Court: United States Court of Appeals for the Tenth Circuit

Filed: 2026-06-30

Docket: 1:24-CR-00210-GPG-1)

The tenth-circuit affirmed the district court’s denial of a motion to suppress evidence found during a search of the defendant’s vehicle. The court held that the defendant’s encounter with law enforcement, which occurred after the traffic stop mission was completed and his documents were returned, was consensual rather than an unlawful extension of detention. The court applied the standard for determining whether a post-stop interaction is a consensual encounter under the Fourth Amendment, asking whether a reasonable person in the defendant’s position would have felt free to leave or disregard the officer’s request. In analyzing this, the court considered factors including the absence of threats or physical touching, the conversational tone of the officer, the return of personal effects prior to further questioning, and the public setting of the encounter with the patrol car door open. The court emphasized that the officer explicitly told the defendant he was “good to go” before asking additional questions, which signaled the end of the detention. Because the interaction was consensual, the court found no Fourth Amendment violation and did not need to address whether reasonable suspicion existed to justify the continued detention. As a result of this affirmation, the district court’s judgment stands, meaning the evidence seized (fentanyl) remains admissible, the defendant’s conditional guilty plea is upheld, and his 120-month sentence remains in effect.

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Court: United States Court of Appeals for the First Circuit

Filed: 2026-06-30

The First Circuit vacated the district court’s grant of summary judgment in favor of the mayor and remanded the case for further proceedings. The court held that a government official’s refusal to reappoint a former employee to a position they previously held constitutes an “adverse employment action” protected under the First Amendment, rejecting the district court’s conclusion that such a refusal was not actionable. Furthermore, the court ruled that the determination of whether political affiliation is an appropriate requirement for a specific public office cannot be based solely on a legislative classification of the position as a “trust” position; instead, it requires a fact-specific inquiry into whether the role involves policymaking, confidential information, or other functions where party affiliation is essential. Applying this standard to the Internal Auditor position in Maricao, Puerto Rico, the court found that the duties were technical and non-policymaking, similar to precedents involving identical roles, meaning political affiliation was not a valid basis for the mayor’s decision. Consequently, the case returns to the district court to address the plaintiff’s First Amendment claim regarding political discrimination without the erroneous legal barriers previously applied.

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Court: United States Court of Appeals for the Fourth Circuit

Filed: 2026-06-30

The Fourth Circuit denied Robert K. Decker’s petition for a writ of mandamus, which sought to compel the United States District Court for the District of Maryland to rule on his pending 28 U.S.C. § 2241 habeas corpus petition. The court determined that the present record failed to demonstrate any undue delay by the district court in adjudicating the underlying petition. Consequently, the court found no basis to issue the requested writ directing the district court to act and denied the petition without oral argument.

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: 2026-06-30

The Fourth Circuit affirmed the district court’s revocation of Stevenson Gilberto Harrison, Jr.’s supervised release and the imposition of a nine-month prison term followed by a new five-year term of supervised release. The court held that the district court acted within its broad discretion under 18 U.S.C. § 3553(a) and did not abuse its authority in determining the sentence was substantively reasonable. The court applied the standard that a revocation sentence is substantively reasonable if, considering the totality of the circumstances, the court states an appropriate basis for the imposed sentence. The opinion emphasized that while courts must consider statutory factors such as the nature of the offense, the defendant’s history, and the need for public protection, they possess extremely broad discretion in weighing these factors. The appellate court found that Harrison failed to meet his high burden of proving the sentence was plainly unreasonable. Specifically, the district court reasonably concluded that continued supervision was necessary to support Harrison’s reentry into society given his prior poor performance on supervised release, including a threat to kill a Deputy U.S. Marshal. Furthermore, the court determined that releasing Harrison without supervision would not serve the interests of the public due to his history of violence and the fact that his unauthorized travel to Arkansas breached the trust of the district court, regardless of his subsequent registration as a sex offender or notification of authorities. As a result of this decision, the nine-month prison sentence and the new five-year term of supervised release remain in effect. The court dispensed with oral argument, noting that the facts and legal contentions were adequately presented in the written materials.

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: 2026-06-30

The Fourth Circuit affirmed the 100-month sentence imposed on Quinton Darnel Delaney, Jr., for possession of a firearm and ammunition by a convicted felon in violation of 18 U.S.C. §§ 922(g)(1) and 924(a)(2). The court addressed Delaney’s argument that the district court improperly expanded the scope of relevant conduct used to calculate his advisory Sentencing Guidelines range. Rather than evaluating the merits of this calculation error, the court applied an assumed error harmlessness inquiry under *United States v. Gomez-Jimenez* and *United States v. Mills*. This standard requires determining whether (1) the district court would have imposed the same sentence regardless of the Guidelines error, and (2) the sentence is substantively reasonable. The court found the first prong satisfied because the district court expressly stated that it would have imposed the same 100-month sentence as an alternative “variant” sentence under 18 U.S.C. § 3553(a) factors and the totality of the circumstances, regardless of the Guidelines calculation. Regarding the second prong, the court reviewed the record for substantive reasonableness, noting that the district court considered Delaney’s recidivism and serious criminal history while also balancing his childhood circumstances. The district court had already accounted for defense arguments regarding relevant conduct by imposing a sentence at the low end of the applicable Guidelines range. Finding no abuse of discretion in concluding the sentence satisfied § 3553(a) standards, the court held that any potential Guidelines error was harmless. Consequently, the criminal judgment is affirmed and oral argument is dispensed with.

