Court: United States Court of Appeals for the Fourth Circuit

Filed: 2026-07-23

The Fourth Circuit granted the petition for review in part and remanded the case to the Benefits Review Board for further proceedings. The court held that while the Administrative Law Judge (ALJ) was permitted to discredit expert opinions inconsistent with the Department of Labor’s preamble regarding coal mine dust exposure, the ALJ erred by rejecting the experts’ opinions based on an improper application of that preamble. Specifically, the court found that although the experts correctly noted coal dust cannot cause asthma—a conclusion contrary to the preamble—the ALJ incorrectly extended this inconsistency to reject their broader reasoning that the miner’s condition was caused by non-coal-dust factors or that the disease was not pneumoconiosis given the lack of radiographical indicia and the end of exposure decades prior. The court applied the standard that an expert opinion is only inconsistent with the preamble if it directly contradicts the regulatory guidance, noting that concluding a miner’s disease was caused by something other than coal dust does not inherently conflict with the preamble’s recognition that coal dust can cause chronic obstructive pulmonary disease. Because the ALJ’s reliance on this improper reasoning prevented the court from determining whether awarding benefits was a foregone conclusion under the harmless error standard, the case was remanded for reconsideration of the expert testimony and the rebuttal burden under the Black Lung Benefits Act.

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 Sixth Circuit

Filed: 2026-07-23

The Sixth Circuit vacated the district court’s imposition of three special conditions of supervised release—requiring a sex offender assessment, periodic polygraph examinations, and sex offense-specific treatment—and remanded the case for resentencing. The court held that the district court abused its discretion by failing to explain on the record how these conditions were reasonably related to the purposes of sentencing or why they were not more restrictive than necessary. The court applied the standard of review for abuse of discretion, noting that while district courts have broad discretion to impose special conditions under 18 U.S.C. § 3583(d), they must satisfy three statutory inquiries: the conditions must be reasonably related to the factors in 18 U.S.C. § 3553(a), involve no greater deprivation of liberty than necessary, and be consistent with Sentencing Commission policy statements. Crucially, under *United States v. Childress* and 18 U.S.C. § 3553(c), a district court must state its rationale for special conditions in open court to allow for meaningful appellate review. The Sixth Circuit found the district court’s explanation insufficient because it relied on only a single, ambiguous reference to a thirteen-year-old sexual battery conviction and a general concern for protecting the defendant’s girlfriend, without explicitly linking those facts to the specific sex-offender conditions or addressing the defendant’s objection that the conditions were unrelated to his underlying felon-in-possession charge. The court rejected the government’s arguments regarding waiver and procedural bars, clarifying that Troutman was appealing the 2026 revocation sentence and its new imposition of conditions, not the original 2018 sentence. The practical consequence is that the challenged sex-offender conditions are removed from Troutman’s supervised release order. The case is remanded to the United States District Court for the Northern District of Ohio to resentence Troutman in a manner consistent with the opinion, requiring the district court to provide a sufficient on-the-record explanation if it chooses to reimpose similar special conditions.

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: 2026-07-23

Docket: 4:24-CR-00387-JDR-1)

The Tenth Circuit affirmed the defendant’s sentence of sixty months in prison and three years of supervised release for conspiracy to commit wire fraud. The court held that the district court did not commit significant procedural error by relying on stipulated loss amounts and victim counts to calculate the applicable Sentencing Guidelines range. The court applied the standard of review for sentencing appeals, examining legal conclusions de novo and factual findings for clear error. It ruled that the defendant’s plea agreement, change-of-plea petition, and statements during the Rule 11 colloquy bound him to the stipulated facts: a loss amount between $3.5 million and $9.5 million and approximately 2,800 victims. Citing the principle that stipulations bind the parties absent special circumstances, the court determined the defendant could not challenge these figures on appeal. Furthermore, the court found the district court’s factual findings were supported by a preponderance of the evidence, noting that the Guidelines require only a reasonable estimate of loss based on available information and that restitution claims for identified victims do not limit the total financial loss used for sentencing calculations. As a result of this decision, the defendant’s conviction and sentence remain in effect, and he must serve the sixty-month prison term followed by three years of supervised release as originally imposed by the district court.

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 Fifth Circuit

Filed: 2026-07-23

The Fifth Circuit reversed the district court’s order denying Katie Young’s motion to proceed in forma pauperis (IFP). The court held that a district court must determine IFP eligibility under 28 U.S.C. § 1915(a) based solely on economic criteria, specifically whether the plaintiff is indigent. The district court erred by denying the motion based on the frivolity of Young’s complaint and her failure to state a claim, which are grounds for dismissal under 28 U.S.C. § 1915(e)(2), not for denying IFP status. While the Fifth Circuit lacks jurisdiction at this stage to determine if the case should be dismissed as frivolous since no final judgment has been entered, it granted Young’s motion to proceed IFP on appeal and remanded with instructions that her motion in the district court should have been granted upon establishing financial eligibility.

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: 2026-07-23

Docket: 4:23-cv-00215-WMR

The Eleventh Circuit affirmed the district court’s grant of summary judgment in favor of Deputy Michael McMaster and Sheriff Gary Gulledge, dismissing Tyler Canaris’s claims for excessive force under the Fourth Amendment and state law torts. The court applied the qualified immunity standard, determining that Deputy McMaster’s actions were objectively reasonable under the circumstances outlined in *Graham v. Connor*. Specifically, the panel found it reasonable for the officer to believe Canaris might be reaching for a weapon given his resistance and sudden arm movements while being detained for suspected car break-ins, thereby justifying the use of force to restrain him. The court further held that Canaris failed to provide evidence of actual malice or intent to injure required to overcome Georgia’s official immunity doctrine for state law claims. Regarding Sheriff Gulledge, the court ruled that supervisory liability cannot be established under *respondeat superior* and requires a direct causal connection to an underlying constitutional violation; since no Fourth Amendment violation occurred, the claim against the Sheriff in his individual capacity was properly dismissed. The practical consequence is that the judgment for the defendants stands, and Canaris’s lawsuit is terminated without relief.

