United States v. Michael Edwards

CourtCourt of Appeals for the Sixth Circuit
DecidedFebruary 2, 2024
Docket23-3549
StatusUnpublished

This text of United States v. Michael Edwards (United States v. Michael Edwards) 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 Edwards, (6th Cir. 2024).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 24a0051n.06

Case No. 23-3549

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED Feb 02, 2024 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 A. EDWARDS, ) Defendant-Appellant. ) OPINION ) )

Before: BOGGS, GILMAN, and NALBANDIAN, Circuit Judges.

NALBANDIAN, Circuit Judge. After one of his drug customers died of an overdose,

Michael A. Edwards pleaded guilty to conspiracy to distribute fentanyl, knowing that the

government would seek an overdose-death enhancement. But, after failing to timely disclose

evidence it planned to use in support of the enhancement, the government withdrew its request for

the enhancement before sentencing.

Shortly after, Edwards was indicted for distributing fentanyl (as opposed to conspiracy)

arising out of the same events—again accompanied by the overdose-death enhancement. Edwards

moved to dismiss this indictment on double jeopardy grounds. But, after the district court rejected

his motion, Edwards pleaded guilty to the second offense. Edwards’s plea agreement included an

appellate waiver, although it preserved his right to appeal the denial of his motion to dismiss.

On appeal, Edwards argues that the Double Jeopardy Clause bars his second prosecution

because the government had planned to seek the overdose-death enhancement in his first No. 23-3549, United States v. Edwards

conviction, but actually pursued it in the second. Edwards has arguably waived his right to raise

this issue but, regardless, it contradicts Supreme Court precedent, so we AFFIRM.

I.

A.

On September 21, 2020, a Munson, Ohio man, identified as A.S., died of a fentanyl

overdose. A police investigation led to Michael A. Edwards and four others, who were found

selling drugs out of a home in Euclid, Ohio. A February 2021 search of this home found counterfeit

oxycodone pills containing fentanyl, a firearm, ammunition, digital scales, and other drug

paraphernalia. The investigation ultimately uncovered that Edwards himself delivered the pills

that caused A.S.’s overdose.

B.

On February 18, 2021, Edwards and four others were indicted in the Northern District of

Ohio for conspiring to possess with intent to distribute and to distribute fentanyl, in violation of

21 U.S.C. §§ 841 and 846.

Edwards pleaded guilty to this charge “aware that the Government would argue at his

sentencing for an enhancement based on its belief that [he] was responsible for the death of the

overdose victim.” R.18, Order at 2, PageID 189. But only a week before sentencing, the

government notified Edwards of previously undisclosed evidence that it planned to use in support

of the overdose-death enhancement. In response to Edwards’s motion in limine, the government

withdrew its sentencing memorandum and all exhibits related to the overdose death. At

sentencing, the government did not seek an enhancement for A.S.’s death. So the district court

sentenced Edwards to 46 months of imprisonment, without considering an overdose-death

enhancement.

2 No. 23-3549, United States v. Edwards

C.

On July 14, 2022, Edwards was once more indicted in the Northern District of Ohio, this

time for (1) distributing a mixture and substance containing fentanyl, in violation of 21 U.S.C.

§ 841, and (2) willfully receiving a firearm while under indictment, in violation of 18 U.S.C.

§§ 922 and 924. The indictment confirmed that the distribution charge related to the events of

September 21, 2020, and asked for an enhanced penalty for A.S.’s death under 21 U.S.C. § 841.

Edwards moved to dismiss the distribution count, claiming a violation of the Double

Jeopardy Clause. Edwards first claimed that his second prosecution was barred under the

“elements” test because it contained “all of the elements” of his first one, “with the additional

element of an increased penalty for the victim’s alleged overdose death.” R.12, Motion to Dismiss

at 9, PageID 40. In the alternative, Edwards claimed that the second prosecution was barred

because it “require[d] the re-litigation of factual and legal issues already addressed in the first.”

Id. at 10, PageID 41.

Although “sympathetic” to Edwards’s situation, the district court rejected his motion to

dismiss, deeming neither argument persuasive. R.18, Order at 7, PageID 191–94. First, Edwards’s

claim that his second prosecution was barred by the “elements” test failed because “the conspiracy

offense and the substantive distribution offense at issue” were “distinct offenses for double

jeopardy purposes,” under United States v. Felix, 503 U.S. 378, 389 (1992). R.18, Order at 4–5,

PageID 191–92. And the district court rejected Edwards’s “alternative test based on the issues

actually litigated during two trials, as such a test has no basis in Double Jeopardy Clause

jurisprudence.” Id. at 6, PageID 193.

3 No. 23-3549, United States v. Edwards

After the district court denied his motion to dismiss, Edwards pleaded guilty to distributing

the fentanyl that caused A.S.’s death, in exchange for the government dismissing the firearm

charge. As part of the agreement, Edwards also waived his appellate rights, except for reserving

the right to appeal the denial of his motion to dismiss.

On June 20, 2023, the district court sentenced Edwards to 180 months’ imprisonment, to

be served concurrently with his earlier conspiracy sentence because “the two cases grow out of

overlapping circumstances and the second prosecution might well have been brought as part of the

first.” R.33, Judgment at 2, PageID 389. Edwards timely appealed.

II.

We review a district court’s denial of a motion to dismiss on double-jeopardy grounds de

novo. United States v. Koubriti, 509 F.3d 746, 748–49 (6th Cir. 2007). The Double Jeopardy

Clause provides that no person shall “be subject for the same offence to be twice put in jeopardy

of life or limb.” U.S. Const. amend. V. The clause protects defendants against “a second

prosecution for the same offense after acquittal or conviction and against multiple punishments for

the same offense.” United States v. Lawrence, 735 F.3d 385, 426–27 (6th Cir. 2013). But “where

the same act or transaction constitutes a violation of two distinct statutory provisions,” a defendant

may be prosecuted for both so long as “each provision requires proof of a fact which the other does

not.” Blockburger v. United States, 284 U.S. 299, 304 (1932). For instance, “a substantive crime

and a conspiracy to commit that crime are not the ‘same offence’ for double jeopardy purposes,”

because the latter offense also requires proof of an agreement to commit the substantive crime.

Felix, 503 U.S. at 389–90 (citing United States v.

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

Related

Blockburger v. United States
284 U.S. 299 (Supreme Court, 1931)
United States v. Bayer
331 U.S. 532 (Supreme Court, 1947)
United States v. Felix
503 U.S. 378 (Supreme Court, 1992)
Yee v. City of Escondido
503 U.S. 519 (Supreme Court, 1992)
Witte v. United States
515 U.S. 389 (Supreme Court, 1995)
Monge v. California
524 U.S. 721 (Supreme Court, 1998)
Guilmette v. Howes
624 F.3d 286 (Sixth Circuit, 2010)
M. Lee Gallenstein v. United States
975 F.2d 286 (Sixth Circuit, 1992)
United States v. Daryl Lawrence
735 F.3d 385 (Sixth Circuit, 2013)
United States v. Koubriti
509 F.3d 746 (Sixth Circuit, 2007)
United States v. James Vanderweele
545 F. App'x 465 (Sixth Circuit, 2013)
Louis Leonor v. Provident Life & Accident Co.
790 F.3d 682 (Sixth Circuit, 2015)

Cite This Page — Counsel Stack

Bluebook (online)
United States v. Michael Edwards, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-michael-edwards-ca6-2024.