Court: United States Court of Appeals for the Fourth Circuit

Filed: 2026-07-09

The fourth-circuit affirmed the district court’s order denying defendant Brandon Lashon Ingram’s second motion for compassionate release under 18 U.S.C. § 3582(c)(1)(A). The court held that the district court did not abuse its discretion in concluding that, even assuming Ingram established extraordinary and compelling reasons for release, the factors set forth in 18 U.S.C. § 3553(a) counseled against granting relief. Consequently, the district court’s denial of the motion stands, and no further proceedings on this appeal are required as the judgment is final.

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: 2026-07-09

The seventh-circuit affirmed the district court’s grant of summary judgment for the defendants in this Fourth Amendment excessive force claim brought under 42 U.S.C. § 1983. The court held that the police officers were entitled to qualified immunity because Mace Davis failed to demonstrate that their use of non-lethal impact weapons violated a clearly established constitutional right. The court applied the two-pronged qualified immunity standard, requiring a plaintiff to show (1) a constitutional violation and (2) that the conduct was clearly established as unlawful at the time. The court determined that even viewing the facts in the light most favorable to Davis, no precedent placed the conclusion that the officers acted unreasonably beyond debate. Distinguishing the controlling case of *Phillips v. Community Ins. Corp.*, the court noted significant factual differences: unlike the intoxicated and non-threatening suspect in *Phillips*, Davis had threatened his ex-wife with a firearm, possessed knives during the standoff, threatened suicide, and verbally abused officers while refusing commands to exit his home. The court reasoned that from an officer’s perspective, there was a reasonable fear that Davis would retreat into the house to retrieve a weapon or harm others, justifying the use of force to prevent his re-entry. Furthermore, the court found that Davis waived any argument regarding the fourth shot and failed to articulate a specific constitutional rule with obvious clarity that would have put officers on notice that their actions were unlawful. The court also noted that Davis failed to argue any theory of municipal liability against the City of Elgin. The practical consequence is that the judgment for the defendants stands, barring Davis from recovering damages for the injuries sustained during the police standoff.

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Court: United States Court of Appeals for the Fourth Circuit

Filed: 2026-07-09

The Fourth Circuit affirmed the district court’s grant of summary judgment for prison officials in a civil rights action brought under 42 U.S.C. § 1983 by the estate of an inmate murdered by another prisoner. The court held that the officers did not violate the Eighth Amendment because the plaintiff failed to establish that they acted with “deliberate indifference” to his safety or medical needs, a standard requiring proof that officials subjectively knew of and disregarded a substantial risk of serious harm. Applying the two-prong test for deliberate indifference (objective seriousness of the deprivation and subjective culpable state of mind), the court found no evidence that Officer Gerald Bush subjectively perceived a risk when he released two inmates without verifying their authorized worker status, despite violating prison protocol. The court ruled that knowingly violating policy does not equate to deliberate indifference and that circumstantial evidence was insufficient to prove Bush actually knew Simmons faced a specific threat from those particular inmates or that the risk was so obvious as to justify an inference of actual knowledge. Similarly, the court found no violation regarding Officer Cheryl Youngquist’s initial delay in opening the dorm door for medical assistance, noting she responded reasonably once she realized the inmate was bleeding heavily, and dismissed claims against other officers who conceded their liability at oral argument or whose actions were deemed good-faith efforts. Because the plaintiff failed to demonstrate an underlying constitutional violation, the officers are entitled to qualified immunity. The practical consequence is that the judgment for the defendants stands, barring the estate from recovering damages based on these specific allegations of negligence and failure to protect.

