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

Defendant Shefiu A. Hanson, serving a 46-month sentence for wire fraud, appealed the district court’s denial of his motion to reduce his sentence under 18 U.S.C. § 3582(c)(2). Hanson had pled guilty to wire fraud and conspiracy for creating fraudulent bank and email accounts to induce businesses to wire money to his accounts. The total loss to 30 victims was $1,122,805.74. Hanson, with no prior convictions, had a Criminal History Category of I and an Offense Level of 22, resulting in a Guidelines Range of 41 to 51 months. He was sentenced to 46 months in May 2023.Hanson moved for a sentence reduction under the newly created U.S.S.G. § 4C1.1, which applies retroactively. The government opposed, arguing Hanson was ineligible because he caused substantial financial hardship to his victims. The district court agreed, finding Hanson caused substantial financial harm to multiple victims, making him ineligible under U.S.S.G. § 4C1.1(a)(6). The court also concluded that a sentence reduction would not adequately reflect the seriousness of the offense or provide just punishment.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the district court did not err in determining Hanson was ineligible for a sentence reduction. The court noted that the financial hardship caused by Hanson did not need to fall perfectly within the factors listed in U.S.S.G. § 2B1.1 n.4F, as the list is non-exhaustive. The district court reasonably concluded that the financial hardship to at least one victim was substantial, citing specific examples of individual victims' hardships. The court affirmed the district court’s order denying Hanson’s motion for a sentence reduction. View "United States v. Hanson" on Justia Law

Clarence Fry was convicted by a jury of the aggravated felony murder of his girlfriend, Tamela Hardison, and was sentenced to death by an Ohio trial court. The conviction and sentence were affirmed by the Ohio courts on direct appeal, and Fry's request for collateral relief was denied. Fry then petitioned for a writ of federal habeas corpus, which the district court denied.The Ohio Supreme Court affirmed Fry's conviction and sentence. The Ohio Court of Appeals denied state collateral relief, and the Ohio Supreme Court declined additional review. Fry filed a habeas petition in federal court, raising 24 grounds for relief. The district court denied his petition and granted a certificate of appealability on five claims: ineffective assistance of trial counsel, trial-court error, and ineffective assistance of appellate counsel.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Fry's trial counsel did not provide ineffective assistance during plea bargaining, as the state court reasonably found no prejudice. The court also held that Fry's counsel did not prevent him from testifying, as the state court's finding that Fry knowingly waived his right to testify was reasonable. Additionally, the court found that Fry's waiver of mitigation evidence was knowing and voluntary, and thus, there was no prejudice from counsel's performance.The court also addressed Fry's claims of trial court error. It held that the trial court did not violate Fry's right to testify by failing to independently inquire about his decision, as there was no Supreme Court precedent requiring such an inquiry. Lastly, the court found that the trial court did not err in accepting Fry's mitigation waiver, as the extensive colloquy showed that Fry's waiver was knowing and voluntary.The Sixth Circuit affirmed the district court's denial of Fry's habeas petition. View "Fry v. Shoop" on Justia Law

Mario Adams, a defendant with a history of mental health issues, was sentenced to 24 months’ imprisonment for violating the terms of his supervised release. Adams argued that the district court improperly considered his mental health as an aggravating factor in its sentencing determination.In 2014, Adams was charged with being a felon in possession of a firearm. He was initially found incompetent to stand trial due to mental health issues but was later deemed competent and pleaded guilty. He was sentenced to 87 months in prison followed by 36 months of supervised release. After his release in 2020, Adams violated the terms of his supervised release multiple times, including missing drug tests, failing to allow home visits, and committing new state crimes.The district court for the Northern District of Ohio revoked Adams’s supervised release based on these violations and sentenced him to 24 months in prison, an upward variance from the Guidelines range of 8 to 14 months. The court emphasized Adams’s conduct, including his absconding from a halfway house and committing violent crimes, as the basis for the sentence.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that the district court did not improperly rely on Adams’s mental health status as an aggravating factor but rather based its decision on Adams’s conduct and the failure of previous interventions to prevent further offenses. The court concluded that the district court’s sentence was procedurally reasonable and based on permissible factors. View "United States v. Adams" on Justia Law

