Jackson, who has an extensive history of firearm and drug-related offenses, was sentenced to more than 17 years in prison after pleading guilty to illegally possessing a Ruger 9mm pistol in violation of federal law. The enhanced sentence was based on the Armed Career Criminal Act, which requires a 15-year minimum for defendants with three or more violent felony or serious drug offense convictions.
Jackson's crime spree in Michigan ran from February to July 2024 and included multiple arrests involving firearms, drug overdoses, possession of fentanyl and methamphetamine, and fleeing from law enforcement before ATF agents arrested him on July 15, 2024. The underlying incident occurred on February 20, 2024, when police attempted to stop his vehicle due to a suspected robbery. Jackson fled, abandoned his car, and discarded the Ruger 9mm during the chase.
Writing for the majority, Batchelder concluded that Jackson had waived any challenge to his sentence by explicitly agreeing to the sentencing provisions. The court noted that Jackson signed a plea agreement stating he had read the document, carefully discussed it with his attorney, and acknowledged he was subject to enhanced penalties under Title 18, United States Code, Section 924(e)(1) because he had been convicted of three or more violent felonies and/or serious drug offenses.
The majority sharply rejected Jackson's argument that he had merely invited error rather than waived his rights. Batchelder wrote that Jackson did not provoke or invite the district court to err, but rather expressly and consistently admitted that he had three qualifying predicate convictions and understood the associated consequences. The court emphasized that Jackson had twice affirmed during his plea hearing that he had at least three prior convictions for crimes of violence and understood the court's obligation to sentence him to at least 15 years.
Jackson's legal team argued that he should not be subject to the ACCA enhancement because he does not actually have three qualifying prior convictions, pointing particularly to questions about whether his 2018 Michigan drug conviction for delivering less than 50 grams of cocaine qualifies as a serious drug offense under federal law. However, the majority found these arguments foreclosed by Jackson's clear admissions.
Circuit Judge Amul Thapar joined the majority opinion, but Circuit Judge Andre Mathis dissented in a lengthy opinion arguing that Jackson invited the error rather than waiving his rights and that the interests of justice demand that the court review the invited error. Mathis argued that Jackson's 2018 drug conviction should not count as an ACCA predicate because Michigan's definition of cocaine at the time criminalized substances that were legal under federal law.
The majority's decision reinforces the Sixth Circuit's strict approach to waiver in sentencing challenges. The court observed that if Jackson has any claim of error, it would be that his attorney provided ineffective assistance, which is a claim he may raise in a post-conviction, collateral proceeding. The ruling adds to ongoing tensions within the circuit about distinguishing between waiver and invited error, with the court acknowledging that much of the tension emerged after the 2021 decision in Montgomery.