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: 2026-07-09

The Eleventh Circuit denied the petition for review filed by Fanis Arelly Yanes Canales and her son, upholding the Board of Immigration Appeals’ final order affirming the denial of asylum and withholding of removal under the Immigration and Nationality Act. The court applied the substantial evidence standard to the Board’s factual findings, ruling that reversal is required only when the record compels it, and reviewed legal errors de novo. The court held that the Board provided reasoned consideration to Yanes Canales’ country condition evidence regarding domestic violence in Honduras. Although the petitioner argued the Board ignored evidence showing the Honduran government’s inability to protect her from an abusive former partner, the court found the record supported the Board’s conclusion that while Honduras does not always effectively enforce its laws, it has demonstrated a willingness to protect victims of familial violence and has enacted serious criminal penalties for abusers. The court noted that the immigration judge correctly determined that “perfect protection is not required” and that Yanes Canales failed to prove the government was unable or unwilling to protect her, particularly given her testimony that she never reported the abuse to Honduran authorities. Because the petitioner failed to meet the burden of proving eligibility for asylum, the court affirmed the ineligibility for withholding of removal as well. Consequently, the petition is denied and the Board’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 Tenth Circuit

Filed: 2026-07-09

Docket: 2:23-CV-02009-DDC-ADM)

The Tenth Circuit affirmed the district court’s denial of several postjudgment motions filed by Christopher VanHorn, including a motion for relief from judgment under Federal Rule of Civil Procedure 60(b) and various related procedural motions. The court reviewed the denial of the Rule 60(b)(3) fraud claim for an abuse of discretion and the denial of the Rule 60(b)(4) void-judgment claim de novo. Regarding Rule 60(b)(3), the court held that relief was properly denied because VanHorn alleged fraud committed in state municipal proceedings rather than fraud directed at the judicial machinery of the federal district court that entered the judgment. The court found no authority supporting relief for fraud on courts other than the one entering the challenged judgment and noted that VanHorn failed to allege misconduct “directed to the judicial machinery” of the federal court. Regarding Rule 60(b)(4), the court affirmed the denial because VanHorn did not challenge the subject-matter jurisdiction of the federal district court itself, and his due process allegations pertained only to corruption in the state proceedings, which was insufficient to render the federal judgment void. Additionally, the court rejected arguments regarding the refusal to hear allegations of adverse-party misconduct as waived because they were not raised in the Rule 60(b) motion. The court also affirmed the denial of VanHorn’s other procedural motions, including those for a hearing, exceeding page limits, and compelling responses, ruling that he waived these challenges by failing to develop arguments against the district court’s reasoning in his opening brief. The appellate court granted VanHorn’s motion to proceed without prepaying costs, denied his motion for sanctions, and partially granted his motion to supplement the record with specific docket documents from the district court. Consequently, the district court’s postjudgment orders 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 Sixth Circuit

Filed: 2026-07-09

The sixth-circuit affirmed the district court’s grant of summary judgment in favor of the Department of Veterans Affairs on Latria Harrison’s claims under the Rehabilitation Act and the Family and Medical Leave Act. The court held that Harrison forfeited her arguments on appeal because her brief merely copied and pasted content from her summary judgment briefing filed below without addressing or challenging the specific reasoning the district court used to dispose of each claim. Applying the standard that an appellant must successfully challenge the grounds relied upon by the lower court, the court determined that regurgitating prior arguments fails to preserve any issue for review. As a result, the appellate court did not reach the merits of the disability accommodation, harassment, or retaliation allegations and left the district court’s judgment in favor of the employer intact.

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: 2026-07-08

The eleventh-circuit denied the petition for review of the Board of Immigration Appeals’ order denying Zenia Carolina Alfaro Mira’s application for cancellation of removal. The court held that substantial evidence supported the agency’s conclusion that Alfaro Mira failed to demonstrate that her removal to El Salvador would result in “exceptional and extremely unusual” hardship to her minor United States citizen children, as required under 8 U.S.C. § 1229b(b)(1). The court applied the “substantial evidence” standard of review, which requires viewing the record in the light most favorable to the agency’s decision and affirming if supported by reasonable, substantial, and probative evidence. The court noted that while it lacks jurisdiction to review pure findings of fact regarding cancellation of removal, it reviews the application of the hardship standard as a mixed question of fact and law. Under this high statutory bar, an applicant must show that conditions resulting from deportation are substantially beyond what is ordinarily expected. The court found that Alfaro Mira did not meet this burden because her son’s ADHD had improved, there was no evidence he would be unable to receive medical care in El Salvador, and her concerns regarding education, violence, and employment were unsupported by specific evidence. Additionally, the record showed that her children could learn Spanish, she has relatives in El Salvador to assist with the transition, and her son’s biological father resides in the United States and could provide care. Consequently, the petition is denied, leaving the BIA’s order affirming the Immigration Judge’s denial of relief in place.

