Court: United States Court of Appeals for the Ninth Circuit

Filed: 2026-08-04

Docket: 5:21-cv-01155-GW-ADS

The ninth-circuit affirmed the district court’s grant of summary judgment for Sheriff Chad Bianco, Undersheriff Dennis Vrooman, and the County of Riverside in a 42 U.S.C. § 1983 action arising from a sewage overflow at the Cois Byrd Detention Center. The court applied de novo review and held that Ramirez failed to raise a genuine dispute of material fact regarding his supervisory liability claims against Bianco and Vrooman, as he could not demonstrate their personal involvement or a sufficient causal connection to the constitutional deprivation despite assuming a violation occurred. Additionally, the court affirmed the dismissal of Ramirez’s *Monell* claim against the County because he offered no evidence of a custom, policy, or insufficient training that caused the injury beyond the isolated incident itself. The practical consequence is that the judgment for the defendants stands and the case is closed.

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: 2026-08-04

The fourth-circuit affirmed the district court’s order dismissing Velesa Draughn’s appeal from a Merit System Protection Board decision as untimely. The court held that Draughn failed to show extraordinary circumstances warranting equitable tolling for her late notice of appeal regarding her removal from the Department of the Army. The practical consequence is that the dismissal stands and the underlying administrative action remains 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 Sixth Circuit

Filed: 2026-08-04

The sixth-circuit affirmed the denial of Jared Metzger’s motion to suppress evidence of child pornography obtained from his cell phone. The court held that officers acted in good faith reliance on a search warrant, applying the exception established in *United States v. Leon*. Although the warrant was issued for drug trafficking and did not explicitly list Metzger’s phone, the affidavit established a minimally sufficient nexus between the device and criminal activity by linking Metzger to a drug-trafficking scheme through his residence at the location, his use of associated vehicles containing a drug ledger, and a Facebook post likely made from the phone that alerted co-conspirators to police surveillance. The court further rejected a particularity challenge, noting that the warrant’s broad authorization to search all cell phones and their contents at the residence was reasonable given the circumstances and that officers immediately stopped the search upon discovering child pornography to obtain a new warrant. Because Metzger pled guilty while preserving his right to appeal, the conviction 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 Seventh Circuit

Filed: 2026-08-04

The Seventh Circuit affirmed the district court’s grant of summary judgment in favor of Insurance Company of the West (ICW), holding that it has no duty to defend or indemnify High Performance Alloys, Inc. (HPA) under its Employers Liability Insurance Policy for a wrongful death suit brought by an employee’s estate. The court applied Indiana law, specifically the Indiana Worker’s Compensation Act and the precedent set in *Baker v. Westinghouse*, which establishes that the Act is the exclusive remedy for workplace injuries occurring “by accident.” The court reasoned that the underlying complaint alleged either gross negligence or reckless disregard of known dangers, which does not constitute the “actual intent” or “actual knowledge that an injury is certain to occur” required to bypass the Act’s exclusivity. Consequently, the claim falls within the Policy’s exclusion for obligations imposed by workers’ compensation law. Alternatively, if the allegations were construed as intentional torts, they would be barred by the Policy’s exclusion for bodily injury intentionally caused or aggravated by the insured, as such injuries are not accidental. The court also denied HPA’s request to certify questions to the Indiana Supreme Court, finding that existing precedent provided a clear path to resolve the dispute without necessitating new state law pronouncements.

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: 2026-08-04

Docket: 2:18-cv-02420-TLN-CKD

The ninth-circuit affirmed the district court’s grant of summary judgment in favor of the County of Sacramento and its deputies on plaintiff Eric Anthony Alston, Jr.’s civil rights and state-law claims arising from his November 2017 arrest and transport. The court held that no reasonable jury could find Deputy Ball’s driving constituted excessive force under the Fourth Amendment, as in-car camera footage contradicted Alston’s account of striking his head on a partition and showed he shifted forward voluntarily; applying *Graham v. Connor*, the court found the intrusion minimal compared to governmental interests. The court further ruled that the deputies did not act with deliberate indifference under the Fourteenth Amendment because they observed Alston descend stairs and walk unassisted before instructing him into the patrol car, meaning there was no substantial risk of serious harm that a reasonable officer would have appreciated. Additionally, the court affirmed summary judgment on state-law negligence claims, finding no evidence that it was foreseeable the deputies’ instructions would cause Alston to fall while wearing a walking boot and handcuffs. Consequently, the court determined that Alston’s Bane Act claim necessarily failed due to the absence of an underlying constitutional violation, and the County could not be held liable under 42 U.S.C. § 1983. The judgment 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 Eleventh Circuit

Filed: 2026-08-04

Docket: 5:22-cr-00053-CAR-CHW-3

The eleventh-circuit affirmed the conviction of a daycare director for failing to report suspected child abuse in violation of 18 U.S.C. § 2258. The court held that sufficient evidence supported the jury’s finding that the defendant had reason to suspect the children suffered mental injury, which constitutes child abuse under the statute. Applying the standard of review de novo, the court determined that a rational trier of fact could infer the defendant suspected abuse based on employee reports of demeaning language and profane music, as well as video footage showing physical mistreatment and signs of psychological harm such as withdrawal. The court rejected the defendant’s argument that the statute required “severe” mental injury, interpreting the statutory examples as illustrative rather than exclusive. Additionally, the court applied the doctrine of deliberate ignorance, finding sufficient evidence that the defendant either saw the abuse on monitors or consciously avoided doing so after receiving reports from staff. The conviction stands, and the defendant remains subject to her two-year probation sentence.

