Steve Karacson v. David Shaver

── Steve Karacson v. David Shaver ── Court: Court of Appeals for the Sixth Circuit Date: May 20, 2026 Category: General RECOMMENDED FOR PUBLICATION Pursuant to Sixth Circuit I.O.P. 32.1(b) File Name: 26a0151p.06 UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT ┐ STEVE ELLIS KARACSON, │ Petitioner-Appellant, │ > No. 25-1089 │ v. │ │ DAVID SHAVER, Warden, │ Respondent-Appellee. │ ┘ Appeal from the United States District Court for the Eastern District of Michigan at Flint. No. 4:20-cv-13100—Matthew F. Leitman, District Judge. Argued: April 28, 2026 Decided and Filed: May 20, 2026 Before: THAPAR, BUSH, and MURPHY, Circuit Judges. _________________ COUNSEL ARGUED: Bailey Lindsey, Adam B. Murphy, Miles Pulsford, NEW YORK UNIVERSITY SCHOOL OF LAW, New York, New York, for Appellant. Scott R. Shimkus, OFFICE OF THE MICHIGAN ATTORNEY GENERAL, Lansing, Michigan, for Appellee. ON BRIEF: Bailey Lindsey, Adam B. Murphy, Miles Pulsford, Daniel S. Harawa, NEW YORK UNIVERSITY SCHOOL OF LAW, New York, New York, for Appellant. Scott R. Shimkus, OFFICE OF THE MICHIGAN ATTORNEY GENERAL, Lansing, Michigan, for Appellee. _________________ OPINION _________________ THAPAR, Circuit Judge. Steve Karacson set fire to his own house. So a Michigan jury convicted him of arson and insurance fraud at a trial where he represented himself.  No. 25-1089 Karacson v. Shaver Page 2 Karacson then petitioned for a writ of habeas corpus, arguing that he didn’t waive his right to counsel. But the district court denied his petition because Michigan state courts reasonably rejected his claim on direct appeal. We affirm. I. In 2017, a fire devastated Steve Karacson’s house. It took firefighters two or three hours to put out the flames. The next day, investigators entered the house with an arson dog and detected the smell of gasoline. They also determined that the fire had multiple origin points inside the house. After reviewing this evidence and eliminating other possible causes, they concluded the fire was an act of arson. Karacson had fire insurance, so the investigation focused on him. Karacson told investigators he wasn’t home on the night of the fire. He claimed instead that he’d traveled to Kentucky two days before the fire and returned the morning after the fire. But location data from his cell phone said otherwise. The morning before the fire, Karacson’s phone connected to towers along a route heading north from Kentucky back to Michigan. And less than an hour before the fire, his phone pinged a tower near his house. Police officers also found a receipt in Karacson’s wallet showing that, just hours before the fire, he had bought a five-gallon gas can and a pair of utility gloves from a Michigan hardware store. So Michigan charged Karacson with arson and insurance fraud. Karacson pled not guilty. A month later, he sought to fire his court-appointed attorney for refusing to file certain motions on his behalf. The trial court denied Karacson’s request for a new attorney. But Karacs