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: 2026-06-30

The First Circuit affirmed the district court’s denial of Calvary Chapel Belfast’s motion for a temporary restraining order and preliminary injunction, holding that the Church failed to demonstrate a likelihood of success on the merits of its claims under the Equal Protection and Free Exercise Clauses of the First Amendment. The court applied the *Arlington Heights* “totality of the circumstances” test to evaluate whether the University of Maine System’s decision to rescind Calvary’s winning bid was motivated by unconstitutional religious animus, rather than a per se rule that community opposition automatically taints government action. Under this standard, the court found no clear error in the district court’s factual determination that Vice Chancellor Ryan Low’s decision to cancel the initial procurement award and restart the bidding process was driven solely by a good-faith desire to avoid approximately $500,000 in relocation costs for an internet connectivity hub, rather than religious bias. The appellate court credited Low’s testimony and found that the alleged procedural irregularities—specifically the rescission of the award and the classification of a disappointed bidder’s appeal as a timely “award protest” rather than an untimely “specification protest”—were not substantive or procedural deviations indicative of discriminatory intent. Because Calvary could not prove that religious animus was a motivating factor in the University’s decisionmaking, it could not satisfy the threshold requirement for preliminary injunctive relief. As a practical consequence, the University is permitted to proceed with its second public procurement process and the sale of the Frederick Hutchinson Center property to Waldo Community Action Partners, which was selected as the winning bidder under the revised evaluation criteria. The federal litigation remains pending on the merits, but Calvary’s request to halt the sale or restore its initial bid status during the appeal is 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: 2026-06-30

The Fourth Circuit denied a certificate of appealability and dismissed the appeal because the petitioner failed to make the requisite showing required under 28 U.S.C. § 2253(c). The court applied the standard established in *Gonzalez v. Thaler* and *Slack v. McDaniel*, which mandates that when a district court denies relief on procedural grounds, such as an untimely filing, a prisoner must demonstrate both that the dispositive procedural ruling is debatable and that the underlying petition states a debatable claim of the denial of a constitutional right. The court independently reviewed the record and concluded that Murray did not satisfy this dual burden regarding his § 2254 habeas petition or his Rule 59(e) motion for reconsideration. Consequently, the appeal was dismissed without oral argument, leaving the district court’s dismissal of the petition as untimely in effect.

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Court: United States Court of Appeals for the Fourth Circuit

Filed: 2026-06-30

The Fourth Circuit dismissed the appeal for lack of jurisdiction because the notice of appeal was not timely filed. The court applied Federal Rule of Appellate Procedure 4(a)(1)(A), which requires a party in a civil case to file a notice of appeal within 30 days after the entry of the district court’s final judgment or order, noting that this deadline is a jurisdictional requirement under *Bowles v. Russell*. Because the district court entered its order on September 29, 2025, the appeal period expired on October 29, 2025, but the petitioner filed the notice of appeal on December 31, 2025, without obtaining an extension or reopening of the period under Fed. R. App. P. 4(a)(5) or 4(a)(6). As a practical consequence, the court denied a certificate of appealability and dismissed the appeal, leaving the district court’s order dismissing the habeas petition without prejudice for failure to exhaust state remedies in place.

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Court: United States Court of Appeals for the Fourth Circuit

Filed: 2026-06-30

The Fourth Circuit remanded the case to the district court after determining that the lower court erred by refusing to docket a Rule 59(e) motion filed by the pro se appellant, Richard J. Forbes. The court applied Federal Rule of Appellate Procedure 4(a)(4)(A), which provides that when a party files a motion to alter or amend judgment within 28 days of a final order, the time to file a notice of appeal runs from the entry of the order disposing of that motion. The appellate court found that Forbes’s “memorandum opinion response” filed within the 28-day window constituted a timely Rule 59(e) motion, and the district court’s refusal to accept it for filing was incorrect. Consequently, the case is remanded for the district court to docket and consider the pending motion, with the appellate court expressly reserving judgment on the ultimate disposition of Forbes’s civil rights claims under 42 U.S.C. § 1983.

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Court: United States Court of Appeals for the Eleventh Circuit

Filed: 2026-06-30

Docket: 4:23-cr-00022-AW-MAF-1

The eleventh-circuit affirmed the 120-month sentence imposed on Defendant-Appellant Pedro Cesar Ramos-Cruz for conspiracy to bring a noncitizen to the United States, illegal entry by a deported noncitizen, and possession of a firearm by a noncitizen. The court applied an abuse of discretion standard of review to evaluate the substantive reasonableness of the sentence under 18 U.S.C. § 3553(a). The court held that Ramos-Cruz failed to meet his burden of proving the sentence was unreasonable. Although the district court imposed an upward variance of sixty-three months above the advisory guidelines range, the court found the district judge adequately explained the justification by considering multiple aggravating factors, including the defendant’s possession of stolen handguns, substantial proceeds from the offense, post-arrest conduct, recruitment of other participants, duration of the criminal activity, misconduct at the Federal Detention Center, re-entries into the United States, and possession of clients’ passports. The court rejected Ramos-Cruz’s argument that the guidelines already accounted for the dangerousness of the smuggling operation, noting that the district court did not apply the specific two-level enhancement under U.S.S.G. § 2L1.1(6) regarding substantial risk of death or serious bodily injury, rendering the argument moot. Furthermore, the court found the district court’s factual finding that Ramos-Cruz smuggled more than 100 persons was supported by record evidence. The sentence was deemed reasonable as it remained well below the statutory maximum of 324 months. The practical consequence is that the judgment of the United States District Court for the Northern District of Florida stands, and the defendant’s appeal is denied.

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