6th Circuit Case Commentaries

“Sand Tires ≠ Street Tires” – Sixth Circuit Clarifies that Off-Road ATVs Are Not “Motor Vehicles” for Auto-Policy or Michigan No-Fault Coverage

Date: Aug 25, 2025

“Sand Tires ≠ Street Tires” – Sixth Circuit Clarifies that Off-Road ATVs Are Not “Motor Vehicles” for Auto-Policy or Michigan No-Fault Coverage Introduction Laurie Leitch’s summer ride on a Polaris...

No Bivens Remedy Against ICE Agents for Immigration-Related Fourth or Fifth Amendment Violations: A Commentary on Enriquez-Perdomo v. Newman

Date: Aug 25, 2025

No Bivens Remedy Against ICE Agents for Immigration-Related Fourth or Fifth Amendment Violations: A Commentary on Riccy Mabel Enriquez-Perdomo v. Ricardo A. Newman, 6th Cir. (2025) 1. Introduction In...

United States v. Radaker-Carter: Sixth Circuit Resolves the Standard-of-Review Split in Pre-trial Identification Suppression Motions

Date: Aug 25, 2025

United States v. Radaker-Carter: Sixth Circuit Resolves the Standard-of-Review Split in Pre-trial Identification Suppression Motions 1. Introduction In United States v. Kyrrah Cornell Radaker-Carter,...

United States v. Jackson: “Plain-View Vehicle Firearm” Rule for § 2D1.1(b)(1) Enhancements

Date: Aug 25, 2025

United States v. Jackson: Establishing the “Plain-View Vehicle Firearm” Rule for § 2D1.1(b)(1) Sentencing Enhancements 1. Introduction On 19 August 2025, the United States Court of Appeals for the...

Securing the Scene: United States v. Claude Coleman and the Sixth Circuit’s Dual Clarifications on Officer-Safety Detentions and Career-Offender Predicates

Date: Aug 25, 2025

Securing the Scene: United States v. Claude Coleman and the Sixth Circuit’s Dual Clarifications on Officer-Safety Detentions and Career-Offender Predicates Introduction United States v. Claude...

The Business-Judgment Shield in Legal-Malpractice “Case-Within-a-Case” Analysis: Commentary on John Shufeldt v. Baker, Donelson, Bearman, Caldwell & Berkowitz, P.C.

Date: Aug 19, 2025

The Business-Judgment Shield in Legal-Malpractice “Case-Within-a-Case” Analysis: Sixth Circuit Clarifies Causation Requirements in Shufeldt v. Baker Donelson 1. Introduction This commentary addresses...

Rule 32(h) Notice and Unconditional-Plea Waiver Clarified: In-Depth Commentary on United States v. Tyjuan Devon Gray (6th Cir. 2025)

Date: Aug 19, 2025

Rule 32(h) Notice and Unconditional-Plea Waiver Clarified: Commentary on United States v. Tyjuan Devon Gray, Nos. 24-1507/1553/1577 (6th Cir. Aug. 15, 2025) I. Introduction The consolidated appeal in...

“Reasonable Notice” Redefined: The Sixth Circuit’s Flexible Approach to Rule 32(h) Upward Departures in United States v. Tyjuan Devon Gray

Date: Aug 19, 2025

“Reasonable Notice” Redefined: The Sixth Circuit’s Flexible Approach to Rule 32(h) Upward Departures in United States v. Tyjuan Devon Gray Introduction On 15 August 2025, the United States Court of...

United States v. Gray – Sixth Circuit Clarifies Rule 32(h) Notice Standards and the Scope of Waiver Following an Unconditional Guilty Plea

Date: Aug 19, 2025

United States v. Gray – Sixth Circuit Clarifies Rule 32(h) Notice Standards and the Scope of Waiver Following an Unconditional Guilty Plea Introduction On 15 August 2025 the United States Court of...

United States v. Grayson – Sixth Circuit Re-Affirms the “Clean-Hands” Exception and Sets a Modern Standard for Authenticating Fragmented Digital Recordings

Date: Aug 19, 2025

United States v. Grayson – Sixth Circuit Re-Affirms the “Clean-Hands” Exception and Sets a Modern Standard for Authenticating Fragmented Digital Recordings Introduction In United States v. Ashley...

