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Eighth Circuit: Prior Convictions Not Relevant to Escape

Leonard Lester Slaughter III was serving a 115-month sentence at a Federal Bureau of Prisons facility when he escaped. After pleading guilty to the escape, the District Court concluded that two prior convictions were not “relevant conduct” and thus counted them as felony convictions when calculating Slaughter’s criminal history category. Slaughter objected and made the

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Sixth Circuit: Jail Guard’s Criticism of Sheriff was Protected Speech

Joseph Boulton, a jail guard at the Genesee County, Michigan jail, lost his claim alleging unconstitutional retaliation for protected speech on July 29, 2015. During union arbitration proceedings, Boulton testified that Sheriff Christopher Swanson had misrepresented the amount of Taser, firearm, and CPR training that Sheriff’s Office employees received. He also shared his concerns about

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