The case involved Sean Christopher Williams, who was convicted after a jury trial in the Eastern District of Tennessee on three counts of manufacturing child pornography under 18 U.S.C. § 2251(a) and sentenced to 1,080 months in prison. Williams appealed, challenging the district court’s admission of evidence of his uncharged bad acts under Federal Rules of Evidence 404(b), 414, and 403; the sufficiency of the evidence on the interstate-commerce element; and the reasonableness of his within-Guidelines sentence. The Sixth Circuit affirmed in full. It held that the contested evidence was either intrinsic to the charged offenses or admissible to show motive, plan, opportunity, or propensity in a child-molestation case and was not unfairly prejudicial under Rule 403; that the government proved the jurisdictional element by showing the images were produced in Tennessee yet recovered on thumb drives in North Carolina, permitting a reasonable inference of interstate transport; and that the district court did not abuse its discretion in weighing the sentencing factors.
The case involved Sean Christopher Williams, who was indicted on a federal charge of possessing ammunition as a felon under 18 U.S.C. § 922(g)(1), along with later charges for producing child pornography and escaping federal custody. After four appointed attorneys withdrew due to breakdowns in the attorney-client relationship stemming from Williams’s refusal to follow their advice and his disruptive conduct, the district court allowed him to represent himself at trial, where he was convicted. On appeal, Williams argued that the district court exhibited bias through its handling of counsel issues, interruptions during his opening statement, warnings about his behavior, and denial of certain motions. The Sixth Circuit affirmed the conviction, holding that Williams’s own choices and repeated non-cooperation caused the loss of counsel and his pro se status. The court further found no evidence of judicial bias, concluding that the district court’s actions were permissible efforts to maintain order and facilitate proceedings rather than any deep-seated antagonism.
Oneka Spicer, an African American woman employed as a cleaner by Harvard Maintenance, Inc. from 2017 to 2018, sued the company under Michigan’s Elliott-Larsen Civil Rights Act, claiming race and sex discrimination plus a hostile work environment. She alleged that complaints about her work, written reprimands, a transfer between buildings, and her eventual suspension and termination after sitting in a tenant’s chair and failing to follow a supervisor’s directive were discriminatory. The Sixth Circuit affirmed the district court’s grant of summary judgment to Harvard and denial of reconsideration. The court held that Spicer failed to raise a genuine issue of material fact on any claim, because Harvard’s documented performance issues and policy violations provided legitimate, non-discriminatory reasons for its actions, Spicer admitted committing major violations, and the isolated incidents she cited were neither severe nor pervasive enough to create an abusive environment.
Charles Crenshaw sued the wardens of three prisons after his federal drug and firearm sentence was reduced from 30 years to roughly 23 years in May 2019 under the First Step Act, claiming he should have been released then rather than remaining in federal custody until his June 2020 transfer to Ohio for a parole violation; he alleged violations of the Fourth, Fifth, Eighth, and Fourteenth Amendments plus related federal and state tort claims, including under the Federal Tort Claims Act. The district court dismissed the complaint for failure to state a claim, and the Sixth Circuit affirmed. The court held the FTCA claim untimely because Crenshaw filed suit more than two years after the Bureau of Prisons denied his administrative claim and the six-month deadline had passed, with no basis for equitable tolling given his lack of diligence and absence of extraordinary circumstances. It further held that claims against the state wardens failed because the complaint alleged no specific actions by them that caused or contributed to his continued federal detention or any constitutional violation.
The case involved Sequoia Energy’s challenge to an award of benefits under the Black Lung Benefits Act to deceased coal miner Delbert Mitchell and his surviving spouse Amy Mitchell. The Sixth Circuit denied the petition for review and affirmed the Benefits Review Board’s decision. Mitchell had worked more than 15 years in underground coal mines and had a totally disabling pulmonary impairment, triggering a statutory presumption that his disability was due to pneumoconiosis arising from his coal-mine employment. Sequoia failed to rebut that presumption because its doctors’ opinions, which relied on negative chest x-rays to rule out legal pneumoconiosis or any contribution to disability, were properly discounted by the ALJ as inconsistent with the Act’s recognition that legal pneumoconiosis can exist without radiographic evidence. Substantial evidence supported the ALJ’s weighing of the medical opinions and the resulting award.
Marvin Johnson was convicted in Ohio state court of kidnapping and murdering his ex-girlfriend’s thirteen-year-old son and of raping and robbing the ex-girlfriend; he received a death sentence that was later vacated when a state court found him seriously mentally ill and resentenced him to life without parole. After exhausting state appeals, Johnson filed a federal habeas petition under 28 U.S.C. § 2254, which the district court denied. On appeal, the Sixth Circuit held that the resentencing mooted any penalty-phase claims but left the guilt-phase challenges intact. It reviewed the two certified claims—whether trial counsel was ineffective for allowing the jury to hear Johnson’s criminal history and whether appellate counsel was ineffective for failing to raise a Confrontation Clause objection to detectives’ testimony about statements from a jailhouse informant—and concluded that Johnson had not shown the state courts’ rejection of those claims was contrary to or an unreasonable application of clearly established federal law, nor that any assumed deficiencies caused prejudice to the guilt-phase outcome. The court therefore affirmed the denial of habeas relief.