6th Circuit Case Commentaries

United States v. Benavides: Defendant Bears the Burden to Prove Eligibility for the § 4C1.1 “Zero-Point Offender” Reduction (Including No Firearm Connection)

Date: Aug 8, 2026

United States v. Benavides: Defendant Bears the Burden to Prove Eligibility for the § 4C1.1 “Zero-Point Offender” Reduction (Including No Firearm Connection) 1. Introduction In United States v. Hugo...

Sixth Circuit: No ADA Accommodation Duty Without Timely Medical Verification; “Honest Belief” Defeats Pretext; Rule 60(b)(3) Trial-Fraud Claims Waived Without Mistrial

Date: Aug 8, 2026

Sixth Circuit: No ADA Accommodation Duty Without Timely Medical Verification; “Honest Belief” Defeats Pretext; Rule 60(b)(3) Trial-Fraud Claims Waived Without Mistrial Introduction In Yarlen Henry v....

United States v. Starling: Tennessee § 39-17-417(c)(1) Cocaine Convictions Are ACCA “Serious Drug Offenses”; Untimely Erlinger Indictment/Ocassions Challenge Gets Plain-Error Review

Date: Aug 8, 2026

United States v. Starling: Tennessee § 39-17-417(c)(1) Cocaine Convictions Are ACCA “Serious Drug Offenses”; Untimely Erlinger Indictment/Occasions Challenge Gets Plain-Error Review 1. Introduction...

United States v. Evan Galasso — Harmless-Error Mootness of a Miranda Custody Dispute After a Conditional Plea, and Admissibility of a Post-Warning Polygraph Confession Under Seibert

Date: Aug 8, 2026

Harmless-Error Mootness of a Miranda Custody Dispute After a Conditional Plea, and Admissibility of a Post-Warning Polygraph Confession Under Seibert 1. Introduction United States v. Evan Galasso...

Sixth Circuit: “Class-of-One” Equal-Protection Challenges to USPS Mail-Delivery Service Must Be Filed at the Postal Regulatory Commission Under 39 U.S.C. § 3662

Date: Aug 8, 2026

Sixth Circuit: “Class-of-One” Equal-Protection Challenges to USPS Mail-Delivery Service Must Be Filed at the Postal Regulatory Commission Under 39 U.S.C. § 3662 1. Introduction In Charles H. Klein,...

Sixth Circuit: Party Presentation and Forfeiture Limit Sua Sponte Defeat of Title VII Retaliation; RIF “Pretext” Can Reach a Jury

Date: Aug 8, 2026

Sixth Circuit: Party Presentation and Forfeiture Limit Sua Sponte Defeat of Title VII Retaliation; RIF “Pretext” Can Reach a Jury 1. Introduction In Mark Pannek; Thomas Strotman v. U.S. Bank National...

Sixth Circuit Adopts Probable-Cause Standard for the “Serious Reasons for Believing” Serious-Nonpolitical-Crime Bar

Date: Aug 8, 2026

Sixth Circuit Adopts Probable-Cause Standard for the “Serious Reasons for Believing” Serious-Nonpolitical-Crime Bar I. Introduction In Leandro Spindola v. Todd Blanche (6th Cir. Aug. 7, 2026), the...

Qualified Immunity and Fourth Amendment Reasonableness: Probable Cause, Inventory Searches, and Obstruction Arrests Despite Policy Imperfections

Date: Aug 8, 2026

Qualified Immunity and Fourth Amendment Reasonableness: Probable Cause, Inventory Searches, and Obstruction Arrests Despite Policy Imperfections 1. Introduction Cody Henderson v. Village of New...

Appellate Forfeiture and Pretext in Performance-Improvement-Plan Discrimination Claims (Noel v. Challenge Manufacturing Holdings)

Date: Aug 7, 2026

Appellate Forfeiture and Pretext in Performance-Improvement-Plan Discrimination Claims (Noel v. Challenge Manufacturing Holdings) Introduction In Jerreece Noel v. Challenge Manufacturing Holdings,...

Voluntary Remand to Reconsider Voluntary Departure Without Reaching Merits; Exhaustion Required for Agency-Bias Due Process Claims

Date: Aug 7, 2026

Voluntary Remand to Reconsider Voluntary Departure Without Reaching Merits; Exhaustion Required for Agency-Bias Due Process Claims Introduction In Newton Scott Mulama v. Todd W. Blanche, Acting U.S....

