ALERT UPDATE 2020 – BI-WEEKLY REPORT U.S. Supreme Court and Federal Circuit Court Wins
Edition: July 28 – August 8, 2025
SUPREME COURT WATCH
The U.S. Supreme Court is in summer recess until October 2025, but the circuit courts continue issuing decisions that may help open the door to relief for incarcerated individuals.
CIRCUIT COURT VICTORIES in the 2nd, 6th, 7th, 8th, 10th and 11th Circuits–United States v. Chastain, (No. 23-7038) 2d Cir. (July 31, 2025)
Conviction VACATED. The Second Circuit ruled that the district court misinstructed the jury by allowing it to convict for wire fraud based on misappropriation of an “intangible interest”
not tied to property rights. This error affected the verdict.
➡ Holding: Conviction for wire fraud and money laundering vacated and remanded for new trial.
United States v. Singh, (No. 23-10433) 6th Cir. (Aug. 7, 2025)
The Sixth Circuit vacated Singh’s healthcare fraud convictions, holding that the district court committed three reversible errors: (1) misdefining “willfully” in the jury instructions;
(2) excluding Singh’s exculpatory statements to an insurance investigator reflecting her state of mind; and (3) permitting lay witness testimony on medical necessity. Because these errors
were not harmless, the case was remanded for further proceedings.
➡ Holding: Conviction vacated and remanded for further proceedings consistent with this opinion.
United States v. Hoyle, (Nos. 23-3977/3978) 6th Cir. (Aug. 6, 2025)
Sentence REVERSED. Malcolm Hoyle received 96 months for a felon-in-possession charge and 24 months for a supervised release violation. The court held that the district court improperly
applied § 3553(a) factors that didn’t apply to the revocation.
➡ Holding: Sentence on the revocation reversed and remanded for resentencing.
Green v. Milwaukee Cty. Circuit Ct., (No. 24-2980), 7th Cir. (Aug. 1, 2025)
Double jeopardy violation FOUND. The Seventh Circuit granted a writ of habeas under § 2241. Green was retried after a mistrial was wrongly declared mid-trial without manifest necessity.
➡ Holding: Mistrial lacked legal basis; retrial barred by Double Jeopardy Clause. Reversed and remanded with instructions to issue unconditional writ.
Lee v. United States, No. 24-2017 (7th Cir. Aug. 8, 2025)
Montez Lee, Jr. pleaded guilty to federal arson and received a 120-month sentence. His initial judgment deferred restitution, which the court later amended to include $842. When Lee filed a
§ 2255 motion a year after the amended judgment, the district court dismissed it as untimely, holding the one-year clock began with the original judgment. The Seventh Circuit disagreed,
holding that the amended judgment restarted the limitations period.
➡ Holding: Reversed and remanded.
Smith v. Walker, (No. 23-3579), 8th Cir. (July 31, 2025)
Summary judgment VACATED. The Eighth Circuit found the district court abused discretion by denying counsel to a pro se plaintiff with a credibility-based civil rights claim and no access to
evidence or legal resources.
➡ Holding: Denial of counsel reversed; case remanded with orders to appoint counsel and reopen discovery.
United States v. Womack, (No. 24-2581), 8th Cir. (Aug. 4, 2025)
Sentence VACATED. Womack was convicted under 18 U.S.C. § 1591(a), but the court applied the sentencing guidelines for § 1591(b)(1), which requires additional jury findings. The Eighth
Circuit corrected this misapplication.
➡ Holding: Sentence vacated and remanded for resentencing under correct base offense level (14 instead of 34).
United States v. Guevara-Lopez, (No. 24-2045), 10th Cir. (Aug. 4, 2025)
Upward variance VACATED. The district court gave the statutory maximum of 60 months—well above the advisory range—without adequate justification under § 3553(a). The Tenth Circuit found
this substantively unreasonable.
➡ Holding: Sentence vacated and remanded for resentencing.
United States v. Spradley, (No. 23-3222) 10th Cir. (July 29, 2025)
Entrapment instruction WRONGFULLY DENIED. The Tenth Circuit ruled that Spradley was entitled to have the jury consider entrapment. The district court improperly refused the instruction.
➡ Holding: Conviction reversed and remanded for a new trial with jury allowed to assess entrapment defense.
United States v. Gyetvay, (Nos. 23-13254, 23-13383) 11th Cir. (August 7, 2025)
Mark Gyetvay, a U.S. accountant tied to Russian energy firms, was found guilty of, among other things, making false statements in an offshore disclosure to intentionally deprive the IRS of
property in the form of tax dollars, as the government posits. However, the district court did not make any factual findings to consider on the question of whether property served as the
“object of the offense” in Count 12, the Court reversed, vacated and remanded for resentencing.
➡ Holding: Sentence vacated and remanded for resentencing.
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