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

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

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