Court: United States Court of Appeals for the First Circuit

Filed: 2026-08-21

The First Circuit affirmed the district court’s grant of summary judgment in favor of police officers against plaintiffs who alleged Fourth Amendment violations and state law torts arising from three warrantless entries into a “sober home” (Genesis House) between October 2019 and January 2020. The court held that the plaintiffs’ claims failed on the merits, were waived due to insufficient argumentation, or were barred by qualified immunity. Regarding the October 2019 entry, the court found that while the initial search for an overdose victim was valid under the emergency aid exception, the plaintiffs failed to provide specific facts demonstrating that any subsequent “continued” search or brief questioning of residents after the exigency ended was objectively unreasonable. The court deemed the plaintiffs’ testimony on this point too conclusory to create a genuine dispute of material fact. For the December 2019 entries, the court affirmed summary judgment because the plaintiffs failed to establish that the specific officers (Detectives Bartolomei and Carpenter) were responsible for the alleged illegal searches or seizures; the record indicated these acts were performed by other unidentified officers or state troopers. Additionally, arguments regarding the reliability of a tip leading to a third entry were deemed waived for lack of developed legal argument, and seizure claims failed because the plaintiffs did not show that a reasonable person would have felt free to terminate the encounter during lawful inquiries. Regarding the January 2020 entries, the court affirmed the district court’s ruling that Detectives Carpenter and Martin were entitled to qualified immunity. The court determined it was objectively reasonable for officers to enter based on an ongoing emergency (an overdose victim still on-site) and to question residents about the incident. Furthermore, the plaintiffs failed to present evidence that Detective Carpenter conducted a separate search beyond what Officer Martin had already performed. Finally, the court affirmed the dismissal of Catanese’s state law civil conspiracy claim because he failed to identify any underlying tort; since all underlying claims against the officers were dismissed on summary judgment, no actionable conspiracy could exist. As a practical consequence, the plaintiffs’ lawsuit against the officers was terminated, and the officers remain immune from liability for their actions at Genesis House.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.

Court: United States Court of Appeals for the First Circuit

Filed: 2026-08-21

The First Circuit affirmed the district court’s grant of summary judgment to police officers in a civil rights action alleging Fourth Amendment violations and state law torts arising from three warrantless entries into a sober home between October 2019 and January 2020. The court concluded that the plaintiffs’ claims were either without merit, waived due to failure to develop arguments, or barred by qualified immunity. Regarding the October 2019 entry in response to an overdose, the court held that the plaintiffs failed to provide sufficient evidence to create a genuine dispute of material fact regarding any “continued” search or seizure after the emergency aid exception justified the initial entry. The testimony offered was deemed conclusory and lacked specific details on the scope or duration of the alleged post-emergency conduct. Furthermore, the questioning of residents about the house owner was found objectively reasonable under the totality of the circumstances to address the drug overdose at a facility dedicated to recovery. For the December 2019 entries, the court affirmed summary judgment because the plaintiffs failed to link specific officers to the alleged unconstitutional searches and seizures. The record did not establish that the named defendants were responsible for actions taken by other officers, such as a state trooper’s search or the arrest of a resident. Additionally, arguments challenging the reliability of a tip used to justify a third entry were deemed waived because they were raised in a footnote without developed legal argumentation. Concerning the January 2020 entry, the court upheld the district court’s ruling that the officers were entitled to qualified immunity. The record supported the finding that it was objectively reasonable for Detective Carpenter to enter and question residents under the emergency aid exception, as the overdose victim remained on-site when he arrived. The plaintiffs failed to develop arguments challenging this legal analysis or to provide evidence that a second search occurred. Finally, the court affirmed the dismissal of the state law conspiracy claim because the plaintiffs could not establish an underlying tort, which is a necessary element for civil conspiracy liability under Massachusetts law. As a result of this decision, the judgment in favor of the officers stands, and the plaintiffs’ claims for damages are dismissed without trial.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.

