Case Explained: UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT UNITED STATES OF AMERICA v. MICHAEL ARNET THOMAS ) ) ) ) ) ) ) ) ) )

Court: United States Court of Appeals for the Sixth Circuit

Filed: 2026-07-10

The Sixth Circuit affirmed Michael Thomas’s 120-month sentence for possessing a stolen firearm, rejecting his claim that the district court violated his Sixth Amendment right to counsel by failing to conduct a more thorough inquiry into his dissatisfaction with appointed counsel. The court applied the rule that while a defendant’s expression of serious dissatisfaction with counsel triggers a duty to inquire whether good cause exists for substitution, this duty is not triggered if the defendant has affirmatively stated they do not want new counsel and are satisfied with their current representation. The court held that Thomas invited any potential error by explicitly telling the district court that his lawyer could adequately represent him, that he did not wish to substitute counsel, and that he wanted to proceed with sentencing immediately; consequently, further inquiry would have been futile as it would only serve to substitute counsel over Thomas’s expressed desire. Even assuming plain-error review was appropriate, the court found no error because Thomas’s clear statements obviated any need for a deeper investigation into his complaints. The practical consequence is that the judgment of the district court stands and Thomas remains subject to the imposed sentence without a remand for resentencing.

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