Court: United States Court of Appeals for the Ninth Circuit

Filed: 2026-07-20

The Ninth Circuit denied Zaji O. Zajradhara’s petition for review of the Office of the Chief Administrative Hearing Officer’s (OCAHO) Final Decision and Order dismissing his complaint alleging violations of the Immigration Reform and Control Act, 8 U.S.C. § 1324b. The court applied a de novo standard of review to the Administrative Law Judge’s (ALJ) conclusions of law and a substantial evidence standard for findings of fact. The court upheld the dismissal of Zajradhara’s national origin discrimination claim because it was based on the same set of facts as a charge filed with the Equal Employment Opportunity Commission under Title VII, which had not been dismissed as outside the scope of Title VII, thereby triggering the statutory prohibition against overlapping charges under 8 U.S.C. § 1324b(b)(2). Regarding the citizenship discrimination claim, the court found substantial evidence supported the ALJ’s determination that Zajradhara failed to establish a prima facie case because the individual selected for the position possessed superior qualifications and no other facts allowed for an inference of discrimination under the *McDonnell Douglas* burden-shifting framework. Finally, the court affirmed the dismissal of the retaliation claim because substantial evidence supported the finding that Zajradhara did not suffer an adverse employment action; specifically, he failed to show he applied for a janitorial services position he claimed was denied due to his protected activity. As a result of this decision, the OCAHO’s order dismissing the complaint remains in effect, and the petition for review is denied without oral argument.

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: 2026-07-20

Docket: 2:22-cv-01664-MTL

The Ninth Circuit affirmed the district court’s grant of summary judgment in favor of the defendants in a § 1983 action brought by an inmate alleging due process violations arising from disciplinary proceedings concerning an MP3 player containing images of child pornography. The court held that Eiland failed to establish the deprivation of a protected liberty interest because his sanction—placement in administrative segregation for 15 days—did not impose an “atypical and significant hardship” relative to the ordinary incidents of prison life under *Sandin v. Conner*. Applying the standard from *Ramirez v. Galaza*, the court found that the sanction mirrored conditions of administrative segregation, did not affect the length of Eiland’s sentence or result in the loss of good-time credits, and was not based on a complete lack of evidence. Consequently, no constitutional violation occurred, and the judgment for the defendants stands.

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: 2026-07-20

The ninth-circuit denied Alicia Reyes Chavez’s petition for review of the Board of Immigration Appeals’ decision denying her claims for asylum, withholding of removal, and protection under the Convention Against Torture. The court applied the substantial evidence standard, upholding the agency’s determination unless the evidence compelled a contrary conclusion. Regarding asylum, the court held that the BIA reasonably found Chavez failed to establish the required nexus between her feared harm and a protected ground; specifically, the record supported the finding that she was targeted by criminals motivated by theft and indiscriminate violence rather than her membership in the proposed particular social group of “Honduran female minor children abandoned by family.” Because there was no nexus at all, the court also upheld the denial of withholding of removal, noting that while its nexus standard is less demanding than asylum’s, a complete lack of nexus precludes relief. The court further dismissed Chavez’s Convention Against Torture claim because she waived any challenge to it by failing to raise it in her opening brief. Consequently, the petition for review is denied and the BIA’s 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 Seventh Circuit

Filed: 2026-07-20

The seventh-circuit affirmed the district court’s grant of summary judgment in favor of the University of Wisconsin System, holding that the University did not act with deliberate indifference to known acts of student-on-student sexual harassment in violation of Title IX of the Education Amendments of 1972. The court applied the standard established in *Davis v. Monroe County Board of Education*, which requires a plaintiff to prove that a school’s response to known harassment was “clearly unreasonable in light of the known circumstances.” The court determined that the University’s overall response—including issuing a no-contact order, providing academic accommodations, conducting a thorough investigation, expelling the alleged harasser, and maintaining the no-contact order after readmitting him based on new evidence—was not clearly unreasonable. The court rejected the plaintiff’s arguments that the University’s decision-making process was flawed or motivated by external pressure, noting that even if the University prioritized institutional interests or lied about its reasons, these factors did not render the response legally indefensible under the high bar of deliberate indifference. Additionally, the court found no evidence that the University failed to enforce the no-contact order or that a single violation by the harasser necessitated additional safety measures absent specific threats. The practical consequence is that the plaintiff’s Title IX claim is dismissed as a matter of law, and the case will not proceed to trial; however, the court explicitly declined to resolve broader circuit splits regarding whether Title IX liability extends to off-campus conduct, single instances of harassment, or situations where no further harassment occurs after a school’s response.

