Court: United States Court of Appeals for the Fifth Circuit

Filed: 2026-07-08

The Fifth Circuit affirmed the district court’s dismissal of Roberto J. Salinas’s 42 U.S.C. § 1983 complaint, which included dismissals for failure to state a claim and as frivolous under 28 U.S.C. § 1915(e), as well as a grant of summary judgment. Regarding the claim that Duval County Sheriff Romeo R. Ramirez violated constitutional rights by entering Salinas’s property without consent, a warrant, or exigent circumstances, the court held that Salinas abandoned the issue on appeal by failing to identify any error in the district court’s analysis. Concerning the due process claim regarding delays in Salinas’s release from jail after posting bail, the court affirmed summary judgment because Salinas failed to demonstrate the existence of any genuine issue of material fact. The court further declined jurisdiction over the magistrate judge’s denial of motions for leave to amend the complaint and for an extension of time to file a notice of appeal, as these orders were not appealed to the district court first. Additionally, claims challenging Salinas’s arrest and treatment while in custody raised for the first time on appeal were not considered. Consequently, the district court’s judgment is affirmed, and Salinas’s motions for judicial notice and to amend the caption 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 Ninth Circuit

Filed: 2026-07-08

Docket: 1:22-cv-00027

The Ninth Circuit affirmed the district court’s grant of summary judgment in favor of United Airlines, dismissing Joseph Laguana’s Americans with Disabilities Act (ADA) claim regarding the failure to provide reasonable accommodations and engage in an interactive process. The court applied a de novo standard of review to determine whether there was a genuine dispute of material fact or if the employer was entitled to judgment as a matter of law. Under the ADA, 42 U.S.C. § 12112(b)(5)(A), and implementing regulations, an employer must engage in an interactive process to identify reasonable accommodations once requested; however, the court held that United Airlines satisfied this obligation because Laguana requested only extended medical leave, which the airline granted. Because Laguana never requested any other specific accommodations beyond the extended leave he received, the employer had no further duty to engage in the interactive process or provide additional accommodations. Consequently, Laguana’s claim failed as a matter of law, and the judgment for United Airlines remains in effect.

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Court: United States Court of Appeals for the Fifth Circuit

Filed: 2026-07-08

The Fifth Circuit dismissed the appeal for lack of jurisdiction because it was filed untimely. The court held that while a timely post-judgment motion under Federal Rule of Civil Procedure 59(e) tolls the 30-day deadline for filing a notice of appeal, a successive post-judgment motion on the same grounds does not restart or extend that deadline. Sanders filed a Rule 59(e) motion which tolled the deadline until its denial; however, his subsequent Rule 60(b) motion was a second attempt to relitigate the same issues and failed to toll the appeal period further. Consequently, the 30-day window expired on March 4, 2024, but Sanders did not file his notice of appeal until June 12, 2025. As the appeal is jurisdictionally barred by the mandatory time limits under 28 U.S.C. § 2107(a) and Federal Rule of Appellate Procedure 4(a), the court lacks authority to review the district court’s dismissal of Sanders’s equal-protection claim.

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Court: United States Court of Appeals for the Ninth Circuit

Filed: 2026-07-08

Docket: 2:24-cv-00893-TSZ

The Ninth Circuit affirmed the district court’s order denying the defendants’ motion to compel arbitration in a putative class action contract dispute. The court held that the defendants waived their right to arbitrate by engaging in litigation conduct inconsistent with that right. Applying the “totality of the circumstances” standard, the panel determined that the defendants made an intentional decision to seek judicial judgment on the merits rather than exercising their arbitration rights. This conclusion was based on the defendants’ repeated motions to dismiss the entire complaint under Federal Rule of Civil Procedure 12(b)(6), their participation in discovery and status conferences for ten months without raising arbitration, and their belated assertion of the right to arbitrate only after their motion to dismiss failed. The court rejected the defendants’ arguments that a reservation of rights in their answer or minimal discovery activity prevented a finding of waiver, noting that express disclaimers are insufficient to defeat a claim of waiver when the party has actively litigated the merits for a prolonged period. Consequently, the case remains in federal district court for further proceedings on the merits.

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Court: United States Court of Appeals for the Federal Circuit

Filed: 2026-07-08

The federal-circuit denied the petitioner’s motion for leave to file a petition for a writ of mandamus directed at the Merit Systems Protection Board. The court held that a writ of mandamus is an extraordinary remedy available only when a petitioner demonstrates a clear and indisputable right to relief and the absence of any other adequate means to attain the desired relief. The court found that the petitioner failed to meet this standard because he did not show that the normal appellate process—seeking review after the Board issues a final decision—was inadequate, nor did he demonstrate that any delay by the Board was so egregious as to warrant such relief. Consequently, while the motion is granted solely to the extent necessary to docket and deny the petition due to a filing restriction imposed on the petitioner in another court, the underlying request for mandamus relief is denied without addressing the merits of the whistleblower appeal.

