Court: United States Court of Appeals for the Sixth Circuit

Filed: 2026-07-13

The Sixth Circuit affirmed the district court’s denial of Gianni Gray’s motion to suppress a third firearm seized at his residence, ruling that the evidence was admissible under the independent-source doctrine despite an initial Fourth Amendment violation during the execution of an arrest warrant. The court applied the two-prong test established in *Murray v. United States*, requiring the government to prove that (1) the decision to seek the search warrant was not prompted by observations made during the unlawful entry, and (2) the information obtained from the illegal search did not influence the magistrate’s decision to issue the warrant. The court found no clear error in the district court’s factual findings that investigators would have sought the search warrant regardless of discovering Gray or the firearms during the initial arrest, as they had already gathered substantial evidence connecting Gray to the residence and the double homicide prior to the entry. Furthermore, the court held that even after excising the tainted information regarding the discovery of the guns from the affidavit, the remaining facts established probable cause and a sufficient nexus between the suspect’s residence and the location of the murder weapon, noting that firearms are not perishable items and the two-year lapse in time did not render the evidence stale. Consequently, the third gun remains admissible as evidence for Gray’s federal conviction under 18 U.S.C. § 922(g)(1), and his sentence stands at 51 months of imprisonment.

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: 2026-07-13

The Fifth Circuit affirmed the district court’s dismissal of Justin Riddle’s copyright infringement claims against X Corp. The court held that Riddle abandoned his challenge to the initial partial dismissal because he failed to meaningfully brief arguments regarding the Rule 12 order, and further found that the dismissal with prejudice of his remaining contributory-copyright claim was not an abuse of discretion. Under Federal Rule of Civil Procedure 41(b), a dismissal with prejudice is appropriate only when there is a clear record of delay or contumacious conduct and lesser sanctions are insufficient to serve the interests of justice. The district court satisfied this standard by documenting Riddle’s repeated misconduct, including ex parte communications, local-rule violations, and threatening language directed at opposing counsel and the court, despite an express warning that such behavior could lead to dismissal. The appellate court noted that the record supported the district court’s findings that all three aggravating factors were present: delay caused by the plaintiff, actual prejudice to the defendant, and intentional conduct. Consequently, the judgment of the United States District Court for the Western District of Texas is affirmed, and all pending motions are denied.

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: 2026-07-13

The Fifth Circuit granted the appointed attorney’s motion to withdraw and dismissed the appeal after reviewing the Anders brief filed by counsel and the relevant portions of the record. The court concurred with counsel’s assessment that the appeal presents no nonfrivolous issues for appellate review, thereby excusing counsel from further responsibilities in the case pursuant to 5th Cir. R. 42.2.

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: 2026-07-13

The Fifth Circuit affirmed the district court’s grant of summary judgment in favor of Officer Tammie Heeth and the City of Onalaska, holding that the officer is entitled to qualified immunity because she did not violate Amberley Lambert’s clearly established rights under the First or Fourth Amendments. Regarding the Fourth Amendment claim, the court applied the probable cause standard, concluding that Officer Heeth had probable cause to stop and arrest Lambert for violating Texas Transportation Code § 542.501 by willfully refusing a lawful order to turn around, as well as for resisting arrest under Texas Penal Code § 38.03(a) when Lambert tensed her body to prevent removal from the vehicle. The court rejected Lambert’s argument that the arrest was unlawful because resistance occurred after an initial seizure, noting that probable cause existed independently before the resistance began. Regarding the First Amendment retaliatory arrest claim, the court applied the framework established in *Nieves v. Bartlett*, which requires a plaintiff to plead and prove the absence of probable cause unless they can satisfy a narrow exception by presenting objective evidence that similarly situated individuals who did not engage in protected speech were not arrested. The court found that Lambert failed to meet this burden because her conduct—driving toward an officer after being ordered to stop—is not endemic or benign like the jaywalking example in *Nieves*, and she provided no objective evidence of similarly situated comparators. Consequently, the existence of probable cause defeated the retaliation claim regardless of the timing relative to Lambert’s prior complaint. The practical consequence is that the judgment for the defendants stands, and Lambert’s civil rights lawsuit is dismissed without further proceedings 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 Fifth Circuit

Filed: 2026-07-13

The Fifth Circuit denied the plaintiff-appellant’s motion to proceed in forma pauperis and dismissed her appeal as frivolous. The court held that the appellant failed to raise a nonfrivolous challenge to the district court’s determination that her appeal was not taken in good faith under 28 U.S.C. § 1915(e)(2)(B). Regarding her state law claims, the court applied attorney immunity principles established in *Troice v. Proskauer Rose* and *Cantey Hanger*, finding that actions taken during representation, including alleged false certifications and negligent supervision, were protected. On her claim under 42 U.S.C. § 1983, the court applied the plausibility standard from *Ashcroft v. Iqbal* and concluded her pleadings failed to demonstrate with facial plausibility that the defendant was a state actor or engaged in a conspiracy with state officials. Additionally, the court affirmed the district court’s decision to dismiss the claims with prejudice without allowing an amendment, ruling that further proceedings would have been futile. As a result, the appeal is dismissed and the appellant is not permitted to proceed on appeal without paying the required fees.

