ALICE M. BATCHELDER, Circuit Judge. An Ohio prisoner, sentenced to death, appeals the denial of his 28 U.S.C. § 2254 petition for a writ of habeas corpus. We AFFIRM.

CLAY, Circuit Judge. Defendant Manndrell Lee appeals his sentence of 60 months’ imprisonment for possession of a stolen firearm in violation of 18 U.S.C. § 922(j), a sentence which reflects an upward variance of almost two years from the high end of Lee’s 30 to 37 months guidelines range. The district court imposed this extreme variance purportedly due to Lee’s criminal history. A district court is certainly able to vary upward from a defendant’s advisory guidelines range based on his criminal history and a specific need for deterrence. See 18 U.S.C. § 3553(a). But where, as here, nothing uniquely problematic about the defendant’s criminal history demonstrates a specific need for deterrence beyond that already captured in the guidelines range, our case law has recognized that some meaningful relationship between the offense of conviction and a defendant’s alleged likelihood of reoffending is needed. Because Lee’s criminal history has little bearing on the instant offense, it does not justify the two-year upward variance that the district court imposed, which nearly doubled Lee’s recommended sentence under the guidelines. We therefore vacate Lee’s sentence and remand for resentencing.

This is an action to set aside a quitclaim deed. In the Complaint for a Declaratory Judgment, the attorney-in-fact for the plaintiff alleges that the plaintiff was not competent to execute the quitclaim deed, that she did not intend to convey title to the property, and she did not receive consideration for the conveyance. At the conclusion of the plaintiff’s case-in-chief and upon the motion of the defendant, the court directed a verdict in favor of the defendant. The court found, inter alia, there was no competent evidence to support the allegations that the plaintiff was not competent to execute the quitclaim deed, that fraud occurred, or that a fiduciary duty owed to the plaintiff was breached, and there was no proof presented that the parties lacked a meeting of the minds. This appeal followed. We affirm.

JANE B. STRANCH, Circuit Judge. This is an unusually postured pre-AEDPA habeas case that turns on the Supreme Court’s modern procedural default jurisprudence. In 1986, Joe Clark Mitchell—a black man—was convicted by an all-white jury of raping two white women in Tennessee. The Warden no longer disputes the assertion that the prosecution’s decision to strike a black prospective juror violated Batson v. Kentucky, 476 U.S. 79 (1986). The district court granted relief on Batson grounds in 1995, but we reversed, holding that Mitchell had to first establish “cause and prejudice” for failing to develop the claim before the state court. Mitchell v. Rees, 114 F.3d 571, 579 (6th Cir. 1997) (“Mitchell I”). We have acknowledged that our holding was error. See Harries v. Bell, 417 F.3d 631, 635 (6th Cir. 2005). Because Supreme Court precedent now enables Mitchell to show the necessary “cause,” and authorizes him to raise his underlying ineffective assistance of counsel (IAC) claim and to seek redress through a Rule 60(b) motion, we REVERSE the district court’s decision, GRANT Mitchell a conditional writ of habeas corpus, and REMAND the case for further proceedings.

CLAY, Circuit Judge. Plaintiffs in this case are the legal custodian and estate representative of Ta’Naejah McCloud, who was born in 2011. Ta’Naejah was in the custody of her biological mother, Tequila Crump, who severely abused her, including through repeated burnings and beatings. Ta’Naejah was hospitalized and interviewed by Cuyahoga County caseworkers, but ultimately was returned to Crump’s custody. Throughout the next year, the county received further reports of abuse and interviewed Ta’Naejah several more times, but never acted to remove her from the household. The abuse eventually resulted in Ta’Naejah’s death.

While several of Plaintiffs’ federal claims are foreclosed by the Supreme Court’s and this Court’s case law, Plaintiffs also allege that the state affirmatively increased Ta’Naejah’s risk of harm by repeatedly interviewing her about her abuse in the presence of her alleged abusers, in violation of state regulations. Because these allegations plausibly allege a claim under the state-created danger doctrine, the district court erred by dismissing Plaintiffs’ complaint. Accordingly, we affirm in part and reverse in part the district court’s order dismissing Plaintiffs’ federal claims, vacate the dismissal of Plaintiffs’ state-law claims, vacate the order striking Plaintiffs’ post-judgment motion, and remand this case for further proceedings. We also deny Defendants’ motion to seal.

