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.

Court: United States Court of Appeals for the Fourth Circuit

Filed: 2026-07-20

The Fourth Circuit affirmed the judgment of the United States District Court for the District of Maryland, upholding Donald Patrick Hildebrandt’s conviction for production of child sexual abuse material in violation of 18 U.S.C. § 2251(a) and his 300-month sentence. The court reviewed the appeal under *Anders v. California*, noting that appointed counsel filed a brief stating there were no meritorious grounds for appeal, while Hildebrandt failed to file a pro se supplemental brief despite an extension of time. Regarding the validity of the guilty plea, the court applied the plain error standard because Hildebrandt did not challenge the plea in the district court. The court found no plain error, concluding that the district court conducted a thorough Federal Rule of Criminal Procedure 11 colloquy and that the plea was knowing, voluntary, and supported by an independent factual basis. Regarding the sentence, the court applied an abuse-of-discretion standard to review both procedural and substantive reasonableness under 18 U.S.C. § 3553(a). The court found the sentence procedurally reasonable because the district court correctly calculated the Guidelines range, considered all relevant factors, provided a meaningful explanation for the sentence, and did not rely on clearly erroneous factual findings. Substantively, the court held that the 300-month sentence was presumptively reasonable as it fell below the advisory Guidelines range of 360 months. The court found no evidence rebutting this presumption, noting the district court appropriately weighed aggravating factors—such as the surreptitious recording of children’s genitalia and the destruction of evidence—against mitigating factors like Hildebrandt’s military service and mental health. As a practical consequence, the judgment is affirmed, and the case is remanded for no further action regarding the conviction or sentence. The court also ordered appointed counsel to inform Hildebrandt in writing of his right to petition the Supreme Court for certiorari and established the procedure for counsel to move for leave to withdraw if a petition is requested but deemed frivolous.

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: 2026-07-20

Docket: 2:22-CR-00210-TC-1)

The Tenth Circuit affirmed Daniel David Egli’s conviction and sentence for possessing child pornography in violation of 18 U.S.C. § 2252A(a)(5)(B). The court rejected Egli’s pro se arguments regarding his competence to waive counsel, denial of access to courts, sufficiency of the indictment and evidence, and ineffective assistance of standby counsel. Regarding the waiver of counsel, the court applied the standard that a defendant must be competent to stand trial to validly waive their right to counsel under *Godinez v. Moran*, rather than possessing the higher competence required to represent oneself. The court found no plain error in the district court’s failure to order a sua sponte competency evaluation because Egli demonstrated understanding of the charges, penalties, and risks during the colloquy, and there was no objective basis at the time to doubt his competence. On the issue of access to courts, the court applied a de novo standard of review and found that the district court did not violate Egli’s due process rights or right of access. The record showed the court ensured Egli had legal materials and granted multiple continuances totaling over three years before trial, despite Egli’s repeated requests for additional delays. Concerning the sufficiency of the indictment and evidence, the court applied a de novo standard to review whether the indictment tracked statutory language and whether a rational trier of fact could find guilt beyond a reasonable doubt. The court held the indictment was sufficient as it tracked 18 U.S.C. § 2252A(a)(5)(B) and that the evidence, including the possession of 496 files, Egli’s admissions regarding his actions, and evidence of his solicitation of child sexual images and administration of pedophile websites, was sufficient to support a finding of knowing possession. Finally, regarding standby counsel, the court applied the principle that a pro se defendant who maintains control over their defense cannot claim ineffective assistance against standby counsel under *McKaskle v. Wiggins*. The court noted Egli maintained control throughout the trial and that any claims regarding ineffective assistance at sentencing must be raised in collateral proceedings rather than on direct appeal. As a result of this affirmation, Egli’s conviction for possessing child pornography stands, and his sentence of 210 months in prison followed by a 24-month term for supervised release violations 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 Fourth Circuit

