Court: United States Court of Appeals for the Fourth Circuit

Filed: 2026-07-28

The fourth-circuit dismissed Michael Chatman’s appeal from the district court’s grant of summary judgment on his Title VII and Age Discrimination in Employment Act claims for lack of jurisdiction. The court held that the timely filing of a notice of appeal is a jurisdictional requirement under Federal Rule of Appellate Procedure 4(a)(1)(B), which mandates that appeals involving the United States or its agencies be filed within 60 days of the district court’s final order. Because Chatman filed his notice of appeal 35 days after the expiration of the 60-day period, and failed to obtain a timely extension under Rule 4(a)(5) or demonstrate delayed notice required for reopening under Rule 4(a)(6), the appeal was untimely. Consequently, the court dismissed the appeal 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: 2026-07-28

The fourth-circuit affirmed the district court’s order dismissing David Keith Willis’s civil rights claims brought under 42 U.S.C. § 1983. The court applied the standard of review for dismissals under 28 U.S.C. § 1915(e)(2) and found no reversible error in the lower court’s adoption of the magistrate judge’s recommendation. As a result, the dismissal 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: 2026-07-28

The fourth-circuit affirmed the district court’s dismissal of David Graham Grice’s civil action, holding that the district court did not abuse its discretion in denying Grice’s requests for default judgment. The court applied the standard of review for discretionary decisions and determined that the defendants were not in default because they timely moved to dismiss the complaint after Grice properly effected service on February 18, 2025, following an initial attempt that failed to comply with Rule 4(b) of the Federal Rules of Civil Procedure. The court further concluded that the district court did not violate Grice’s due process rights by sua sponte directing him to correct defects in service. Consequently, the judgment of the district court 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 Tenth Circuit

Filed: 2026-07-28

Docket: 4:24-CR-00193-SEH-1)

The tenth circuit affirmed the district court’s judgment against Jason Eugene Ellett, who was convicted of being a felon in possession of a firearm in violation of 18 U.S.C. § 922(g)(1). The court held that Ellett’s Second Amendment challenge to the statute is foreclosed by binding circuit precedent. Specifically, the court relied on *United States v. McCane*, which established that § 922(g)(1) does not violate the Second Amendment, and subsequent decisions such as *Vincent v. Bondi* and *United States v. Warner*, which confirmed that this holding remains valid under the Supreme Court’s rulings in *New York State Rifle & Pistol Association v. Bruen* and *United States v. Rahimi*. The court further noted that the statute’s constitutionality applies regardless of whether the predicate felony is violent or nonviolent. Consequently, the district court’s denial of Ellett’s motion to dismiss and his subsequent sentence were upheld.

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Court: United States Court of Appeals for the First Circuit

Filed: 2026-07-27

The first-circuit issued an errata sheet amending its opinion issued on July 23, 2026, in the case of Prakash Dhoj Rana v. Todd Blanche. The court’s stated basis for this action was to correct a clerical error on page 13, footnote 4, line 2, by replacing the word “noncitizens'” with “noncitizen’s.” This administrative order does not alter the substantive holding or disposition of the underlying immigration case but serves to ensure the accuracy of the published text.

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Court: United States Court of Appeals for the Eleventh Circuit

Filed: 2026-07-27

Docket: 1:23-cr-00111-KD-MU-12

The eleventh-circuit affirmed the convictions of Jeffrey Ryan Clark, Richard Dewise, and Otis Sanders Jr. for drug conspiracy and distribution offenses under 21 U.S.C. §§ 841(a)(1) and 846, as well as Clark’s 120-month prison sentence. The court applied a de novo standard to review the sufficiency of the evidence, concluding that a reasonable jury could find guilt beyond a reasonable doubt based on circumstantial evidence establishing actual or constructive possession and aiding-and-abetting liability. The court rejected arguments regarding the lack of direct physical possession, uncorroborated accomplice testimony, and the failure to instruct on Pinkerton coconspirator liability for substantive counts, noting that convictions could stand on alternative theories of guilt. Regarding trial errors, the court held that the district court did not abuse its discretion in denying a motion for mistrial following Sanders’s outburst during closing arguments, as the incident was brief and the jury’s mixed verdict suggested critical deliberation. The court further determined that any Confrontation Clause violation arising from the admission of a codefendant’s statements without a specific limiting instruction was harmless beyond a reasonable doubt given the overwhelming independent evidence of guilt. Additionally, the court applied the concurrent-sentence doctrine to decline review of Clark’s sentencing on Count 18, finding that any error would not alter his total term of imprisonment or cause adverse collateral consequences. However, the court vacated the conditions of supervised release for Clark and Dewise and remanded for limited resentencing. The court ruled that the district court violated due process by imposing discretionary conditions of supervised release in the written judgment without pronouncing them at the sentencing hearing. Citing *United States v. Rodriguez*, the court held that while standard conditions may be referenced generally, specific discretionary conditions must be explicitly stated during the hearing to provide defendants with notice and an opportunity to object; the existence of similar conditions in a presentence investigation report was insufficient to cure this defect.

