Court: United States Court of Appeals for the Sixth Circuit

Filed: 2026-07-14

The Sixth Circuit denied Gabriel Mejia Perez’s petition for review of the Board of Immigration Appeals’ decision affirming the denial of his application for cancellation of removal under 8 U.S.C. § 1229b(b)(1). The court applied the substantial evidence standard to review the agency’s conclusion that Perez failed to demonstrate that his removal would result in “exceptional and extremely unusual hardship” to his three United States citizen children, a statutory requirement where the hardship must be significantly different from or greater than what is normally expected. The court found that no reasonable adjudicator would be compelled to conclude otherwise, noting that the Immigration Judge and BIA properly considered all factors in the aggregate—including the children’s continued residence with their mother, their good health, access to government insurance, and Perez’s ability to maintain financial support and contact from Mexico—and determined that while removal would cause hardship, it did not meet the high statutory threshold. Consequently, the petition is denied, leaving the BIA’s order affirming the denial of relief 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: 2026-07-14

The Seventh Circuit affirmed the district court’s grant of summary judgment in favor of the Small Business Administration (SBA), rejecting challenges to the agency’s “Corporate Group Rule” under the Paycheck Protection Program (PPP). The court held that the SBA acted within its statutory authority by defining a “business concern” for loan limit purposes to include affiliated entities under common control, thereby imposing a $20 million aggregate cap on loans to such groups rather than per individual limited liability company. The court applied the arbitrary and capricious standard of review under the Administrative Procedure Act, finding that the SBA’s interpretation was consistent with the CARES Act and 15 U.S.C. § 7(a) of the Small Business Act. The opinion reasoned that while the statute does not explicitly authorize aggregate limits, it also does not forbid them; Congress granted the SBA emergency rulemaking authority to manage limited funds, and the agency’s decision to treat affiliated nursing homes as a single corporate group was a reasonable exercise of administrative discretion to ensure resources were distributed to the largest possible number of borrowers. The court further rejected arguments regarding retroactivity, noting that loan forgiveness is a future benefit subject to current regulations at the time of disbursement, and affirmed the administrative judge’s finding that the nursing homes were controlled by a single partnership entity. As a result, the SBA’s limitation of loan forgiveness to $20 million for the group of 203 affiliated nursing homes stands, leaving the plaintiffs liable for repayment of the excess amounts guaranteed by the government. The judgment is final and no further appellate review is available on these grounds.

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: 2026-07-14

The Seventh Circuit affirmed the district court’s grant of summary judgment in favor of the Small Business Administration (SBA), upholding the validity of the SBA’s “Corporate Group Rule” which limits Paycheck Protection Program (PPP) loans to $20 million for all businesses under common control. The court held that the rule is a permissible exercise of the SBA’s administrative discretion under Section 7(a) of the Small Business Act (15 U.S.C. § 636(a)) and emergency rulemaking authority granted by the CARES Act. The court rejected the appellants’ argument that each limited liability company within a corporate group must be treated as an independent “business concern” entitled to separate loan limits. The opinion reasoned that neither the statute nor the regulations define “business concern” exclusively by state law incorporation status; rather, federal agencies are permitted to treat affiliated businesses as a single entity for regulatory purposes to ensure the equitable distribution of limited funds. The court found the SBA’s rationale—that the rule promotes the availability of loans to the largest possible number of borrowers—was cogent and not arbitrary or capricious. Additionally, the court dismissed arguments regarding retroactivity, noting that the rule applied prospectively to the forgiveness phase of the loan and that applicants could have withdrawn funds once the rule was published. The court also determined that a partnership acting as a common parent with majority ownership and voting control over multiple nursing homes properly qualifies as a single corporate group under the regulation. The practical consequence is that the SBA’s limitation on aggregate loan guarantees for affiliated businesses remains in effect, and the appellants are not entitled to additional loan forgiveness or relief beyond the $20 million cap applied to their corporate group.