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 Ninth Circuit

Filed: 2026-07-23

Docket: 8:24-cv-00227-SVW

The ninth-circuit dismissed in part for lack of appellate jurisdiction and affirmed in part the district court’s judgment regarding appeals stemming from a bankruptcy case involving Park Diversified, L.P. The court held that it lacks jurisdiction to review the district court’s order remanding claims against certain defendants to state court, applying 28 U.S.C. § 1447(d), which prohibits appellate review of remand orders based on defects in removal procedure or lack of subject-matter jurisdiction, as established in *Things Remembered, Inc. v. Petrarca*. The court further affirmed the district court’s finding that the bankruptcy court possessed subject-matter jurisdiction over “core” bankruptcy claims and validly exercised ancillary jurisdiction to resolve non-core claims based on a stipulation retaining jurisdiction, citing *In re Gruntz* and *In re Valdez Fisheries Dev. Ass’n*. Additionally, the court affirmed the imposition of sanctions under Federal Rule of Civil Procedure 11, concluding that the district court did not abuse its discretion in deeming the appellants’ motion for rehearing frivolous given the clarity of the remand order. The practical consequence is that the case is remanded to the district court with instructions to carry out the order remanding the specified claims to state court, while the sanctions and findings regarding bankruptcy jurisdiction remain 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 Eighth Circuit

Filed: 2026-07-23

The eighth-circuit affirmed the district court’s order granting a preliminary injunction enjoining Sharpe Holdings, Inc. from evicting La Belle Dairy or interfering with its possession of leased forage land. The court first established appellate jurisdiction over the order, ruling that despite being labeled a “temporary restraining order,” it functioned as an appealable preliminary injunction because it remained in effect for more than 28 days and lacked a specific expiration date, thereby having the practical effect of an injunction under Federal Rule of Civil Procedure 65. The court further held that Sharpe waived or forfeited its due process argument regarding inadequate notice and opportunity to be heard by failing to raise these objections in the district court and proceeding as if a preliminary injunction were under consideration. On the merits, the court applied the standard for granting a preliminary injunction, which requires a showing of a probability of success on the merits, a threat of irreparable harm, that the balance of equities favors the movant, and that the injunction serves the public interest. The court found La Belle Dairy had a “fair chance of prevailing” on its breach of contract claims regarding the lease’s land-sale provision. Applying Missouri law, the court rejected Sharpe’s argument that the agreement was an unenforceable “agreement to agree,” concluding that the provision specifying fair market value determined by a third-party appraiser provided a sufficient method for price determination and that the land description was adequate given the parties’ history and attached maps. Additionally, the court found La Belle Dairy likely succeeded on its claim that it had not breached the lease by failing to sign a new addendum, as its communications did not constitute unequivocal acceptance of Sharpe’s proposed terms. The court also determined that irreparable harm existed because damages are inadequate for disputes involving interests in real property and eviction was imminent based on Sharpe’s threats, while the balance of equities favored La Belle Dairy given Sharpe’s minimal harm from maintaining the status quo.

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Court: United States Court of Appeals for the Federal Circuit

Filed: 2026-07-23

The federal-circuit court dismissed the appeal for failure to prosecute in accordance with the court’s rules. The dismissal was based on the appellant’s failure to file several required documents and payments, including the Entry of Appearance form for an attorney admitted to the bar, the Certificate of Interest, the Docketing Statement required by the Appellate Mediation Guidelines, the docketing fee mandated by Federal Circuit Rule 52(d), and the brief required by Federal Circuit Rule 31(d) within the permitted timeframes. As a result of this dismissal, the appeal is terminated without review on the merits.

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 Federal Circuit

Filed: 2026-07-23

The federal-circuit dismissed the appeal for failure to prosecute in accordance with the rules. The court’s decision was based on the appellant’s failure to file the required Notice of Unrepresented Person Appearance form and failure to pay the docketing fee mandated by Federal Circuit Rule 52(d) within the permitted time frame. As a result of this dismissal, the appeal is terminated without consideration of the underlying merits of the case.

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 Eighth Circuit

Filed: 2026-07-23

The Eighth Circuit affirmed Ladonna Henderson’s 37-month prison sentence for multiple firearm-related offenses, rejecting her claim that the sentence was substantively unreasonable. The court applied an abuse of discretion standard of review, examining whether the district court failed to consider relevant factors, gave significant weight to improper factors, or committed a clear error of judgment in weighing appropriate factors. Henderson argued the district court improperly relied on the unsupported fact that she fled prosecution by leaving her home in Waterloo for Illinois. The appellate court found no clear error in the district court’s factual findings, noting that the record contained evidence supporting the conclusion that Henderson left the jurisdiction to evade responsibility for her charges, even though the court also acknowledged her safety concerns regarding a former partner as a partial motivation. Because the district court’s weighing of these competing factors was supported by the record and within its broad discretion, the sentence was upheld. The judgment of the district court remains in effect, and Henderson must serve the imposed term of imprisonment and 3-year supervised release.

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