The U.S. Court of Appeals for the Sixth Circuit affirmed Tuesday the denial of a habeas corpus petition filed by Ohio prisoner Jamal Dye, who was convicted of murder in the fatal shooting of James Gray at a party. The decision in *Dye v. Frederick* (6th Cir. 2026) upholds the U.S. District Court for the Northern District of Ohio's rejection of Dye's constitutional challenges to his state court conviction.
The case stems from a shooting that occurred at a party at Gray's home, where an altercation between Dye and Gray escalated to deadly violence. According to court records, Dye shot and killed Gray during the incident, leading to multiple criminal charges including aggravated murder, murder, felonious assault, discharge of a firearm in prohibited premises, and carrying a concealed weapon.
Dye pleaded not guilty to all charges and proceeded to trial before a state court jury in Ohio. The prosecution presented testimony from six witnesses who attended the party, with Elizabeth Torres serving as the sole eyewitness to the actual shooting. Torres testified that she observed Dye shoot Gray but did not personally witness any physical struggle between the two men immediately before the shooting occurred.
Additional witnesses provided testimony about ongoing altercations between Dye and Gray throughout the evening of the party. Multiple witnesses testified that Gray and several other individuals had beaten and fought with Dye during the course of the night, suggesting a pattern of escalating conflict that preceded the fatal shooting.
The state's case also included evidence obtained from social media platforms, specifically photographs showing Dye holding firearms. These images were introduced at trial to establish Dye's access to and familiarity with weapons. A police officer also provided testimony regarding related matters, though the complete details of that testimony are not specified in the available court records.
Following his conviction in state court, Dye filed a petition for a writ of habeas corpus under 28 U.S.C. § 2254, which allows state prisoners to challenge their convictions in federal court on constitutional grounds. The federal habeas corpus statute permits prisoners to seek relief when they believe their constitutional rights were violated during their state court proceedings.
The U.S. District Court for the Northern District of Ohio reviewed Dye's habeas petition and denied relief. Dye then appealed that denial to the Sixth Circuit Court of Appeals, arguing that the district court erred in rejecting his constitutional claims. The specific constitutional violations alleged by Dye in his habeas petition are not detailed in the available court records.
A three-judge panel consisting of Circuit Judges Alice M. Batchelder, William Clay Jr., and Karen Moore heard Dye's appeal. Judge Batchelder authored the court's opinion affirming the district court's denial of habeas relief. The decision, filed January 21, 2026, was marked "not recommended for publication," indicating the court viewed it as applying established legal principles rather than creating new precedent.
The Sixth Circuit's affirmance means Dye has exhausted his federal appellate options regarding his habeas corpus petition. Under federal law, habeas corpus petitions filed by state prisoners face significant procedural hurdles and must demonstrate that the state court's decision was contrary to or involved an unreasonable application of clearly established federal law as determined by the Supreme Court.
The case number 25-3129 reflects that the appeal was filed in 2025 and processed through the Sixth Circuit's regular appellate procedures. George Frederick, identified as the warden in the case caption, was named as the respondent in his official capacity as the custodian of Dye, who remains incarcerated following his state court conviction.
The Sixth Circuit Court of Appeals has jurisdiction over federal appeals from Ohio, Michigan, Kentucky, and Tennessee. The court regularly reviews habeas corpus petitions filed by state prisoners challenging their convictions, though successful petitions are relatively rare due to the deferential standard of review federal courts apply to state court decisions.
While the court's opinion affirms the denial of Dye's habeas petition, the specific legal arguments raised by Dye and the court's reasoning for rejecting those claims are not detailed in the available excerpts of the decision. The case represents another example of the federal courts' limited role in reviewing state criminal convictions absent clear constitutional violations.
The decision concludes Dye's challenge to his murder conviction in federal court, though he may retain certain limited options for future legal challenges depending on the specific circumstances of his case and any new evidence or legal developments that might emerge.