Court: United States Court of Appeals for the Seventh Circuit

Filed: 2026-07-23

The seventh-circuit affirmed the district court’s grant of summary judgment for defendants Dr. Daniel Rippetoe and Deputy Warden Tricia Pretorius in a civil rights action brought by incarcerated plaintiff Brad Passwater under 42 U.S.C. § 1983 alleging violations of his Eighth Amendment right to be free from cruel and unusual punishment due to deliberate indifference to his serious medical needs. Regarding Dr. Rippetoe, the court applied the standard that prison medical professionals are liable only if their conduct demonstrates an absence of professional judgment such that “no minimally competent professional would have so responded,” a threshold higher than mere negligence or failure to follow best practices. The court held that while Dr. Rippetoe failed to conduct a post-medication assessment as required by policy, the record lacked evidence that he actually read the medical report indicating Passwater’s adverse reaction, nor was there proof that any minimally competent physician would have necessarily intervened upon reading it under those specific circumstances. Consequently, the court found no evidentiary basis for a reasonable jury to conclude Dr. Rippetoe acted with deliberate indifference. Regarding Deputy Warden Pretorius, the court applied the rule that an official may be liable for systemic policy violations if they are aware of a lapse in enforcement and fail to act. While the court acknowledged evidence suggesting Pretorius knew suicide companions were not adhering to a two-hour shift policy and failed to correct it, the claim failed on the element of causation. The court determined that Passwater’s severe self-inflicted injuries were caused by the intervening, superseding act of the specific suicide companion assigned to him who refused to stand and observe through the cell window as instructed. This intervening act severed the causal link between Pretorius’s alleged policy failures and the specific harm suffered by Passwater. The practical consequence is that the judgment in favor of the defendants stands, and Passwater receives no relief; the case is closed with no further proceedings on these claims.

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: 2026-07-23

Docket: 4:24-cv-05130-RLP

The ninth-circuit reversed the district court’s grant of summary judgment in favor of correctional officers and remanded the case for further proceedings. The court held that while the plaintiff, a prisoner, had sufficiently established that his sincerely held religious beliefs required access to an Arabic-language Quran, the district court erred by failing to apply the multi-factor balancing test from *Turner v. Safley* to determine if the prison’s actions were reasonably related to legitimate penological interests. Under this standard, the lower court was required to evaluate factors such as whether there is a valid rational connection between the regulation and the government interest, the existence of alternative means for exercising the right, the impact on guards and other inmates, and whether ready alternatives exist. Additionally, because the district court did not make the necessary factual findings regarding the legitimacy of the prison’s justification under *Turner*, the court reversed the qualified immunity determination. The practical consequence is that the case will return to the district court to conduct the required analysis of the First Amendment free exercise claim and the associated qualified immunity defense before a final judgment can be entered.

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: 2026-07-23

The Sixth Circuit affirmed the district court’s grant of summary judgment in favor of defendant NYX, LLC, dismissing Darin Newson’s claims of racial discrimination and retaliation under Title VII, 42 U.S.C. § 1981, and Michigan’s Elliot Larsen Civil Rights Act (ELCRA). The court applied the *McDonnell Douglas* burden-shifting framework to review the plaintiff’s circumstantial evidence claims de novo. Regarding the retaliation claim, the court held that Newson failed to establish the requisite causal connection between his protected activity (filing administrative complaints) and the alleged adverse employment action. The record indicated that the alleged denial of overtime began in February 2019, prior to Newson’s complaints filed in June 2019 and April 2022, and Newson provided no evidence that the alleged denial escalated or worsened following his protected activity. Additionally, the court deemed any potential error by the district court in excluding Newson’s EEOC right-to-sue letter harmless because the plaintiff failed to establish a prima facie case regardless of the document’s admissibility. Regarding the discrimination claim, the court ruled that Newson failed to identify a similarly situated comparator who received more favorable treatment. The court found that potential comparators Abdul and Ahmed were not similarly situated in all relevant respects due to differences in shift assignments, job responsibilities, supervisory status, and disciplinary records. Furthermore, Newson’s testimony regarding differential treatment was deemed mere speculation and conjecture without specific factual evidence to support the allegation that his coworkers received more overtime opportunities. As a practical consequence, the judgment for NYX stands, and Newson’s lawsuit is dismissed with no relief granted.

