United States v. Michael Avant

CourtCourt of Appeals for the Sixth Circuit
DecidedMarch 27, 2025
Docket24-4007
StatusUnpublished

This text of United States v. Michael Avant (United States v. Michael Avant) 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. Michael Avant, (6th Cir. 2025).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 25a0168n.06

No. 24-4007

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED Mar 27, 2025 KELLY L. STEPHENS, Clerk ) UNITED STATES OF AMERICA, ) Plaintiff-Appellee, ) ON APPEAL FROM THE ) UNITED STATES DISTRICT v. ) COURT FOR THE NORTHERN ) DISTRICT OF OHIO MICHAEL AVANT, ) Defendant-Appellant. ) OPINION ) )

Before: MOORE, GIBBONS, and MURPHY, Circuit Judges.

KAREN NELSON MOORE, Circuit Judge. On November 5, 2024, a district court

determined that Michael Avant had violated the terms of his three-year term of supervised release,

revoked Avant’s supervised release, and sentenced Avant to one hundred days of incarceration,

with no term of supervised release to follow. Avant appealed the one-hundred-day sentence on

the grounds that the sentence was both procedurally and substantively unreasonable. Then, on

February 12, 2025, Avant was released from prison.

Because the sentence that Avant challenges as unreasonable has concluded, and because

he has failed to demonstrate any continuing injury resulting from the challenged sentence, we

DISMISS this appeal as moot. No. 24-4007, United States v. Avant

I. FACTUAL BACKGROUND

A. Supervised Release Violation and Revocation

Michael Avant was sentenced to 168 months of imprisonment, to be followed by a three-

year term of supervised release, after pleading guilty to one count of bank robbery in violation of

18 U.S.C. § 2113(a). R. 2–3 (Ill. Judgment at 2–3) (Page ID #41–42).1 Avant was released from

prison in January 2022, at which point he commenced his supervised release term under the

supervision of the Northern District of Ohio. R. 2 (Transfer of Juris. at 1) (Page ID #31). Avant’s

supervised release was scheduled to conclude on January 12, 2025. Id.

On October 24, 2024, the United States Probation Office filed a violation report indicating

that Avant had violated the terms of his supervised release. R. 22 (Viol. Report at 2–5) (Page ID

#140–43). Specifically, the Probation Office reported that Avant had refused to sign a form

authorizing a probation officer to conduct a credit check to ensure that Avant had not incurred new

debt or credit without the authorization of the district court or probation officer. Id. at 3 (Page ID

#141).

The district court held a hearing to determine whether to revoke Avant’s supervised release

based upon the alleged violation. R. 32 (Viol. Hr’g Tr. at 1) (Page ID #166). Avant admitted his

refusal to sign the credit authorization form, explaining that his refusal was motivated by his

concern that the credit check would affect his ability to obtain a mortgage loan with his wife after

the conclusion of the supervised release term. Id. at 3, 7–9 (Page ID #168, 172–74). The district

1 Avant committed that bank robbery—which occurred in July 2007 in Normal, Illinois—while serving a five- year term of supervised release following a 210-month sentence of imprisonment for an armed bank robbery that he had committed many years earlier—in 1991—in Portland, Oregon. R. 1–4 (Or. Judgment at 2–3) (Page ID #20–21); R. 3 (2008 PSR at ¶¶ 5, 39, 41) (Page ID #48, 56–57, 58).

2 No. 24-4007, United States v. Avant

court, after explaining that Avant’s only two options were to comply with the terms of his

supervised release or have his supervised release revoked, asked Avant whether he would consent

to signing the authorization form. Id. at 5, 10 (Page ID #170, 175). Avant declined to do so. Id.

at 10 (Page ID #175). The district court thereupon found Avant in violation of the terms of his

supervised release. Id. After hearing arguments from both parties as to the appropriate sentence,

the district court sentenced Avant to a below-Guidelines term of one hundred days of

imprisonment, with no term of supervised release to follow. Id. at 14 (Page ID #179); R. 27

(Revocation Order at 2) (Page ID #156).

