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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.


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OPINION
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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.


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OPINION
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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.