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: 2026-07-14

The fifth-circuit affirmed the district court’s judgment denying defendant Marvin Antonio Reyes’s postjudgment motion to withdraw his guilty plea. The court held that Reyes failed to demonstrate error in the denial of his motion or meet the stringent standard required for plea withdrawal under Federal Rule of Criminal Procedure 11(e) after sentencing. While the court acknowledged Reyes’s claim of ineffective assistance of counsel, it declined to address the merits on this record because the existing record was insufficient to evaluate the allegations, noting that such claims are better suited for collateral review. Additionally, the court refused to consider Reyes’s challenge to the forfeiture order because the argument was raised for the first time in his reply brief. The judgment stands as affirmed.

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: 2026-07-14

The Fifth Circuit reversed the district court’s denial of summary judgment and rendered judgment in favor of Defendant-Appellant Matthew Valdez on his claim of qualified immunity. The court held that Deputy Valdez was entitled to qualified immunity because he possessed at least arguable probable cause for both the initial on-scene seizure and the subsequent arrest warrant affidavit, thereby negating any false arrest liability under 42 U.S.C. § 1983. Regarding the on-scene arrest, the court applied the standard that an officer is entitled to qualified immunity if they reasonably but mistakenly conclude probable cause exists. The court found that the totality of circumstances known to Valdez at the time of the arrest—including that Parsons was the only witness to the shield’s disappearance, was agitated, remained near the missing item for 30 minutes, and could not account for its location—provided an objectively reasonable basis to believe Parsons committed theft under Texas law. The court rejected the argument that the lack of direct observation or the later discovery of the shield negated probable cause, noting that probable cause deals with probabilities rather than certainty. Regarding the arrest warrant affidavit, the court applied the *Franks v. Delaware* standard, which requires a showing that an affiant made material omissions knowingly, intentionally, or with reckless disregard for the truth. The court determined that Valdez did not omit any material facts necessary to vitiate probable cause. While Parsons alleged five omissions, the court found three were already indicated in the affidavit and two others (a threat by a different deputy and reports of neighbors) would not have destroyed probable cause given Parsons’s specific knowledge of the shield’s location at the time of arrest. The practical consequence is that Valdez is granted judgment as a matter of law on the false arrest claims, effectively dismissing the lawsuit against him. The case is remanded with instructions to enter judgment in favor of Valdez.

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: 2026-07-14

The Fifth Circuit denied the petition for review of a final order by the Occupational Safety and Health Review Commission (OSHRC) that found Precision Refractory Services, L.L.C. liable for a serious violation of 29 C.F.R. § 1926.451(h)(2)(i)–(v). The court affirmed the Commission’s finding that the employer failed to prevent objects from falling off scaffolding and striking employees, specifically rejecting the argument that liability was barred because the scaffolding exceeded ten meters in height and required toeboards. The court held that the regulation provides five “alternative means” of compliance and that an employer is liable for failing to implement any one of them, regardless of whether specific methods like toeboards were technically feasible or required by other standards. Regarding the element of knowledge, the court applied the standard requiring the Secretary of Labor to prove by a preponderance of the evidence that the employer knew, or with reasonable diligence could have known, of the violative condition. The court found substantial evidence in the record supporting the imputation of knowledge from supervisory personnel to the employer, noting testimony that tools and materials were present on upper scaffold levels and being thrown downward. Additionally, the court affirmed the finding that the violation was “serious” based on the presence of a danger of falling objects. As a practical consequence, the OSHRC’s order imposing a $7,000 fine on Precision Refractory Services remains in full force and effect, and the employer is not relieved of liability for the safety violation.

