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

The case revolves around Gregory Rogers, who was convicted of various drug and firearm-related crimes. The evidence leading to his conviction was obtained from his girlfriend's car, where he was found alone in the passenger seat. Rogers claimed that the evidence was collected in violation of his Fourth Amendment rights, arguing that he had a legitimate expectation of privacy in the vehicle.Previously, the trial court had denied Rogers' motion to suppress the evidence. The court ruled that Rogers lacked a legitimate expectation of privacy in the vehicle as he was neither the owner nor the driver of the car and failed to show that he had permission to occupy it. The court also determined that the search was a valid inventory search. After trial, a jury convicted Rogers on all six counts.The United States Court of Appeals for the Sixth Circuit affirmed the trial court's decision. The court agreed with the trial court that Rogers had no legitimate expectation of privacy in the vehicle. The court noted that Rogers had not exhibited a subjective expectation of privacy. He was neither the owner nor the driver of the vehicle, and he had not shown that he had "complete dominion and control" over the car. The court also noted that Rogers had twice informed the police that the car was not his and had loudly disclaimed his authority over the vehicle. Therefore, the court concluded that Rogers could not establish that the police had violated his Fourth Amendment rights. View "United States v. Rogers" on Justia Law

The case involves two separate appeals by Brian Witham and Michael Savage, both of whom pleaded guilty to various federal crimes, including one count each of using, carrying, and brandishing a firearm in relation to a crime of violence under 18 U.S.C. § 924(c). As part of their plea deals, the government dismissed additional charges under the same statute. Later, both Witham and Savage sought to vacate their § 924(c) convictions, arguing that their offenses did not constitute "crimes of violence" in light of a subsequent Supreme Court ruling in United States v. Davis.In the lower courts, both Witham and Savage's motions to vacate their § 924(c) convictions were rejected. The courts reasoned that they had procedurally defaulted their claims by failing to raise them on direct appeal. The courts also held that their claims of actual innocence of the attempted bank extortion/firearm charge did not excuse the default because they could not show their innocence with respect to the other dismissed firearms charges.The United States Court of Appeals for the Sixth Circuit affirmed the lower courts' decisions. The court held that a defendant who has accepted a plea bargain may not collaterally attack his conviction unless he can show that he is actually innocent of equally or more serious charges dismissed as part of the bargain. Because Witham and Savage's plea agreements both involved the dismissal of § 924(c) charges, and because neither of them has shown actual innocence of the dismissed charges, the court ruled that their procedural defaults could not be excused. View "Witham v. United States" on Justia Law

The case involves two separate appeals by Brian Witham and Michael Savage, who pleaded guilty to various federal crimes, including using a firearm during a crime of violence. Both appellants later sought to vacate their convictions under 28 U.S.C. § 2255, arguing that their offenses no longer qualified as crimes of violence under United States v. Davis. The district courts rejected their motions, reasoning that they had procedurally defaulted their claims by failing to raise them on direct appeal. The courts also held that the appellants could not demonstrate their "actual innocence" of other serious charges that the government had dismissed as part of their plea deals.The United States Court of Appeals for the Sixth Circuit affirmed the lower courts' decisions. The court held that a defendant who secures the dismissal of equally serious charges through a plea bargain must demonstrate his "actual innocence" of those charges to avoid procedural default. The court rejected the appellants' arguments that the rule should only apply to more serious charges and that a statute enacted after the Supreme Court's decision in Bousley v. United States had changed the landscape. The court concluded that the statute, 18 U.S.C. § 3296, did not speak to the issue at hand and did not undermine the rationale of Bousley. View "Savage v. United States" on Justia Law

