Case Explained: 26a0209p.06

Court: United States Court of Appeals for the Sixth Circuit Filed: 2026-07-29 The sixth-circuit affirmed the convictions and sentences of defendants Chanel Logan and Khari Smith, but vacated the sentence of defendant Saruba Smith and remanded for resentencing. The court held that Logan’s 360-month sentence was reasonable, rejecting her claims that the district court relied on unreliable information regarding her criminal history, erroneously applied a two-level drug-premises enhancement under U.S.S.G. § 2D1.1(b)(12), or imposed a substantively unreasonable sentence based on disparities with co-defendants. The court found the enhancement proper because Logan’s apartment contained substantial quantities of drugs and manufacturing equipment, indicating its primary use was for drug trafficking rather than mere incidental storage. Regarding Smith, the court held that sufficient evidence supported his conviction under 21 U.S.C. § 843(b) for using a phone to facilitate a drug offense, as he knowingly used his phone to connect an undercover buyer with Logan. The court also rejected Smith’s challenge to the denial of a mitigating-role reduction under U.S.S.G. § 3B1.2, finding he played a key role in planning and organizing the drug deal, and upheld the consecutive sentence as adequately explained by the district court. For Saruba, the court held that while her conviction for aiding and abetting was supported by sufficient evidence and any judicial bias or Rule 605 error was harmless, the district court committed plain error by failing to apply a mandatory two-level offense level reduction under U.S.S.G. § 2D1.1(a)(5) after granting her a mitigating-role adjustment under § 3B1.2. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.