6th Circuit Case Commentaries

Sanctions for Municipal “Lawfare”: Pattern-Based Frivolousness Under § 1927 and § 1988, and Broad Fee-Shifting Under T.C.A. § 29-20-113

Date: Mar 15, 2026

Sanctions for Municipal “Lawfare”: Pattern-Based Frivolousness Under § 1927 and § 1988, and Broad Fee-Shifting Under T.C.A. § 29-20-113 I. Introduction In Glenn Whiting v. City of Athens, Tennessee...

Rule 38 “Frivolous-as-Argued” Appeals: Sanctions for Fake Citations, Record Misrepresentation, and Defiance of Show-Cause Orders Under Appellate Inherent Authority

Date: Mar 15, 2026

Rule 38 “Frivolous-as-Argued” Appeals: Sanctions for Fake Citations, Record Misrepresentation, and Defiance of Show-Cause Orders Under Appellate Inherent Authority Case: Glenn Whiting v. City of...

Rule 11(b)(3) “Some Evidence” Suffices for § 2251(a) Pleas; Commerce Clause Attacks Are Waivable and Non‑Jurisdictional

Date: Mar 15, 2026

Rule 11(b)(3) “Some Evidence” Suffices for § 2251(a) Pleas; Commerce Clause Attacks Are Waivable and Non‑Jurisdictional Case: United States v. Austin David Stafford (6th Cir. Mar. 13, 2026) (not...

Dual-Use Locations and Leadership Conduct: Affirming §3B1.1(a) and §2D1.1(b)(12) Enhancements on Undisputed PSR/Plea Facts

Date: Mar 15, 2026

Dual-Use Locations and Leadership Conduct: Affirming §3B1.1(a) and §2D1.1(b)(12) Enhancements on Undisputed PSR/Plea Facts Case: United States v. Kevin Willie Carter (6th Cir. Mar. 13, 2026) (not...

Pattern-of-Lawfare Sanctions: Sixth Circuit Affirms Fees Under § 1927, § 1988, and T.C.A. § 29-20-113 for Frivolous Speech-Retaliation/Defamation Suits

Date: Mar 15, 2026

Pattern-of-Lawfare Sanctions: Sixth Circuit Affirms Fees Under § 1927, § 1988, and T.C.A. § 29-20-113 for Frivolous Speech-Retaliation/Defamation Suits I. Introduction Glenn Whiting v. City of...

Opening Statements Can Supply “Good Cause” to Excuse Rule 404(b) Notice and Admit Other-Acts Text Messages to Prove Knowledge/Intent

Date: Mar 15, 2026

Opening Statements Can Supply “Good Cause” to Excuse Rule 404(b) Notice and Admit Other-Acts Text Messages to Prove Knowledge/Intent I. Introduction In United States v. Dayton Peterson (Sixth...

United States v. Peterson & Lohden: Opening-Statement “Door-Opening” as Good Cause to Excuse Rule 404(b) Notice for Rebuttal Other-Acts Evidence

Date: Mar 15, 2026

United States v. Peterson & Lohden: Opening-Statement “Door-Opening” as Good Cause to Excuse Rule 404(b) Notice for Rebuttal Other-Acts Evidence Introduction In United States v. Dayton Peterson and...

Strict Substantiation and Timing for § 162 Legal Fees, § 165 Theft Losses, and § 172 NOL Carryovers (Sixth Circuit)

Date: Mar 14, 2026

Strict Substantiation and Timing for § 162 Legal Fees, § 165 Theft Losses, and § 172 NOL Carryovers (Sixth Circuit) I. Introduction Case: Michael H. Shaut v. Commissioner of Internal Revenue (6th...

Lowrance v. CoreCivic: Pleading Standards for Deliberate Indifference and Monell Liability—No § 1983 Claim from an Isolated Intake-Referral Lapse or General Understaffing Allegations

Date: Mar 14, 2026

Lowrance v. CoreCivic: Pleading Standards for Deliberate Indifference and Monell Liability—No § 1983 Claim from an Isolated Intake-Referral Lapse or General Understaffing Allegations I. Introduction...

Good Moral Character for Post-Conclusion Voluntary Departure Is Assessed Through Adjudication (Post-Application Conduct May Be Considered)

Date: Mar 14, 2026

Good Moral Character for Post-Conclusion Voluntary Departure Is Assessed Through Adjudication (Post-Application Conduct May Be Considered) I. Introduction In Diego Arateco-Munoz v. Pamela Bondi (6th...

