Court: United States Court of Appeals for the Fourth Circuit

Filed: 2026-06-29

The Fourth Circuit denied a certificate of appealability and dismissed the appeal because the appellant failed to make the requisite showing that reasonable jurists could find the district court’s assessment of his constitutional claims debatable or wrong. Under 28 U.S.C. § 2253(c)(1)(B) and (c)(2), an appeal from a denial of relief on a motion under 28 U.S.C. § 2255 is not permissible without such a certificate, which requires a substantial showing of the denial of a constitutional right. The court independently reviewed the record and concluded that Beasley did not satisfy this standard for either substantive or procedural grounds. Consequently, the appeal is dismissed, and no further proceedings are authorized in this circuit.

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: 2026-06-29

The Sixth Circuit affirmed Lorin Kal Buckner’s conviction on two counts of conspiracy to commit fraud (mail/wire fraud and bankruptcy fraud) and his 120-month sentence. The court held that Buckner failed to demonstrate reversible error regarding his waiver of the right to counsel, his competency, the procedural reasonableness of his sentence, or the sufficiency of evidence supporting his criminal contempt conviction. Regarding the waiver of counsel, the court applied the standard from *Faretta v. California* and Sixth Circuit precedent requiring that a district court’s colloquy be “substantially similar” to the model inquiry found in the Bench Book for United States District Judges. The court determined that the district judge’s questioning, which included leading yes-or-no questions about Buckner’s understanding of the Constitution, Federal Rules of Criminal Procedure, and the dangers of self-representation, satisfied this standard. The court rejected Buckner’s argument that his subsequent use of “sovereign citizen” legal theories constituted a substantial change in circumstances requiring a new waiver inquiry, noting that no degree of legal knowledge is required to knowingly waive counsel and that defendants may assert fringe theories while still understanding the criminal nature of the proceedings. On the issue of competency, the court applied the standard under 18 U.S.C. § 4241(a), which requires “reasonable cause” to doubt a defendant’s capacity to understand the proceedings. Relying on *United States v. Coleman* and *United States v. Tucci-Jarraf*, the court ruled that idiosyncratic beliefs, unconventional legal arguments, and sovereign citizen rhetoric do not alone establish incompetence absent evidence of a deeper breakdown in cognitive ability. The record showed Buckner maintained a rational understanding of the proceedings, filed competent motions citing specific rules and case law, and was found by appointed counsel to be of sound mind. Regarding sentencing challenges, the court applied plain-error review to Buckner’s unpreserved objections. It found no error in the district court’s application of U.S.S.G. § 2B1.1(b)(9)(B) for fraudulent action during a bankruptcy proceeding, reasoning that fraud persists through the proceeding even if the false representation occurred prior to filing. The court also affirmed the two-level enhancement for being an organizer or leader under U.S.S.G. § 3B1.1(c), finding sufficient evidence that Buckner controlled participants in the scheme. Finally, the court dismissed Buckner’s challenge to his summary criminal contempt ruling for lack of jurisdiction, holding that Federal Rule of Appellate Procedure 3(c)(1)(B) requires a notice of appeal to specifically designate the contempt order, which Buckner failed to do. As a practical consequence, Buckner’s conviction and sentence remain in effect, and he must serve his 120-month imprisonment term.

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: 2026-06-29

The Sixth Circuit affirmed the district court’s grant of summary judgment to all defendants in this civil rights action brought under 42 U.S.C. § 1983. The court held that the arresting officers had probable cause to arrest the plaintiff, John Stafford, for aggravated menacing, which defeated his claims of unreasonable seizure and malicious prosecution. The court applied the standard that probable cause exists when events would cause an objectively reasonable officer to believe there is a “probability or substantial chance of criminal activity.” The court found that witness statements, video evidence, and Stafford’s own admission that he pointed a gun at golfers satisfied this low bar under Ohio law. Regarding Stafford’s argument that the officers ignored his “Stand Your Ground” self-defense claim, the court ruled that officers are not required to investigate a defendant’s legal defenses prior to arrest unless a reasonable officer would “conclusively know” the defense applies. Because the facts regarding whether Stafford was acting in self-defense or on his own property were contradictory and unclear at the time of arrest, the probable cause determination stood. The court further held that the officers did not participate in or improperly influence the independent decision by a special prosecutor to file charges, breaking the causal chain necessary for a malicious prosecution claim. Additionally, the court rejected the plaintiff’s Fourth Amendment intrusion into privacy claim regarding his transport to the police station, noting that the officer attempted to avoid media coverage and that the Sixth Circuit has not recognized a constitutional violation for photographing a suspect during normal police transport. As a practical consequence, because Stafford failed to establish an underlying constitutional violation, his claims for civil conspiracy and municipal liability under *Monell* also failed. The court affirmed the district court’s dismissal of Stafford’s state-law claims without prejudice, concluding that the district court properly declined to exercise supplemental jurisdiction once the federal claims were resolved.