In the case before the United States Court of Appeals for the Sixth Circuit, the defendant, Jyoti Agrawal, was convicted of three financial crimes. Agrawal had obtained over $1.5 million in federal and state grants to research and develop a scanning electron microscope. However, she forged a letter in her company’s application to the Department of Energy, and later lied about how the funds were spent. She diverted a portion of the grant funds for personal expenses, including her MBA. The district court found that Agrawal's conduct caused a loss of $1,548,255, which was used to calculate her sentencing guidelines range. She was also ordered to pay restitution of the same amount.On appeal, Agrawal challenged the district court’s evidentiary and instructional rulings at trial, its estimate of the amount of loss from her fraud, and its decision to find her personal property forfeitable due to the fraud. However, the Court of Appeals found that the alleged evidentiary and instructional errors were harmless, the district court properly refused to offset its loss amount by her project expenses, and the court properly subjected her personal property to forfeiture because she commingled that property with grant funds.Furthermore, the court rejected Agrawal's challenges to her sentence, including her claim that the court identified an incorrect guidelines range, miscalculated the restitution amounts, and entered an illegal forfeiture judgment. The court affirmed the lower court's decision. View "United States v. Agrawal" on Justia Law

In the case under review, the appellant, Lafayette Deshawn Upshaw, was convicted of crimes associated with two separate incidents occurring on the same day: a gas station robbery and a home invasion. Following exhaustion of state court remedies, Upshaw sought habeas relief in federal court, upon which the district court granted relief on claims of ineffective assistance of counsel and violation of the Batson rule.The ineffective assistance of counsel claim was based on trial counsel's failure to investigate potential alibi witnesses. The Batson rule violation claim was derived from the State’s use of peremptory challenges to strike six Black jurors. The Warden appealed the district court's decision, but the United States Court of Appeals for the Sixth Circuit affirmed the lower court's ruling.The court found that the trial counsel's failure to investigate potential alibi witnesses and to request an adjournment to rectify the situation was unreasonable and prejudicial to Upshaw, constituting ineffective assistance of counsel. The court also found that the State's failure to provide race-neutral reasons for striking certain jurors, coupled with the trial court's failure to properly evaluate the State's justifications, constituted a violation of the Batson rule. The court held that even a single racially motivated peremptory strike requires relief. The court concluded that both of these errors entitled Upshaw to habeas relief. View "Upshaw v. Stephenson" on Justia Law

The case involved Ricardo Alvarado, who was convicted of possessing a firearm as a felon under 18 U.S.C. § 922(g)(1). His crime was reported by officers who responded to a call that a man was carrying what appeared to be a machine gun in a mobile home park. Alvarado was found with a Ruger AR-556 semi-automatic rifle, and upon investigation, officers discovered that he had two prior felony convictions. He was sentenced to 104 months' imprisonment, including a four-level sentencing enhancement for reckless endangerment.Alvarado appealed his conviction and sentence. He contended that his conviction violated the Second Amendment based on the standard articulated in New York State Rifle & Pistol Ass’n v. Bruen, an issue he raised for the first time on appeal. He also argued that the evidence did not support a sentencing enhancement for reckless endangerment.The United States Court of Appeals for the Sixth Circuit affirmed Alvarado’s conviction but vacated his sentence and remanded the case to the district court for resentencing. The court found that the constitutionality of § 922(g)(1) under Bruen was subject to reasonable dispute and would not disturb Alvarado’s conviction on plain error review. However, the court found that the district court erred in applying a sentencing enhancement for reckless endangerment. Without record evidence of anyone in proximity to Alvarado’s line of fire, or otherwise facing an imminent risk of harm, the Government could not satisfy Tennessee’s zone of danger requirement. Consequently, Alvarado's sentence was vacated. View "United States v. Alvarado" on Justia Law

