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UNITED STATES OF AMERICA,
Plaintiff-Appellee,
v.
ADAM CARSON,
Defendant-Appellant.
   No. 21-3518
Appeal from the United States District Court for the Northern District of Ohio at Cleveland.
No. 1:17-cr-00008-1—Donald C. Nugent, District Judge.
Argued: November 29, 2022
Decided and Filed: December 16, 2022
Before: WHITE, THAPAR, and READLER, Circuit Judges.


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OPINION
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THAPAR, Circuit Judge. When the district court took all but $300 from Adam Carson’s inmate trust account to pay his court-ordered restitution, it made no findings and cited no authorities. Because the law requires more, we vacate and remand for further findings.



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RALPH GRAGG,
Plaintiff-Appellant,
v.
UPS PENSION PLAN,
Defendant-Appellee.
   No. 22-3379
Appeal from the United States District Court for the Southern District of Ohio at Columbus.
No. 2:20-cv-05708—Algenon L. Marbley, Chief District Judge.
Argued: October 20, 2022
Decided and Filed: December 16, 2022
Before: BATCHELDER, GRIFFIN, and KETHLEDGE, Circuit Judges.


_________________________
OPINION
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KETHLEDGE, Circuit Judge. The limitations period for an ERISA claim “to recover benefits due” under a plan does not expire before the alleged underpayment on which the claim is based. Here, UPS driver Ralph Gragg received from each of two pension plans a letter whose particulars contradicted each plan’s more general description of the monthly payments that he would receive after turning 65. Eight years later Gragg received his first such payments, which were much lower than he expected. Gragg brought this suit, which the district court held was time-barred because, the court held, Gragg’s claim had accrued when he received the plans’ letters eight years before. But the letters did not cause the injury upon which Gragg sued; the underpayments did. And before that injury his claim had not accrued. We reverse the district court’s dismissal of Gragg’s claim.



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UNITED STATES OF AMERICA,
Plaintiff-Appellee,
v.
CHRISTOPHER MICHAEL SAMMONS,
Defendant-Appellant.
   No. 22-3113
Appeal from the United States District Court for the Southern District of Ohio at Columbus.
No. 2:19-cr-00107-1—Sarah Daggett Morrison, District Judge.
Argued: December 7, 2022
Decided and Filed: December 16, 2022
Before: SUTTON, Chief Judge; COLE and GRIFFIN, Circuit Judges.


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OPINION
_________________________

SUTTON, Chief Judge. In online chats with two undercover officers, Christopher Sammons shared child pornography, requested videos of his correspondents sexually abusing children, described abusing his niece, and offered more videos down the road of planned abuse. The FBI apprehended Sammons hours before he was scheduled to babysit his niece, and he confessed to taking and sharing explicit photos of her online. A jury convicted him of several child-pornography charges. We affirm.