## Facts

- A fire occurred at Steve Allen Pritchard’s Kentucky residence around 3:05 a.m. on June 30, 2011; firefighters responded.
- Firefighter Charles Sparks suffered a fatal heart attack while responding to the fire.
- Sparks had preexisting coronary disease, hypertension, and diabetes; testimony indicated that the physiological stress of firefighting can trigger a heart attack.
- The government’s theory was that Pritchard set the fire to collect insurance proceeds and arranged for his wife, children, and dog to be away from the home that night.
- Evidence indicated Pritchard gave investigators a false alibi after the fire.
- Pritchard told his wife, Brandi, about prior fires he claimed to have set for insurance money; the government offered this as proof of motive, intent, and plan.
- Brandi initially resisted but later participated and helped pursue insurance proceeds; she later cooperated with authorities.
- Evidence showed Pritchard threatened violence to prevent Brandi from confessing; she obtained emergency protective orders.
- Investigators obtained historical cell-site location information (CSLI) without a warrant using Stored Communications Act procedures.
- A jury convicted Pritchard of malicious destruction of property by fire affecting interstate commerce, with death resulting (18 U.S.C. § 844(i)), and mail fraud (18 U.S.C. § 1341); the court imposed 360 months on the arson count and a concurrent 240 months on the fraud count, plus a two-level leadership enhancement.

## Issues

1. Whether the evidence was sufficient to prove that Pritchard’s arson was a “direct or proximate result” of Sparks’s death under 18 U.S.C. § 844(i), given Sparks’s preexisting conditions.
2. Whether the district court abused its discretion by admitting evidence of prior fires and related materials under Federal Rule of Evidence 404(b), as well as protective orders and arson-motive expert testimony.
3. Whether historical CSLI obtained without a warrant should have been suppressed after Carpenter v. United States, or whether the good-faith exception applied.
4. Whether the district court clearly erred by applying a two-level organizer/leader enhancement under U.S.S.G. § 3B1.1(c).

## Decision

- The Sixth Circuit affirmed the convictions and sentence.
- The court held the causation evidence was sufficient for § 844(i) because arson foreseeably causes firefighter response and stress-related medical events, and expert testimony supported the link between firefighting and a heart attack.
- The court upheld admission of prior-fire evidence under Rule 404(b) as probative of motive, intent, preparation/planning, and absence of mistake, with prejudice not substantially outweighing probative value.
- The court upheld admission of protective orders and related evidence as relevant to coercion and consciousness of guilt, and allowed the arson-motive expert testimony.
- The court declined to suppress CSLI because investigators acted in good-faith reliance on then-valid statutory process under the Stored Communications Act.
- The court upheld the § 3B1.1(c) enhancement because Pritchard planned and directed the arson and coverup and exercised control over Brandi through threats and coercion.

## Legal Principles

- When a statute requires that death be a “direct or proximate result” of a defendant’s conduct, liability generally requires both but-for causation and foreseeability-based proximate causation.
- For proximate cause in this setting, the precise victim vulnerability need not be foreseeable if the general type of harm is foreseeable (e.g., responders experiencing serious medical events from emergency-response stress).
- Rule 404(b) permits evidence of other acts to prove non-propensity purposes such as motive, intent, preparation, plan, and absence of mistake, subject to Rule 403 balancing and limiting instructions.
- Evidence of threats and protective orders may be admissible to show coercion and consciousness of guilt where it is relevant and not unfairly prejudicial.
- Even if later precedent establishes a warrant requirement for certain searches (such as historical CSLI), suppression may be unavailable where officers reasonably relied on then-existing law (good-faith exception).
- A two-level organizer/leader enhancement under U.S.S.G. § 3B1.1(c) may apply in a small scheme if the defendant directed another participant’s actions in planning or execution.

## Conclusion

The Sixth Circuit held that a jury could reasonably find a firefighter’s stress-triggered fatal heart attack to be a foreseeable, proximate result of insurance-motivated arson under § 844(i), and it affirmed evidentiary rulings, denied suppression of pre-Carpenter CSLI under the good-faith exception, and upheld a leadership enhancement based on the defendant’s control of a co-participant.


United States v. Pritchard, 964 F.3d 513 (6th Cir. 2020)