United States v. Dolores Reid, 764 F.3d 528

Reid was executive director for River Rouge School District during the 2010–2011 year and coordinated contracts with Flaggs and Associates, owned by her brother-in-law.
She helped Flaggs secure four school contracts, including a Jump Start program falsely claimed as mandatory to enroll students and generate payments.
Flaggs received $75,000; initial $37,000 was followed by a cash withdrawal and a small personal withdrawal by Reid; journal entries referenced gifts and favors from Flaggs.
SES program contracts were awarded to multiple providers; Flaggs had favorable terms and broader reach than competitors, with evidence of preferential treatment.
Reid’s journal and post-interview statements admitted receiving cash/gifts for favorable treatment; a search of her home yielded incriminating journals and a Flaggs-purchased flat-screen TV.
Reid was indicted for bribery under 18 U.S.C. § 666(a)(1)(B) and mail fraud under 18 U.S.C. § 1341; the jury convicted on both counts and she received concurrent 60-month sentences.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Batson challenge timing	Reid asserts Batson violation for striking jurors after prayer-journal question.	Government claims Batson applies; for-cause strikes may be challenged; timing matters.	Batson challenge must be raised during voir dire; Reid waived by not objecting timely.
Miranda validity of post-warning questioning	Reid argues statements were obtained in violation of Miranda.	Government did not require a post-search Miranda warning due to waiver/Rule 12(b) issue.	Miranda claim not reviewed on the merits due to failure to raise a suppression motion under Rule 12(b).
Ineffective assistance regarding sentencing	Counsel failed to challenge loss calculations under Washington and offsetting the loss amount.	Record insufficient to adjudicate Sixth Amendment claims on direct appeal.	Court declines to address on direct appeal; record undeveloped for ineffective-assistance determination.

Batson v. Kentucky, 476 U.S. 79 (U.S. Supreme Court, 1986) (prohibits race-based peremptory strikes; burden shifts to government to show neutral reason)
Massaro v. United States, 538 U.S. 500 (U.S. Supreme Court, 2003) (ineffective-assistance claims generally require post-conviction review; direct appeal limited)
United States v. Ferguson, 669 F.3d 756 (6th Cir. 2012) (direct-appeal authority for ineffective assistance requires developed record)
Oldfield, 859 F.2d 392 (6th Cir. 1988) (Rule 12(b) suppression issues not reviewable on direct appeal when not raised timely)
Peraza, 25 F.3d 1051 (6th Cir. 1994) (unpublished; timely objection to discriminatory challenges affects waiver)