United States v. Joshua Saunders

CourtCourt of Appeals for the Sixth Circuit
DecidedJune 26, 2026
Docket25-3634
StatusUnpublished

This text of United States v. Joshua Saunders (United States v. Joshua Saunders) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Joshua Saunders, (6th Cir. 2026).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 26a0276n.06

Case No. 25-3634

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED Jun 26, 2026 ) KELLY L. STEPHENS, Clerk UNITED STATES OF AMERICA, ) Plaintiff-Appellee, ) ) ON APPEAL FROM THE UNITED v. ) STATES DISTRICT COURT FOR ) THE NORTHERN DISTRICT OF JOSHUA SAUNDERS, ) OHIO Defendant-Appellant. ) ) OPINION

Before: BOGGS, KETHLEDGE, and THAPAR, Circuit Judges.

THAPAR, Circuit Judge. Joshua Saunders wanted to appeal his conviction and sentence

for distributing child pornography and sexually abusing a minor. But his lawyer didn’t file a timely

notice of appeal. Because that qualified as ineffective assistance of counsel, the district court

reissued the judgment to let Saunders file a delayed appeal. Saunders now uses that appeal to

argue that the district court needed to hold a full resentencing hearing instead of simply reissuing

the judgment. But a full resentencing hearing wasn’t necessary, so we affirm.

I.

Federal agents caught Joshua Saunders receiving and distributing child pornography on an

online messaging app. In total, Saunders possessed or circulated 760 images and 223 videos of

children engaged in sexually explicit conduct. His collection included disturbing images of adults

engaging in sex acts with toddlers under the age of 5 and prepubescent children under 12. It also

included several videos and images of children being subjected to sadistic abuse. Worse still, some No. 25-3634, United States v. Saunders

of the videos showed Saunders himself sexually abusing his 10-year-old cousin. So Saunders was

charged with receiving, distributing, and possessing child pornography, as well as sexually

exploiting a child.

Instead of going to trial, Saunders entered a plea agreement. Under that agreement, he pled

guilty to receiving and distributing child pornography and sexually exploiting a minor, and the

government dismissed the count for possessing child pornography. Saunders also agreed to waive

his right to appeal or collaterally attack his conviction and sentence, except in two limited

circumstances. First, Saunders could appeal his sentence if it exceeded the statutory maximum

punishment or the recommended term of imprisonment under the Sentencing Guidelines. Second,

he could pursue legal remedies for “claims of ineffective assistance of counsel or prosecutorial

misconduct.” R. 24, Pg. ID 65.

At a plea hearing, the district court warned Saunders that he would face an “extremely

lengthy” sentence if he pled guilty. R. 43, Pg. ID 1930. The district court told Saunders that his

sentence would likely fall between a mandatory minimum of 15 years’ imprisonment and a

statutory maximum of 80 years’ imprisonment. Saunders confirmed that he still wanted to waive

his right to appeal any within-Guidelines sentence below that statutory maximum. Saunders also

verified in his written plea agreement that he had discussed the plea with his counsel and was

satisfied with the legal services he’d received.

At sentencing, the district court calculated Saunders’s Guidelines range as 360 to 960

months’ imprisonment. Neither side objected to that calculation. The district court considered the

victim-impact statements it received from children depicted in the images and videos that Saunders

collected, including from the cousin he abused. And it listened to statements from Saunders, his

parents and grandmother, and his minor victim’s mother and relatives. The district court ultimately

-2- No. 25-3634, United States v. Saunders

sentenced Saunders to 480 months’ imprisonment and a lifetime of supervised release for his

“more than awful” and “egregious” conduct. R. 41, Pg. ID 1884, 1879.

The district court entered a final judgment, and Saunders didn’t file a notice of appeal. But

a few months later, he wrote a letter to the district court stating that he had been “trying to file for

an appeal.” R. 35, Pg. ID 1859. He explained that he had directed his attorney to file a notice of

appeal, move for an extension of time to appeal, and withdraw as Saunders’s appellate counsel.

But his attorney hadn’t done any of those things. The district court construed Saunders’s letter as

a motion for an extension of time to appeal and denied it as untimely.

So Saunders tried to prove that he’d asked his lawyer to appeal. About six months after

the final judgment entry, Saunders sent the district court a copy of a letter he had previously mailed

to his attorney. Sure enough, in that letter, Saunders had instructed his lawyer to file a notice of

appeal. He also told him to “request and prepare an extension of time to appeal, an appeal, and a

motion to withdraw as appellate counsel.” R. 37, Pg. ID 1862. He emphasized that “time [wa]s

of the essence” for his requests. Id.

At that point, the district court appointed a federal public defender to represent Saunders.

With his new lawyer’s help, Saunders then requested that the district court vacate his sentence

because he received ineffective assistance of counsel. See 28 U.S.C. § 2255. He asserted that his

first lawyer (1) advised him to sign a plea agreement that didn’t benefit him, (2) failed to obtain

mental-health records or investigate other mitigating evidence, and (3) neglected to file a notice of

appeal when asked. To support that final ground for relief, Saunders’s mother provided an

affidavit confirming that she had repeatedly asked Saunders’s lawyer in person, over the phone,

and by text message to timely appeal.

-3- No. 25-3634, United States v. Saunders

The district court granted partial relief on the third claim and dismissed the other two claims

without prejudice. Based on Saunders’s and his mother’s efforts, the district court found that “the

record clearly establishes that but for” his attorney’s failure to file a notice of appeal, Saunders

“would have timely appealed.” R. 64, Pg. ID 2117. As a result, the district court concluded that

Saunders had been denied effective assistance of counsel. See Roe v. Flores-Ortega, 528 U.S.

470, 480 (2000). To give Saunders a chance to appeal, the district court vacated Saunders’s

original sentence and reissued the same judgment. Saunders then timely appealed the amended

judgment and the order dismissing his first two grounds for relief.

Saunders also requested a certificate of appealability to challenge the dismissal of his first

two ineffective-assistance claims. The district court denied that request without prejudice, and this

court did the same. We explained that Saunders could pursue his other ineffective-assistance

claims once we resolved his now-revived direct appeal.

II.

On appeal, Saunders argues that he presented new information about his psychological

state and maturity in his habeas petition that undermines the district court’s rationale for his

sentence. He therefore claims that the district court abused its discretion by reissuing the amended

judgment without resentencing him.

But the district court didn’t abuse its discretion. When a defendant shows that counsel

failed to file a notice of appeal when asked, he’s “entitle[d] . . . to relief in the form of a delayed

appeal.” Campbell v. United States, 686 F.3d 353, 360 (6th Cir. 2012). To issue that relief, the

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Roe v. Flores-Ortega
528 U.S. 470 (Supreme Court, 2000)
Massaro v. United States
538 U.S. 500 (Supreme Court, 2003)
John M. Rosinski v. United States
459 F.2d 59 (Sixth Circuit, 1972)
Thomas L. Ludwig v. United States
162 F.3d 456 (Sixth Circuit, 1998)
Robert Campbell v. United States
686 F.3d 353 (Sixth Circuit, 2012)

Cite This Page — Counsel Stack

Bluebook (online)
United States v. Joshua Saunders, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-joshua-saunders-ca6-2026.