Remembering Deborah Rhode: Co-Author, Friend, and Feminist Co-Conspirator

JOANNA L. GROSSMAN, KATHARINE BARTLETT, DEBORAH L. BRAKE

SMU Dedman School of Law professor Joanna L. Grossman, Duke Law professor Katharine T. Bartlett, and Pitt Law professor Deborah L. Brake reflect on the life and achievements of Professor Deborah Rhode, who recently passed away. Professors Grossman, Bartlett, and Brake describe Professor Rhode’s countless contributions to the legal academy and to the fight for gender equity.

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United States v. Milliron

Docket: 19-3720

Opinion Date: January 11, 2021

Judge: Guy

Areas of Law: Criminal Law

U.S. Marshals searching for Milliron in Ohio, based on an outstanding Florida warrant, located Milliron driving his truck. Milliron led the Marshals and local police on a 35-mile chase, hurling glass bottles and makeshift plastic Molotov cocktails toward the officers' vehicles. Milliron eventually crashed into a building. Milliron’s truck was a mobile methamphetamine lab. Milliron's “one-pot methamphetamine” Molotov cocktails contained flammable liquid and chemicals used to manufacture methamphetamine. Milliron had 13 rounds of ammunition in his pocket. Milliron was charged with: using a dangerous weapon to forcibly interfere with federal officers performing official duties, 18 U.S.C. 111(a)(1), (b); possession of a firearm not registered to him; carrying and using a destructive device in relation to a crime of violence; possession of products which may be used to manufacture methamphetamine; intent to manufacture approximately 4.7 grams of methamphetamine; possession with intent to distribute 4.7 grams of methamphetamine; and being a felon-in-possession of ammunition. Milliron pleaded guilty to Counts 1, 4, 5, and 7. Months later, Milliron unsuccessfully moved to withdraw his plea, arguing “counsel acknowledge[d] that his representation . . . was deficient” because he had failed to explain that an 18 U.S.C. 111(b) conviction “requires that the defendant intended to cause injury.” With a two-level enhancement for possessing a “dangerous weapon,” a three-level enhancement because a dangerous weapon was possessed and its use was threatened, and a three-level reduction for acceptance of responsibility, Milliron’s Guidelines range was 77-96 months. The Sixth Circuit affirmed his 110-month sentence. The appeal waiver bars review of Milliron’s challenge to the denial of his motion to withdraw his plea. The district court correctly assigned the sentencing enhancements. The sentence was reasonable; Milliron “was a violent offender, both on the day in question and previously.”