Chad Andrew Readler

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.

criminal lawprocedurefederal power

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.

criminal lawgunsprocedure

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.

civil rightslabor & employment

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.

criminal lawcivil rightstorts & liabilityprocedure

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.

labor & employmenthealthcare

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.

criminal lawprocedurefederal power

Scott Allen DeBruyn was convicted by a Michigan jury of delivering oxycodone to his friend Camille Gesiakowski, resulting in her death from an overdose shortly after her release from jail. He moved for a new trial on grounds of ineffective assistance of counsel, arguing that his trial attorneys failed to adequately investigate and present evidence of alternative causes of death, such as difluoroethane inhalation from air duster or a seizure due to abrupt cessation of anti-seizure medication. State courts denied relief on the merits, and the federal district court denied his subsequent habeas petition. The Sixth Circuit affirmed, holding that DeBruyn failed to meet AEDPA’s requirements because he could not show that the state courts unreasonably applied Strickland’s prejudice prong; his new expert evidence established only theoretical possibilities rather than a reasonable probability that the jury would have reached a different verdict.

criminal lawprocedure

The case involved a class action by Newtyn Partners and another fund against Alliance Data Systems (now Bread Financial) and three executives, alleging securities fraud in connection with ADS’s 2021 spinoff of its LoyaltyOne division into a new public company called Loyalty Ventures. Plaintiffs claimed that defendants made misleading statements portraying Loyalty as a stable business with long-term prospects, while concealing the loss of a major AIR MILES client and other weaknesses that later contributed to Loyalty’s bankruptcy. The Sixth Circuit affirmed the district court’s dismissal of the complaint, holding that Newtyn failed to plead with particularity either actionable false or misleading statements or a strong inference of scienter, as the challenged statements were either non-actionable opinions or forward-looking statements protected by the PSLRA safe harbor, and the complaint did not show defendants knew the spinoff would fail. The court applied the same analysis to reject the alternative scheme-liability claims under Rule 10b-5(a) and (c), and dismissed the control-person claims because they required an underlying primary violation.

business & regulatory

In United States v. Tomarcus Baskerville, the Sixth Circuit addressed appeals by three members of the Junk Yard Dogs gang—Tomarcus Baskerville, Courtland Springfield, and Thomas Earl Smith—who were convicted after a jury trial in federal district court in Tennessee on charges including racketeering conspiracy, murder and attempted murder in aid of racketeering, and firearm offenses arising from a series of gang-related shootings in the Memphis area in 2020. The court affirmed all three defendants’ convictions, rejecting challenges to the sufficiency of the evidence and various constitutional and evidentiary claims, including arguments about the admission of summary charts under Federal Rule of Evidence 403. However, consistent with the government’s concession of error, the court vacated Smith’s sentence on one § 924(c) firearm count and remanded for resentencing because the district court had improperly imposed a 10-year mandatory minimum based on firearm discharge when the jury had found only that Smith carried or used a firearm.

criminal lawgunsprocedure

Charles Bozzo, a former Michigan Department of Corrections correctional officer, sued two MDOC employees under 42 U.S.C. § 1983 after his 2019 termination for alleged harassing comments toward a coworker. He claimed the termination and subsequent arbitration process violated his constitutional rights, primarily under the Fourteenth Amendment’s procedural due process guarantee. The district court dismissed the case as barred by the statute of limitations and for failure to state a claim; the Sixth Circuit affirmed. The court reasoned that Bozzo’s claims accrued no later than March 2021 when the arbitrator ruled against him, but he did not file suit until December 2023. It further held that the arbitration hearing under his collective bargaining agreement—conducted before a neutral arbitrator with opportunities to present evidence and challenge the opposing side—provided constitutionally adequate post-termination process, and his allegations of arbitrator bias or errors concerned the outcome rather than any procedural defect.

