U.S. Court of Appeals for the Sixth Circuit

United States v. Kyle Wagner

August 12, 2026

Summary

The court held that the Government proved by clear and convincing evidence that Wagner posed a danger to J.S. and the community, and that no combination of release conditions could reasonably assure public safety. Applying de novo review to the ultimate detention determination and clear-error review to factual findings, the court concluded that Wagner's escalating threats, doxxing conduct, private communications about killing a former official, and history of disregarding court restrictions required pretrial detention. The court therefore reversed the district court's release order. BLOOMEKATZ, J., dissenting, would have deferred to the district court and affirmed release under stringent conditions.