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: 2026-07-23

Docket: 8:24-cv-00227-SVW

The ninth-circuit dismissed the appeal filed by defendants Klein, Kimura London and White LLP, and Becker regarding the district court’s order remanding claims to state court for lack of appellate jurisdiction under 28 U.S.C. § 1447(d), which prohibits review of orders remanding cases to state courts based on procedural defects or lack of subject-matter jurisdiction. The court affirmed the district court’s judgment that the bankruptcy court possessed subject-matter jurisdiction over “core” bankruptcy claims and ancillary jurisdiction over related claims pursuant to a stipulation retaining jurisdiction, and further affirmed the imposition of Federal Rule of Civil Procedure 11 sanctions against the appellants for filing a frivolous motion for rehearing. The practical consequence is that the case is remanded to the district court with instructions to carry out the order directing the bankruptcy court to remand the specific claims to state court, while the jurisdictional and sanctions rulings stand.

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: 2026-07-23

The Fifth Circuit vacated the district court’s order denying Defendant Talanzo Debrow’s motion to dismiss his indictment for possession of a firearm by a convicted felon and remanded the case for further proceedings. The court held that the government failed to meet its burden under *New York State Rifle & Pistol Ass’n v. Bruen* to demonstrate a historical tradition supporting the permanent disarmament of individuals with Debrow’s specific predicate conviction for aggravated criminal damage to property. The court applied the Second Amendment “historical inquiry” standard, requiring the government to identify Founding-era laws that are “relevantly similar” to 18 U.S.C. § 922(g)(1) regarding both the burden imposed on the right of armed self-defense and the justification for that burden. The court rejected the government’s primary argument that Debrow’s underlying conduct (attempting to ram police cars) rendered him dangerous, noting that Fifth Circuit precedent limits as-applied challenges to the statutory elements of the predicate conviction itself, not uncharged or unproven conduct. Furthermore, the court found the government’s reliance on historical “going-armed” laws insufficient because Debrow’s predicate offense was a property crime involving only foreseeability of harm rather than a specific element of purposeful or knowing use of physical force against another person. The practical consequence is that the district court must reconsider Debrow’s motion to dismiss in the first instance, allowing for proper development of the historical record and argumentation regarding whether his specific conviction falls within the Nation’s historical tradition of firearm regulation.

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: 2026-07-23

The Fourth Circuit affirmed the district court’s judgment denying Donald McDuffin Williams’s motion to withdraw his guilty plea, dismissing his Speedy Trial Act claim, and upholding his sentence despite a procedural error regarding consecutive sentencing. The court applied an abuse of discretion standard to the plea withdrawal claim, requiring Williams to demonstrate a “fair and just reason” under Federal Rule of Criminal Procedure 11(d)(2)(B), specifically that he lacked close assistance of competent counsel due to an actual conflict of interest that adversely affected his lawyer’s performance under *Cuyler v. Sullivan*. The court found no such conflict or adverse effect because Williams failed to identify a plausible alternative defense strategy clearly suggested by the circumstances and did not explain how the withheld evidence would have harmed his co-defendant. Regarding the Speedy Trial Act claim, the court applied the rule that entering a guilty plea constitutes a waiver of speedy trial rights. On the issue of consecutive sentencing, the court reviewed for plain error after noting the government’s concession that the district court lacked authority to order a sentence run consecutively to an anticipated federal revocation sentence; however, the court held that this error did not affect Williams’s substantial rights because a Maryland district court subsequently ordered the revocation sentence to run consecutively in accordance with U.S.S.G. § 7B1.3(f), rendering the outcome consistent with sentencing guidelines. As a practical consequence, Williams’s conviction and 104-month imprisonment sentence remain in effect, and no further relief is granted.

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: 2026-07-23

The Fifth Circuit affirmed the district court’s judgment in this civil bankruptcy appeal. The court issued a per curiam opinion citing Federal Rule of Appellate Procedure 47.6 and local rule 5th Cir. R. 47.6, indicating that the decision was made without oral argument and is not designated for publication. No specific legal standards, statutes, or factual reasoning were provided in the text beyond the affirmation itself. As a result, the district court’s ruling stands as final, and the appellant’s claims are rejected.