labor & employmentcivil rightsprocedure

The case involved a dispute among plaintiffs' law firms over the process and allocation of attorney's fees following a $600 million class-action settlement in the East Palestine train derailment litigation. Morgan & Morgan, which had received nearly $8 million in fees, appealed after the district court declined to revisit its prior fee orders, contending that the quick-pay provisions and lack of detailed review violated fairness requirements. The Sixth Circuit largely affirmed the district court's rulings, reasoning that greater supervision of the allocation process was needed under Rule 23 but that the overall fee decisions were sound, while remanding solely for further consideration of Morgan & Morgan's specific share based on audit data and multiplier information.

procedure

Kevin Lamb sued inspector Scott Crofoot and Jonesfield Township after Crofoot entered Lamb’s property without permission, posted a stop-work order, and later mailed a violation notice for constructing a greenhouse in his front yard in breach of local zoning rules; Lamb alleged Fourth and Fourteenth Amendment violations under 42 U.S.C. § 1983, challenged the zoning ordinance itself, and asserted a state trespass claim. The district court dismissed the entire complaint with prejudice. The Sixth Circuit affirmed the dismissal of the constitutional claims, holding that Lamb had no protected property interest in building in violation of the ordinances and that Crofoot’s limited entry to post the order was neither a search nor a seizure. It reversed in part, however, instructing that the facial and as-applied challenges to the specific zoning provision and the trespass claim be dismissed without prejudice for lack of standing and because the court had declined supplemental jurisdiction.

civil rightspropertyproceduretorts & liability

The case arose from a class-action settlement approving Norfolk Southern’s $600 million payment to resolve claims by residents and businesses affected by the 2023 East Palestine train derailment and chemical release. Five objecting class members appealed the district court’s approval of the settlement; the district court then ordered them to post an $850,000 appeal bond by January 30, 2025, to cover potential administrative and taxable costs. The objectors neither paid the bond nor sought a stay, and more than eight months later they filed a motion— one day after the deadline—to extend the time to pay or reduce the bond amount. The Sixth Circuit held it lacked jurisdiction over the untimely motion to extend and therefore dismissed that appeal; it also dismissed the underlying appeals of the settlement itself because the objectors had failed to post the required bond. The court noted that the objectors had expressly declined to treat their filings as a stay request, leaving no procedural avenue to review the bond order on the merits.

proceduretorts & liabilityenvironment

Charles Bozzo, a former Michigan Department of Corrections correctional officer, sued two MDOC officials under 42 U.S.C. § 1983 after his 2019 termination for alleged workplace harassment, claiming violations of multiple constitutional rights including Fourteenth Amendment procedural due process. The district court dismissed the case as untimely under the statute of limitations and for failure to state a claim, and the Sixth Circuit affirmed. The court held that Bozzo’s claims accrued at his termination in 2019 and were time-barred when filed in 2023. On the remaining procedural due process claim, the court concluded that the three-day arbitration hearing provided under Bozzo’s collective bargaining agreement satisfied constitutional requirements, as it included a neutral decisionmaker, representation, and an opportunity to present and challenge evidence; his allegations of bias or unfairness concerned the outcome rather than the adequacy of the procedures themselves.

civil rightslabor & employmentprocedure

Darryl Broadnax, a Black Muslim man, sued Rhombus Energy Solutions under Title VII and Michigan law after the company fired him from his production-manager role, alleging that the termination was due to his race, religion, and his report of a coworker’s use of the word “colored” rather than legitimate performance concerns. Rhombus countered that it had hired Broadnax based on a fabricated resume and terminated him after multiple incidents of unauthorized discipline, harassment of employees, and policy violations that created a “mutiny” on the production floor. The district court granted summary judgment to Rhombus on all claims, and the Sixth Circuit affirmed. The appeals court held that Broadnax failed to show Rhombus’s stated reasons were pretextual or that any protected activity caused the firing, and he forfeited arguments on his hostile-work-environment claim by not demonstrating prejudice from the district court’s sua sponte ruling or offering contrary evidence on appeal.

