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

The case revolves around Roy Christopher West, who is serving a life sentence without parole for a conviction that the district judge has attributed to a sentencing error. West was indicted in 2010 on a charge of conspiracy to use interstate commerce facilities in the commission of murder for hire. He was tried twice, and during the second trial, he was convicted and sentenced to life imprisonment without parole. However, the indictment did not include any allegation that personal injury or death resulted from the conspiracy, and the jury was not instructed that death was an element of West's offense. The district court sentenced West under the federal murder-for-hire statute, which imposes a life sentence in cases where "death results." The court concluded that sentencing West to life imprisonment under these circumstances violated West's constitutional rights.West initially moved to vacate his sentence under 28 U.S.C. § 2255, arguing that his trial counsel was ineffective for failing to investigate a causation defense. The district court denied that motion. West then moved for compassionate release, arguing that his unconstitutionally imposed life sentence, combined with his rehabilitation while incarcerated, created an extraordinary and compelling circumstance that warranted a sentence reduction. The district court agreed and reduced his sentence to time served. However, the Government appealed, and the appellate court reversed, holding that compassionate release could not be used as a vehicle for second or successive § 2255 motions.West then sought relief from judgment under Federal Rule of Civil Procedure 60(b). The district court construed West's motion as a second or successive § 2255 motion and transferred it. West opposed the transfer and asked the appellate court to remand to the district court for a ruling on the merits of his Rule 60(b) motion. The appellate court vacated the district court's order construing West's motion as a second or successive § 2255 motion and remanded the motion to the district court to consider under Rule 60(b). View "In re: West" on Justia Law

Emmanuel Merritt was convicted for being a felon in possession of firearms and was sentenced to 120 months in prison. Prior to his guilty plea, Merritt had spent several months evading authorities, leading the district court to deny him a two-point reduction in his total offense level for not accepting responsibility. Additionally, the district court increased Merritt's criminal history score by three points due to a past state offense that included a total prison sentence of 870 days. Merritt contested both decisions, arguing that his sentence was only 330 days due to credits he received.The United States District Court for the Western District of Michigan disagreed with Merritt's objections. It found that Merritt had not clearly demonstrated acceptance of responsibility and that his criminal history score was calculated correctly. Merritt was sentenced to a within-Guidelines sentence of 120 months in prison.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The appellate court found that the district court did not err in denying the two-point reduction for acceptance of responsibility, given Merritt's history of evading authorities. The court also upheld the district court's calculation of Merritt's criminal history score, ruling that the Guidelines required the addition of three points for Merritt's past state offense. View "United States v. Merritt" on Justia Law

Keita Jerrod Hayden was convicted for violating the terms of his supervised release for the second time. The district court imposed a seven-month term of incarceration followed by an eight-year term of supervised release. Hayden challenged his supervised-release term on two grounds: first, that it is longer than his statute of conviction allows, and second, that the district court violated his right to be present at sentencing by imposing the mandatory and standard conditions by reference.The district court had previously sentenced Hayden to a ten-year prison term and eight years of supervised release for knowingly and intentionally possessing with the intent to distribute a mixture containing cocaine base. Hayden violated the terms of his supervised release twice, first by driving under the influence of alcohol, and second by being intoxicated in a public place. Each time, the district court sentenced him to imprisonment followed by an eight-year supervised-release term.The United States Court of Appeals for the Sixth Circuit affirmed the district court's judgment. The court found that the district court did not exceed the statutory-maximum term of supervised release and provided Hayden with sufficient notice of the conditions to satisfy due process. The court also determined that the district court did not violate Hayden's due-process right by incorporating the standard supervised-release conditions by reference. The court concluded that the district court had followed an appropriate procedure in imposing four special discretionary conditions upon Hayden during his supervised release. View "United States v. Hayden" on Justia Law

The case involves Lance Tobias, who ran an operation shipping and receiving drugs and cash for dealers and their customers. He pleaded guilty to crimes involving the possession and distribution of fentanyl. The district court denied Tobias “safety-valve” relief, an offense-level reduction for defendants who make full disclosures to the government, citing Tobias’s failure to disclose any information regarding his customers. As a result, Tobias qualified for a ten-year mandatory minimum under 21 U.S.C. § 841(b)(1)(B). The court imposed the mandatory minimum and a $100,000 fine without calculating Tobias’s sentencing range under the United States Sentencing Guidelines. Tobias appealed the district court’s denial of safety-valve relief and his sentence.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s decision. The court found that the district court’s denial of safety-valve relief was supported by the record. The court also found that any sentencing error survives plain-error review. The court held that Tobias failed to provide the government with enough information to warrant safety-valve relief. The court also found that the district court’s failure to calculate Tobias’s Guidelines range before imposing the statutorily mandated minimum term of imprisonment and a $100,000 fine did not affect Tobias’s substantial rights. View "United States v. Tobias" on Justia Law