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: 2026-06-29

Docket: 2:13-cr-00005-TFM-MU-1

The eleventh-circuit affirmed the 13-month sentence imposed on Willie James Lowe, Jr. following the revocation of his supervised release. The court applied a two-step reasonableness review process under *United States v. Trailer*, first assessing procedural reasonableness and then substantive reasonableness. Regarding the procedural claim that the district court failed to adequately explain its reasoning under 18 U.S.C. § 3553(c), the court applied plain error review because Lowe failed to object at the sentencing hearing. The court held that no plain error occurred because the district court’s explanation was clear on the face of the record, citing Lowe’s non-compliance with supervised release terms, disbelief in his testimony, and the need for accountability as sufficient reasons for a within-guidelines sentence. Regarding the substantive claim that the court dismissed mitigating evidence, the court applied the deferential abuse-of-discretion standard under *Gall v. United States*. The court concluded the district court did not commit clear error of judgment or give significant weight to improper factors, specifically deferring to the district court’s credibility determinations regarding Lowe’s testimony and the witnesses’ statements. As a result, the sentence is upheld, and the judgment of the district court 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 Fourth Circuit

Filed: 2026-06-29

The Fourth Circuit affirmed the district court’s summary judgment in favor of defendant Arvinder Kakar on plaintiff Knockout Holdings’ defamation and declaratory judgment claims. The court first addressed a jurisdictional issue raised during oral argument, remanding the case to determine if complete diversity of citizenship existed under 28 U.S.C. § 1332 at the time the complaint was filed. Upon receiving the district court’s ruling that diversity existed because Kakar and a former member were Maryland citizens while no Knockout members were, the appellate court reviewed this finding for clear error and legal conclusion de novo, ultimately agreeing that complete diversity was present and affirming the jurisdictional ruling. Regarding the merits, the court applied a de novo standard of review to the summary judgment award, evaluating whether there was a genuine dispute of material fact and if the moving party was entitled to judgment as a matter of law. The court rejected Knockout’s argument that Kakar’s statements to an IBM employee were defamatory, holding that the statements were protected opinions under the First Amendment because they expressed Kakar’s subjective views regarding ongoing state litigation and his business relationship with Knockout, rather than asserting verifiable facts. Additionally, the court reviewed the district court’s refusal to grant declaratory relief for abuse of discretion, concluding that no reversible error occurred because the underlying defamation claims were not actionable, thereby eliminating the controversy of sufficient immediacy required under the Declaratory Judgment Act. As a practical consequence, the judgment in favor of Kakar stands, Knockout Holdings’ appeal is dismissed, and the case is closed with no further proceedings in federal court.

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: 2026-06-29

The Fourth Circuit dismissed the appeal in part for lack of jurisdiction and affirmed the district court’s denial of qualified immunity in part. The court held that while it has jurisdiction under the collateral order doctrine to review purely legal questions regarding a magistrate judge’s denial of qualified immunity, it lacks authority to reweigh record evidence or resolve factual disputes. Because Officer Devine’s arguments challenging the objective reasonableness of his use of lethal force relied on a view of the facts contrary to the magistrate judge’s findings, the court dismissed those portions of the appeal. The court affirmed the remainder of the ruling, concluding that no reversible error existed regarding the purely legal questions presented, specifically that the officer’s conduct did not violate clearly established statutory or constitutional rights under 42 U.S.C. § 1983. Consequently, the case proceeds to trial on the Fourth Amendment seizure claim.