Machineguns Beyond Second-Amendment Protection: The Sixth Circuit’s Post-Bruen Reaffirmation in United States v. Brown

Date: Aug 19, 2025

Machineguns Beyond Second-Amendment Protection: The Sixth Circuit’s Post-Bruen Reaffirmation in United States v. Brown 1. Introduction On 14 August 2025 the United States Court of Appeals for the...

“Harmless-Error” after Erlinger: The Sixth Circuit’s Two-Track Approach in United States v. Durham & Barnes

Date: Aug 19, 2025

“Harmless-Error” after Erlinger: The Sixth Circuit’s Two-Track Approach in United States v. Nathaniel Durham 1. Introduction The consolidated appeal of United States v. Durham & Barnes (Nos....

Sixth Circuit Refines Harmless-Error Doctrine after Erlinger: A Two-Tier Approach to “Different Occasions” under the ACCA

Date: Aug 19, 2025

Sixth Circuit Refines Harmless-Error Doctrine after Erlinger: A Two-Tier Approach to “Different Occasions” under the ACCA Introduction In United States v. Phillip Barnes (consolidated with United...

The “Direct-Connection” Doctrine: Sixth Circuit Confirms FCC Authority to Mandate PII-Breach Reporting and Clarifies the Scope of CRA Disapprovals

Date: Aug 15, 2025

The “Direct-Connection” Doctrine: Sixth Circuit Confirms FCC Authority to Mandate PII-Breach Reporting and Clarifies the Scope of CRA Disapprovals Introduction In CTIA – The Wireless Association v....

The Sixth Circuit’s Two-Step Test for Affiliated Ute in Mixed Securities-Fraud Cases – Commentary on Diane Owens v. FirstEnergy Corp.

Date: Aug 15, 2025

The Sixth Circuit’s Two-Step Test for Applying the Affiliated Ute Presumption in Mixed Omission / Misrepresentation Securities-Fraud Actions 1. Introduction In Diane Owens v. FirstEnergy Corporation,...

Mixed Securities-Fraud Actions After Owens v. FirstEnergy: The Sixth Circuit’s Two-Step Test for Affiliated Ute and the Reaffirmed Comcast Damages Mandate

Date: Aug 15, 2025

Mixed Securities-Fraud Actions After Owens v. FirstEnergy: The Sixth Circuit’s Two-Step Test for Affiliated Ute and the Reaffirmed Comcast Damages Mandate 1. Introduction In Diane Owens v....

The Sixth Circuit’s Two-Step Test for Affiliated Ute in Mixed Securities-Fraud Actions: Commentary on Diane Owens v. FirstEnergy Corp.

Date: Aug 15, 2025

The Sixth Circuit’s Two-Step Test for Affiliated Ute in Mixed Securities-Fraud Actions (Commentary on Diane Owens v. FirstEnergy Corporation, 23-3940/3943/3945/3946/3947, 6th Cir. Aug. 13 2025) 1....

Refining Reliance: Sixth Circuit Establishes Two-Step, Four-Factor Framework for Affiliated Ute Presumption in Mixed Securities-Fraud Cases

Date: Aug 15, 2025

Refining Reliance: Sixth Circuit Establishes Two-Step, Four-Factor Framework for Affiliated Ute Presumption in Mixed Securities-Fraud Cases Introduction In Diane Owens v. FirstEnergy Corporation, the...

“Primarily Omissions” Re-Defined: Sixth Circuit’s Two-Step Test for Affiliated Ute and Rigorous Comcast Damages Review in Diane Owens v. FirstEnergy

Date: Aug 15, 2025

“Primarily Omissions” Re-Defined: Sixth Circuit’s Two-Step Test for Affiliated Ute and Rigorous Comcast Damages Review in Diane Owens v. FirstEnergy 1. Introduction The United States Court of Appeals...

Reaffirming Exhaustion via Ginther Motions: Sixth Circuit Clarifies § 2254 Procedure in Fischer v. Nagy

Date: Aug 15, 2025

Reaffirming Exhaustion via Ginther Motions: Sixth Circuit Clarifies § 2254 Procedure in Fischer v. Nagy 1 Introduction The United States Court of Appeals for the Sixth Circuit has once again...