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Court: United States Court of Appeals for the Fourth Circuit

Filed: 2026-07-08

The Fourth Circuit affirmed the district court’s denial of George Steen’s federal habeas corpus petition under 28 U.S.C. § 2254. The court held that when a state appellate court issues a reasoned decision disposing of an ineffective assistance of counsel claim on only one prong (prejudice) while leaving another prong (deficient performance) unaddressed, the federal habeas court must defer solely to the appellate court’s stated reasoning under AEDPA standards. The district court erred by deferring to the state trial court’s analysis of the deficient-performance prong; instead, any review of that unaddressed prong must be conducted de novo. However, because the North Carolina Court of Appeals reasonably concluded that Steen failed to demonstrate prejudice—finding that the newly discovered records would have been cumulative given evidence already presented at trial regarding the accuser’s credibility and prior sexual knowledge—the court affirmed the denial of relief on alternative grounds. The practical consequence is that Steen’s conviction remains in effect, and no federal writ of habeas corpus is granted.

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: 2026-07-08

Docket: 2:23-cv-00441-KFP

The Eleventh Circuit reversed the district court’s judgment, holding that an adjunctive specialty automobile insurance policy for antique vehicles may validly exclude portable uninsured motorist (UM) coverage for non-covered vehicles when the insured maintains a separate primary policy that satisfies Alabama’s statutory minimum UM requirements. The court determined that under Alabama Code § 32-7-22(j), the legal requirements for a motor vehicle liability policy may be fulfilled by the combined effect of policies from one or more carriers, meaning the portable UM mandate in Alabama Code § 32-7-23(a) does not require every individual policy to independently provide full coverage. In applying this standard, the court relied on the plain text of the statutes, prior Alabama Supreme Court precedent allowing exclusions where other valid insurance exists, and a prediction that the Alabama Supreme Court would align with the majority of state courts interpreting similar laws, including the recent Colorado Supreme Court decision in *Essentia Ins. Co. v. Hughes*. The court concluded that because the insured received the full $25,000 portable UM coverage required by law through his separate GEICO policy, the specialty policy’s exclusion did not violate Alabama public policy or statutory mandates. Consequently, the case is remanded to the district court for proceedings consistent with this opinion, effectively reinstating Essentia Insurance Company’s position that it bears no liability for the uninsured motorist claim arising from an accident involving a vehicle not covered by its specific antique auto policy.

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: 2026-07-08

Docket: 2:25-cv-01314-RDP

The eleventh-circuit vacated the district court’s dismissal of Kevin Glasco’s amended complaint with prejudice and remanded the case with instructions to dismiss specific claims without prejudice. The court held that while the district court correctly applied the Rooker-Feldman doctrine and Younger abstention to bar Glasco’s due process, unlawful enforcement, and equal protection claims under 42 U.S.C. § 1983, it erred in dismissing those jurisdictional claims with prejudice rather than without prejudice. The court determined that these claims sought review and rejection of a state court child support judgment, which is barred by Rooker-Feldman, or interfered with ongoing state proceedings under Younger abstention principles. Additionally, the court vacated the dismissal of Glasco’s Title II Americans with Disabilities Act claim against the Jefferson County Family Court because the complaint failed to allege facts establishing standing for injunctive relief; specifically, Glasco did not show a real and immediate threat of future discrimination after the underlying hearing had concluded. The district court was instructed to dismiss this ADA claim without prejudice. The court affirmed the district court’s denial of Glasco’s motions for a preliminary injunction and to seal documents, finding no abuse of discretion in those rulings.

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