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

Ronda Jones was arrested by Officer Steven Naert after attempting to walk to the scene of her son's car accident. Jones had been drinking at home and was suspected by Naert of having driven the car while intoxicated due to her prior DUI arrest. When Jones tried to leave her home to check on her son, Naert arrested her for disorderly conduct, citing a Michigan statute that prohibits such behavior. The statute does not criminalize public intoxication alone; it requires probable cause to believe that the individual would pose a danger to others.The United States District Court for the Western District of Michigan granted Officer Naert qualified immunity on Jones's false arrest claim, holding that he had probable cause for the arrest. The court also granted summary judgment on Jones's malicious prosecution claim, concluding that Naert did not participate in the decision to prosecute her. Jones appealed these decisions.The United States Court of Appeals for the Sixth Circuit reviewed the case and held that Officer Naert lacked probable cause to arrest Jones for disorderly conduct. The court found that Jones's actions did not indicate she would pose a danger to others by walking a short distance while intoxicated. However, the court affirmed the district court's decision to grant Naert qualified immunity because Jones failed to show that the unlawfulness of the arrest was "clearly established" at the time. The court also affirmed the summary judgment on the malicious prosecution claim, as there was no evidence that Naert influenced the decision to prosecute Jones. View "Jones v. Naert" on Justia Law

Eric Vaughn was pulled over for speeding, fled from the police, and discarded a pistol during the chase. As a convicted felon, he was indicted for unlawful possession of a firearm and pleaded guilty. The district court sentenced him to 53 months in prison and three years of supervised release, including several special conditions.At sentencing, Vaughn objected to the first special condition, which allowed the probation officer to determine the frequency of drug tests and whether he needed alcohol treatment. He requested a more specific schedule, but the district court overruled his objection, stating it would consider guidance if Vaughn felt over-tested. Vaughn did not object to the second special condition, which allowed the probation officer to decide if his mental health treatment should be inpatient or outpatient.The United States Court of Appeals for the Sixth Circuit reviewed Vaughn's appeal. Vaughn argued that the district court improperly delegated its judicial authority to the probation office by not specifying the details of his supervised release conditions. The court reviewed the first special condition de novo and the second for plain error due to Vaughn's failure to object at sentencing.The Sixth Circuit held that the district court did not improperly delegate its authority. It found that the court's use of "shall participate" language in the special conditions was sufficient to meet statutory and constitutional requirements. The court also noted that probation officers are allowed to determine the specifics of treatment programs. The court affirmed the district court's judgment, concluding that there was no improper delegation of judicial authority in Vaughn's supervised release conditions. View "United States v. Vaughn" on Justia Law

In May 2023, Martavious Kincaide pleaded guilty to three federal firearms offenses in the Western District of Kentucky. Deandre Swain, a criminal defendant in Kentucky state court, sought to intervene in Kincaide’s case to unseal a document titled “Plea Agreement Supplement.” Swain believed this document might contain a cooperation agreement that could aid his defense in his state court case. The Western District of Kentucky requires that all plea supplements, which may contain cooperation agreements, be sealed to protect cooperators from potential harm.The United States District Court for the Western District of Kentucky denied Swain’s motion to intervene. The court held that the General Order 2010-06, which mandates the sealing of plea supplements, was consistent with the First Amendment. The court reasoned that the order was the narrowest method to protect the safety of cooperators and that Swain’s specific interest did not override the need for consistency in applying the General Order.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s decision. The Sixth Circuit held that there is no qualified First Amendment right of access to cooperation agreements. The court applied the “experience and logic” test from Press-Enterprise Co. v. Superior Court, concluding that there is no historical tradition of public access to such documents and that public access would not play a significant positive role in the functioning of the judicial process. The court emphasized that public access to cooperation agreements could endanger cooperators and undermine government investigations. Thus, the denial of Swain’s motion to intervene was affirmed. View "United States v. Kincaide" on Justia Law

Ali Naji entered the Dearborn police station, pointed a gun at Corporal Timothy Clive, and attempted to shoot him. The gun malfunctioned, and while Naji tried to fix it, Clive shot and killed him. Hussein Naji, representing Ali Naji's estate, sued Clive and the City of Dearborn under 42 U.S.C. § 1983 for excessive force and state tort claims. The district court granted summary judgment in favor of Clive and the City on all claims.The United States District Court for the Eastern District of Michigan found that Clive's use of deadly force was objectively reasonable under the circumstances. Naji had pointed a gun at Clive and attempted to fire, posing an immediate threat. The court also noted that Clive was behind bulletproof glass and that the incident occurred in a busy police station. The court dismissed the claims against the City of Dearborn, as there was no underlying constitutional violation to support municipal liability.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo and affirmed the district court's decision. The court held that Clive's actions were objectively reasonable and that he had probable cause to believe Naji posed an immediate threat. The court also rejected the argument that Naji's mental illness should have altered the assessment of the threat. Additionally, the court found that Clive was entitled to qualified immunity and that the City of Dearborn could not be held liable without an underlying constitutional violation.The court also addressed the state law claims, finding that Clive acted in good faith and was immune from assault and battery claims under Michigan law. The court dismissed the gross negligence claim, noting that it was essentially an excessive force claim in disguise and that Naji's representative failed to establish a legal duty for Clive to follow internal departmental policies. The court affirmed the district court's grant of summary judgment in favor of Clive and the City of Dearborn. View "Naji v. City of Dearborn, Michigan" on Justia Law