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Court: United States Court of Appeals for the Eleventh Circuit

Filed: 2026-07-27

Docket: 1:24-cv-22787-KMM

The Eleventh Circuit affirmed the district court’s dismissal of Jonathan Harrington’s complaint against Veritext, LLC and the Florida Board of Bar Examiners with prejudice. The court held that Harrington abandoned his challenge to the district court’s finding that Veritext was entitled to absolute immunity under Florida’s litigation privilege doctrine because he failed to argue that point on appeal. Citing *Sapuppo v. Allstate Floridian Ins. Co.* and *Timson v. Sampson*, the court applied the rule that issues not properly briefed by an appellant, including pro se litigants, are deemed abandoned. Consequently, because the dismissal rested on multiple independent grounds and Harrington did not challenge the immunity ground, the judgment could not be reversed. The practical consequence is that the case remains dismissed with prejudice, barring further amendments to the complaint.

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Court: United States Court of Appeals for the Eleventh Circuit

Filed: 2026-07-27

The eleventh-circuit denied the petition for review filed by Danny Leo Valdivia-Aleman and his family seeking asylum, withholding of removal, and protection under the United Nations Convention Against Torture (CAT). The court affirmed the Board of Immigration Appeals’ (BIA) order upholding the immigration judge’s denial of these claims based on an adverse credibility determination. The court applied the substantial evidence standard of review to the BIA’s factual findings and credibility determinations, noting that an adverse credibility finding can alone support a denial of asylum if supported by specific, cogent reasons. The court held that Valdivia-Aleman failed to exhaust administrative remedies regarding nine of the thirteen inconsistencies cited by the immigration judge and his argument that the judge failed to consider corroborating evidence; consequently, these issues were precluded from review under *Santos-Zacaria v. Garland*. Regarding the exhausted claims, the court found the immigration judge’s adverse credibility determination supported by substantial evidence, citing specific inconsistencies in testimony regarding protest attendance, the petitioner’s wife’s membership in a political organization, and discrepancies between documentary evidence and oral testimony. Furthermore, the court ruled that because Valdivia-Aleman failed to establish eligibility for asylum due to lack of credibility, he necessarily could not demonstrate eligibility for withholding of removal or CAT protection. As a result of this decision, the petition is denied, and the BIA’s order affirming the denial of all requested relief 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 Eleventh Circuit

Filed: 2026-07-27

Docket: 6:23-cr-00214-GAP-RMN-1

The Eleventh Circuit affirmed Angela Chew’s convictions for conspiracy to bribe a public official, bribery of a public official, and wire fraud. The court held that the district court did not abuse its discretion in denying Chew’s third motion for a continuance because she failed to demonstrate specific, substantial prejudice resulting from the denial; the record showed her counsel had ample time to prepare over ten months, and the excluded exhibits would not have indicated a different outcome given the overwhelming evidence of guilt. Regarding the motion for judgment of acquittal, the court applied de novo review and found sufficient evidence existed under 18 U.S.C. § 201(a)(1) to support the jury’s finding that Chew was a “public official,” as the statute broadly defines any federal agency employee acting in an official function as such, regardless of whether the position is high-level or involves managerial discretion. Finally, the court declined to review Chew’s challenge to the jury instructions regarding the definition of a public official under 18 U.S.C. § 201(b)(2) because the doctrine of invited error precluded appellate review, as Chew and the government had jointly proposed the instruction that was given. The practical consequence is that Chew’s convictions stand and her 96-month prison sentence remains in effect.

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Court: United States Court of Appeals for the Fourth Circuit

Filed: 2026-07-27

The Fourth Circuit affirmed the district court’s judgment denying immigration benefits to the parents of naturalized citizens who previously held Special Immigrant Juvenile (SIJ) status. The court held that the plain text of 8 U.S.C. § 1101(a)(27)(J)(iii)(II) creates a permanent bar preventing any natural or adoptive parent of an individual granted SIJ status from receiving immigration benefits based on that parentage, regardless of whether the parent abused, neglected, or abandoned the child. The court found that USCIS’s implementing regulation, 8 C.F.R. § 204.11(i), faithfully carries out this statutory prohibition and is consistent with the statute’s language and purpose to protect children from their parents. Furthermore, the court ruled that the exclusion clause survives equal protection review under the Fifth Amendment’s Due Process Clause because the classification is rationally related to the legitimate government interest of preventing harm to abused or neglected children by excluding potentially abusive parents from obtaining immigration benefits through their children. Consequently, the plaintiffs’ claims challenging USCIS’s interpretation and the constitutionality of the statute were rejected, and the lower court’s decision in favor of the government was upheld.

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