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: 2026-06-29

Docket: 1:24-cv-23477-BB

The eleventh-circuit affirmed the district court’s dismissal of Isabel del Pino Allen’s amended complaint with prejudice and its denial of her motion for relief pursuant to Federal Rule of Civil Procedure 59(e). The court held that the district court did not abuse its discretion in determining that the plaintiff’s pleadings constituted impermissible “shotgun pleadings” because they failed to provide the defendant with fair notice of the specific claims asserted or the factual grounds supporting them. The court applied the standard of review for abuse of discretion, requiring affirmation unless the district court made a clear error of judgment or applied the wrong legal standard. Under Federal Rule of Civil Procedure 8(a)(2) and Rule 10(b), a complaint must contain a short and plain statement showing entitlement to relief with claims set forth in numbered paragraphs limited to a single set of circumstances. The appellate court found that Allen’s amended complaint, while containing numbered paragraphs, failed to separate distinct causes of action into separate counts or clearly link factual allegations to specific legal theories. Instead, the filing contained loose references to Florida statutes and contradictory statements regarding her intent to assert a bad faith claim, rendering it impossible to discern which facts supported which claims. The court further reasoned that allowing further amendment would be futile because Allen had already been given an opportunity to correct these deficiencies and had explicitly stated she did not intend to pursue the only viable cause of action (bad faith) while attempting to relitigate claims previously rejected in prior suits against the same defendant. Additionally, the district court properly considered documents outside the four corners of the complaint, such as previous judicial records and GEICO’s motions, to conclude that dismissal with prejudice was appropriate under the court’s inherent authority to control its docket. The denial of the Rule 59(e) motion was upheld because Allen failed to present newly discovered evidence or demonstrate a manifest error of law or fact, instead attempting to relitigate issues already resolved. As a practical consequence, the dismissal stands with prejudice, meaning the case is closed and Allen cannot refile the same claims in federal court.

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: 2026-06-26

Docket: 1:22-CV-00214-SWS)

The Tenth Circuit dismissed the appeal for lack of appellate jurisdiction because the district court’s order remanding the case to the United States Forest Service without vacatur was not a final decision under 28 U.S.C. § 1291. The court applied the administrative remand rule, which generally precludes appellate review of district court orders that return matters to an agency for further proceedings. Although the Conservation Groups argued that the “practical finality” exception should apply because the issue was important and urgent, the court rejected this argument, noting that the decision to remand with or without vacatur involved a fact-intensive inquiry applying the *Allied-Signal* factors, which is typically left to the district court’s discretion. Consequently, the order did not meet the criteria for the practical finality exception, as the issue was not outside the trial court’s discretion. The practical consequence is that the Conservation Groups’ challenge to the remedy determination cannot be reviewed by the appellate court at this time; the case remains with the district court and the agency to implement the remand instructions consistent with the prior appellate mandate.

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: 2026-06-26

The sixth-circuit affirmed the district court’s dismissal of the Washingtons’ discrimination claims against First National Bank of Pennsylvania under the Fair Housing Act (FHA), the Equal Credit Opportunity Act (ECOA), Ohio state law, and the Americans with Disabilities Act (ADA). The court held that while the district court erred by requiring the plaintiffs to plead facts establishing a prima facie case of discrimination at the motion-to-dismiss stage, such an error was harmless because the complaint failed to meet the ordinary plausibility pleading standards established in *Bell Atlantic Corp. v. Twombly* and *Ashcroft v. Iqbal*. The court applied the standard that a plaintiff is not required to plead facts establishing a prima facie case under the *McDonnell Douglas* burden-shifting framework, as that framework is an evidentiary standard for summary judgment or trial, not a pleading requirement. Instead, the court reviewed whether the complaint contained sufficient factual matter to state a plausible claim for relief by allowing the court to draw a reasonable inference that the defendant discriminated against the plaintiffs based on race or disability. The court found the complaint insufficient because it relied on conclusory assertions that the bank treated other applicants differently without providing specific factual content regarding those comparators. Additionally, the court affirmed the dismissal of the ADA claim because the appellants failed to address the district court’s reasoning regarding that specific statute in their opening brief. The practical consequence is that the judgment of the United States District Court for the Northern District of Ohio dismissing the complaint is upheld, and the Washingtons’ lawsuit against the bank is terminated without leave to amend based on the current record.

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: 2026-06-26

The Fifth Circuit granted the Federal Public Defender’s motion to withdraw and dismissed the appeal after reviewing the Anders brief filed by counsel and the relevant record. The court concurred with counsel’s assessment that the appeal presented no nonfrivolous issues for appellate review, applying the standard established in *Anders v. California* and *United States v. Flores*. As a result, the appointed attorney was excused from further responsibilities, and the case was dismissed without addressing the merits of the underlying criminal conviction.

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