B. Proceedings on Appeal

Avant timely appealed the district court’s order revoking his supervised release, arguing

that the one-hundred-day sentence was both procedurally and substantively unreasonable. R. 28

(Notice of Appeal at 1) (Page ID #157); Appellant Br. at 6. Soon after his appeal was docketed in

this court, Avant moved for release pending appeal. D. 9. A panel of this court denied the motion,

concluding that the appeal failed to raise a substantial question of law or fact. United States v.

Michael Avant, No. 24-4007 (6th Cir. Jan. 17, 2025) (order).

Meanwhile, Avant’s appeal was expedited for briefing and submission, with briefing

completed on January 21, 2025. D. 5, 6. Then, on February 12, 2025, Avant was released from

prison. See D. 19 at 1; D. 20 at 2. As a result of Avant’s release, we requested supplemental

briefing by both parties addressing whether Avant’s release from prison rendered this appeal moot.

3 No. 24-4007, United States v. Avant

II. DISCUSSION

On appeal, Avant challenges both the procedural and substantive reasonableness of his

one-hundred-day sentence. But we are foreclosed from reaching the merits of Avant’s appeal

because his release from prison has rendered this case moot.

“The Constitution’s case or controversy requirement confines the jurisdiction of the courts

to ‘real and substantial controvers[ies] admitting of specific relief through a decree of a conclusive

character.’” Demis v. Sniezek, 558 F.3d 508, 512 (6th Cir. 2009) (quoting North Carolina v. Rice,

404 U.S. 244, 246 (1971)). “Accordingly, this Court lacks jurisdiction to consider any case or

issue that has ‘lost its character as a present, live controversy’ and thereby becomes moot.” Id.

(quoting Hall v. Beals, 396 U.S. 45, 48 (1969)). In other words, “[w]e have no power to adjudicate

disputes which are moot.” McPherson v. Mich. High Sch. Athletic Ass’n, Inc., 119 F.3d 453, 458

(6th Cir. 1997) (en banc) (quoting Crane v. Ind. High Sch. Athletic Ass’n, 975 F.2d 1315, 1318

(7th Cir. 1992)).

“Simply stated, a case is moot when the issues presented are no longer ‘live’ or the parties

lack a legally cognizable interest in the outcome.” Powell v. McCormack, 395 U.S. 486, 496

(1969). “The mootness inquiry must be made at every stage of a case.” McPherson, 119 F.3d at

458. This is because, at each stage of the litigation, “[t]he parties must continue to have a personal

stake in the outcome of the lawsuit.” Demis, 558 F.3d at 512 (quoting Lewis v. Cont’l Bank Corp.,

494 U.S. 472, 477–78 (1990)). Thus, even where neither party raises the issue of mootness, “if an

event occurs while a case is pending on appeal that makes it impossible for the court to grant ‘any

effectual relief whatever’ to a prevailing party, the appeal must be dismissed.” Church of

4 No.

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Related

Mills v. Green
159 U.S. 651 (Supreme Court, 1895)
Powell v. McCormack
395 U.S. 486 (Supreme Court, 1969)
Hall v. Beals
396 U.S. 45 (Supreme Court, 1969)
North Carolina v. Rice
404 U.S. 244 (Supreme Court, 1971)
Lewis v. Continental Bank Corp.
494 U.S. 472 (Supreme Court, 1990)
Spencer v. Kemna
523 U.S. 1 (Supreme Court, 1998)
Demis v. Sniezek
558 F.3d 508 (Sixth Circuit, 2009)
United States v. Lewis
166 F. App'x 193 (Sixth Circuit, 2006)
Noelle Hanrahan v. Gary Mohr
905 F.3d 947 (Sixth Circuit, 2018)
United States v. Thomas
43 F. App'x 728 (Sixth Circuit, 2002)

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