During a regulatory inspection on May 9, 2022, Sergeant Jeff Fuller of the Tennessee Highway Patrol stopped a semitrailer. The truck's driver, Euclide Aquino Urraca, exhibited suspicious behavior, and the truck's paperwork and cargo had numerous irregularities. Fuller noticed that the truck's cargo did not match the bill of lading, and the driver and his co-driver were evasive when asked about a heavily taped box found under the bunk. A dog sniff of the truck led to the discovery of 20 kilograms of cocaine.The United States District Court for the Western District of Tennessee held an evidentiary hearing and found that Fuller lacked reasonable suspicion to extend the stop for the dog sniff. The court largely credited Fuller’s testimony but rejected his claim that he believed the box contained narcotics at the time of the search. Consequently, the district court granted Urraca’s motion to suppress the cocaine found in the truck.The United States Court of Appeals for the Sixth Circuit reviewed the case and determined that the objective facts known to Fuller at the time of the dog sniff justified the investigation. The court held that the combination of the drivers' suspicious behavior, the irregularities in the truck's paperwork and cargo, and the evasive responses about the box provided reasonable suspicion to extend the stop. The court concluded that the dog sniff was permissible, and the subsequent search, which uncovered the cocaine, was lawful under the automobile exception. Therefore, the Sixth Circuit reversed the district court's decision to suppress the evidence. View "United States v. Aquino Urraca" on Justia Law

Jaylin Morton was indicted for possessing a firearm as a felon, in violation of 18 U.S.C. § 922(g)(1). Morton moved to dismiss the indictment, arguing that the prosecution violated his Second Amendment rights. The district court denied his motion, and Morton conditionally pleaded guilty, retaining the right to appeal the denial of his motion to dismiss.The United States District Court for the Eastern District of Kentucky denied Morton’s motion to dismiss, reasoning that his prior felonies demonstrated that he was a serious and direct threat to public safety. The court concluded that § 922(g)(1) constitutionally applied to him. Morton then appealed the district court’s decision.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Morton’s criminal history, which included multiple violent offenses such as shooting at his ex-girlfriend and her family, and assaulting his then-girlfriend, demonstrated his dangerousness. The court applied the framework established in United States v. Williams, which allows for disarming individuals who are deemed dangerous based on their criminal history. The court concluded that Morton’s conviction was consistent with the Second Amendment as interpreted in Williams and affirmed the district court’s denial of Morton’s motion to dismiss the indictment. View "United States v. Morton" on Justia Law

Brian Washington, a federal prisoner, pleaded guilty in 2013 to possession of crack cocaine with intent to distribute and using and carrying a firearm in a drug trafficking crime. Due to prior convictions, he was classified as a career offender and sentenced to 280 months in prison. Washington did not appeal his convictions, and his post-conviction relief claims were unsuccessful. He has since filed four motions for compassionate release, all of which were denied by the district court.The United States District Court for the Eastern District of Kentucky denied Washington's fourth motion for compassionate release. Washington appealed, arguing that the disparity between crack and powder cocaine sentences, his declining mental health, age, and rehabilitation efforts constituted extraordinary and compelling reasons for his release. The district court found these arguments unpersuasive and denied the motion.The United States Court of Appeals for the Sixth Circuit reviewed the district court's denial for abuse of discretion. The court held that the disparity between crack and powder cocaine sentences does not constitute an extraordinary and compelling reason for compassionate release. The court also noted that Washington's claims regarding his mental health and age were forfeited as they were not raised in the district court. Additionally, the court found that rehabilitation alone is not an extraordinary and compelling reason for release, as per 28 U.S.C. § 994(t). Consequently, the Sixth Circuit affirmed the district court's denial of Washington's motion for compassionate release. View "United States v. Washington" on Justia Law

In 2005, Delano Hale was sentenced to death by an Ohio court for the murder of Douglas Green. Green was found dead in a motel room, wrapped in plastic bags, and had been shot multiple times. Hale was arrested driving Green's stolen vehicle and later admitted to the shooting, claiming it was in self-defense against Green's sexual advances. Hale was convicted of aggravated murder and other charges, and the jury recommended the death penalty.Hale's conviction and sentence were affirmed by the Ohio Supreme Court and the Ohio Court of Appeals. Hale filed for post-conviction relief, which was denied by the trial court and affirmed by the appellate court. He then sought federal habeas relief, raising multiple claims, including ineffective assistance of counsel and sentencing errors under Blakely v. Washington.The United States Court of Appeals for the Sixth Circuit reviewed Hale's habeas petition. The court denied Hale's claim of ineffective assistance of counsel, finding that his trial counsel's decision not to call a forensic expert was a reasonable strategic choice. The court noted that Hale's counsel had considered hiring an expert but ultimately chose a different strategy, which did not constitute deficient performance under Strickland v. Washington.The court also denied Hale's claim regarding his noncapital sentences, which were enhanced based on judicial factfinding in violation of Blakely. The Ohio Supreme Court had reviewed this claim for plain error and found no prejudice, concluding that a jury would have reached the same sentencing conclusions. The Sixth Circuit found this determination reasonable and upheld the Ohio Supreme Court's decision.The Sixth Circuit affirmed the district court's denial of Hale's habeas petition, concluding that Hale's claims did not warrant relief under the deferential standards of the Antiterrorism and Effective Death Penalty Act (AEDPA). View "Hale v. Cool" on Justia Law