civil rightslabor & employmentprocedure

Diego Pavia, a Vanderbilt quarterback, sued the NCAA after its eligibility rules—particularly the “JUCO Rule” counting seasons played at junior college toward the four-season limit—barred him from playing in the 2025 season. The district court issued a preliminary injunction in his favor, and the NCAA appealed. While the appeal was pending, the NCAA granted Pavia a waiver allowing him to play for Vanderbilt in 2025. The Sixth Circuit dismissed the appeal as moot, holding that the waiver gave Pavia complete relief at the preliminary-injunction stage and eliminated any live controversy. The court noted that Pavia’s underlying antitrust challenge to the JUCO Rule remains for further proceedings on remand.

business & regulatoryprocedure

In United States v. Daniel Jackson, the defendant was convicted by a jury of possessing methamphetamine and fentanyl with intent to distribute after a traffic stop in Kentucky, during which officers found the drugs in his truck and in the back seat of a police cruiser where he had been seated. Jackson testified at trial that officers planted the drugs, but the jury rejected his account. On appeal, the Sixth Circuit affirmed the district court's 97-month sentence, which included an obstruction-of-justice enhancement for perjury, because the jury's verdict combined with the evidence of the drugs' location and discovery supported the finding that Jackson knowingly lied under oath, consistent with Supreme Court precedent allowing such enhancements without violating the right to testify. The court also upheld a supervised-release condition permitting searches of Jackson's electronic devices, ruling under plain-error review that the district court adequately explained the condition as necessary for officer safety and to reduce recidivism risk given Jackson's refusal to accept responsibility.

criminal lawprocedure

Elva Trinidad-Contreras, a Mexican citizen who entered the U.S. unlawfully in 2003, sought cancellation of removal under 8 U.S.C. § 1229b(b)(1) on the ground that her deportation would cause exceptional and extremely unusual hardship to her two U.S.-citizen sons. An immigration judge denied relief after a hearing, finding the claimed economic, educational, cultural, and medical hardships insufficient, and the Board of Immigration Appeals affirmed. The Sixth Circuit dismissed the petition in part for lack of jurisdiction over factual arguments and denied it in part, concluding that the agency correctly applied the statutory standard because the asserted hardships—such as lower wages, adjustment to life in Mexico, and routine medical needs—did not rise beyond those ordinarily accompanying removal.

immigration

Tiffany Boggs was convicted in 2022 of conspiracy and possession with intent to distribute methamphetamine, and after serving her prison term she began a three-year period of supervised release that required her to abstain from drugs, submit to testing, and complete mental health and substance abuse treatment. She repeatedly violated those conditions through theft, drug use, attempts to falsify a drug test, termination from a treatment program, and fleeing from an arrest warrant, prompting the district court to revoke her supervised release and impose a six-month prison sentence. On appeal, Boggs argued that her sentence was procedurally unreasonable because the district court wrongly rejected her claim that her father’s recent death had caused her violations by impairing her mental health. The Sixth Circuit affirmed, holding that the district court did not abuse its discretion or rely on clearly erroneous facts, as the violations formed an ongoing pattern that began before the father’s death and could not be attributed to that single event.

criminal law

Avis Coward, a convicted felon, pled guilty to possessing a firearm in violation of 18 U.S.C. § 922(g)(1) after a child fatally shot himself with Coward’s handgun, prompting Coward to direct others to hide the weapon, destroy evidence, and conceal the vehicle involved. He moved to dismiss the charge on Second Amendment grounds and appealed the district court’s application of a sentencing enhancement under U.S.S.G. § 3B1.1(c) for his leadership role in the ensuing evidence-tampering conspiracy. The Sixth Circuit affirmed both the conviction and the sentence. It upheld the felon-in-possession prohibition as consistent with the Second Amendment and found the enhancement proper because Coward recruited accomplices, supplied them with critical location and disposal instructions, monitored their progress via coded calls, and stood to benefit most from the scheme.

gunscriminal lawprocedure