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: 2026-07-13

The Fifth Circuit affirmed the district court’s imposition of special supervised-release conditions following Rafael Perdomo-Limus’s guilty plea conviction for illegal reentry. The court held that Perdomo-Limus failed to demonstrate plain error in the district court’s oral pronouncement of his sentence, specifically rejecting his argument that the court erred by failing to explicitly inquire whether he had reviewed the presentence report and its appendix with counsel prior to sentencing. Applying the standard for plain error review, the court relied on *United States v. Villafana-Mondragon*, 170 F.4th 360 (5th Cir. 2026), to conclude that the omission did not affect Perdomo-Limus’s substantial rights or the fairness of the proceedings. Consequently, the judgment of the district court stands, and the supervised-release conditions 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 Fifth Circuit

Filed: 2026-07-13

The Fifth Circuit granted the Government’s motion for summary affirmance and affirmed the district court’s judgment upholding Chamnap In’s conviction under 18 U.S.C. § 922(g)(1) for possessing a firearm after a felony conviction. The court held that In’s arguments, raised for the first time on appeal, are foreclosed by binding precedent: specifically, *United States v. Diaz*, 116 F.4th 458 (5th Cir. 2024), which established that § 922(g)(1) does not facially violate the Second Amendment, and *United States v. Perryman*, 965 F.3d 424 (5th Cir. 2020), which foreclosed Commerce Clause challenges based on the interpretation of the statute’s interstate travel element. Consequently, the court denied In’s appeal as a matter of law and dismissed his alternative motion for an extension of time to file an appellate brief as moot.

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: 2026-07-13

Docket: 6:23-CV-01233-DDC)

The Tenth Circuit affirmed the district court’s grant of summary judgment in favor of the defendant, Textron Aviation, Inc., dismissing Erika Cordova’s claims of sex, race, and national origin discrimination, as well as retaliation, under Title VII and 42 U.S.C. § 1981. The court applied a de novo standard of review to the summary judgment ruling, requiring that all evidence be viewed in the light most favorable to the non-moving party but affirming where no reasonable jury could find for the appellant. The court rejected Cordova’s primary argument that she was misled by the defendant’s attorney into failing to submit evidence during the summary judgment phase, finding that the email exchange cited by Cordova referred only to trial exhibits and did not address summary judgment obligations. Furthermore, the court noted that Cordova was represented by appointed counsel who submitted a 90-page response with extensive evidence, and Cordova failed to explain how her newly introduced “Exhibit E” would have altered the outcome or met procedural requirements under Fed. R. App. P. 28(a)(8)(A). Regarding the remaining arguments, the court held that the district court properly considered the cumulative impact of alleged incidents in its hostile-environment analysis and had already thoroughly addressed specific sexual harassment allegations. The practical consequence is that the judgment against Cordova stands, her appeal is dismissed, and she must proceed with her employment at Textron without the legal relief sought. The court also granted Cordova’s motion to proceed on appeal without prepayment of costs or fees.

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: 2026-07-13

Docket: 4:26-cv-00027-MW-MAF

The eleventh-circuit dismissed the appeal sua sponte for lack of jurisdiction. The court held that it could not review the district court’s March 10, 2026 order because that order was interlocutory and did not constitute a final decision under 28 U.S.C. § 1291, as it directed the plaintiff to file an amended complaint rather than disposing of all claims. Furthermore, the court determined that the notice of appeal filed by the pro se prisoner was ineffective because it was submitted before the district court entered its final judgment dismissing the case; consequently, any issues regarding injunctive relief contained in the earlier order merged into the final judgment and are reviewable only upon a proper appeal from that final judgment. As a result, the appeal is dismissed and all pending motions are denied as moot.

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: 2026-07-13

Docket: 5:23-cv-00366-PGB-PRL

The eleventh-circuit affirmed the district court’s denial of Robert Harris’s post-judgment motions to amend his habeas corpus petition and for reconsideration. The court held that the district court did not abuse its discretion in rejecting these requests because Harris’s arguments regarding the “saving clause” of 28 U.S.C. § 2255(e) were barred by the law-of-the-case doctrine, as the issue had been necessarily decided during prior appeals in the same case. Furthermore, the court applied the rule that a district court lacks authority to grant leave to amend a habeas petition after it has entered final judgment. Regarding the motion for reconsideration under Federal Rule of Civil Procedure 59(e), the court found the denial proper because such motions cannot be used to relitigate issues or raise matters that could have been presented before entry of judgment. Consequently, Harris’s request for relief was denied, and the district court’s prior dismissal of his claims remains in effect.

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