BERNICE BOUIE DONALD, Circuit Judge. Daniel Pirkel has long been seeking appellate representation to help him attack his no contest plea to a series of crimes for which he was convicted in 2008. He filed pro se appeals before the Michigan Court of Appeals and the Michigan Supreme Court, but, without the benefit of appellate counsel, he lost those appeals. Next, he filed a pro se 28 U.S.C. § 2254 habeas petition in federal court, challenging the Michigan courts’ procedure in allowing his appellate counsel to withdraw and failing to appoint replacement counsel. The district court did not appoint counsel and denied Pirkel relief. Now, with the benefit of counsel, Pirkel’s claims are clear. At the outset, we note that the right to counsel is fundamental to our adversary system. Here, however, the Michigan trial court failed to conduct its own review of the merits of Pirkel’s appeal before allowing Pirkel’s appellate counsel to withdraw based on a conclusory statement that he could not find any issues to appeal. The Constitution requires more before a court allows counsel to withdraw. Thus, in denying Pirkel’s claims on appeal, the Michigan courts unreasonably applied clearly established federal law announced by the Supreme Court. Accordingly, Pirkel is entitled to a new first-tier appeal in the Michigan courts that complies with the guarantees of the Constitution. We REVERSE and REMAND.

MURPHY, Circuit Judge. Federal drug laws impose enhanced sentences if a “death results” from the use of the drugs that a defendant distributes. This “death-results” enhancement led the district court in this case to impose a life sentence on Russell Davis. Davis sold drugs that were later shared with Jacob Castro-White, who tragically died of a fentanyl overdose. Davis argues that the enhancement does not apply because he did not sell drugs directly to Castro-White. The enhancement’s text, however, does not require such a buyer-seller relationship with the victim. We also reject Davis’s other evidentiary and instructional claims.

At the same time, Davis raises a valid challenge to the warrant that allowed the police to search his home and seize his cellphone. The government now concedes that the affidavit supporting this warrant lacked probable cause. But the government asserts that the affiant gave additional unrecorded oral testimony to establish probable cause in front of the state magistrate who issued the warrant. The Fourth Amendment does not mandate recorded testimony, so we will allow the government to offer evidence of this additional testimony in an evidentiary hearing on remand. We thus deny most of Davis’s claims, but remand for limited proceedings on this Fourth Amendment issue.

SILER, Circuit Judge. Plaintiff Mary Stewart appeals the district court’s grant of summary judgment to defendants, Officer Matthew Rhodes and the City of Euclid, on her claims brought pursuant to 42 U.S.C. § 1983 and state law. We AFFIRM dismissal of Stewart’s federal claims but REVERSE dismissal of Stewart’s state law claims and REMAND to the district court.