Court: United States Court of Appeals for the Eighth Circuit

Filed: 2026-08-11

The eighth-circuit affirmed the district court’s grant of summary judgment to Broan-Nutone, LLC, holding that Berkley National Insurance Company failed to present sufficient evidence to establish a manufacturing defect claim under Minnesota law. The court applied the standard for strict liability manufacturing defect claims, which requires a plaintiff to prove by a preponderance of the evidence that (1) the product was in a defective condition unreasonably dangerous for its intended use, (2) the defect existed at the time the product left the defendant’s control, and (3) the defect proximately caused the injury. While acknowledging that plaintiffs may rely on circumstantial evidence rather than specific deviations from a flawless product, the court emphasized that such evidence must allow a reasonable inference that the defect existed when the product was distributed, without requiring speculation. The court found Berkley’s expert testimony insufficient because it failed to demonstrate that the alleged malfunction—overheating due to a failed thermal protection device or insulation by dust and lint—was present when Broan manufactured and sold the fan. Given that the fan had been installed more than ten years prior to the fire, creating a substantial opportunity for mishandling, misuse, or environmental accumulation of debris, the evidence did not rule out the possibility that the defect developed after the product left Broan’s control. Consequently, the practical consequence is that the district court’s ruling stands, dismissing Berkley’s claim and leaving Broan-Nutone without liability for the fire damages.

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: 2026-08-11

The Eighth Circuit affirmed the district court’s denial of Malachi Handley’s motion to suppress evidence found in his vehicle, holding that while a drug dog’s physical intrusion into an open vehicle window constitutes a Fourth Amendment search under *United States v. Jones* and *Florida v. Jardines*, the exclusionary rule does not apply because law enforcement officers acted in objectively reasonable reliance on binding Eighth Circuit precedent (*United States v. Lyons*) existing at the time of the stop. The court applied the standard that warrantless searches are per se unreasonable unless an exception applies, noting that a dog’s intrusion into a vehicle is a physical trespass for information gathering that qualifies as a search. However, the court determined that under *Davis v. United States*, the exclusionary rule serves only to deter deliberate, reckless, or grossly negligent police conduct and does not apply when officers rely on binding appellate precedent until it is authoritatively overruled. The court found that although *Jones* and *Jardines* cast doubt on the specific holding in *Lyons* regarding instinctive canine actions, neither Supreme Court decision explicitly overruled *Lyons*, and a reasonable officer could not have anticipated that the precedent was invalid. Consequently, the officers’ reliance on *Lyons* to conclude the dog’s unprompted entry did not violate the Fourth Amendment was objectively reasonable, precluding the application of the exclusionary rule despite the technical constitutional violation. As a result, the evidence seized (a firearm and marijuana) remains admissible for Handley’s criminal prosecution, and his conviction for being a felon in possession of a firearm stands; no further relief is granted regarding the suppression motion.

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: 2026-08-11

The Fourth Circuit granted the petition for review, denied the Government’s motion to dismiss, and reversed in part and vacated in part the Board of Immigration Appeals’ decision, remanding the case for further proceedings. The court held that reinstatement orders constitute “final orders of removal” under 8 U.S.C. § 1252(a)(1), thereby establishing jurisdiction to review withholding-only claims even when the petitioner does not expressly challenge removability on the merits. Furthermore, the court determined that the 30-day filing deadline in 8 U.S.C. § 1252(b)(1) is a non-jurisdictional claims-processing rule subject to equitable tolling. Applying this standard, the court found that an extraordinary circumstance existed because the Supreme Court’s decision in *Riley v. Bondi* altered the state of play regarding when a petition must be filed, and the petitioner diligently pursued his rights by filing within 30 days of the Board’s final decision as understood at the time. On the merits, the court found the IJ and Board abused their discretion by failing to meaningfully engage with evidence that Navarro’s anti-gang activities constituted an imputed political opinion, ignored evidence that his proposed particular social group (“Individuals in El Salvador Who Witness and Report Crimes by MS-13 to the Police”) possessed social distinction and particularity, and disregarded substantial evidence supporting his claim for protection under the Convention Against Torture. The court vacated the denial of withholding of removal and CAT relief and remanded for the agency to reconsider these claims consistent with the opinion’s legal standards.

