Court: United States Court of Appeals for the Fourth Circuit

Filed: 2026-09-29

The Fourth Circuit dismissed the appeal for lack of jurisdiction because the order Lucas sought to challenge was neither a final order nor an appealable interlocutory or collateral order. The court applied the statutory requirements of 28 U.S.C. § 1291 and § 1292, along with Fed. R. Civ. P. 54(b) and the standard established in *Cohen v. Beneficial Indus. Loan Corp.*, determining that the district court’s order denying her motion for reconsideration did not meet the criteria for appellate review. As a result of this dismissal, the appeal is terminated without a decision on the merits of Lucas’s claims against the various defendants.

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: 2026-09-29

Docket: 5:24-cv-00716-WFJ-PRL

The eleventh-circuit dismissed the appeal sua sponte for lack of jurisdiction because the notice of appeal was untimely. The court applied the standard set forth in Federal Rule of Appellate Procedure 4(a)(1) and 28 U.S.C. § 2107(a), which requires a notice of appeal to be filed within 30 days of the entry of judgment. Although the prison mailbox rule under Fed. R. App. P. 4(c)(1) deems a pro se prisoner’s filing timely when delivered to prison officials, the court found that Ward’s notice was not deemed filed until August 10, 2026, well past the February 5, 2025 deadline triggered by the January 6, 2025 judgment entry. Consequently, the appeal was dismissed without reaching the merits of the habeas corpus claim under 28 U.S.C. § 2254, leaving the district court’s dismissal order in place.

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: 2026-09-29

The fourth-circuit affirmed summary judgment on Colette Cunningham’s retaliation claim but reversed and remanded her gender-disparate treatment and pay disparity claims under Title VII. The court held that Cunningham waived any challenge to the district court’s ruling on retaliation because she failed to address the issue in her opening brief. Regarding the disparate-treatment claim, the court determined that the district court erred in concluding Cunningham failed to establish a prima facie case. Applying the *McDonnell Douglas* burden-shifting framework, the Fourth Circuit found that the record contained genuine issues of material fact regarding whether the Sheriff’s Office subjected Cunningham to adverse employment actions—such as forcing her to perform Captain-level duties while retaining her Lieutenant rank, denying her administrative support, and requiring overtime—and whether she was treated differently than similarly situated male Captains who were not required to work overtime or serve as duty officers. The court ruled that the difference in formal rank between Cunningham and her comparators was not dispositive given that she performed the same day-to-day duties for nine months. On the pay disparity claim, the court reversed the summary judgment because the district court’s analysis was incomplete. While acknowledging that Cunningham’s total annual compensation was similar to that of her male comparator Captains, the Fourth Circuit noted a genuine issue of material fact regarding whether those comparators had to work the same number of hours to earn that salary. Since the record did not clarify if the Captains were exempt from overtime while Cunningham was required to work extra hours to achieve comparable pay, the court found it necessary to remand for further proceedings to determine if the Sheriff’s Office paid Cunningham a lower hourly rate than men performing similar duties. The case is remanded for these claims to proceed consistent with the opinion, while the retaliation dismissal stands.

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: 2026-09-29

Docket: 2:21-cv-00797-RAH-JTA

The eleventh-circuit affirmed the district court’s ruling as applied to Bruce Henry, holding that Alabama’s Sex Offender Registration and Community Notification Act is unconstitutional as applied to him. The court determined that Henry retains a fundamental right under the Due Process Clause of the Fourteenth Amendment to live with his children, despite his prior conviction for possessing child pornography. Because the Act abridges this fundamental right, the court applied strict scrutiny, requiring Alabama to prove the statute is narrowly tailored to further its compelling interest in child safety. The court concluded that the Act fails strict scrutiny on three grounds. First, the law is overinclusive because it imposes a permanent, categorical ban on residence with children for any offender convicted of a sex offense involving a child, regardless of whether the offense involved direct contact or if the individual poses a current danger to their own children. Second, the law is underinclusive because it permits covered offenders unsupervised visitation with minors in certain circumstances while simultaneously banning them from residing with their own children. Third, viable less restrictive alternatives exist, such as individualized judicial hearings to assess parental fitness, which other states utilize effectively without compromising child safety. Consequently, the Act’s application to Henry is invalid, and he is permitted to reside with his son.

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: 2026-09-29

Docket: 2:19-CV-02402-TC)

The Tenth Circuit affirmed the district court’s grant of partial summary judgment to the boilermakers on their claims for early-retirement benefits and the timeliness of those claims, while reversing the district court’s grant of summary judgment to the defendants on breach of fiduciary duty claims brought by 66 plaintiffs. Regarding the interpretation of the multi-employer pension plan, the court applied de novo review but acknowledged that because the plan grants discretion to the trustees, their interpretation would be upheld unless arbitrary and capricious. However, the court held that the trustees’ interpretation was arbitrary and capricious because it conflicted with the plan’s unambiguous language. The plan requires participants to “withdraw completely” from employment in jobs classified under a collective bargaining agreement or involving supervision of such workers; it does not require withdrawal from all employment with any company contributing to the plan. Consequently, the boilermakers who worked for non-covered employers remained eligible for benefits. On the issue of timeliness for benefit claims, the court applied 29 C.F.R. § 2560.503-1(g)(1)(iv), which requires plan administrators to notify claimants of the time limits for bringing a civil action following an adverse benefit determination. The court found that the defendants failed to provide this notice in their initial denials and that subsequent appeal denials were also defective for failing to identify pertinent evidence or specific plan sections. Therefore, the defendants could not rely on the two-year statute of limitations to bar these claims. Regarding the breach of fiduciary duty claims, the court applied the three-year statute of limitations under 29 U.S.C. § 1113(2), which begins to run only when the plaintiff has “actual knowledge” of the breach. The court held that the district court erred in treating the denial of benefits as the start of the limitations period, noting there was no evidence in the administrative record that the claimants had actual knowledge of the trustees’ alleged fraudulent concealment or misleading statements regarding the new unwritten eligibility requirements. As a practical consequence, the boilermakers are entitled to early-retirement benefits under the plan’s correct interpretation, and their breach of fiduciary duty claims against 66 plaintiffs will proceed in the district court for further proceedings consistent with this opinion. The court declined to address arguments regarding statutory provisions on benefit reductions or recoupment amounts as moot by its ruling on the plan interpretation.