Repeated Written Demands to Proceed Pro Se Effect a Knowing Waiver of Appellate Counsel; Defaulted Trial-IAC Claims Fail Absent a “Substantial” Strickland Showing

Date: Mar 14, 2026

Repeated Written Demands to Proceed Pro Se Effect a Knowing Waiver of Appellate Counsel; Defaulted Trial-IAC Claims Fail Absent a “Substantial” Strickland Showing Introduction In Scot Gaither v. Tim...

Ambiguous “No Competition” Franchise Clause Bars Preliminary Rate Injunction, but City Lacks Charter Power to Regulate Mainland Ferry Parking

Date: Mar 14, 2026

Ambiguous “No Competition” Franchise Clause Bars Preliminary Rate Injunction, but City Lacks Charter Power to Regulate Mainland Ferry Parking Case: Shepler's Inc. v. City of Mackinac Island, Michigan...

Enforcing Appeal Waivers to Bar Review of Plea-Withdrawal Denials and Applying Leon Good-Faith Where Warrants Show a “Modicum of Evidence” of Nexus

Date: Mar 14, 2026

Enforcing Appeal Waivers to Bar Review of Plea-Withdrawal Denials and Applying Leon Good-Faith Where Warrants Show a “Modicum of Evidence” of Nexus I. Introduction Case: United States v. Claibon...

United States v. Elijah Chappell: Ongoing-Emergency 911/Bodycam Statements as Nontestimonial Evidence and “Probable-Cause-Independent” Franks Challenges in § 922(g)(1) Cases

Date: Mar 14, 2026

United States v. Elijah Chappell: Ongoing-Emergency 911/Bodycam Statements as Nontestimonial Evidence and “Probable-Cause-Independent” Franks Challenges in § 922(g)(1) Cases I. Introduction Parties:...

Reasoned-Basis Discretion to Deny § 3582(c)(2) Relief After Retroactive Amendment 821 Without Detailed Disparity Findings

Date: Mar 14, 2026

Reasoned-Basis Discretion to Deny § 3582(c)(2) Relief After Retroactive Amendment 821 Without Detailed Disparity Findings 1. Introduction United States v. Wydell Dixon (6th Cir. Mar. 12, 2026)...

Sixth Circuit: Handcuffed Hallway Terry Stops May Be Reasonable; Suppression Theories Raised Only After Hearings Need Not Be Decided

Date: Mar 14, 2026

Sixth Circuit: Handcuffed Hallway Terry Stops May Be Reasonable; Suppression Theories Raised Only After Hearings Need Not Be Decided 1) Introduction United States v. Gregory Kilgore, III (6th Cir....

KRS § 413.245 Discovery Is Triggered by Notice of Injury—Not a Later Judicial Interpretation (Trust-Drafting Malpractice)

Date: Mar 13, 2026

KRS § 413.245 Discovery Is Triggered by Notice of Injury—Not a Later Judicial Interpretation (Trust-Drafting Malpractice) Case: Mary Eitel v. Stoll Keenon Ogden PLLC (6th Cir. Mar. 11, 2026) (not...

Speculation Is Insufficient to Show Jury Deadlock or Merits-Based Juror Removal; Alternate Substitution Requires a Clear Showing of Prejudice

Date: Mar 13, 2026

Speculation Is Insufficient to Show Jury Deadlock or Merits-Based Juror Removal; Alternate Substitution Requires a Clear Showing of Prejudice I. Introduction United States v. Tevye Tyshear Shelton...

United States v. Vijaya Shetty — Factual-Basis Review at “Judgment” and Whole-Record Plain-Error Analysis of Guilty Pleas

Date: Mar 13, 2026

United States v. Vijaya Shetty: Rule 11 Factual Basis Is Measured When the District Court Enters Judgment—and Appellate Review May Use the Entire Record Under Plain-Error Review Court: U.S. Court of...

Severance Releases Bar Discrimination Claims When “Knowing and Voluntary”: Clear Terms, Ample Review Time, and Signature Create a Strong Presumption of Validity

Date: Mar 12, 2026

Severance Releases Bar Discrimination Claims When “Knowing and Voluntary”: Clear Terms, Ample Review Time, and Signature Create a Strong Presumption of Validity I. Introduction Nakisha West v. Dow...