In United States v. Moreno Jackson, II, the defendant appealed his 212-month sentence after pleading guilty to illegally possessing a firearm as a felon under 18 U.S.C. § 922(g)(1). The district court applied the Armed Career Criminal Act (ACCA) enhancement based on Jackson’s prior convictions, imposing the 15-year mandatory minimum. The Sixth Circuit affirmed the sentence, holding that Jackson had waived any appellate challenge by expressly acknowledging in his plea agreement and at his plea hearing that he was subject to the ACCA enhancement due to at least three prior qualifying convictions. The court found this acknowledgment, combined with his confirmation that he understood the agreement’s terms and had reviewed them with counsel, precluded review of the sentence’s procedural reasonableness. A dissent argued that one prior drug conviction no longer qualified as an ACCA predicate under intervening Supreme Court precedent, constituting plain error.
The case arose after Linda Elam’s death at a Kentucky nursing home operated by BLC Lexington, prompting her estate’s executrix, Bonnie Townsend, to sue the facility in state court for wrongful death, negligence, and related claims. BLC Lexington responded by filing a federal action to enforce an arbitration agreement that Townsend had signed during Elam’s admission, seeking to halt the state proceedings and compel arbitration. The district court enforced the agreement as to most claims, an arbitrator ruled for BLC Lexington after a full hearing, and the district court confirmed the award; the Sixth Circuit affirmed. The court held that Townsend’s challenge to the arbitrator’s impartiality—based on a decades-old public censure—was both untimely under the FAA and unsupported by evidence of bias, and it found no indication that the arbitrator had applied an incorrect legal standard or otherwise exceeded his authority.
Oscar Rivera-Gaona, a Mexican citizen, overstayed a temporary agricultural worker visa in 2007 and was placed in removal proceedings in 2017. He applied for asylum, withholding of removal, and protection under the Convention Against Torture, claiming fear of harm from a neighbor and his family stemming from a 2004 altercation in Mexico over a romantic dispute. The immigration judge denied all relief, and the Board of Immigration Appeals affirmed. The Sixth Circuit held that it lacked jurisdiction to review the asylum claim due to its untimely filing and found that substantial evidence supported the denial of withholding and CAT relief, as Rivera-Gaona failed to show a likelihood of persecution or torture, had not faced threats since leaving Mexico in 2007, and provided no credible basis for not reporting incidents to authorities. The court therefore denied the petition for review.
The case involved Terrell Lamar Williams, who was serving a term of supervised release after pleading guilty to a cocaine conspiracy. While on release, he violated its conditions by defrauding an older woman of approximately $300,000 through a fake kidnapping scheme, repeatedly faking drug tests to conceal ongoing drug use, and driving with a suspended license. The district court revoked his supervised release, imposed a 30-month prison sentence, and added a special condition barring contact with his romantic partner, who had assisted in the fraud. On appeal, the Sixth Circuit affirmed, holding that the revocation and sentence were proper given the violations and that the no-contact condition was reasonably related to preventing further criminal activity, protecting the victim, and promoting public safety. The court noted that the condition allowed for future modification and did not necessarily infringe on any asserted right to marriage.
Daniel Westerling, a former security guard at East Tennessee Children’s Hospital, sued the hospital under the Fair Labor Standards Act, alleging that he was not paid overtime for work performed during meal periods that were automatically deducted from his paychecks. He claimed that he had to monitor his radio and remain available during those breaks, meaning they were not bona fide meal periods. The district court dismissed the complaint for failure to state a plausible claim and denied leave to amend. The Sixth Circuit affirmed, holding that the allegations were too conclusory because merely monitoring a radio and being available to respond does not constitute compensable work during meal breaks under the FLSA, and Westerling had not properly moved to amend with a proposed complaint.
In United States v. Stephen Duane Woods, Jr., the defendant appealed the denial of his motion to suppress a pistol found during a warrantless search of his car after he was charged as a felon in possession of a firearm. The Sixth Circuit affirmed the district court’s ruling. Officers responded to a reported domestic assault in which Woods allegedly put a gun to the victim’s chest; after locating him in his orange Dodge and failing to find the weapon on his person or in the surrounding area despite reasonable searches, they had probable cause to believe evidence of the crime was in the vehicle, permitting the search under the automobile exception to the Fourth Amendment warrant requirement.