Qualified Immunity Where an Inmate Shows No External Distress: No Clearly Established Duty to Immediately Act on an Oral Chest-Pain Complaint

Date: Aug 7, 2026

Qualified Immunity Where an Inmate Shows No External Distress: No Clearly Established Duty to Immediately Act on an Oral Chest-Pain Complaint 1. Introduction In Larry Richardson v. Nathan Falk (Sixth...

Strickland Prejudice Required to Excuse Procedural Default of a Plea-Breach Sentencing Claim

Date: Aug 7, 2026

Strickland Prejudice Required to Excuse Procedural Default of a Plea-Breach Sentencing Claim Introduction In Demond Liles v. V. Michael Fisher (Sixth Cir. Aug. 6, 2026), Demond D. Liles sought...

Reasonably Equivalent Value in Family Debt-Release Transfers: Corporate Loans Are Not Personal Guaranties Absent Clear Contractual Commitment (Sixth Circuit)

Date: Aug 7, 2026

Reasonably Equivalent Value in Family Debt-Release Transfers: Corporate Loans Are Not Personal Guaranties Absent Clear Contractual Commitment (Sixth Circuit) Introduction Kathleen Sullivan v. Timothy...

Gowdy v. University Hospitals Cleveland: Clear Video Can Defeat § 1983 Retaliation/Seizure Claims on the Pleadings and Officers May Briefly Detain Bystanders to Secure an Arrest Scene

Date: Aug 1, 2026

Gowdy v. University Hospitals Cleveland: Clear Video Can Defeat § 1983 Retaliation/Seizure Claims on the Pleadings and Officers May Briefly Detain Bystanders to Secure an Arrest Scene 1. Introduction...

Limiting Instructions Need Not Accompany Each Exhibit’s Publication; Drug-Related Text Messages Admissible Under Rule 404(b) to Prove Intent and Rebut “No Longer Dealing” Defense

Date: Jul 31, 2026

Limiting Instructions Need Not Accompany Each Exhibit’s Publication; Drug-Related Text Messages Admissible Under Rule 404(b) to Prove Intent and Rebut “No Longer Dealing” Defense I. Introduction In...

Post-Appeal Release and Mootness: Disputed Settlement Facts Require District-Court Determination Before Merits Review

Date: Jul 30, 2026

Post-Appeal Release and Mootness: Disputed Settlement Facts Require District-Court Determination Before Merits Review 1. Introduction Tammy Russell v. U.S. Dep't of Treasury (6th Cir. July 29, 2026)...

Anti-Waiver Statutes Do Not Preempt Forum Choice-of-Law: Kentucky’s § 188 “Most Significant Relationship” Test Governs Sales-Representative Termination Disputes

Date: Jul 30, 2026

Anti-Waiver Statutes Do Not Preempt Forum Choice-of-Law: Kentucky’s § 188 “Most Significant Relationship” Test Governs Sales-Representative Termination Disputes Case: Bonfiglioli USA, Inc. v. Midwest...

Renewing Rule 29 Motions to Preserve Sufficiency Claims and Treating Digital-Forensics Disputes as Weight (Not Admissibility)

Date: Jul 30, 2026

Renewing Rule 29 Motions to Preserve Sufficiency Claims and Treating Digital-Forensics Disputes as Weight (Not Admissibility) Introduction In United States v. Scott Nelson (6th Cir. July 29, 2026)...

United States v. Khari Qunarll Smith (6th Cir. 2026) Commentary

Date: Jul 30, 2026

Judicial “Testimony” Under Rule 605 Is Subject to Rule 52(a) Harmless-Error Review Requiring an Effect on Substantial Rights United States v. Khari Qunarll Smith (with co-appellants Saruba Asante...

Sixth Circuit Establishes Harmless-Error Framework for Rule 605 Judicial “Testimony” and Clarifies Sentencing/Drug-Premises Applications

Date: Jul 30, 2026

Sixth Circuit Establishes a “Substantial Rights” Harmless-Error Standard for Rule 605 Judicial “Testimony” (and Remands Where a Mandatory Guideline Reduction Was Omitted) 1. Introduction United...