Court: United States Court of Appeals for the Tenth Circuit

Filed: 2026-08-21

Docket: 5:21-CV-00179-SLP)

The tenth-circuit affirmed the denial of Ronnie Fuston’s federal habeas corpus petition, rejecting his claims that his conviction and death sentence violated constitutional rights. The court held that the Oklahoma Court of Criminal Appeals did not unreasonably apply clearly established Supreme Court law under the Antiterrorism and Effective Death Penalty Act (AEDPA), 28 U.S.C. § 2254(d)(1). Regarding Fuston’s claim under *Beck v. Alabama*, 447 U.S. 625 (1980), which requires a lesser-included offense instruction in capital cases when the evidence supports it, the court found that the state court reasonably determined the evidence did not permit a rational juror to find Fuston guilty of second-degree murder while acquitting him of first-degree murder. The court noted that uncontroverted testimony indicated Fuston shot the victim four times after seeing the victim move, demonstrating an intent to kill rather than a depraved mind without premeditation. Consequently, the state court’s denial of the instruction was not an unreasonable application of *Beck*. Regarding Fuston’s claim under *Atkins v. Virginia*, 536 U.S. 304 (2002), which prohibits executing intellectually disabled defendants, the court addressed whether Fuston was entitled to an evidentiary hearing despite presenting multiple IQ scores, including one of 81. The court concluded that Supreme Court precedent in *Atkins*, *Hall v. Florida*, *Moore v. Texas*, and *Brumfield v. Cain* did not clearly establish that a defendant with at least one IQ score above the standard error of measurement (SEM) threshold must receive a hearing when other scores fall below it. Because the law was not clearly established, the state court’s reliance on Oklahoma law, which deems an IQ score of 76 or above conclusive evidence against intellectual disability, did not involve an unreasonable application of federal law. As a practical consequence, Fuston’s death sentence remains in effect, and the district court’s denial of his habeas petition stands. The appellate court granted a certificate of appealability on both issues but ultimately ruled against the petitioner on the merits of each claim.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.

Court: United States Court of Appeals for the First Circuit

Filed: 2026-08-21

The First Circuit affirmed the district court’s grant of summary judgment to law enforcement officers in a civil rights action alleging Fourth Amendment violations and state law torts arising from police entries into a “sober home” in Falmouth, Massachusetts. The court held that the plaintiffs failed to demonstrate genuine disputes of material fact regarding the reasonableness of the searches and seizures under the emergency aid exception to the warrant requirement, or that the officers’ conduct violated clearly established law sufficient to overcome qualified immunity. The court applied de novo review, viewing facts in the light most favorable to the plaintiffs, but found their claims insufficient for several reasons. First, regarding the October 2019 entry, the court ruled that the plaintiffs’ testimony was too conclusory to establish that Officer Curtis conducted a search beyond the scope of the emergency aid exception or that his brief questioning of residents following an overdose was objectively unreasonable. Second, concerning the December 2019 entries, the court found that the plaintiffs failed to provide evidence linking Detectives Bartolomei and Carpenter to specific alleged unlawful searches or seizures, as the record indicated other officers performed those actions or the plaintiffs’ testimony regarding the detectives’ involvement was inconsistent. The court also deemed arguments challenging the reliability of a witness’s tip waived due to lack of developed argumentation. Third, for the January 2020 entry, the court upheld the district court’s finding that Detective Carpenter’s entry and questioning were justified by the emergency aid exception because the overdose victim remained on-site when he arrived, and the plaintiffs failed to present evidence that a second search was conducted by him. Additionally, the court affirmed the dismissal of Catanese’s state law conspiracy claim because no underlying tort had been established against the officers. The plaintiffs’ failure to develop arguments for numerous other state law claims resulted in those claims being deemed waived. As a result of this decision, the judgment in favor of the defendants is final and binding; the civil lawsuit brought by the former residents and homeowner against the police officers is dismissed, and no damages or injunctive relief will be awarded to the plaintiffs.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.

