6th Circuit Case Commentaries

United States v. Viramontes-Hernandez: Clarifying “Relevant Conduct” for the §2G2.2(b)(5) Pattern-of-Activity Enhancement

Date: Jul 23, 2025

United States v. Viramontes-Hernandez: Clarifying “Relevant Conduct” for the §2G2.2(b)(5) Pattern-of-Activity Enhancement Introduction United States v. Emanuel Jose Viramontes-Hernandez, No. 24-1773...

Sixth Circuit Affirms District Courts’ Discretion to Treat Unscored Misdemeanor Conduct and Related Firearms as Aggravating Factors Under § 3553(a) – A Commentary on United States v. Bunn

Date: Jul 23, 2025

Sixth Circuit Affirms District Courts’ Discretion to Treat Unscored Misdemeanor Conduct and Related Firearms as Aggravating Factors Under § 3553(a) Comprehensive Commentary on United States v....

McClendon El v. Washington: Clarifying the Absence of a Liberty Interest in Avoiding Sex-Offender Programming under Michigan’s Discretionary Parole System

Date: Jul 22, 2025

McClendon El v. Washington: Clarifying the Absence of a Liberty Interest in Avoiding Sex-Offender Programming under Michigan’s Discretionary Parole System 1. Introduction In Anthony McClendon El v....

“Conscious Abandonment Equals Waiver” – United States v. Scales and the Sixth Circuit’s Clarification on Government Waiver of Probable-Cause Arguments

Date: Jul 22, 2025

“Conscious Abandonment Equals Waiver” – United States v. Scales and the Sixth Circuit’s Clarification on Government Waiver of Probable-Cause Arguments Introduction United States v. Jeffrey L. Scales,...

“Holistic Comparator Analysis in Workforce Reductions” – A Commentary on Dawn Hayes v. Clariant Plastics & Coatings USA, Inc.

Date: Jul 22, 2025

“Holistic Comparator Analysis in Workforce Reductions” Commentary on Dawn Hayes v. Clariant Plastics & Coatings USA, Inc. I. Introduction In Hayes v. Clariant, the Sixth Circuit revisits the...

Arbitrator Findings & Post-Reinstatement Delay as Evidence of Pretext and Retaliation: A Commentary on Jeff Smith v. City of Union, Ohio (6th Cir. 2025)

Date: Jul 22, 2025

Arbitrator Findings & Post-Reinstatement Delay as Evidence of Pretext and Retaliation Commentary on Jeff Smith v. City of Union, Ohio, 89 F.4th ___ (6th Cir. 2025) Introduction In Jeff Smith v. City...

Private-University Police as State Actors: A Commentary on Warman v. Mount St. Joseph University (6th Cir. 2025)

Date: Jul 22, 2025

Private-University Police as State Actors: A Commentary on Warman v. Mount St. Joseph University (6th Cir. 2025) 1. Introduction In Matthew Warman v. Mount St. Joseph University, the United States...

Abeyance, Not Dismissal: Sixth Circuit Clarifies That Tennessee Criminal-Malpractice Claims Must Be Stayed Until Post-Conviction Relief Is Finally Resolved

Date: Jul 19, 2025

Abeyance, Not Dismissal: Sixth Circuit Clarifies That Tennessee Criminal-Malpractice Claims Must Be Stayed Until Post-Conviction Relief Is Finally Resolved Introduction In Dimitar Petlechkov v....

Sixth Circuit Reaffirms: Unauthorized Overtime as Legitimate, Nondiscriminatory Basis for Termination; No ADEA Hostile Environment Without an Age Nexus

Date: Jul 18, 2025

Sixth Circuit Reaffirms: Unauthorized Overtime as Legitimate, Nondiscriminatory Basis for Termination; No ADEA Hostile Environment Without an Age Nexus Case: Cynthia Barnes v. Secretary of Veterans...

No Duty to Infer “Implied” PSGs; Failures on Persecution and Nexus Obviate “Unable/Unwilling” Findings; Defective NTAs Do Not Strip Jurisdiction — Sixth Circuit Commentary on Torres de Lopez v. Bondi

Date: Jul 18, 2025

No Duty to Infer “Implied” PSGs; Failures on Persecution and Nexus Obviate “Unable/Unwilling” Findings; Defective NTAs Do Not Strip Jurisdiction — Sixth Circuit in Torres de Lopez v. Bondi Court:...