Jonathon Neuhard was convicted by a jury of producing, receiving, and possessing child pornography. The evidence included testimony from his niece, MV1, who identified herself in the images and stated that Neuhard had taken them. Law enforcement found the images on a laptop and memory card in Neuhard's trailer, with metadata linking the images to his phone. Neuhard sought to vacate his sentence under 28 U.S.C. § 2255, claiming ineffective assistance of trial and appellate counsel.The United States District Court for the Eastern District of Michigan denied Neuhard's motion but granted a certificate of appealability. Neuhard argued that his trial counsel, Richard Korn, failed to adequately investigate and present evidence of his autism and did not request an evidentiary hearing regarding a government witness's mention of polygraph tests. He also contended that his appellate counsel was ineffective for not appealing the denial of his mistrial motion.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found that Korn had conducted a reasonable investigation into Neuhard's autism and made a strategic decision not to present this evidence at trial, fearing it would harm Neuhard's case. The court also determined that Neuhard did not suffer prejudice from Korn's failure to request an evidentiary hearing about the polygraph testimony, as the district court had issued a clear and immediate instruction to the jury to disregard the comment.Regarding appellate counsel, the court held that the decision not to appeal the mistrial denial was within the bounds of reasonable professional judgment. The court noted that appellate counsel had raised six other issues on appeal, and the mistrial claim was not clearly stronger than the issues presented.The Sixth Circuit affirmed the district court's denial of Neuhard's § 2255 motion. View "Neuhard v. U.S." on Justia Law

Tamir Abdullah, a federal prisoner convicted of crack-cocaine offenses, sought to reduce his life sentence under Section 404 of the First Step Act of 2018. This act made the Fair Sentencing Act's provisions retroactive, aiming to reduce sentencing disparities between crack and powder cocaine offenses. Abdullah argued that his conviction for conspiring to distribute between 500 grams and 1.5 kilograms of crack cocaine qualified as a "covered offense" under the First Step Act, making him eligible for a sentence reduction.The United States District Court for the Northern District of Ohio initially failed to address the merits of Abdullah's motion. Instead, it construed the motion as one for "compassionate release" due to the COVID-19 pandemic and denied it, citing the low number of COVID-19 cases in Abdullah's prison. Abdullah appealed this decision.The United States Court of Appeals for the Sixth Circuit reviewed the case and found that the district court had erred in its interpretation of Abdullah's motion. However, the appellate court affirmed the denial of the motion based on intervening case law. The court held that Abdullah was not entitled to a sentence reduction under the Fair Sentencing and First Step Acts because the changes in drug quantity thresholds did not affect his mandatory life sentence. Specifically, the Fair Sentencing Act increased the threshold for a mandatory life sentence from 50 grams to 280 grams of crack cocaine, but Abdullah's conviction involved quantities well above this new threshold.Therefore, the Sixth Circuit affirmed the district court's denial of Abdullah's motion for a sentence reduction, concluding that the district court had no discretion to reduce his sentence under the applicable laws. View "United States v. Abdullah" on Justia Law

The defendant, Tarrence Parham, pleaded guilty to being a felon in possession of a firearm. During sentencing, the district court increased his base offense level, concluding that his prior Tennessee conviction for attempted second-degree murder constituted a crime of violence under the Sentencing Guidelines. Parham appealed this conclusion and the district court’s refusal to dismiss the indictment on Second Amendment grounds.The United States District Court for the Western District of Tennessee denied Parham’s motion to dismiss the indictment, which argued that 18 U.S.C. § 922(g)(1) was unconstitutional under New York State Rifle & Pistol Ass’n v. Bruen. Parham then pleaded guilty to the single-count indictment. The Probation Office determined his base offense level was 22, considering his prior conviction for attempted second-degree murder as a crime of violence. Parham objected, but the district court overruled his objection and sentenced him to 108 months’ imprisonment, relying on an unpublished opinion from the Sixth Circuit.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s decision. The court held that the elements of attempted second-degree murder in Tennessee categorically match the Guidelines’ definition of a crime of violence. The court also found that Parham’s Second Amendment challenge was foreclosed by binding precedent, specifically United States v. Williams, which upheld the constitutionality of § 922(g)(1) both facially and as applied to individuals with a history of dangerous behavior. Consequently, the Sixth Circuit affirmed the district court’s judgment, including the calculation of Parham’s base offense level and the denial of his motion to dismiss the indictment. View "United States v. Parham" on Justia Law

The defendant, Sylvester Gailes, has a history of domestic violence, including multiple incidents where he physically assaulted his partners. In 2012, he struck his girlfriend in the face, and in 2014, he dragged her by her hair and kicked her in the head. In 2018, he assaulted another ex-girlfriend, choking her and threatening her with a handgun. Gailes was convicted of domestic-violence misdemeanors for each of these incidents. Later, during a traffic accident investigation, police found Gailes in possession of two loaded pistols, leading to his indictment for violating 18 U.S.C. § 922(g)(9), which prohibits individuals convicted of domestic-violence misdemeanors from possessing firearms.The United States District Court for the Western District of Tennessee denied Gailes's motion to dismiss the indictment, in which he argued that 18 U.S.C. § 922(g)(9) is unconstitutional in light of the Supreme Court's decision in New York State Rifle & Pistol Ass’n v. Bruen. Gailes then pleaded guilty to the charges and was sentenced to 50 months in prison. He appealed the district court's decision, challenging the constitutionality of the statute under the Second Amendment.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court applied the two-step framework from Bruen, first determining that the Second Amendment's plain text covers Gailes's conduct. The court then examined whether the statute is consistent with the Nation's historical tradition of firearm regulation. The court found that historical analogues, such as surety laws and "going armed" laws, support the constitutionality of disarming individuals who pose a clear threat of physical violence. Consequently, the court held that 18 U.S.C. § 922(g)(9) is facially constitutional and affirmed the district court's judgment. View "United States v. Gailes" on Justia Law

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