The U.S. Court of Appeals for the Sixth Circuit issued a published opinion Monday affirming the conviction and sentence of Robert Messersmith for possession of a firearm by a convicted felon, rejecting his claims that the government breached his plea agreement and that his sentence was unreasonable.
The three-judge panel, consisting of Circuit Judges Gilman, Griffin, and Murphy, upheld the district court's sentence in *United States v. Messersmith* (6th Cir. 2026). Judge Griffin authored the opinion for the court.
The case stems from an incident that occurred while Messersmith was out on bond for a second-degree burglary charge. According to court records, Kentucky police attempted to pull Messersmith over for speeding, but he fled until his truck became stuck in a pond. The circumstances that followed led to federal charges for firearm possession by a convicted felon under 18 U.S.C. § 922(g)(1).
Messersmith entered a guilty plea to the federal charge before U.S. District Judge Danny C. Reeves in the Eastern District of Kentucky at Pikeville. The district court sentenced him to what the appeals court described as a "bottom-of-the-Guidelines sentence," indicating the punishment fell at the lower end of the applicable federal sentencing guidelines range.
On appeal, Messersmith raised two primary arguments challenging his conviction and sentence. First, he claimed the government breached the terms of his plea agreement during the sentencing proceedings. Plea agreements are contracts between defendants and prosecutors that must be honored by both parties, and material breaches can void the agreement or require other remedies.
Second, Messersmith argued that his sentence was substantively unreasonable under federal sentencing law. Courts of appeals review sentences for reasonableness, examining both the procedural aspects of sentencing and whether the final sentence is substantively appropriate given the facts and applicable law.
The Sixth Circuit rejected both arguments in its published opinion. The court found no breach of the plea agreement by the government and determined that Messersmith's sentence was reasonable. The opinion provides no detailed analysis of the court's reasoning, as the available excerpt focuses on the procedural history and basic holdings.
The decision was recommended for publication under Sixth Circuit Internal Operating Procedure 32.1(b), indicating the court believes the case establishes or clarifies important legal precedent. Published federal appellate decisions carry precedential weight and become binding authority for district courts within the circuit.
Felon-in-possession charges under 18 U.S.C. § 922(g)(1) are among the most commonly prosecuted federal gun crimes. The statute prohibits anyone previously convicted of a felony from possessing firearms or ammunition. Penalties can include up to 10 years in federal prison, with enhanced sentences available for defendants with multiple prior convictions under the Armed Career Criminal Act.
The case illustrates the intersection between state and federal criminal law, as Messersmith's initial encounter with law enforcement involved state traffic and burglary charges, but the firearm possession led to federal prosecution. Federal authorities often pursue gun charges when defendants have prior felony convictions that make firearm possession illegal under federal law.
Christopher Wiest of Chris Wiest, Atty at Law, PLLC in Covington, Kentucky, represented Messersmith on appeal. The government was represented by Assistant U.S. Attorneys Charles P. Wisdom Jr. and Amanda Harris Huang from the U.S. Attorney's Office in Lexington, Kentucky.
The case was assigned docket number 25-5496 on appeal and originated from criminal case number 7:24-cr-00020-1 in the Eastern District of Kentucky. The appeals court decided and filed its opinion on Jan. 13, 2026.
This decision adds to the body of Sixth Circuit precedent on felon-in-possession prosecutions and plea agreement enforcement. The published status means the ruling will guide future cases involving similar legal questions within the circuit, which covers Kentucky, Michigan, Ohio, and Tennessee.
The affirmance demonstrates federal appellate courts' general deference to district court sentencing decisions when they fall within guidelines ranges and follow proper procedures. Appeals courts typically reverse sentences only when they find clear procedural errors or determine that a sentence is substantively unreasonable given the circumstances.
Messersmith's case concluded at the circuit court level, as the Supreme Court rarely grants certiorari in routine felon-in-possession cases unless they present novel constitutional or statutory interpretation questions. The defendant could petition for Supreme Court review, but such petitions face long odds given the straightforward nature of the legal issues involved.