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: 2026-07-08

The Fifth Circuit affirmed the district court’s grant of summary judgment in favor of Walmart, holding that the plaintiff’s decedent did not qualify as “disabled” under the Americans with Disabilities Act (ADA). The court applied the *McDonnell Douglas* burden-shifting framework and reviewed the district court’s decision de novo. While acknowledging the ADA Amendments Act of 2008 (ADAAA) lowered the threshold for proving a disability, the Fifth Circuit clarified that the ADAAA does not create a regulatory presumption of disability or absolve plaintiffs from presenting evidence that an impairment substantially limits a major life activity. The court found no genuine dispute of material fact regarding this element because the plaintiff continued to perform his routine duties as a store manager, never requested medical leave, and subsequently secured employment requiring more physical labor, thereby failing to demonstrate that his residual stroke symptoms or diabetes substantially limited activities such as caring for oneself, performing manual tasks, eating, sleeping, or walking. As the plaintiff could not establish the first element of a prima facie case of discrimination, the court affirmed the judgment without addressing Walmart’s other defenses regarding notice or pretextual reasons for termination. The practical consequence is that the district court’s dismissal of the ADA claim stands, and no relief is granted to the estate.

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Court: United States Court of Appeals for the Eleventh Circuit

Filed: 2026-07-08

Docket: 1:24-cv-01489-LMM

The eleventh-circuit affirmed the district court’s grant of summary judgment in favor of Chicago Title Insurance Company, holding that Maxie O’Neal Price, III was not entitled to title insurance coverage for his dispute with neighbors over an easement. Applying Georgia law under a de novo standard of review, the court determined that the final title insurance policy superseded and merged into the earlier commitment issued prior to closing, rendering the policy the exclusive source of coverage between the parties. Because the policy contained an unambiguous exclusion for claims involving “covenants, conditions, restrictions, easements and/or servitudes,” and the dispute arose from an alleged easement, the court found no coverage existed under the operative contract. Additionally, the court rejected Price’s claim for equitable reformation of the policy to match the commitment’s terms, ruling that Georgia law requires proof of a mutual mistake by both parties to reform a written contract, whereas Price could only demonstrate a unilateral mistake and had effectively abandoned the argument on appeal by failing to address it in his opening brief. Consequently, Chicago Title is not liable for breach of contract or bad faith damages, and the judgment in favor of the insurer stands.

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Court: United States Court of Appeals for the Fifth Circuit

Filed: 2026-07-08

The fifth-circuit granted the Federal Public Defender’s motion to withdraw and dismissed the appeal. The court based its decision on an independent review of the record, which concurred with counsel’s assessment that the appeal presented no nonfrivolous issues for appellate review under the standard established in *Anders v. California* and *United States v. Flores*. As a result, the appointed counsel is excused from further responsibilities, and the criminal appeal is terminated without consideration of 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: 2026-07-08

The Fifth Circuit affirmed the district court’s grant of summary judgment based on qualified immunity for three police officers accused of deliberate indifference to a detainee’s serious medical needs, resulting in his death. The court held that while a genuine dispute of material fact existed regarding whether Officer Weaver actually knew of the detainee’s unconscious state during transport, she was still entitled to immunity because it was not clearly established law in 2019 that an officer observing a detainee lose consciousness during transport must immediately secure aid. The court applied the two-prong qualified immunity standard: (1) whether the officers violated a statutory or constitutional right under the Fourteenth Amendment’s deliberate indifference standard, and (2) whether that right was clearly established at the time of the conduct. Regarding Officers Hobbs and Scott, the court found no evidence they actually knew of the risk; Hobbs mistook symptoms of sickle cell trait-induced collapse for exercise exhaustion, and Scott relied on Hobbs’s assessment without interacting with the detainee. The court ruled that such a “symptoms-only scenario” where officers lack medical training does not support an inference of actual knowledge sufficient to overcome immunity. Regarding Officer Weaver, while the court acknowledged that video evidence created a factual dispute over whether she observed the detainee losing consciousness, it concluded on the second prong that no precedent existing in August 2019 placed the constitutional question beyond debate. The court noted that the Fifth Circuit did not establish a duty to immediately call for emergency assistance in response to a serious threat to an inmate’s life until its 2021 decision in *Cope v. Cogdill*, and prior cases like *Allen* involved more obvious medical emergencies or longer delays than those alleged here. The practical consequence is that the plaintiffs’ civil rights claim under 42 U.S.C. § 1983 against all three officers is dismissed, and the judgment in favor of the officers stands.

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Court: United States Court of Appeals for the Fifth Circuit

Filed: 2026-07-08

The Fifth Circuit affirmed the district court’s grant of summary judgment to Officer Kenneth Nassar on qualified-immunity grounds. The court held that even assuming the officer’s use of force violated the Fourth Amendment, the plaintiff failed to demonstrate that the right was clearly established at the time of the incident. Applying the two-prong qualified immunity test, the court determined that existing precedent did not place the constitutional question beyond debate in this specific context. While general principles from *Tennessee v. Garner* and *Graham v. Connor* prohibit deadly force absent a significant threat of death or serious physical injury, the Supreme Court has clarified that these cases do not create clearly established law outside “obvious” violations. The court found no such obvious violation because the suspect was armed with a stolen handgun, fled after commands to stop, and turned to face the officer in a rapidly unfolding encounter involving a report of brandishing firearms and traffic violations. Consequently, a reasonable official would not have understood that using deadly force under these circumstances violated clearly established law. The practical consequence is that the plaintiff’s federal civil rights claim against the officer is dismissed, and the judgment stands as affirmed.

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