June 10, 2026

The following opinions were issued on June 9 after The Indiana Lawyer’s deadline.

7th Circuit Court of Appeals
USA v. Joshua Schatz
No. 24-2252

Appeal from the United States District Court for the Southern District of Indiana, Terre Haute Division, Judge James R. Sweeney, II. Before Judges Rovner, Pryor and Kolar. The court affirms the district court’s application of a statutory enhancement to Joshua Schatz’s sentence for possessing child pornography based on his prior Indiana conviction for child molesting. The court concludes that Schatz’s prior conviction, despite its broader age range, “relates to” the federal definitions of aggravated sexual abuse and abusive sexual conduct involving a minor, aligning with the statutory language. Judge Kolar authored the opinion.

7th Circuit Court of Appeals
USA v. Frank Washington III
No. 25-2379

Appeal from the United States District Court for the Northern District of Indiana, Hammond Division, Judge James T. Moody. Before Judges Ripple, Kolar and Maldonado. Defendant Frank Washington III appeals his 70-month sentence for possessing a firearm as a convicted felon, arguing that the district court did not adequately explain its decision. The court acknowledged Washington’s documented health concerns but failed to provide an individualized assessment of factors related to his sentence duration. As the court’s explanation was insufficient for meaningful appellate review, the panel vacated Washington’s sentence and remanded the case for resentencing. The opinion was authored per curiam.

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