6th Circuit Case Commentaries

United States v. Vannelli: District Courts May Reject Rule 11(c)(1)(C) Pleas on § 3553(a) Grounds and Treat Multi-Day Child-Sex Conduct as “Separate Occasions” Under U.S.S.G. § 4B1.5(b) (Even Assuming Wooden Applies)

Date: Apr 5, 2026

United States v. Vannelli: District Courts May Reject Rule 11(c)(1)(C) Pleas on § 3553(a) Grounds and Treat Multi-Day Child-Sex Conduct as “Separate Occasions” Under U.S.S.G. § 4B1.5(b) (Even...

United States v. John C. Farris: Sixth Circuit Sanctions for Unverified AI-Generated Appellate Briefing and Reaffirms Nondelegable Duty of Candor and Citation Verification

Date: Apr 5, 2026

United States v. John C. Farris: Sixth Circuit Sanctions for Unverified AI-Generated Appellate Briefing and Reaffirms Nondelegable Duty of Candor and Citation Verification Court: Court of Appeals for...

ACCA Elements Clause: Intent Must Attach to the Use of Force (Not the Resulting Injury) and Florida Aggravated Assault/Felony Battery and Ohio Domestic Violence Qualify as Violent Felonies

Date: Apr 4, 2026

ACCA Elements Clause: Intent Must Attach to the Use of Force (Not the Resulting Injury) and Florida Aggravated Assault/Felony Battery and Ohio Domestic Violence Qualify as Violent Felonies...

Mercer v. Stewart: Omitted Defense-of-Others Instructions Are Mixed Questions Governed by AEDPA § 2254(d)(1), and Habeas Relief Is Barred Absent a Clearly Established Supreme Court Right

Date: Apr 4, 2026

Mercer v. Stewart: Omitted Defense-of-Others Instructions Are Mixed Questions Governed by AEDPA § 2254(d)(1), and Habeas Relief Is Barred Absent a Clearly Established Supreme Court Right 1....

Violent-Felony Arrests, Active Resistance, and Qualified Immunity: Fact-Specific “Clearly Established” Limits on Takedowns and Knee Strikes

Date: Apr 4, 2026

Violent-Felony Arrests, Active Resistance, and Qualified Immunity: Fact-Specific “Clearly Established” Limits on Takedowns and Knee Strikes Case: Latoya Aaron v. Darren King (as Legal Guardian of...

Mercer v. Stewart: Denial of Defense-of-Others Instruction Is a § 2254(d)(1) Mixed Question; No Clearly Established Federal Right Requires the Instruction

Date: Apr 4, 2026

Denial of a Defense-of-Others Jury Instruction Is Reviewed Under AEDPA § 2254(d)(1), and Keahey Forecloses Habeas Relief Absent Clearly Established Supreme Court Law Requiring the Instruction...

Full Faith and Credit Claim Preclusion Bars Later I-864 Affidavit of Support Enforcement When the Claim Could Have Been Raised in Divorce

Date: Apr 4, 2026

Full Faith and Credit Claim Preclusion Bars Later I-864 Affidavit of Support Enforcement When the Claim Could Have Been Raised in Divorce Introduction In Randy Kris Ramgoolam v. Ritu Gupta (6th Cir....

Sixth Circuit: No Williams Remand When the Record Makes Felon Dangerousness “Self-Evident” Under § 922(g)(1)

Date: Apr 4, 2026

Sixth Circuit: No Williams Remand When the Record Makes Felon Dangerousness “Self-Evident” Under § 922(g)(1) I. Introduction Case: United States v. Tony Wilkinson (6th Cir. Apr. 2, 2026)...

Sixth Circuit Limits Judicial-Ethics Enforcement: “Cascading” Discipline Fails Strict Scrutiny Absent Proven, Knowing Falsity

Date: Apr 4, 2026

Sixth Circuit Limits Judicial-Ethics Enforcement: “Cascading” Discipline Fails Strict Scrutiny Absent Proven, Knowing Falsity Case: Hon. Donna Greenwell Dutton v. Jimmy Shaffer, et al. (6th Cir.)...

Sixth Circuit Limits “Cascading” Judicial-Ethics Enforcement: Integrity and Relationship Canons Cannot Be Used to Punish Campaign Speech Absent an Independent, Fact-Supported Basis Beyond Alleged Falsity

Date: Apr 4, 2026

Sixth Circuit Limits “Cascading” Judicial-Ethics Enforcement: Integrity and Relationship Canons Cannot Be Used to Punish Campaign Speech Absent an Independent, Fact-Supported Basis Beyond Alleged...

