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Mar 9 2026
6th Cir. 24-6022 Published

Ricky Lee Welch v. Laura Plappert, Warden

The Sixth Circuit reversed a district court dismissal of a federal habeas petition, holding that a prisoner's motion for a belated appeal under Kentucky law tolls the federal statute of limitations. The court ruled that because the state appeal remained pending under a recognized exception for ineffective assistance of counsel, the one-year federal clock did not run during that period.

Constitutional Habeas Corpus - State Prisoner (28 USC 2254)
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Mar 9 2026
11th Cir. 8:22-cr-00407-SDM-UAM-2 Per Curiam

UNITED STATES OF AMERICA v. ANDREA MITCHELL LESTER BEST

The Eleventh Circuit affirmed the convictions and sentences of Andrea Mitchell and Lester Best, rejecting challenges to the sufficiency of evidence for aggravated identity theft and wire fraud. The court further upheld a four-level sentencing enhancement for Best, finding he acted as an organizer or leader of the fraudulent scheme.

Criminal Fraud Sentencing Guidelines
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Mar 9 2026
11th Cir. 1:22-cr-20473-DPG-2 Per Curiam

UNITED STATES OF AMERICA v. JOSE SALAS-BORREGO

The Eleventh Circuit affirmed the defendant's convictions for drug conspiracy and possession aboard a vessel subject to U.S. jurisdiction under the Maritime Drug Law Enforcement Act. The court rejected all constitutional challenges regarding the statute's reach in exclusive economic zones and its definition of stateless vessels.

Criminal Drug Trafficking
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Mar 9 2026
11th Cir. 7:23-cr-00264-LSC-GMB-1 Per Curiam

UNITED STATES OF AMERICA v. BRANDON DEVANTE OLIVER

The Eleventh Circuit affirmed Brandon Oliver's conviction for possessing a firearm as a convicted felon, rejecting his Second Amendment challenge to the federal statute. The court held that longstanding prohibitions on felons possessing firearms remain presumptively lawful under the Second Amendment despite recent Supreme Court rulings.

Criminal Firearms
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Mar 9 2026
11th Cir. 5:04-cr-00028-TKW-MJF-1 Per Curiam

UNITED STATES OF AMERICA v. LANCE H. REID

The Eleventh Circuit affirmed a 36-month prison sentence for a supervised release violation, rejecting the defendant's claim that the sentence was substantively unreasonable. The court held that the district court properly weighed the severity of the defendant's drug violations and his lack of candor regarding his treatment plan.

Criminal Drug Trafficking
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Mar 9 2026
11th Cir. 3:24-cr-00068-MCR-1 Per Curiam

UNITED STATES OF AMERICA v. JEREMY EHLERS

The Eleventh Circuit affirmed a 600-month sentence for child pornography production and distribution, rejecting the defendant's claim that the district court failed to weigh his voluntary cessation of conduct. The court held that the permanence of the images and the need for deterrence justified the sentence within the Guidelines range.

Child Sexual Abuse Material Criminal Sentencing Guidelines Supervised Release
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Mar 6 2026
9th Cir. 2:22-cv-06206-ODW-ADS Unpublished

JOSE LUIS AYALA v. ROBERTO A. ARIAS, Warden

The Ninth Circuit affirmed the denial of a state prisoner's habeas petition, ruling that his request to represent himself was made too close to trial to be considered timely under federal law. The court held that the California Court of Appeal reasonably applied Supreme Court precedent by finding the request untimely when made on the eve of trial.

Constitutional Habeas Corpus - State Prisoner (28 USC 2254)
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Mar 6 2026
9th Cir. 1:22-cr-00062-JLT-SKO-4 Unpublished

UNITED STATES OF AMERICA v. ALMA GARZA

The Ninth Circuit affirmed Alma Garza's conviction for drug conspiracy and possession, ruling that a less-than-three-day warrantless detention of a mailed package was reasonable under the Fourth Amendment. The court held that investigators acted diligently and that an evidentiary hearing was unnecessary given the lack of specific factual allegations from the defense.

Criminal Sentencing Guidelines
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