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: 2026-08-04

The Fourth Circuit vacated the district court’s denial of qualified immunity to Defendant G. Andrew Hall in his individual capacity, holding that it was not clearly established in November 2021 that an employer must provide an employee with an opportunity to cure any inauthenticity of a Family and Medical Leave Act (FMLA) certification before contacting the certifying medical provider for authentication purposes. The court applied the qualified immunity standard, which requires that the right alleged to have been violated be “clearly established” such that every reasonable official would understand their conduct is unlawful. Analyzing 29 C.F.R. § 825.307(a), the court concluded that the regulatory term “deficiencies,” which triggers a seven-day cure period under § 825.305(c), reasonably refers only to incomplete or insufficient certifications and does not clearly encompass issues of authenticity. Consequently, Hall’s interpretation of the regulations was reasonable, and he was entitled to immunity on this basis. The court remanded the case for the district court to address the antecedent legal question of whether qualified immunity is an available defense to interference claims under the FMLA.

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: 2026-08-04

The eighth-circuit affirmed the conviction of Christopher Spider for conspiracy to distribute methamphetamine and witness tampering, while vacating the convictions of Lance Brunsting due to his death during the appeal. Regarding Spider, the court applied de novo review for sufficiency of the evidence and abuse of discretion for evidentiary rulings. It held that sufficient evidence supported the conspiracy conviction, as multiple witnesses, wiretaps, and admissions established the agreement and Spider’s intentional participation, noting that witness credibility is a jury determination. The court further ruled that admitting Spider’s prior federal drug convictions under Federal Rule of Evidence 404(b) was not an abuse of discretion because it was relevant to show intent and knowledge, possessing probative value that outweighed any prejudicial effect. Finally, the court found any error in the district court’s drug quantity calculation harmless, as the mandatory minimum sentence of 300 months would apply regardless of whether the quantity was nine pounds or six pounds. For Brunsting, the court applied the rule that criminal proceedings abate *ab initio* upon a defendant’s death during appeal, vacating his convictions and remanding with instructions to dismiss the indictment.

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: 2026-08-04

Docket: 2:25-cv-04793-SMB–JFM

The ninth-circuit vacated the district court’s judgment dismissing Ai-Yee Liu’s 28 U.S.C. § 2241 habeas corpus petition and remanded the case for further proceedings. The court held that the district court erred by summarily dismissing the petition because Liu raised cognizable, non-frivolous claims regarding her detention. Applying de novo review, the court determined that under *Neiss v. Bludworth*, a district court must not dismiss a habeas petition at the screening stage if it alleges such claims. On remand, the district court is directed to serve the government and require it to file a response. The court also denied Liu’s motion to stay removal as moot.

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: 2026-08-04

Docket: 1:20-cv-00591-TFM-MU

The eleventh-circuit affirmed the district court’s denial of Estella Curry’s federal habeas corpus petition challenging her state conviction for reckless murder. The court applied the deferential standards of the Antiterrorism and Effective Death Penalty Act (AEDPA), 28 U.S.C. § 2254(d)(1) and (d)(2), which prohibit relief unless the state court’s decision was contrary to or an unreasonable application of clearly established federal law, or based on an unreasonable determination of facts. Regarding Curry’s claim that the trial court denied her Sixth Amendment right to self-representation, the court held that the state court did not unreasonably apply *Faretta v. California*. The record showed Curry failed to make a “clear and unequivocal” request to proceed pro se; instead, she vacillated between requesting new counsel, asking for time to decide, and expressing dissatisfaction with her appointed attorney. The court further rejected the argument that the state court’s factual determination was unreasonable, noting it properly focused on the final hearing where Curry explicitly stated she could not make an informed decision at that time. On the sufficiency of the evidence claim, the court applied the *Jackson v. Virginia* standard, determining whether any rational trier of fact could have found the essential elements of reckless murder beyond a reasonable doubt. The court found the state appellate court’s denial of this claim was not unreasonable because Alabama law does not require proof that the defendant was under the influence of a “controlled substance” as a statutory element; rather, such evidence merely supports the finding of extreme indifference to human life. Even excluding references to controlled substances, sufficient evidence remained regarding Curry’s excessive speed and impairment from prescription medications. Additionally, the court held that Curry forfeited her argument regarding the *Martinez* exception to procedural default for ineffective assistance of counsel claims by failing to address it in her appellate briefs. Consequently, the judgment of the district court denying habeas relief was affirmed, leaving Curry’s state conviction and life sentence intact.

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