Post–Loper Bright Validation of DOL’s 2013 Third-Party Home-Care Overtime Rule and No Standing to Challenge Companionship Definition

Date: Apr 4, 2026

Post–Loper Bright Validation of DOL’s 2013 Third-Party Home-Care Overtime Rule and No Standing to Challenge Companionship Definition I. Introduction In U.S. Dep't of Labor v. Americare Healthcare...

Sixth Circuit Bars “50%-Served” Customs for Early Termination of Supervised Release Absent an Individualized § 3553(a) Analysis

Date: Apr 4, 2026

Sixth Circuit Bars “50%-Served” Customs for Early Termination of Supervised Release Absent an Individualized § 3553(a) Analysis I. Introduction In United States v. Guy Collins (6th Cir. Apr. 1,...

United States v. Collins: Early-Termination Denials Cannot Rest on a “Fifty-Percent” Custom Without an Individualized § 3553(a) Analysis

Date: Apr 4, 2026

United States v. Collins: Early-Termination Denials Cannot Rest on a “Fifty-Percent” Custom Without an Individualized § 3553(a) Analysis 1. Introduction In United States v. Guy Collins (Sixth Cir....

Post-Esteras Revocation Sentencing: Courts May Sanction Breach of Trust and Consider Violation Seriousness (for Deterrence/Rehabilitation) and May Impose Consecutive Terms When Separately Explained

Date: Apr 4, 2026

Post-Esteras Revocation Sentencing: Courts May Sanction Breach of Trust and Consider Violation Seriousness (for Deterrence/Rehabilitation) and May Impose Consecutive Terms When Separately Explained...

Post-Esteras Revocation Sentencing: Breach-of-Trust and Violation Seriousness Remain Permissible; Consecutive Terms Supported by § 7B1.3(f)

Date: Apr 4, 2026

Post-Esteras Revocation Sentencing: Breach-of-Trust and Violation Seriousness Remain Permissible; Consecutive Terms Supported by § 7B1.3(f) Introduction In United States v. Michael Williams (6th Cir....

Chapter 20 Lien-Retention Rule: No “Plan-Completion” Substitute for § 1325(a)(5)(B)(i)(I) When § 1328 Discharge Is Unavailable

Date: Apr 3, 2026

Chapter 20 Lien-Retention Rule: No “Plan-Completion” Substitute for § 1325(a)(5)(B)(i)(I) When § 1328 Discharge Is Unavailable 1. Introduction In re: Sharenne L. Tucker is a Sixth Circuit Bankruptcy...

FINRA May Discipline Unregistered “Associated Persons” Who Control Member Firms; Jarkesy-Based Jury-Trial Objections Must Be Exhausted Before the SEC

Date: Mar 29, 2026

FINRA May Discipline Unregistered “Associated Persons” Who Control Member Firms; Jarkesy-Based Jury-Trial Objections Must Be Exhausted Before the SEC I. Introduction Case: Eric Smith v. SEC, No....

Pearson v. Michigan Department of Corrections: Qualified Immunity for Non-Treating Officials Who Rely on Contract Medical/Infection-Control Judgments; Michigan GTLA “The Proximate Cause” Not Resolved on the Pleadings

Date: Mar 28, 2026

Pearson v. Michigan Department of Corrections: Qualified Immunity for Non-Treating Officials Who Rely on Contract Medical/Infection-Control Judgments; Michigan GTLA “The Proximate Cause” Not Resolved...

Sixth Circuit: Nursing-Home Arbitration Enforced When POA Signer Acts as “Resident Representative” Without Affirmatively Disclaiming Agency; Contract Terms May Be Clarified by Integrated Admission Papers

Date: Mar 28, 2026

Sixth Circuit: Nursing-Home Arbitration Enforced When POA Signer Acts as “Resident Representative” Without Affirmatively Disclaiming Agency; Contract Terms May Be Clarified by Integrated Admission...

Correctable Due-Process Claims Must Be Exhausted Before the BIA and Require a Showing of Prejudice in In Absentia Reopening

Date: Mar 28, 2026

Correctable Due-Process Claims Must Be Exhausted Before the BIA and Require a Showing of Prejudice in In Absentia Reopening I. Introduction In Chinedu Onyenobi v. Pamela Bondi (Sixth Cir. Mar. 26,...

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