Michael Gardner was convicted of sex trafficking a minor and production of child pornography. He prostituted his 17-year-old girlfriend, B.H., and recorded himself having sex with her. Gardner was sentenced to 240 months in prison. After an unsuccessful appeal, Gardner sought habeas relief under 28 U.S.C. § 2255, claiming ineffective assistance of counsel for not introducing B.H.'s prior advertisements for sex work as evidence and for not seeking an evidentiary hearing.The United States District Court for the Eastern District of Michigan denied Gardner's habeas petition but granted a certificate of appealability on two issues: whether Gardner’s trial counsel was ineffective for failing to introduce the minor victim’s prior advertisements for sex work and whether Gardner was entitled to an evidentiary hearing.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Gardner’s counsel was not ineffective for failing to introduce the prior advertisements because they were irrelevant to the charges and inadmissible under Federal Rule of Evidence 412. The court also found that the advertisements would not have impeached B.H.'s testimony, as her statements were focused on the period after she reconnected with Gardner. Additionally, the court ruled that Gardner was not entitled to an evidentiary hearing because he did not present a factual dispute that would warrant such a hearing.The Sixth Circuit affirmed the district court’s denial of Gardner’s § 2255 petition and the denial of an evidentiary hearing. View "Gardner v. U.S." on Justia Law

Nathaniel Taylor was stopped by a police officer for speeding on an interstate in Knoxville, Tennessee. During the stop, the officer requested a K-9 unit based on Taylor’s suspicious activities, including his movements in the car, his criminal history, and the presence of multiple air fresheners. The K-9 unit indicated the presence of drugs, leading to a search of Taylor’s vehicle, which uncovered a firearm. As a felon, Taylor was prohibited from possessing a firearm. Taylor was subsequently indicted for being a felon in possession of a firearm and moved to suppress the evidence, arguing that the officer lacked reasonable suspicion to detain him beyond the time necessary to issue a traffic citation.The United States District Court for the Eastern District of Tennessee denied Taylor’s motion to suppress. Taylor then conditionally pleaded guilty, reserving his right to appeal the district court’s ruling on the motion to suppress.The United States Court of Appeals for the Sixth Circuit reviewed the case and determined that the officer did not have reasonable suspicion to prolong the traffic stop. The court found that the factors cited by the officer, including Taylor’s travel plans, criminal history, air fresheners, and movements, did not collectively amount to reasonable suspicion. The court held that the officer’s extension of the stop to conduct a dog sniff was not justified. Consequently, the Sixth Circuit reversed the district court’s denial of Taylor’s motion to suppress and remanded the case for further proceedings consistent with its opinion. View "United States v. Taylor" on Justia Law

Joseph Scott Gray, a decorated U.S. Army veteran, was convicted of defrauding the Department of Veterans Affairs (VA) by lying about his health to obtain benefits. After leaving the military in 2003, Gray falsely claimed severe disabilities to receive increased benefits, including "individual unemployability" and "aid and attendance" benefits. His fraudulent activities were exposed when investigators videotaped him performing daily activities without assistance, contradicting his claims of severe disability.The United States District Court for the Western District of Michigan convicted Gray of several fraud-related offenses. The jury found him guilty, and the district court sentenced him to five years in prison and ordered him to pay $264,631 in restitution, covering benefits received from 2004 onward. Gray appealed, challenging the exclusion of an expert witness, the calculation of his criminal history score, the reasonableness of his sentence, and the restitution order.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court upheld the exclusion of Gray's expert witness, Dr. Ennis Berker, as the proposed testimony was deemed irrelevant to the issues at trial. The court also found no procedural error in the calculation of Gray's criminal history score and deemed the five-year sentence substantively reasonable, considering the severity and duration of his fraudulent conduct.However, the court vacated the restitution order, ruling that it should not cover losses before January 2015, as the indictment only charged Gray with a conspiracy beginning in 2015. The case was remanded for recalculation of the restitution amount, limited to the period specified in the indictment. View "United States v. Joseph Gray" on Justia Law