Court: United States Court of Appeals for the Seventh Circuit

Filed: 2026-08-07

The Seventh Circuit affirmed the district court’s grant of summary judgment in favor of Ridge Tool Manufacturing Company, Inc., holding that the exclusion of the plaintiff’s expert witnesses under Federal Rule of Evidence 702 was proper and left the plaintiff with insufficient evidence to sustain his product liability, negligence, and failure-to-warn claims. The court applied the gatekeeping standard of Rule 702, as amended in 2023, which requires that expert testimony be based on sufficient facts, reliable principles and methods, and a reliable application of those methods to the case facts. Regarding the plaintiff’s design defect claim, the court found the mechanical engineer’s report inadmissible because it relied solely on the existence of similar designs in competitor products without testing feasibility, analyzing maintenance costs, or evaluating compatibility with the specific machine. The court distinguished this from precedent where testing was unnecessary because the alternative design was already in widespread use, noting that the plaintiff failed to provide a denominator for his industry comparison and offered no data on the safety relative to the actual machine. Regarding the failure-to-warn claim, the court found the human factors expert’s report unreliable because she opined on the inadequacy of the user manual without addressing the fact that the plaintiff never read it, and she failed to propose or test a specific alternative warning label that would have prevented the injury. The practical consequence is that the plaintiff’s appeal is dismissed and the district court’s summary judgment ruling stands. Without admissible expert testimony to support his theories of design defect or inadequate warnings, and lacking any alternative evidence such as a proposed better warning label, the plaintiff cannot meet the burden required to survive summary judgment under Illinois law.

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 Seventh Circuit

Filed: 2026-08-07

The Seventh Circuit affirmed the district court’s grant of summary judgment in favor of the City of Chicago, holding that the Estate failed to present sufficient evidence to create a genuine dispute of material fact regarding the City’s liability under the Americans with Disabilities Act (ADA), the Illinois Human Rights Act, and the Illinois Wrongful Death Act. The court applied the standard for failure-to-accommodate claims, requiring proof that the employer was aware of the disability and failed to provide a reasonable accommodation. The court reasoned that while the City’s documentation of the accommodation process was irregular and some documents appeared backdated due to the chaotic nature of the pandemic response, undisputed testimony established that Marco DiFranco was reassigned on March 23, 2020, to monitor public infrastructure from his individual police vehicle, thereby isolating him from others. The court held that procedural deviations did not negate the fact that DiFranco received a reasonable accommodation. Furthermore, regarding causation, the court noted that the Estate conceded the accuracy of the City’s exposure report, which indicated DiFranco was exposed to Covid-19 on or before March 19, prior to his request for reassignment. Because the Estate presented no evidence that DiFranco contracted the virus from a workplace exposure occurring after his accommodation request, it could not establish that any delay in accommodation proximately caused his death under the Wrongful Death Act. The practical consequence is that the judgment in favor of the City stands, and the Estate’s claims for damages are dismissed without trial.

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: 2026-08-07

Docket: 0:22-cr-60128-RAR-2

The eleventh-circuit vacated the defendant’s sentence and remanded the case for further proceedings because the government failed to present substantial evidence that the defendant agreed to jointly undertake a criminal activity with One Medical Services, the entity responsible for $3.2 million in fraudulent Medicare claims. Under U.S.S.G. § 1B1.3(a)(1)(B), a defendant is accountable for the acts of others only if those acts were within the scope of the jointly undertaken criminal activity, in furtherance of that activity, and reasonably foreseeable. The court held that while the defendant admitted to selling Medicare beneficiary cards knowing they would be used for fraud, the record contained no evidence of an explicit or implicit agreement between the defendant and One Medical Services to jointly undertake a multi-million dollar scheme. The court distinguished the case from *United States v. Whitman*, noting that a mere buyer-seller relationship or general awareness of a larger scheme is insufficient to impute the full scope of a co-conspirator’s conduct. Because the district court’s finding of a joint undertaking was clearly erroneous due to the lack of evidence, the defendant cannot be held responsible for the $3.2 million loss, and the sentence must be recalculated based only on the specific acts within his own agreed-upon scope.