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 District of Columbia Circuit

Filed: 2026-07-14

The D.C. Circuit vacated the district court’s grant of summary judgment in favor of the States and remanded the case with instructions to dismiss the plaintiffs’ claim that the Postal Service violated 39 U.S.C. § 3661(b) by failing to seek an advisory opinion from the Postal Regulatory Commission before implementing 2020 operational changes. The court held that the district court lacked subject matter jurisdiction over this claim because Congress established a comprehensive statutory review scheme in the Postal Accountability and Enhancement Act (39 U.S.C. §§ 3661–63) that implicitly precludes initial district court review. Applying the two-step framework from *Thunder Basin Coal Co. v. Reich*, the court found that: (1) Congress’s intent to channel such complaints to the Commission is fairly discernible in the detailed statutory structure, which mandates initial administrative review followed by exclusive appellate review in the D.C. Circuit; and (2) the claim falls squarely within the scope of that scheme because it is not collateral to the statute, does not foreclose meaningful judicial review (as parties may petition this court after Commission action), and involves questions well within the Commission’s specialized expertise regarding postal policy changes. The court rejected the States’ argument that the urgency of the 2020 election or the lack of immediate injunctive relief from the Commission justified bypassing the administrative process, noting that Congress’s channeling decision imposes specific timing constraints that parties must adhere to.

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: 2026-07-14

The Fifth Circuit affirmed the district court’s grant of final judgment in favor of the defendants and dismissal of the plaintiff’s claims with prejudice. The court held that the Louisiana judges sued could not be liable under 42 U.S.C. § 1983 in their official capacities because neither a State nor its officials acting in an official capacity constitute “persons” subject to suit under the statute. Regarding the individual-capacity claims, the court ruled that the defendants were protected by absolute judicial immunity, which shields judges from lawsuits arising from judicial actions performed within the bounds of their jurisdiction. The court found that the plaintiff’s allegations regarding the management of court filings and courtroom proceedings constituted judicial acts rather than nonjudicial actions or acts taken in the complete absence of jurisdiction. Consequently, the plaintiff’s claims failed to state a plausible claim for relief under the standard set forth in *Ashcroft v. Iqbal*, and the judgment was affirmed without reversal.

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: 2026-07-14

Docket: 2:22-cv-00272-TOR

The Ninth Circuit reversed and remanded the district court’s denial of mandatory attorneys’ fees to the prevailing defendant-appellants under Washington law (RCW 4.84.250). The court held that a district court exercising diversity jurisdiction may award fees under RCW 4.84.250 if the “amount pleaded” falls below $10,000, even if the amount in controversy initially met federal diversity jurisdiction thresholds at the time of removal. Applying Washington law to interpret the state statute, the court determined that the “amount pleaded” requires only notice to the opposing party prior to trial that the claim is for $10,000 or less, rather than a formal amendment of the complaint under Federal Rule of Civil Procedure 15. Because the plaintiff provided such notice in a settlement-offer letter after dismissing union plaintiffs, the statutory requirement was satisfied. Consequently, the case is remanded for the district court to determine if defendants are entitled to fees under RCW 4.84.250 and, if so, to award additional reasonable attorneys’ fees for the appeal under RCW 4.84.290 and revisit the award of taxable costs.

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: 2026-07-14

The Fifth Circuit affirmed the district court’s grant of final judgment in favor of the defendants and dismissal of the plaintiff’s claims with prejudice. The court held that the state judges sued could not be held liable under 42 U.S.C. § 1983 because neither a State nor its officials acting in their official capacities qualify as “persons” subject to suit under the statute. Furthermore, the court ruled that judicial immunity barred the plaintiff’s individual-capacity claims, as the judges’ alleged conduct—managing court filings and proceedings—constituted judicial actions performed within the bounds of their jurisdiction. Applying de novo review to the Rule 12(b)(6) dismissal, the court found no reversible error, noting that even with liberal construction of the pro se plaintiff’s brief, his conclusory allegations failed to state a plausible claim for relief or allege nonjudicial acts or actions taken in the complete absence of jurisdiction. Consequently, the judgment dismissing the civil rights claims against the judges remains in effect.

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