The case involves Brian Dewayne Darden-Mosby, who was convicted of two federal drug-dealing offenses. During the investigation, Drug Enforcement Agency (DEA) agents executed a search warrant for Darden-Mosby’s house and car, discovering an unregistered firearm, a money counter, drug ledgers, marijuana, and a backpack containing cocaine. They also seized $112,690 in cash found in various locations in his bedroom. After the search, police pulled over one of Darden-Mosby’s cocaine suppliers and found Darden-Mosby in the passenger seat with a bank envelope containing $2,500 in cash and two cashier’s checks totaling nearly $150,000.The United States prosecuted Darden-Mosby for various crimes based on the drugs and guns found in his house. As part of the prosecution, the government initiated criminal-forfeiture proceedings against the cash from Darden-Mosby’s bedroom, the two cashier’s checks, and the $2,500 found in Darden-Mosby’s pocket. Darden-Mosby sought to suppress the cashier’s checks and $2,500, arguing the detective’s search violated the Fourth Amendment. The district court denied the motion. The government ultimately opted not to introduce that evidence at trial, and it dismissed the criminal forfeiture claims against the two checks.A jury convicted Darden-Mosby of two drug-dealing offenses. The government declined to prosecute the forfeiture of the $2,500 in cash from the traffic stop any further but continued to pursue criminal forfeiture of the $112,690 from Darden-Mosby’s house. After a hearing and additional briefing, the court concluded the cash was connected to Darden-Mosby’s drug dealing and ordered the criminal forfeiture of the money.Separate from the government’s criminal-forfeiture actions, the DEA commenced administrative-forfeiture proceedings against the two cashier’s checks and the $2,500. These proceedings resulted in the administrative forfeiture of all three assets.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed in part and reversed in part. The court affirmed the district court’s criminal-forfeiture order with respect to the $92,470 found in the safe and shoebox at Darden-Mosby’s house but reversed with respect to the $20,220 found in and on the dresser. The court found that Darden-Mosby offered credible evidence that the $20,220 found on and in the dresser had legal sources and purposes. However, the court found that Darden-Mosby’s evidence was considerably weaker when it came to the $92,470 in the safe and shoebox. View "United States v. Darden-Mosby" on Justia Law

The case involves Tommy Kirtdoll, who was under investigation by a multijurisdictional task force in southwest Michigan for leading a drug-trafficking organization. After several undercover drug deals, the task force obtained a search warrant for Kirtdoll's house, which was described in detail in the warrant application. Upon executing the warrant, officers found drugs and distribution equipment, leading to Kirtdoll's indictment on multiple drug offenses.Kirtdoll challenged the validity of the search warrant, citing three errors: the address listed was not his, the tax identification number was incorrect, and the property owner's name was not his. He argued that these mistakes rendered the warrant unconstitutional due to lack of particularity, as required by the Fourth Amendment. The district court denied Kirtdoll's motion, ruling that the warrant's other accurate descriptors were particular enough to satisfy the Fourth Amendment. Kirtdoll pleaded guilty but reserved the right to appeal the district court's decision.The United States Court of Appeals for the Sixth Circuit reviewed the warrant's particularity de novo. The court held that the Fourth Amendment does not require perfection in search warrants, but rather enough detail for the executing officer to identify the intended place with reasonable effort. The court found that despite the errors, the warrant contained three descriptors that indisputably applied only to Kirtdoll's house and clearly identified it as the premises to be searched. These included the house's geographic location, a detailed description of the house, and a unique identifier - a red star affixed to its west side. The court concluded that the warrant for Kirtdoll's house was specific enough to meet the Fourth Amendment's particularity requirement, and thus, the district court properly denied Kirtdoll's motion to suppress. The court affirmed the district court's decision. View "United States v. Kirtdoll" on Justia Law

Calvin Caver was sentenced to life imprisonment for conspiring to distribute more than 50 grams of crack cocaine, having committed three prior felony drug offenses. The Fair Sentencing Act of 2010 later increased the amount of crack cocaine required to trigger a life sentence to 280 grams. The First Step Act of 2018 allowed defendants like Caver to seek retroactive relief as if they had committed their crimes after the Fair Sentencing Act. Caver sought a reduced sentence under the First Step Act, but the district court held that the Act gave it no discretion to grant him relief. The court reasoned that Caver's jury had found that his drug crime involved at least 500 grams of crack cocaine, an amount that still exceeded the 280 grams required to trigger a mandatory life sentence after the Fair Sentencing Act.The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court clarified that if the Fair Sentencing Act's changes would still trigger the same mandatory-minimum sentence that a district court originally imposed, a district court lacks discretion to reduce the defendant’s sentence below that minimum under the First Step Act. The court also noted that the First Step Act allows a court to impose a reduced sentence as if the Fair Sentencing Act were in effect at the time the covered offense was committed. The court concluded that no plausible reading of the First Step Act or the caselaw interpreting it permitted the district court to sentence Caver below the mandatory-minimum term that he faced under the Fair Sentencing Act. View "United States v. Caver" on Justia Law