Court: United States Court of Appeals for the Eleventh Circuit

Filed: 2026-08-21

Docket: 3:23-cr-00024-TES-CHW-1

The eleventh circuit vacated the defendant’s sentence and remanded the case for resentencing because the district court failed to make explicit factual findings necessary for meaningful appellate review. The court held that while it reviews guideline interpretation de novo and factual findings for clear error, a sentencing court must provide specific findings of fact when applying enhancements based on co-conspirator liability under U.S.S.G. § 1B1.3(a)(1)(B). The district court applied a two-level enhancement under U.S.S.G. § 2D1.1(b)(1) for firearm possession but provided only a conclusory statement that “if a co-conspirator possesses that then you can assess the firearm enhancement.” The appellate court found this record insufficient to determine whether the enhancement was based on the defendant’s own possession of the weapon or the possession of a co-conspirator. Because the district court did not make individualized findings regarding the scope of the criminal activity undertaken by the defendant, nor identify the specific co-conspirator or the foreseeability of the firearm’s presence, the appellate court could not assess whether the enhancement was legally warranted or if the defendant was eligible for a zero-point offender reduction under U.S.S.G. § 4C1.1. As a practical consequence, the case is sent back to the district court to make explicit factual findings clarifying the basis for the firearm enhancement and addressing the defendant’s eligibility for sentencing adjustments before a new sentence can be imposed.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.

Court: United States Court of Appeals for the Eleventh Circuit

Filed: 2026-08-21

The eleventh-circuit denied Rishi Ramdial’s petition for review of a Board of Immigration Appeals (BIA) decision, upholding the determination that his Florida conviction for robbery by sudden snatching constitutes an “aggravated felony” under the Immigration and Nationality Act (INA), thereby rendering him ineligible for cancellation of removal. The court applied the categorical approach to compare the elements of Florida Statute § 812.131(1) against the generic federal definition of a “theft offense” found in 8 U.S.C. § 1101(a)(43)(G). The court held that the statute is not divisible and that its least culpable conduct matches the generic definition of theft, which requires a taking of property without consent and with criminal intent to deprive the owner or a person with a superior possessory interest, even if the deprivation is temporary. Specifically, the court rejected Ramdial’s arguments that the Florida statute was overbroad because it allowed for the deprivation of non-owners, covered temporary takings, or lacked an express “without consent” element, concluding instead that Florida law and jury instructions inherently require a superior possessory interest in the victim and a nonconsensual taking. As a result, Ramdial’s petition is denied, and his removal order remains in effect.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.

Court: United States Court of Appeals for the Eleventh Circuit

Filed: 2026-08-21

Docket: 1:21-cv-00504-LSC

The Eleventh Circuit affirmed the district court’s denial of Wakilii Brown’s habeas corpus petition, holding that the admission of his ambiguous statement to his aunt did not violate his federal Due Process rights. The court applied the standard for fundamental fairness, determining that erroneously admitted evidence violates due process only if it is a “crucial, critical, and highly significant factor” in the conviction. The panel found Brown’s statement—which merely indicated he had “hurt them girls” rather than confessing to murder—was not crucial because it was used solely for impeachment purposes, occupied less than one percent of the trial record, was ambiguous enough to be interpreted as non-homicidal conduct, and was double hearsay. Furthermore, the court applied the highly deferential standard under the Antiterrorism and Effective Death Penalty Act (AEDPA), concluding that the Alabama state appellate court did not unreasonably apply the *Chapman* harmless-error standard when it determined any error was harmless beyond a reasonable doubt. The court also independently reviewed the claim under the *Brecht* standard, finding that the admission of the statement did not have a “substantial and injurious effect or influence” on the jury’s verdict given the overwhelming independent evidence of guilt, including eyewitness testimony from Brown’s daughter, fingerprint evidence linking him to the binding tape, his theft of checks and flight, and his prolonged standoff with police. Consequently, no relief was granted, and Brown’s death sentence remains in effect.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.

