Case Explained: UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT UNITED STATES OF AMERICA v. MICAH COURTNEY GRAY ) ) ) ) ) ) ) ) ) )

Court: United States Court of Appeals for the Sixth Circuit

Filed: 2026-07-09

The Sixth Circuit affirmed Micah Gray’s convictions on four counts of methamphetamine distribution and possession with intent to distribute, as well as his 288-month sentence. The court held that the district court properly denied Gray’s motions to suppress evidence from his apartment and his sister’s vehicle because the supporting affidavits established a “minimally sufficient nexus” between Gray’s drug trafficking activities and the locations searched; even assuming arguendo that probable cause was lacking, the good-faith exception to the exclusionary rule applied as officers objectively relied on the warrants. The court further ruled that alleged violations of Kentucky state procedure did not require suppression under federal law, that Gray failed to preserve a *Franks* challenge by not contesting untimeliness grounds, and that the district court did not abuse its discretion in denying a motion to reopen a suppression hearing or funding for a handwriting expert due to lack of necessity. Additionally, the court found no error in denying access to grand jury materials absent a particularized need, rejected Sixth Amendment and Fifth Amendment challenges regarding jury venire composition due to Gray’s failure to prove systematic exclusion, deemed evidentiary rulings harmless or correct under rules of completeness and chain of custody, and concluded that the refusal to recall a witness for duplicative testimony did not violate the right to compulsory process. Finally, the court determined the sentence was not substantively unreasonable as the district court properly weighed the factors under 18 U.S.C. § 3553(a) and applied a downward variance. As a result, Gray’s judgment of conviction and sentence stands.

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