JusticiabilityDoctri
Whether a criminal defendant can seek post-conviction relief based on a supervening Supreme Court decision that undermines the legal theory supporting their conviction
The Sixth Circuit issued its ruling in my case on May 21, 2025 — just one day before this Court's decision in Kousisis v. United States, which directly addresses the “material misrepresentation” theory applied in my case. My petition will also present the questions of whether restitution can be awarded to non-victims without proof of actual loss, whether exclusion of sworn statements from the alleged victim violated my right to present a complete defense, and whether | was denied effective assistance of counsel at trial and on appeal. | am now proceeding pro se due to my counsel’s prior deficiencies, and | have faced substantial delays in preparing my petition caused first by limited legal access and repeated lockdowns at FCI Hazelton Satellite Camp, and then