CLAY, Circuit Judge. Plaintiffs Cherryl Kirilenko-Ison and Susan Bauder-Smith appeal the district court’s order granting summary judgment in favor of their former employer, Defendant Board of Education of Danville Independent Schools (“School Board”). Plaintiffs assert that the School Board illegally retaliated against them for their advocacy on behalf of two disabled students, in violation of the Americans with Disabilities Act (“ADA”), 42 U.S.C. § 12101 et seq., Section 504 of the Rehabilitation Act (“Section 504”), 29 U.S.C. § 701 et seq., and the Kentucky Civil Rights Act (“KCRA”), Ky. Rev. Stat. § 344. Plaintiffs also claim that the School Board violated the Kentucky Whistleblower Act, Ky. Rev. Stat. § 61.102, by retaliating against them for reporting a parent’s suspected child neglect to Kentucky’s Cabinet for Families and Children. Plaintiff Kirilenko-Ison further asserts that the School Board failed to accommodate her disability and constructively discharged her, in violation of the ADA and the KCRA. For the reasons that follow, we affirm in part and reverse in part the district court’s grant of summary judgment.

BOGGS, Circuit Judge. International Outdoor, Inc. (“International Outdoor”) sought to erect billboards in the City of Troy, Michigan. After the City of Troy denied International Outdoor’s application for a permit and then for a variance from the limitations imposed by the City’s sign ordinance, International Outdoor brought suit challenging the constitutionality of the City’s ordinance under 42 U.S.C. § 1983 and alleging that the sign ordinance violated International Outdoor’s First Amendment rights.

For the reasons stated below, we affirm the district court’s grant of the City of Troy’s motion for summary judgment on International Outdoor’s claim that the City’s sign ordinance constitutes an unconstitutional prior restraint. However, we vacate the district court’s grant of the City of Troy’s motion to dismiss International Outdoor’s claim that the City’s sign ordinance imposes content-based restrictions without a compelling government interest, and we remand for reconsideration under the Reed standard. We also vacate and remand the district court’s denial of International Outdoor’s motion for attorney’s fees, pending reconsideration of the City of Troy’s motion to dismiss.

The Appellant, Nathan Lamar Swanson, Jr., pled guilty to attempted possession of a firearm by a felon, aggravated kidnapping, aggravated assault, and possession of a Schedule IV controlled substance with the intent to sell. The Appellant was given a total effective sentence of fourteen years as a Range I offender. The Appellant subsequently filed a pro se motion seeking to withdraw his guilty plea. Upon being appointed counsel, the Appellant filed an amended motion seeking to withdraw his guilty plea, alleging that trial counsel failed to adequately investigate the charges and to advise the Appellant as to a viable defense, resulting in an unknowing, involuntary plea. The trial court denied relief, and the Appellant appeals. Following our review, we affirm.

This action involves the termination of a mother’s parental rights to her minor child. Following a bench trial, the trial court found that clear and convincing evidence existed to establish the following statutory grounds of termination: (1) wanton disregard for the child’s welfare; (2) substantial noncompliance with the permanency plan; (3) severe child abuse; and (4) failure to manifest an ability and willingness to parent. The court also found that termination was in the best interest of the child. We affirm the trial court.

JANE B. STRANCH, Circuit Judge. In 2011, Michigan narrowed the crimes covered by the Sex Offender Registration Act (SORA) making Anthony Hart no longer a “sex offender.” Defendants required him to continue registering as one, and he did. In July 2013, he registered an incorrect address and, in January 2014, failed to update his address. Defendants arrested Hart each time, using warrant requests incorrectly representing that he was required to register under SORA. The first time, Hart spent the night in jail; the second time, he served 19 months in prison. When prison officials finally realized the mistake, they released Hart and his convictions were vacated. Hart then sued for false arrest, malicious prosecution, and defamation. Five Defendants, employees of the city police and county sheriff’s departments, moved to dismiss the suit based on qualified immunity. The district court denied the motion and, for the reasons explained below, we AFFIRM IN PART and REVERSE IN PART.