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 First Circuit

Filed: 2026-09-29

The First Circuit affirmed the district court’s decision confirming an arbitration award that required Harvard College to include psychology doctoral students conducting lab-based research within its collective bargaining unit with the Harvard Graduate Students Union. The court rejected Harvard’s arguments that the arbitrator exceeded her authority or violated public policy, holding that the dispute concerned the interpretation of the Collective Bargaining Agreement (CBA) rather than the statutory scope of the bargaining unit under the National Labor Relations Act (NLRA). The court applied a highly deferential standard of review to the arbitration award, noting that judicial oversight is “extremely limited” and awards are nearly impervious to vacatur. The court held that an award may only be set aside if it draws its essence from the CBA, meaning the arbitrator’s interpretation must have a plausible basis in the contract’s text, history, or past practices. Regarding substantive arbitrability, the court distinguished between determining the scope of a bargaining unit (an NLRB function) and interpreting who fits within an already-established unit defined by the parties’ contract; because the CBA explicitly defined “Research Assistant[s]” to include students regardless of funding sources, the arbitrator was authorized to interpret these contractual terms. Furthermore, the court rejected the public policy argument, reasoning that the award did not violate the NLRA or workers’ associational rights because Article 33 of the CBA preserves the students’ right to opt in or out of union membership and dues payments. As a result of this affirmation, the arbitration award stands as final and binding. Harvard is required to designate all psychology doctoral students performing lab-based research as members of the bargaining unit, provide them with lost benefits and payments, and process their claims, while the Union’s request for confirmation of the award is upheld.

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: 2026-09-29

Docket: 1:19-cr-00448-LMM-CCB-1

The eleventh-circuit affirmed the district court’s judgment revoking Sedarious Lawrence’s supervised release and imposing a sentence of twelve months and one day of imprisonment. The court applied an abuse of discretion standard to review the revocation and substantive reasonableness of the sentence, while reviewing factual findings for clear error. Regarding the revocation, the court held that even if the district court clearly erred in finding Lawrence willfully violated the no-contact condition, the error was harmless because Lawrence admitted to a separate violation of using a controlled substance (testing positive for THC), which alone provided an adequate basis for revocation under 18 U.S.C. § 3583(e)(3). Regarding the sentence, the court found the district court did not abuse its discretion in weighing the factors set forth in 18 U.S.C. § 3553(a); the court was permitted to emphasize deterrence given Lawrence’s status as a repeat violator, and the failure to explicitly discuss mitigating evidence regarding indigency did not constitute error where the record reflected consideration of all relevant factors. The sentence was deemed reasonable as it fell within the applicable guideline range and well below the statutory maximum. Consequently, the judgment and sentence remain in effect, and Lawrence 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 Fourth Circuit

Filed: 2026-09-29

The Fourth Circuit affirmed Jalisa Hawkins’s conviction for violating 21 U.S.C. §§ 841(a)(1) and 841(b)(1)(C). Regarding her claim that the district court erred in describing permissible uses of prior bad act evidence under Federal Rule of Evidence 404(b), the court applied the plain error standard under Federal Rule of Criminal Procedure 52(b) because Hawkins failed to object at trial. The court held that she did not satisfy her burden of demonstrating a clear and obvious error affecting her substantial rights. Regarding her claim of ineffective assistance of counsel based on an ex parte discussion between her attorney and the judge, the court ruled that the claim was unreviewable on direct appeal because the record did not conclusively establish ineffective assistance. The court stated that such claims must be raised in a timely motion in the district court under 28 U.S.C. § 2255. Consequently, the judgment of conviction is 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 Fourth Circuit

Filed: 2026-09-29

The fourth-circuit affirmed the district court’s order dismissing John Anaya’s civil complaint, denying his motions to amend, and denying as moot his motions for in camera review. The court found no reversible error in the lower court’s proceedings after reviewing the record. Consequently, the dismissal of the case stands, and Anaya’s request to remand the matter to the district court was 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 Fourth Circuit

Filed: 2026-09-29

The Fourth Circuit affirmed Whitteney Guyton’s 66-month sentence imposed for health care fraud and making false statements relating to health care matters. The court applied an abuse-of-discretion standard of review to Guyton’s claims that the above-Guidelines sentence was procedurally and substantively unreasonable, concluding that the district court acted reasonably by conducting an individualized assessment of the 18 U.S.C. § 3553(a) factors, including her offense conduct, post-offense actions, pre-trial release violations, history, and the need for deterrence. Regarding Guyton’s argument that the district court committed error under *United States v. Rogers*, the court held that the sentencing judge satisfied the requirement to announce all non-mandatory conditions of supervised release by expressly incorporating the recommended conditions listed in the presentence investigation report into the oral pronouncement, a practice validated by *United States v. Bullis*. The practical consequence is that Guyton’s conviction and sentence stand as imposed by the district court.

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