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Court: United States Court of Appeals for the Eleventh Circuit

Filed: 2026-08-11

Docket: 3:23-cv-00346-WWB-SJH

The eleventh-circuit dismissed the appeal sua sponte for lack of jurisdiction because the petitioner’s notice of appeal was untimely. The court held that under 28 U.S.C. § 2107(a) and Fed. R. App. P. 4(a)(1)(A), a notice of appeal in a civil case must be filed within 30 days of the final judgment. Although the petitioner’s filing on March 9, 2026, was deemed timely under the prison mailbox rule (Houston v. Lack), it exceeded the statutory deadline of February 25, 2026, which applied to the January 26, 2026, final order. Consequently, the court denied all pending motions as moot and dismissed the appeal without addressing the merits of the habeas corpus claim.

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Court: United States Court of Appeals for the Eleventh Circuit

Filed: 2026-08-11

Docket: 3:22-cr-00141-TJC-PDB-1

The eleventh-circuit affirmed Scott Hollington’s convictions for unlawfully prescribing controlled substances and obstruction of justice, as well as his 144-month prison sentence. The court held that sufficient evidence supported the convictions under a de novo standard of review. For the drug charges, the court applied the standard that prescribing controlled substances outside the “usual course of professional practice” or for no “legitimate medical purpose” violates 21 U.S.C. § 841. Relying on *United States v. Heaton*, the court found it common sense that exchanging prescriptions for sex falls outside professional practice, and sufficient evidence showed Hollington prescribed amphetamine to a patient without reviewing records or performing physical exams. Regarding obstruction of justice under 18 U.S.C. § 1503(a), the court determined there was sufficient evidence that Hollington knowingly altered medical records of undercover officers after his indictment to impede the administration of justice. On sentencing, the court applied an abuse of discretion standard to review the reasonableness of the sentence under 18 U.S.C. § 3553(a). The court found no procedural error in the district court’s decision to impose an upward variance from the advisory guideline range of 30 to 37 months, noting the court adequately explained that the guidelines failed to account for Hollington’s sexual misconduct with patients. Substantively, the sentence was reasonable because Hollington was not similarly situated to other physicians who received lesser sentences, as he committed sexual assault rather than merely engaging in sexual relationships. The court also rejected arguments regarding disparities with state sentences and the government’s sentencing recommendation, affirming that district courts are not bound by party recommendations. As a practical consequence, Hollington’s convictions and sentence remain in effect; he will serve 144 months of imprisonment consecutively to his existing three-year state sentence.

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: 2026-08-11

Docket: 4:21-cv-01649-SGC

The eleventh-circuit vacated the district court’s judgment against USAA on the breach-of-contract claim and remanded the case for a new trial, while affirming the grant of summary judgment to USAA on the bad-faith denial-of-coverage claim. The court held that the “innocent-insured exclusion” in the insurance policy is enforceable under Alabama law because it does not contravene any positive statute or well-established rule of law. The court reasoned that Alabama courts are averse to voiding contractual provisions on public policy grounds unless their illegality is clear and certain, and noted that while the Alabama legislature has prohibited such exclusions in specific domestic abuse contexts via the Domestic Abuse Insurance Protection Act, it has not done so generally. Consequently, the exclusion’s unambiguous language barring coverage for losses caused by any insured’s intentional acts applies to the plaintiff, even if he was innocent of the arson. Regarding the bad-faith claim, the court affirmed summary judgment because USAA possessed an arguable lawful basis for denying the claim: evidence suggesting the plaintiff himself committed arson, including motive, cell tower data placing him near the scene, and his expertise in severing gas lines. The practical consequence is that the case returns to the district court for a new trial where USAA may present the innocent-insured exclusion as a defense, though the plaintiff’s bad-faith claim remains dismissed.

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: 2026-08-11

The Eleventh Circuit denied consolidated petitions for review filed by various railroads and industry associations challenging the Federal Railroad Administration’s (FRA) 2024 “Crew Size Rule.” The court held that the FRA acted within its statutory authority under the Federal Railroad Safety Act of 1970, which empowers the Secretary of Transportation to issue safety regulations “as necessary,” interpreting this phrase as granting broad discretion rather than imposing a strict evidentiary bar requiring quantitative proof of necessity. Applying the Administrative Procedure Act’s arbitrary and capricious standard, the court found the FRA reasonably exercised its authority by relying on predictive judgments, safety research regarding cognitive demands, public comments detailing close calls, and trends such as increasing train lengths and human-factor accidents to justify the rule. The court rejected arguments that the agency failed to consider labor costs or violated the “change-in-position doctrine” when reversing its 2019 decision not to regulate, noting that the 2019 order had been vacated by the Ninth Circuit and thus did not constitute a binding prior policy requiring heightened justification. Additionally, the court ruled that the rule did not conflict with the Rail Safety Improvement Act’s risk reduction program and that the FRA’s failure to meet a statutory 12-month procedural deadline did not warrant vacatur because Congress did not specify such a consequence for noncompliance. Consequently, the petitions were denied, leaving the Crew Size Rule in effect.

