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UNITED STATES OF AMERICA,
Plaintiff-Appellee,
v.
STEVE ALLEN PRITCHARD,
Defendant-Appellant. |
No. 18-6210 |
Appeal from the United States District Court
for the Western District of Kentucky at Bowling Green.
No. 1:16-cr-00028-1—Gregory N. Stivers, District Judge.
Argued: October 23, 2019
Decided and Filed: July 7, 2020
Before: CLAY, THAPAR, and NALBANDIAN, Circuit Judges.
_________________________
OPINION
_________________________
NALBANDIAN, Circuit Judge. Some men just want to watch the world burn. Others
start fires to collect insurance money. Steve Pritchard is the latter. But after playing with fire
several times, Pritchard’s penchant for profiting from arson took a deadly turn. Instead of only
damaging property, a fire started by Pritchard in June 2011 led to firefighter Charles Sparks’s
death. While responding to the fire, Sparks suffered a fatal heart attack. Although Pritchard
could have supposed that a firefighter would respond to the blaze, he had no reason to suspect
that Charles Sparks would arrive on the scene, bringing with him a history of coronary disease
and spotty use of his prescription medication. At issue is whether Pritchard caused Sparks’s
death within the meaning of the federal arson statute, 18 U.S.C. § 844(i).
Pritchard’s appeal turns on first principles of causation. The common law typically
permits liability only when the perpetrator acts as both the but-for and the legal cause of the
harm. And that distinction often matters. Every fledgling law student knows that “a kingdom
might be lost ‘all for the want of a horseshoe nail,’” see Massachusetts v. EPA, 549 U.S. 497,
546 (2007) (Roberts, C.J., dissenting), but we still don’t hold the blacksmith responsible for the
defeat despite his faulty craftmanship’s role as the but-for cause. For that reason, laws that
invoke proximate causation generally impose liability when the harm was foreseeable. Under
18 U.S.C. § 844(i), Sparks’s death need only be “a direct or proximate result of [Pritchard’s]
conduct.” Because the government introduced testimony showing how firefighting can trigger a
heart attack, we find that the jury had sufficient evidence to hold Pritchard responsible for
Sparks’s death. Pritchard also alleges that the lower court committed various reversible errors,
including wrongly admitting propensity evidence, denying his motion to suppress cell phone data
seized by the government, and applying an unwarranted sentencing enhancement. Those
arguments also lack merit. Thus, we AFFIRM. |
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CECIL KOGER,
Plaintiff-Appellant,
v.
GARY C. MOHR, et al.,
Defendants-Appellees. |
No. 19-4020 |
Appeal from the United States District Court
for the Northern District of Ohio at Youngstown.
No. 4:17-cv-02409—Benita Y. Pearson, District Judge.
Argued: April 28, 2020
Decided and Filed: July 7, 2020
Before: CLAY, COOK, and WHITE, Circuit Judges.
_________________________
OPINION
_________________________
HELENE N. WHITE, Circuit Judge. Cecil Koger is an inmate of the Ohio Department of
Rehabilitation and Correction (ODRC) and a practicing Rastafarian. Between 2006 and 2018,
Koger made numerous religious-practice accommodation requests, including requests to grow
his dreadlocks, keep a religious diet, observe fasts, and commune with other Rastafarians.
Alleging that ODRC’s responses were inadequate, Koger brought these claims under the
Religious Land Use and Institutionalized Persons Act (RLUIPA) and 42 U.S.C. § 1983 against
several ODRC officials. The district court granted summary judgment to Defendants. We affirm
in part, reverse in part, and remand for further proceedings. |
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