No State-Law End-Run Around ERISA for Top-Hat Plans; “Equitable Surcharge” Is Not Available Under § 1132(a)(3)

Date: Jul 18, 2025

No State-Law End-Run Around ERISA for Top-Hat Plans; “Equitable Surcharge” Is Not Available Under § 1132(a)(3) Introduction In Jerry Aldridge v. Regions Bank, No. 24-5603 (6th Cir. July 17, 2025),...

Misreading Rule 15 Is Not a “Mistake”: Sixth Circuit Clarifies Relation-Back, Notice-of-Appeal Specificity, and Affirms Kentucky’s One-Year Limitations for § 1983 Claims

Date: Jul 17, 2025

Misreading Rule 15 Is Not a “Mistake”: Sixth Circuit Clarifies Relation-Back, Notice-of-Appeal Specificity, and Affirms Kentucky’s One-Year Limitations for § 1983 Claims Introduction In Jennie V....

Resetting the 182‑Day Clock and Recognizing “Reader” Support: The Sixth Circuit’s Persuasive Guidance on Michigan’s PWDCRA in Poplar v. Genesee County Road Commission

Date: Jul 17, 2025

Resetting the 182‑Day Clock and Recognizing “Reader” Support: The Sixth Circuit’s Persuasive Guidance on Michigan’s PWDCRA in Poplar v. Genesee County Road Commission Introduction In Donna Poplar v....

Double-Waiver Forecloses Interlocutory Arbitration Appeal in Bankruptcy: Sixth Circuit Affirms Where Appellants Neither Preserved the Arbitration Agreement Nor Challenged Bankruptcy-Conflict Grounds

Date: Jul 17, 2025

Double-Waiver Forecloses Interlocutory Arbitration Appeal in Bankruptcy: Sixth Circuit Affirms Where Appellants Neither Preserved the Arbitration Agreement Nor Challenged Bankruptcy-Conflict Grounds...

Sixth Circuit Clarifies Narrow Judicial Review of I‑751 Good‑Faith Marriage Waivers: Credibility and Weight-of-Evidence Challenges Are Unreviewable

Date: Jul 17, 2025

Sixth Circuit Clarifies Narrow Judicial Review of I‑751 Good‑Faith Marriage Waivers: Credibility and Weight-of-Evidence Challenges Are Unreviewable Introduction In Nathaniel Kumedzro v. Pamela Bondi,...

Sixth Circuit Clarifies No Shortcuts Under Daubert or the TPLA: Expertise Must Match the Theory; Malfunction Theory and Consumer-Expectation Shortcuts Fail for Complex Medical Implants

Date: Jul 17, 2025

Sixth Circuit Clarifies No Shortcuts Under Daubert or the TPLA: Expertise Must Match the Theory; Malfunction Theory and Consumer-Expectation Shortcuts Fail for Complex Medical Implants Case: Joseph...

Sixth Circuit: No Lesser-Included Simple Possession Instruction Absent Countervailing Evidence; Reaffirmation of Speedy Trial Act Dismissal-Without-Prejudice Factors and Valid Faretta Waiver

Date: Jul 16, 2025

Sixth Circuit: No Lesser-Included Simple Possession Instruction Absent Countervailing Evidence; Reaffirmation of Speedy Trial Act Dismissal-Without-Prejudice Factors and Valid Faretta Waiver...

Responsiveness Over Results: Sixth Circuit Reaffirms that Consistent Police Intervention Defeats “Unable or Unwilling” and that Plausible Explanations Do Not Salvage Adverse Credibility

Date: Jul 16, 2025

Responsiveness Over Results: Sixth Circuit Reaffirms that Consistent Police Intervention Defeats “Unable or Unwilling” and that Plausible Explanations Do Not Salvage Adverse Credibility Introduction...

Misreading PSR “National Sentencing Averages” Is a Procedural Error Reviewed Only for Plain Error; Within‑Guidelines Sentences Remain Presumptively Reasonable in the Sixth Circuit

Date: Jul 15, 2025

Misreading PSR “National Sentencing Averages” Is a Procedural Error Reviewed Only for Plain Error; Within‑Guidelines Sentences Remain Presumptively Reasonable in the Sixth Circuit Case: United States...

“Not a Mine-Run Failure to Register”: Sixth Circuit Reaffirms Broad Discretion to Impose Significant Upward Variances and Lifetime Supervised Release in SORNA Cases

Date: Jul 15, 2025

“Not a Mine-Run Failure to Register”: Sixth Circuit Reaffirms Broad Discretion to Impose Significant Upward Variances and Lifetime Supervised Release in SORNA Cases Case: United States v. Travis...