The case involves Terrence Jordan and Damara Sanders, who were pulled over by a state trooper for speeding. During the stop, the trooper noticed inconsistencies in their travel plans and observed Jordan's heavy breathing, which raised his suspicion. He called for a canine unit, which detected the presence of drugs. A subsequent search of the vehicle and the defendants revealed marijuana, pill presses, digital scales, plastic baggies, firearms, and a significant quantity of pills containing a fluorofentanyl-fentanyl mixture.The defendants were charged with possessing a firearm as a felon, possessing a controlled substance with the intent to distribute, and possessing firearms in furtherance of drug trafficking. They sought to suppress the evidence obtained from the traffic stop, arguing that the trooper lacked reasonable suspicion to extend the stop. The District Judge denied the motion. The defendants also proposed a lesser-included-offense instruction for simple possession of a controlled substance, which the court rejected, citing the quantity of drugs and distribution paraphernalia as evidence of intent to distribute.The United States Court of Appeals for the Sixth Circuit affirmed in part, vacated in part, and remanded for further proceedings. The court held that the trooper had reasonable suspicion to extend the stop, based on the defendants' suspicious travel plans, Sanders's implausible explanations, and Jordan's heavy breathing. The court also agreed with the district court's decision not to give a lesser-included-offense instruction, given the substantial evidence of the defendants' intent to distribute drugs. However, the court vacated the defendants' convictions for possessing firearms in furtherance of drug trafficking due to an error in the jury instructions. The case was remanded for further proceedings consistent with the court's opinion. View "United States v. Jordan" on Justia Law

The case involves Carlos Brown, a defendant who was indicted on fraud and identity theft charges related to a credit card scheme. Brown argued that his right to a speedy trial, as stipulated by the Speedy Trial Act, was violated twice during the 1,176 days between his arraignment and his guilty plea. The first violation involved a 36-day delay in transporting Brown from Ohio to the Federal Medical Center in Lexington for his competency evaluation. The second violation involved a 21-day period after the denial of Brown’s first motion to dismiss.The district court denied both of Brown's motions to dismiss. It ruled that the 36-day delay was excludable and entered a 21-day retroactive ends-of-justice continuance after denying Brown's first motion to dismiss.The United States Court of Appeals for the Sixth Circuit found that the district court erred in denying both motions. The court held that the 36-day delay in transporting Brown was not excludable and that the district court abused its discretion by not properly placing its reasoning for the 21-day retroactive ends-of-justice continuance on the record. As a result, the court vacated Brown's conviction and remanded the case to the district court to determine whether his indictment should be dismissed with or without prejudice. View "United States v. Brown" on Justia Law

The case involves Jose Yanel Sanchez-Perez, a native and citizen of El Salvador, who entered the United States in 1998. In 2009, Sanchez-Perez pleaded guilty to committing misdemeanor domestic assault under Tennessee law. The following day, the Department of Homeland Security initiated removal proceedings against him. In 2015, an immigration judge found Sanchez-Perez ineligible for cancellation of removal because he failed to establish that he had been continuously present in the United States for ten years prior to receiving the notice to appear. However, the judge also found that Sanchez-Perez was not statutorily barred from seeking cancellation of removal due to his 2009 domestic-violence conviction.The Board of Immigration Appeals (BIA) dismissed Sanchez-Perez’s appeal and agreed with the immigration judge’s findings that Sanchez-Perez lacked the requisite continuous physical presence and thus was not eligible for cancellation of removal. In 2018, the immigration judge found that Sanchez-Perez’s 2009 conviction is categorically a crime of violence, and thus Sanchez-Perez was statutorily barred from obtaining cancellation of removal. The BIA dismissed Sanchez-Perez’s appeal from this decision.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found that the BIA erred in determining that Sanchez-Perez’s 2009 conviction was categorically a crime of violence, and thus Sanchez-Perez was statutorily barred from obtaining cancellation of removal. The court noted that the Tennessee statute at issue criminalizes conduct that does not require the use or threatened use of violent physical force. Therefore, the court granted Sanchez-Perez’s petition for review, vacated the BIA’s order, and remanded the case to the BIA for proceedings consistent with its opinion. View "Sanchez-Perez v. Garland" on Justia Law