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 Fourth Circuit

Filed: 2026-07-20

The Fourth Circuit affirmed the district court’s order dismissing Rickel Marquavius Daniel Jeffries’s civil rights complaint brought under 42 U.S.C. § 1983. The court reviewed the record and found no reversible error in the district court’s decision to adopt the magistrate judge’s recommendation for dismissal. Consequently, the judgment of the lower court stands without further proceedings or oral argument.

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 Seventh Circuit

Filed: 2026-07-20

The Seventh Circuit reversed the district court’s grant of habeas relief to Jeffrey Hineman, denying his petition for a writ of habeas corpus under 28 U.S.C. § 2254. The court held that the Wisconsin Supreme Court’s denial of Hineman’s claims did not involve an unreasonable application of clearly established federal law as required by the Antiterrorism and Effective Death Penalty Act (AEDPA). Regarding Hineman’s *Brady* claim, the court applied the standard for materiality established in *United States v. Bagley*, which requires a “reasonable probability” that the outcome would have been different had the evidence been disclosed. The Seventh Circuit agreed with the state court that the suppressed March Child Protective Services (CPS) report was merely cumulative impeachment evidence because it contained language nearly identical to the police report already in Hineman’s possession at trial. The court reasoned that the failure of the prosecution to disclose the CPS report did not deprive Hineman of a fair trial, as the defense possessed equivalent information and could have used it for the same purpose. Furthermore, the court noted that AEDPA does not require state courts to explicitly analyze every piece of evidence in their opinions or follow specific opinion-writing standards set by lower federal courts. Regarding the ineffective assistance of counsel claim under *Strickland v. Washington*, the court applied the identical “prejudice” standard used for *Brady* materiality. The court found that Hineman failed to demonstrate prejudice because his trial counsel’s failure to obtain the CPS report did not create a reasonable probability of a different result, given that the defense already held a police report with the same content. The court also rejected the argument that counsel was ineffective for failing to obtain later CPS reports, finding no clear error in the state court’s determination that those additional reports would not have altered the trial’s outcome. The practical consequence of this decision is that Hineman’s conviction and twenty-five-year sentence stand, and his federal habeas petition is denied. The case is remanded with instructions to dismiss the petition.

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: 2026-07-20

The Sixth Circuit affirmed the district court’s grant of summary judgment in favor of Trinity Health Grand Rapids, rejecting the plaintiff-appellant physician’s claims under the Americans with Disabilities Act (ADA) and declining to exercise supplemental jurisdiction over his state-law wrongful discharge claim. The court held that the hospital’s requirement that the physician undergo a fitness-for-duty examination, including a psychiatric evaluation, was “job-related and consistent with business necessity” under 42 U.S.C. § 12112(d)(4)(A). Applying the standard from *Kroll v. White Lake Ambulance Auth.*, the court found the hospital had a reasonable belief based on objective evidence that the physician’s behavior threatened a vital function of the business, specifically patient safety in a high-stakes anesthesiology environment. This reasonable belief was grounded in documented performance shortfalls, such as hesitation to treat patients and refusal to handle complex cases, as well as aberrant behavioral issues including paranoid ideation and disruptive conduct that impaired hospital operations. The court further ruled that the ADA does not require a single decision-maker for ordering such examinations, allowing collective bodies like the Medical Executive Committee to make the determination, and rejected the physician’s pretext arguments due to a lack of record support and the forfeiture of arguments raised for the first time on appeal. Additionally, the court affirmed the dismissal of the retaliation claim because the physician failed to establish that he engaged in protected activity, as his refusal to submit to the examination was not opposition to an unlawful act given the lawfulness of the hospital’s request. Consequently, the judgment remains with Trinity Health Grand Rapids, and the physician’s state-law claims are dismissed without prejudice to federal adjudication.