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Court: United States Court of Appeals for the Ninth Circuit

Filed: 2026-08-11

Docket: 3:24-cv-05907-MLP

The Ninth Circuit affirmed the district court’s order upholding the Commissioner of Social Security’s denial of benefits to Zachary L. Yandrich. The court applied a de novo standard of review to the district court’s decision and reviewed the Administrative Law Judge’s (ALJ) findings for substantial evidence or legal error. The court held that substantial evidence supported the ALJ’s evaluation of medical opinions, specifically finding it permissible to discount the opinions of Dr. Jamito, Dr. Wingate, and Mr. Bolden as inconsistent with the longitudinal record, while reasonably crediting the better-supported opinions of Drs. Sacks, Ahn, and Melamed. Additionally, the court determined the ALJ provided specific, clear, and convincing reasons for discounting Yandrich’s symptom testimony regarding disabling fatigue and social anxiety because these allegations conflicted with normal medical findings and reported activities; these same valid reasons were deemed germane grounds for rejecting similar lay witness testimony from Amanda DeLouise. Finally, the court rejected challenges to the residual functional capacity and step-five analysis, noting that the ALJ was required to include only supported limitations and permissibly relied on Medical-Vocational Rule 201.27 to find Yandrich not disabled. As a result of this affirmation, the denial of Social Security benefits 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 Eleventh Circuit

Filed: 2026-08-11

Docket: 1:24-cr-00009-AW-MAL-2

The eleventh-circuit affirmed Kenneth Steele’s 90-month below-Guidelines sentence for conspiring to distribute methamphetamine. The court held that the district court did not err in declining to apply a four-level mitigating-role reduction under Amendment 833, ruling that the amendment is substantive and therefore does not apply retroactively to sentences imposed before its effective date. Additionally, the court rejected Steele’s claim of substantive unreasonableness, applying an abuse-of-discretion standard to review whether the district court properly weighed the factors under 18 U.S.C. § 3553(a). The appellate panel found that the district court did not abuse its discretion because it explicitly considered Steele’s mitigating circumstances, including his guilty plea and cooperation, while giving significant weight to aggravating factors such as the seriousness of the offense and Steele’s prior perjury during trial. As a result, Steele’s conviction and sentence remain in effect, and he must serve the imposed term 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 Eleventh Circuit

Filed: 2026-08-11

The Eleventh Circuit denied consolidated petitions for review filed by various railroads and industry associations challenging the Federal Railroad Administration’s (FRA) “Crew Size Rule,” which generally requires freight trains to operate with a minimum of two crewmembers. The court held that the FRA acted within its statutory authority under the Federal Railroad Safety Act of 1970, rejecting the argument that the phrase “as necessary” in 49 U.S.C. § 20103(a) imposes an evidentiary bar requiring proof that a rule is essential to safety; instead, the court interpreted the phrase as granting the agency discretion to regulate when reasonably related to railroad safety. Applying the Administrative Procedure Act’s arbitrary and capricious standard, the court found the FRA’s decision reasonable based on its consideration of public comments regarding human error and fatigue, research on cognitive demands, trends in increasing train lengths, and uncertainties surrounding Positive Train Control technology. The court further ruled that the 2019 Withdrawal Order did not constitute a binding prior policy triggering a heightened change-in-position doctrine because it had been vacated by the Ninth Circuit, and even if it did, the FRA provided a reasoned explanation for its reversal based on reassessed safety concerns. Additionally, the court determined that *Michigan v. EPA* did not compel a formal cost-benefit analysis requiring the inclusion of foregone labor savings, and found no conflict between the Crew Size Rule and the Rail Safety Improvement Act’s risk reduction program. Finally, the court held that the FRA’s failure to finalize the rule within the statutory 12-month deadline did not warrant vacatur, as the statute lacked a specified consequence for noncompliance. The petitions were denied, leaving the Crew Size Rule in effect.

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