The case revolves around an appeal by Karnail Singh, who was charged with using a fraudulently procured passport and making false statements to immigration officials. Singh pleaded guilty to using a fraudulently procured passport in exchange for a lower sentencing range and the dismissal of the false-statement count. After his plea, the government initiated proceedings to revoke his citizenship. In response, Singh petitioned for a writ of coram nobis, requesting the district court to set aside his conviction, arguing he would not have pled guilty had he known his plea could affect his citizenship. The district court denied his petition, leading to this appeal.The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court ruled that Singh's plea was knowing and satisfied due process, regardless of whether he understood it could impact his citizenship. They found that the district court complied with Rule 11 of the Federal Rules of Criminal Procedure, which requires the court to inform the defendant that a conviction may have immigration-related consequences.Singh also claimed ineffective assistance of counsel, arguing his attorney incorrectly informed him that his plea would only affect his citizenship if he committed another crime. The court rejected this claim, citing lack of evidence that Singh would have chosen to go to trial if he had received different advice from his counsel.Finally, the court rejected Singh's argument that the district court should have held a hearing before ruling on his coram nobis petition, stating that the record clearly showed Singh was not entitled to coram nobis relief. View "United States v. Singh" on Justia Law

Timothy Jaimez was found guilty of federal drug charges and sentenced to supervised release. Following several violations of the terms of his release, the district court sentenced him to sixty months' imprisonment. Jaimez appealed the decision, arguing that his sentence was both procedurally and substantively unreasonable.The United States Court of Appeals for the Sixth Circuit disagreed with Jaimez's arguments. Jaimez claimed that the court inadequately explained his sentence, improperly considered certain sentencing factors, and incorrectly classified his release violation. The appellate court found that the district court had sufficiently explained the sentence, correctly considered relevant sentencing factors, and accurately classified the release violation.Jaimez also argued that his sentence was substantively unreasonable. He claimed that the court placed too much weight on his conduct underlying the release violation, inflicted "double punishment" by considering conduct for which he had already been punished in Ohio, and imposed a sentence that was too long in light of mitigating evidence. The appellate court disagreed with all of these points, finding that the district court had appropriately weighed Jaimez's conduct and that the sentence did not constitute "double punishment." The court also found that the sentence length was reasonable given the circumstances.The appellate court upheld the district court's sentence of sixty months' imprisonment for Jaimez. The holding of the case is that the district court correctly considered the relevant sentencing factors, accurately classified the release violation, and imposed a reasonable sentence given the circumstances. The court affirmed the district court's decision. View "United States v. Jaimez" on Justia Law

In this case, the United States Court of Appeals for the Sixth Circuit considered an appeal by Herbert Marsh, who was convicted of various charges related to a robbery of a Nashville pawn shop. Marsh and two co-conspirators stole eleven firearms and over $8,000 in cash. Marsh challenged the denial of his motion to suppress evidence obtained from a traffic stop the day after the robbery, arguing the stop was based on a mistaken interpretation of Tennessee traffic law. The court held that the officers' interpretation was objectively reasonable and did not violate the Fourth Amendment, affirming the denial of Marsh's motion to suppress.Marsh also argued that the calculation of his sentence was procedurally unreasonable. The court rejected Marsh's argument that the district court's calculations constituted double counting, finding that the district court’s factual findings fully supported holding Marsh accountable for his co-conspirator’s conduct through the base offense level and the enhancements. The court held that the base offense level and the three firearms enhancements penalized Marsh for distinct harms, so there was no impermissible double counting. Consequently, the court affirmed the judgment of the district court. View "United States v. Marsh" on Justia Law

In this case adjudicated by the United States Court of Appeals for the Sixth Circuit, Fred Golson, Jr. had pleaded guilty to two counts of being a felon in possession of a firearm and ammunition. The district court added a two-level enhancement to Golson's sentencing guidelines range, based on the assessment that his flight from law enforcement during one of the underlying incidents amounted to reckless endangerment. Golson challenged this enhancement, arguing that he wasn't the driver of the vehicle during the incident.The appellate court affirmed the district court's decision. It found that, despite Golson not being the driver, the undisputed facts of the case created a reasonable inference that he was an active participant in the reckless flight from police. The court considered Golson's active participation in the crime, his extensive criminal record, his immediate flight from the crashed vehicle, and his subsequent involvement in another shooting and immediate flight from that scene as indicators of his active participation in the reckless flight. Consequently, the court found no error, plain or otherwise, in the district court's application of the two-level enhancement. View "United States v. Golson" on Justia Law