Filed: 2026-07-20

The Fourth Circuit affirmed the conviction of Brandon Stephon Brown for possession of a firearm and ammunition by a convicted felon in violation of 18 U.S.C. § 922(g)(1). The court rejected Brown’s arguments that the district court erred in denying his pretrial motions to dismiss the indictment under the Speedy Trial Act and to suppress physical evidence. Regarding the Speedy Trial Act claim, the court applied a de novo standard of review for legal interpretations and clear error review for factual findings. The court held that the 30-day filing period under 18 U.S.C. § 3161(b) was not triggered by Brown’s time in state custody because he was arrested on a state charge and prosecuted in state court, rather than being held solely to answer federal charges. The court found no clear error in the district court’s determination that the arrest was not federal and that the state charge was not merely a placeholder for the federal prosecution. Regarding the motion to suppress, the court applied de novo review for legal conclusions and clear error review for factual findings, viewing the evidence in the light most favorable to the government. The court determined that the officers had reasonable suspicion to conduct a *Terry* stop based on the totality of the circumstances. Specifically, the court found that Brown was seized only after he made a sudden movement away from officers and dropped a firearm, as he was unaware of an officer’s brief weapon draw prior to that moment. The court concluded that the combination of evasive conduct, the dropping of the gun immediately following that movement, and the location in a high-crime area provided a particularized, objective basis for reasonable suspicion that Brown was involved in criminal activity. Additionally, the court noted that Brown’s Second Amendment challenges under *New York State Rifle & Pistol Ass’n v. Bruen* were foreclosed by Fourth Circuit precedent in *United States v. Canada* and *United States v. Hunt*, which hold that 18 U.S.C. § 922(g)(1) is facially constitutional and precludes as-applied challenges. As a practical consequence, the judgment of the district court is affirmed, and Brown’s conviction stands. The court dispensed with oral argument due to the adequacy of the written materials.

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 grant of summary judgment dismissing Jermaine Staggers’ retaliation claim against the Department of Health and Human Services under Title VII of the Civil Rights Act of 1964. The court reviewed the record to determine whether material disputes of fact existed that would preclude summary judgment, applying the standard that an appellate court may affirm a lower court’s judgment for any ground apparent from the record. Finding no reversible error in the district court’s conclusion that Staggers failed to establish a genuine issue of material fact regarding his retaliation claim, the court upheld the dismissal 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 Eighth Circuit

Filed: 2026-07-20

The eighth-circuit affirmed the district court’s denial of Fernando Valenzuela’s motion for a sentence reduction under 18 U.S.C. § 3582(c)(2). The court applied an abuse-of-discretion standard, concluding that while Valenzuela was eligible for a reduction, none was warranted because the district court properly reviewed the factors set forth in 18 U.S.C. § 3553(a) and determined that the initial 135-month prison term remained appropriate punishment. Relying on *Chavez-Meza v. United States*, the court held that the district court’s certification of its consideration of these factors provided a reasoned basis for its decision. Consequently, the court granted Valenzuela’s counsel’s motion to withdraw and upheld the denial of relief without further modification.

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 grant of summary judgment in favor of the defendants, dismissing the plaintiff’s claims for disability discrimination under the Americans with Disabilities Act (ADA) and retaliation under the False Claims Act (FCA) and Maryland False Health Claims Act (MFHCA). The court applied de novo review to the summary judgment ruling, assessing whether there was a genuine dispute of material fact. Regarding the ADA claim, the court applied the *McDonnell Douglas* burden-shifting framework. While assuming without deciding that the plaintiff established a prima facie case, the court held that she failed to prove pretext at the third step. The employer proffered a legitimate, non-discriminatory reason for termination: the plaintiff’s rude, disrespectful, and insubordinate behavior which disrupted team collaboration. The court rejected the plaintiff’s arguments that this reason was false or pretextual based on several factors: her positive annual review did not negate the documented history of problematic conduct; the employer’s progressive disciplinary policy was permissive and allowed for immediate termination for serious misconduct; the employer’s reasons were consistent rather than shifting; contemporaneous documentation existed for the alleged misconduct; supervisor comments regarding the plaintiff’s facial appearance were made without knowledge of her disability; and comparator evidence did not show similarly situated employees with similar misconduct were treated more favorably. Regarding the FCA and MFHCA retaliation claims, the court applied the standard requiring a plaintiff to prove they engaged in protected activity based on an objectively reasonable belief that the employer was violating the statute. The court found the plaintiff failed to establish this element because her belief that the employer would commit fraud by combining infection data from Post-Anesthesia Care Unit (PACU) and Intensive Care Unit (ICU) beds was not objectively reasonable, as the necessary data had not yet been collected to determine if reporting was required. Furthermore, the court found the plaintiff did not engage in protected activity because refusing to collect data that was not illegal, asking a compliance question without alerting authorities of false reporting, and forwarding information to coworkers rather than supervisors did not constitute efforts to stop potential violations. As a practical consequence, the judgment of the United States District Court for the District of Maryland is affirmed, resulting in final dismissal of the plaintiff’s employment discrimination and retaliation claims with no further proceedings on these issues.

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 Karen Williams’s civil action without prejudice for lack of subject matter jurisdiction. The court held that Williams forfeited her right to appellate review of the magistrate judge’s recommendation because she failed to file timely and specific objections after receiving proper notice of the consequences of noncompliance. Applying the standard established in *Thomas v. Arn* and Fourth Circuit precedent, the court determined that when parties are warned that failure to object waives review, the failure to do so precludes appellate consideration of the recommendation’s substance. Consequently, the judgment of the district court stands, and no further proceedings on the merits will occur in this circuit.

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