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6th Circuit Rules Out Federal Judge for New Trial after Biased Comment on Defendant’s Appearance

The 6th U.S. Circuit Court of Appeals in Cincinnati has overturned the drug convictions of a Michigan defendant, Leron Liggins of Southfield, after a federal judge’s biased comments. The judge, U.S. District Judge Stephen J. Murphy III of the Eastern District of Michigan, had stated during a hearing that the accused man “looks like a criminal to me.” The appeals court ruled that this remark violated Liggins’ Fifth Amendment due process right to a fair trial before an impartial tribunal, and as a result, the convictions have been overturned.

Judge Murphy’s comments were made during a hearing in January 2020 when Liggins was seeking new legal representation after firing his second lawyer. The defendant had also been indecisive about whether to plead guilty, causing delays in the case. Judge Murphy’s remarks were as follows: “I’m tired of this case. I’m tired of this defendant. I’m tired of getting the runaround. This guy has got my attention… This guy looks like a criminal to me. This is what criminals do.” He had further criticized Liggins for allegedly dealing heroin and playing games with the court.

The appeals court stated that such remarks from the presiding judge were “personal and condemnatory,” which compromised the fairness of the trial process. The court’s decision emphasized that a different judge should retry Liggins to ensure a fair and unbiased trial. The court’s ruling was based on the violation of Liggins’ due process rights and the potential racial bias evident in the judge’s comments.

Judge Murphy’s refusal to let Liggins speak during the hearing was also criticized by the appeals court. While judges can require defendants to communicate through their attorneys, it was deemed an abuse of discretion to enforce this when the defendant was dissatisfied with his lawyer.

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The government’s argument that Murphy’s comments reflected Liggins’ conduct rather than the appeals court rejected his appearance. The court highlighted that a reasonable observer could interpret the remarks as prejudging Liggins’ guilt based on his physical appearance. The court found the judge’s conduct to be troubling and not understandable given the circumstances.

The case raised concerns about potential racial bias, as Liggins is Black while Judge Murphy is white. The appeals court indicated that Murphy’s comment about Liggins looking like a criminal raised the specter of racial bias, which further underscored the need for a fair trial.

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Liggins had been convicted of conspiracy to possess with intent to distribute and to distribute heroin, as well as aiding and abetting his courier’s possession with intent to distribute heroin. However, the 6th Circuit Court of Appeals reversed these convictions due to the judge’s unacceptable remarks and the perceived bias.

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Rachel E: