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UNITED STATES OF AMERICA,
Plaintiff-Appellee,
v.
ANTHONY R. PALOS,
Defendant-Appellant.
   No. 19-4186
Appeal from the United States District Court
for the Northern District of Ohio at Cleveland.
No. 1:19-cr-00186-1—Benita Y. Pearson, District Judge.
Decided and Filed: October 15, 2020
Before: ROGERS, SUTTON, and STRANCH, Circuit Judges.


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OPINION
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ROGERS, Circuit Judge. Anthony Palos pleaded guilty to being a felon in possession of a firearm and was sentenced to 63 months’ imprisonment. Palos makes two challenges to his sentence on appeal. First, he argues that one of his previous drug trafficking convictions no longer qualifies as a “controlled substance offense” after our decision in United States v. Havis, 927 F.3d 382 (6th Cir. 2019) (en banc) (per curiam), and therefore his base offense level under the Guidelines was miscalculated. The Government concedes that our reading of Havis in United States v. Cavazos, 950 F.3d 329 (6th Cir. 2020), is controlling on this issue and that a remand is warranted. Second, Palos argues that he should not have received a sentencing enhancement for possession of a stolen firearm because he had no knowledge that the firearm he possessed was stolen. But our rejection of the same contention in United States v. Murphy, 96 F.3d 846 (6th Cir. 1996), remains good law notwithstanding the more recent decisions of United States v. Roxborough, 99 F.3d 212 (6th Cir. 1996), Havis, and Rehaif v. United States, 139 S. Ct. 2191 (2019).



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MEMPHIS A. PHILIP RANDOLPH INSTITUTE; THE EQUITY ALLIANCE; FREE HEARTS; THE MEMPHIS AND WEST TENNESSEE AFL-CIO CENTRAL LABOR COUNCIL; THE TENNESSEE STATE CONFERENCE OF THE NAACP; SEKOU FRANKLIN,
Plaintiffs-Appellants,
v.
TRE HARGETT; MARK GOINS; AMY P. WEIRICH,
Defendants-Appellees.
   No. 20-6046
Appeal from the United States District Court
for the Middle District of Tennessee at Nashville.
No. 3:20-cv-00374—Eli J. Richardson, District Judge.
Decided and Filed: October 15, 2020
Before: MOORE, GIBBONS, and READLER, Circuit Judges.


_________________________
OPINION
_________________________

JULIA SMITH GIBBONS, Circuit Judge. In the midst of the COVID-19 pandemic, absentee voting has found its way into the spotlight. Record numbers of voters are expected to vote by mail in the November 2020 election, and the increased interest in absentee voting has also led to increased interest in the policies and procedures governing how and when voters may vote absentee. In resolving cases of significant public interest, judges must, as they do in all cases, reach decision by employing independent, unbiased analysis, based on the law and the facts of a particular case.

The plaintiffs in this case consist of individuals and organizations located in Tennessee, and together they have brought five claims challenging the Tennessee statutory scheme that governs absentee voting. One claim challenges the eligibility criteria that Tennessee has imposed for absentee voters, one claim challenges limits on the plaintiffs’ ability to distribute unsolicited absentee ballots, two claims challenge Tennessee’s procedures for verifying voter signatures on absentee ballots, and the final claim challenges a restriction on first-time voters’ ability to vote absentee. Our decision today deals only with the two claims involving Tennessee’s signature verification procedures. For the reasons that follow, we AFFIRM the district court’s order denying the plaintiffs’ requested preliminary injunction on those claims, although we do so on a basis different from that relied on by the district court.