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Court: United States Court of Appeals for the Fifth Circuit

Filed: 2026-07-20

The fifth-circuit granted the Federal Public Defender’s motion to withdraw and dismissed the appeal after reviewing the Anders brief and the record. The court concurred with counsel’s assessment that the appeal presented no nonfrivolous issues for appellate review, applying the standard established in *Anders v. California* and *United States v. Flores*. As a result, the appointed counsel was excused from further responsibilities, and the criminal appeal was terminated without reaching the 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 Ninth Circuit

Filed: 2026-07-20

Docket: 3:24-cv-00901-AN

The Ninth Circuit affirmed the district court’s grant of summary judgment in favor of the City of Hood River, holding that the city’s short-term rental ordinances do not violate the dormant Commerce Clause. The court applied de novo review and determined that the ordinances do not discriminate against out-of-state interests because they apply equally to resident and non-resident property owners; while non-residents cannot personally serve as the primary residents required by the rules, this is because they are not similarly situated to local residents who can. Furthermore, the court found that the ordinances do not prevent out-of-state homeowners from extracting economic value from their properties, as they may still satisfy the requirements by leasing to long-term tenants or offering non-transient rentals. Under the *Pike v. Bruce Church, Inc.* balancing test, the court ruled that Plaintiffs failed to introduce evidence demonstrating that the ordinances impose a substantial or significant burden on interstate commerce, noting that the loss of a more profitable rental method does not constitute such a burden. Regarding procedural issues, the court found any potential error in accepting a late-filed declaration harmless and confirmed that the district court did not fail to address Plaintiffs’ arguments regarding existing lawful uses of property. Consequently, the judgment for the City stands, and the case is closed with no remand or further relief granted to the appellants.

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 Fourth Circuit

Filed: 2026-07-20

The Fourth Circuit affirmed Tamarcus Ellis’s conviction for drug trafficking, holding that the district court’s partial closure of the courtroom during one witness’s testimony did not violate the Sixth Amendment’s Public Trial Clause. While the court acknowledged that a violation of this right constitutes structural error requiring a new trial, it applied a modified version of the *Waller* test tailored to partial closures—where the exclusion is limited in scope or duration rather than total. Under this relaxed standard, the court required only a “substantial reason” for the closure, rather than an “overriding interest,” while still mandating that the closure be no broader than necessary, that reasonable alternatives be considered, and that adequate findings be made. The court found that the district court satisfied these requirements based on specific evidence of potential witness intimidation. The record showed that a U.S. Marshal reported spectators clicking their teeth and rocking in the gallery during a cooperating witness’s prior testimony, conduct perceived as signaling disagreement. The district court acted to protect the witness from this intimidation and maintain order, limiting the closure to approximately one hour for the remainder of the witness’s direct examination and cross-examination. The court further found the closure was narrowly tailored because it excluded only unidentified members of the public while allowing the defendant’s family and defense counsel’s parents to remain, and that the court considered alternatives by initially contemplating a total closure before adopting this more limited approach. Additionally, the district court made sufficient findings on the record through its inquiries with the Marshal, government counsel, and defense counsel regarding the witness’s demeanor and the alleged conduct. The practical consequence of this decision is that Ellis’s conviction and 480-month sentence stand, and no new trial is ordered. The appellate court rejected Ellis’s argument that the closure was trivial or that it automatically mandated reversal, concluding instead that the district court’s actions were a justified response to a substantial reason for protecting the integrity of the trial process.

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