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: 2026-08-07

Docket: 2:18-cv-02699-FMO-MAA

The Ninth Circuit affirmed the district court’s denial of Fernando Delgado’s petition for a writ of habeas corpus under the Antiterrorism and Effective Death Penalty Act (AEDPA), 28 U.S.C. § 2254, rejecting his claims that trial errors regarding gang-related testimony and jury instructions were not harmless beyond a reasonable doubt. The court applied the deferential standard of review set forth in AEDPA, specifically 28 U.S.C. § 2254(d)(1) and (d)(2), which prohibits federal habeas relief unless the state court’s decision was contrary to or involved an unreasonable application of clearly established federal law, or was based on an unreasonable determination of the facts. Regarding the Confrontation Clause claim, the court held that the California Court of Appeal’s application of the *Chapman v. California* harmless error standard was not unreasonable because the challenged testimony from a gang expert regarding an out-of-court conversation was cumulative of other evidence establishing the gang-related motive. Regarding the “kill zone” jury instruction claim, the court assumed without deciding that the instruction violated due process by failing to require proof of intent to kill each specific victim, but concluded that the state court’s determination that this error was harmless was not unreasonable. The court found it reasonable for the state court to determine that undisputed evidence supported an inference of intent to kill all four victims, as Delgado fired at close range at a group of individuals standing together. Consequently, the judgment of the district court denying habeas relief is affirmed, and no relief is granted to the petitioner.

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: 2026-08-07

The Sixth Circuit reversed the district court’s denial of qualified immunity to Officer William Lawless in this Fourth Amendment civil rights case brought under 42 U.S.C. § 1983. The court held that no constitutional violation occurred at any of the three challenged junctures: the initial traffic stop, the inventory search, and the subsequent arrest for obstruction of official business. Regarding the September 13 traffic stop, the court applied the probable cause standard, noting that while there is some circuit split on whether reasonable suspicion or probable cause is required for civil traffic violations, the officers satisfied the higher probable cause standard. The court ruled that an officer’s reasonable mistake regarding a driver’s speed does not defeat probable cause under *Heien v. North Carolina*. Because Officer Lawless reasonably relied on radar gun readings and visual observations indicating speeding, the stop was lawful regardless of whether Henderson actually exceeded the speed limit at the exact moment of measurement. Regarding the September 22 inventory search, the court applied the exception for warrantless inventory searches established in *Colorado v. Bertine*. The court found the impoundment lawful because it was based on a standardized criterion (impounding vehicles connected to the commission of a crime, specifically driving with expired registration) rather than suspicion of criminal activity. The court further held that the search did not violate the Fourth Amendment despite minor deviations from department policy regarding paperwork and the opening of a locked container. Citing *United States v. Hockenberry* and *Whren v. United States*, the court reasoned that imperfect compliance with internal policies does not render a search unconstitutional absent evidence that the officers used the inventory process as a pretext for an investigatory search. The policy to conduct a “complete physical inventory” was sufficient to authorize opening closed containers. Regarding the arrest for obstruction of official business, the court applied Ohio law and Sixth Circuit precedent requiring an “affirmative act” that hampers or impedes a public official’s lawful duties. The court found probable cause existed because Henderson engaged in loud, boisterous conduct, refused to sit on the curb as directed, walked toward officers during the search, and attempted to lock his vehicle to prevent access. These actions constituted an affirmative act intended to obstruct the inventory search, satisfying the elements of the offense under Ohio Revised Code § 2921.31(A). Finally, the court held that Henderson’s state-law malicious prosecution claim failed as a matter of law because it required a showing of lack of probable cause for the underlying arrest, which the court had already determined existed. The practical consequence is that Officer Lawless is granted qualified immunity, and the case is remanded to the district court with instructions to dismiss the surviving claims against him.

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: 2026-08-07

The eighth-circuit affirmed the defendant’s conviction and sentence for being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1), rejecting his claim that the district court abused its discretion by imposing an upward variance from the advisory Sentencing Guidelines range. Applying the abuse of discretion standard set forth in *United States v. Feemster*, the court held that the district court did not overlook relevant factors, give significant weight to improper factors, or commit a clear error of judgment when weighing the defendant’s history and characteristics against the government’s request for a longer sentence due to his lack of deterrence from prior prison terms. Consequently, the judgment of the United States District Court for the Eastern District of Arkansas is affirmed, leaving the 96-month prison term and three years of supervised release 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 Fourth Circuit

Filed: 2026-08-07

The Fourth Circuit affirmed the district court’s order revoking Jermar Hardin’s supervised release and imposing a 12-month imprisonment sentence. The court held that the district court did not abuse its discretion in finding Hardin committed Violation 1 of his supervised release conditions, as the record supported the finding by a preponderance of the evidence and the court followed all procedural requirements under Fed. R. Crim. P. 32.1(b)(2) and U.S. Sentencing Guidelines § 7C1.3(b). Regarding Hardin’s claim that his sentence was procedurally unreasonable due to the consideration of a prohibited factor, the court applied the plain error standard because the issue was not raised below. The court concluded that even if an error occurred, it did not affect Hardin’s substantial rights or seriously affect the fairness, integrity, or public reputation of the judicial proceedings. Consequently, the revocation judgment stands, and no further relief is granted to the appellant.