Court: United States Court of Appeals for the First Circuit

Filed: 2026-08-21

The First Circuit affirmed the district court’s grant of summary judgment to police officers in a civil rights action alleging Fourth Amendment violations and state law torts arising from three warrantless entries into a “sober home” in Falmouth, Massachusetts, between October 2019 and January 2020. The court held that the plaintiffs’ claims failed on the merits due to insufficient evidence, were waived for failure to develop arguments, or were barred by qualified immunity. Regarding the October 2019 entry, the court found the plaintiffs’ claims regarding a “continued” search and seizure of residents for questioning after an overdose exigency ended were conclusory and unsupported by specific facts in the record. The court applied the emergency aid exception standard, noting that even assuming a seizure occurred, the officers’ brief questioning about the house operator was objectively reasonable given the context of responding to a drug overdose at a sober home. For the December 2019 entries, the court ruled that plaintiffs failed to establish a genuine dispute of material fact linking specific defendants to alleged illegal searches or seizures, as evidence pointed to unidentified officers or state troopers rather than the named detectives. Additionally, arguments regarding the reliability of a witness’s tip for a third search were deemed waived due to lack of developed argumentation. Concerning the January 2020 entry, the court affirmed the district court’s conclusion that Detective Carpenter was entitled to qualified immunity. The court determined that it was objectively reasonable for officers to enter and question residents based on an ongoing emergency aid situation involving a resident who had overdosed and was still on-site when they arrived. The plaintiffs failed to provide evidence that a second search occurred or develop arguments challenging the reasonableness of the detention and questioning under the totality of circumstances. Finally, the court affirmed the dismissal of the state law civil conspiracy claim because the plaintiffs could not identify an underlying tort, as all substantive claims against the officers had already been dismissed. The practical consequence is that the judgment in favor of the defendants stands, the plaintiffs’ appeal is denied, and no damages or injunctive relief will be awarded to the former residents and homeowner.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.

Court: United States Court of Appeals for the Tenth Circuit

Filed: 2026-08-21

Docket: 1:23-CR-00230-NYW-1)

The Tenth Circuit affirmed the district court’s denial of the defendant’s motion for compassionate release. The appellate court held that because the district court provided two independent grounds for denying relief—finding neither “extraordinary and compelling reasons” under 18 U.S.C. § 3582(c)(1)(A) nor a favorable outcome based on statutory sentencing factors under 28 U.S.C. § 3553(a)—the defendant was required to challenge both conclusions to justify reversal. Since the defendant failed to contest the district court’s reliance on the statutory sentencing factors, which independently supported the denial, the ruling stands regardless of the merits of the medical care argument. Additionally, the court rejected the defendant’s due process claim regarding his inability to file a reply brief after missing the government’s response, concluding that any additional arguments he would have raised pertained only to the “extraordinary and compelling reasons” analysis and would not have affected the outcome based on the unchallenged statutory factors. Consequently, the sentence reduction motion remains denied, and the defendant must serve the original 70-month term.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.

Court: United States Court of Appeals for the Eleventh Circuit

Filed: 2026-08-21

Docket: 3:24-cv-00616-MW-HTC

The eleventh-circuit vacated the district court’s order dismissing a pro se prisoner’s civil rights complaint and remanded the case for further proceedings. The court held that the district judge abused their discretion by failing to treat the inmate’s objections to a magistrate’s report and recommendation as either an amendment to the complaint or a motion requesting leave to amend. The court applied the standard of review for abuse of discretion regarding the denial of a request to amend a complaint, noting that pro se filings must be liberally construed. The legal basis for the decision centered on Federal Rule of Civil Procedure 15(a)(1), which allows a party to amend a complaint once as a matter of course before a responsive pleading is served. Because the district court had not yet received a response from the defendants, the inmate retained the right to amend his complaint as a matter of course. The court found that the inmate’s objections contained specific factual allegations—namely, that an inmate who had previously assaulted him was wandering freely and making threats—that sufficiently alleged an imminent danger of serious physical injury under the Prison Litigation Reform Act (PLRA), 28 U.S.C. § 1915(g). By dismissing the complaint without considering these supplemental allegations or granting leave to amend, the district court failed to provide the inmate with the procedural avenues required by law. The practical consequence is that the dismissal order is set aside, and the case is sent back to the district court to reconsider the complaint in light of the new factual allegations regarding imminent danger, either by accepting them as an amendment or by ruling on a formal motion to amend.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.