to Hensley’s offense level under U.S.S.G. § 3D1.4 for multiple counts of similar severity and another five points under § 4B1.5(b)(1) for engaging in a pattern of prohibited sexual conduct. Hensley objected, arguing that this constituted impermissible double counting. The district court disagreed and sentenced him within the adjusted range, acknowledging its discretion but choosing to consider the higher guideline recommendation to avoid unwarranted sentencing disparities.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the district court did not err in its application of the sentencing guidelines. It found that the text of § 4B1.5(b)(1) explicitly allows for its application in addition to other provisions, thus permitting what Hensley termed "double counting." The appellate court also determined that the district court understood its discretion to deviate from the guidelines, as evidenced by its detailed explanation and decision to use a hypothetical lower range while still considering the higher guideline recommendation. Consequently, the Sixth Circuit affirmed the district court’s judgment. View "U.S. v. Hensley" on Justia Law

Nathaniel Jackson was convicted of a capital offense and sentenced to death. His sentencing was marred by judicial bias and misconduct, including ex parte communications between the judge and prosecutor and the prosecutor ghostwriting the judge’s sentencing opinion. When this misconduct was revealed, the Ohio appellate courts ordered new sentencing proceedings. However, the trial judge denied Jackson’s motion to present additional mitigating evidence and resentenced him based on the old record, issuing a nearly identical opinion to the original one.The Ohio appellate courts affirmed Jackson’s sentence despite the trial judge’s misconduct. Jackson then filed a habeas corpus petition in federal district court. The district court granted the petition on the grounds that Jackson was unconstitutionally denied the opportunity to present mitigating evidence but denied his other claims, including judicial bias.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Ohio’s standard for assessing judicial bias was contrary to clearly established federal law. On de novo review, the court found that the trial judge was unconstitutionally biased. The court also held that the exclusion of mitigating evidence at Jackson’s resentencing violated the Eighth Amendment, as capital defendants have the right to present all relevant mitigating evidence. Consequently, the court affirmed the district court’s issuance of a writ of habeas corpus on the mitigating-evidence claim, reversed the denial on the judicial-bias claim, and remanded for further proceedings. View "Jackson v. Cool" on Justia Law

O’Bryan Mitchell was involved in an incident where he fled from police while holding a firearm. The police were responding to a report of a man discharging a firearm near Franklin Park in Massillon, Ohio. Mitchell, who matched the suspect's description, fled on foot when ordered to stop. During the chase, he discarded the firearm, which was later recovered and found to be loaded with his DNA on it. Mitchell was also found in possession of methamphetamine and a digital scale. He was indicted on one count of possession of a firearm by a convicted felon and pleaded guilty.The United States District Court for the Northern District of Ohio sentenced Mitchell to 78 months of imprisonment, an upward variance from the Sentencing Guidelines range of 51 to 63 months. The court justified the variance based on Mitchell’s criminal history, his possession of narcotics, his poor institutional adjustment, and his repeated violations of supervised release. The court also ordered that Mitchell’s federal sentence run consecutively to any term of imprisonment arising from any pending state-court conviction or parole violation.Mitchell appealed to the United States Court of Appeals for the Sixth Circuit, arguing that his sentence was both procedurally and substantively unreasonable. He contended that the district court was predisposed to impose a higher sentence, failed to adequately explain the upward variance, and did not properly consider mitigating factors. He also argued that the court erred by ordering his federal sentence to run consecutively to any state sentence.The Sixth Circuit affirmed the district court’s judgment. It found that the district court adequately explained its rationale for the upward variance and considered the relevant 18 U.S.C. § 3553(a) factors. The appellate court also held that the district court did not plainly err in ordering the federal sentence to run consecutively to any state sentence, as it had sufficiently considered the relevant factors and the presentence report. View "United States v. Mitchell" on Justia Law

The case revolves around Corey Neal, who was charged with federal gun possession after Shelby County officers, armed with a warrant, discovered three firearms at his residence. Neal challenged the validity of the search under the Fourth Amendment, but his plea was rejected, leading him to plead guilty to the charges. The case was then brought to appeal, where Neal reiterated his Fourth Amendment claim.The District Court for the Western District of Tennessee had previously denied Neal's motion to suppress the evidence found at his residence. The court agreed that the warrant lacked probable cause but invoked the good faith exception to the exclusionary rule from United States v. Leon, which allows evidence obtained in good faith reliance on a search warrant later found to be deficient. Neal pleaded guilty to the second count in the indictment, reserving his right to appeal the ruling, and was sentenced to 92 months' imprisonment.The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court found that the affidavit supporting the search warrant established a "minimally sufficient nexus" between the items sought and the place to be searched. The court reasoned that the affidavit provided more than a naked guess that contraband might be found at Neal's residence. It established recent drug trafficking by Neal and evidence of Neal's residency. The court concluded that the affidavit was not so bare bones as to necessitate the application of the exclusionary rule, thereby upholding the lower court's application of the good faith exception to the exclusionary rule. View "United States v. Neal" on Justia Law