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: 2026-08-07

Docket: 1:23-CR-00586-DHU-1)

The tenth-circuit affirmed the defendant’s conviction for assaulting a security consultant who was assisting federal officers, holding that the victim qualified as an “official victim” under 18 U.S.C. § 111 and § 1114. The court applied a fact-specific standard of review to determine whether the evidence supported the jury’s finding that the victim was acting within the scope of his official duties and assisting a federal officer in the performance of those duties, viewing the evidence in the light most favorable to the government. The court reasoned that Congress intended § 111 to protect both federal officers and federal functions, ensuring a federal forum for offenses involving them. The analysis focused on whether the victim was acting within the compass of his employment rather than engaging in a “personal frolic,” without requiring a bright-line test or a direct contractual relationship with the federal agency. The court found that the security consultant’s duties—conducting rounds and inspecting cells at a facility contracted by the United States Marshals Service to house federal pretrial detainees—constituted a federal function. The fact that the consultant was employed by a private contractor (CoreCivic) rather than directly by the government, or had an agreement with CoreCivic instead of the Marshals Service, did not disqualify him from statutory protection. Citing precedent such as *United States v. Feola* and *United States v. Holder*, the court concluded that a reasonable jury could find the consultant was assisting federal officers in their official duties at the time of the assault. As a result of this affirmation, the defendant’s forty-seven-month prison sentence remains in effect, and the judgment of the district court is final.

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: 2026-08-07

Docket: 5:22-cv-00478-JSM-PRL

The eleventh-circuit vacated the district court’s grant of summary judgment to the Lehman defendants and remanded the case with instructions to enter summary judgment in favor of RLI Insurance Company. The court held that under Florida law, the Lehmans failed to satisfy the exhaustion requirement of their umbrella insurance policy because they did not fully consume the limits of their underlying Philadelphia Indemnity Insurance policy. The court applied a de novo standard of review and interpreted the insurance contract according to its plain meaning as a Florida Supreme Court would. Relying on dictionary definitions, the court determined that the term “exhaust” denotes the total use or consumption of an object until nothing is left. The RLI policy explicitly required that “policy limits of any and all Underlying Insurance have been exhausted by payment of judgments or settlements.” Because the Lehmans settled their claim with Philadelphia for $50,001 against a $500,000 policy limit, they had not fully consumed the underlying policy’s limits. The court distinguished the Lehmans’ reliance on *Reliance Insurance Co. v. Transamerica Insurance Co.*, noting that case involved a materially different exhaustion clause and did not address the plain meaning of “exhaust” in the context of specific policy limits. As a practical consequence, the district court must now enter summary judgment for RLI, effectively denying coverage under the umbrella policy because the condition precedent of exhausting underlying limits was not met.

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 District of Columbia Circuit

Filed: 2026-08-07

The D.C. Circuit affirmed the District Court’s dismissal of Goce Gligorov’s civil RICO and tort claims against three corporate defendants for lack of personal jurisdiction. The court held that exercising personal jurisdiction over the foreign corporate defendants would violate the Fifth Amendment’s Due Process Clause because there was no reasonable nexus between the defendants and the United States. The court applied a “reasonableness” test, assuming without deciding that this standard governs federal-question cases under Rule 4(k)(2) following *Fuld v. Palestine Liberation Organization*. Under this framework, the court balanced the plaintiff’s interest in obtaining relief, the United States’ sovereign interest, and the burden on the defendants. The court found that Gligorov failed to establish a concrete interest in litigating in the U.S., as he is a non-resident Slovenian national with no significant business ties to the country other than speculative lost contracts. Furthermore, the court determined there was no meaningful U.S. sovereign interest in resolving this dispute, which involved alleged corruption and conspiracy among foreign officials and entities occurring almost exclusively overseas. Finally, the court concluded that the burden on the defendants was unreasonable given their scant connections to the United States; while one defendant operated hotels in California, the allegations of a conspiracy to harm Gligorov’s reputation were far outside the scope of its hotelier business, and the other two defendants had no U.S. presence at all. Regarding jurisdictional discovery, the court affirmed the District Court’s denial of Gligorov’s motion, ruling that his request constituted an impermissible “fishing expedition.” The court found Gligorov lacked a good-faith basis to believe further discovery would uncover facts establishing a reasonable nexus, as his pleadings contained no specific allegations connecting the defendants’ conduct to the United States in a way that would justify jurisdiction. The practical consequence is that the District Court’s partial final judgment dismissing the claims against the corporate defendants stands, leaving Gligorov without a forum in the United States to pursue these specific claims against those entities.

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