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: 2026-07-23

The fourth-circuit affirmed the district court’s denial of the Government’s motion to dismiss Badar Khan Suri’s habeas corpus petition, holding that the Eastern District of Virginia possessed proper jurisdiction and that no provisions of the Immigration and Nationality Act (INA) stripped the court of subject matter authority. The court ruled that jurisdiction was established under two exceptions to the default habeas rules: the “unknown custodian” exception, because Suri’s location and immediate custodian were undisclosed due to rapid, secret transfers across state lines that prevented counsel from filing in the district of confinement; and the exception articulated in Justice Kennedy’s concurrence in *Rumsfeld v. Padilla*, which applies when the Government moves a detainee to make it difficult for counsel to file a petition or engages in forum shopping. Furthermore, the court held that 8 U.S.C. §§ 1252(g), 1252(b)(9), and 1252(a)(5) did not bar review because Suri’s claims challenged his detention and conditions of confinement as unconstitutional retaliation for protected speech and due process violations, which are legally distinct from the Government’s decision to commence removal proceedings or any final order of removal. The court also affirmed the district court’s use of the All Writs Act to issue an injunction barring Suri’s removal while the petition was pending, finding this necessary to preserve the court’s jurisdiction and prevent the frustration of its proceedings given the Government’s intent to deport Suri before judicial review could occur.

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: 2026-07-23

Docket: 1:20-cv-23287-DPG

The Eleventh Circuit affirmed the district court’s dismissal of the plaintiffs’ complaint for lack of personal jurisdiction over British corporations WPP, PLC and Imperial Brands, PLC. The court held that while the Helms-Burton Act creates a private cause of action for trafficking in confiscated Cuban property, it does not expressly authorize nationwide service of process under Federal Rule of Civil Procedure 4(k)(1)(C). Consequently, the plaintiffs’ claims against these foreign defendants must be evaluated under Rule 4(k)(2), which requires that exercising jurisdiction be consistent with the Fifth Amendment’s Due Process Clause. Relying on the Supreme Court’s decision in *Fuld v. Palestine Liberation Organization*, 606 U.S. 1 (2025), the Eleventh Circuit determined that the Fifth Amendment does not incorporate the Fourteenth Amendment’s “minimum contacts” standard but instead imposes a flexible “reasonableness” inquiry. Applying this reasonableness test, which weighs the burden on the defendant, the interests of the forum state, and the plaintiff’s interest in obtaining relief, the court concluded that asserting jurisdiction over WPP and Imperial would be unreasonable. The court found that neither defendant received clear statutory notice under the Helms-Burton Act that they could be sued in U.S. courts, neither engaged in conduct with a meaningful connection to the United States, and neither maintained a significant presence in the country sufficient to justify the severe burden of litigating in Florida. Additionally, the court held that the actions of WPP’s U.S.-based subsidiaries could not be imputed to the parent company absent alter-ego status, which was not established. As a result of this decision, the plaintiffs’ claims against WPP and Imperial remain dismissed. The case is closed with respect to these defendants, and no further proceedings regarding personal jurisdiction over them will occur in the federal courts.

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: 2026-07-23

The Ninth Circuit denied Roberto Diaz-Boyzo’s petition for review of a Board of Immigration Appeals order finding him removable under 8 U.S.C. § 1227(a)(2)(E)(i). The court held that Diaz-Boyzo’s 2013 conviction for fourth-degree assault under Oregon Revised Statutes § 163.160(1)(a), (3)(c) constitutes a “crime of child abuse, child neglect, or child abandonment.” Applying the categorical approach, the court determined that while the Oregon statute was overbroad because it covered conduct unrelated to children, it was divisible into discrete offenses based on alternative aggravating elements. Using the modified categorical approach and reviewing the indictment and plea agreement, the court found Diaz-Boyzo was convicted specifically under subsection (3)(c), which applies when an assault is committed in the immediate presence of or witnessed by a minor child. The panel concluded this offense matches the federal definition because committing an assault in the immediate presence of a child places the child in real danger of bodily or mental harm, satisfying the actus reus requirement established in *Leon-Briviesca v. Blanche*. Furthermore, the court found the statute satisfied the mens rea requirement, as Oregon law imputes at least criminal negligence to the circumstance element when no specific mental state is prescribed, which aligns with the minimum culpability required for a crime of child abuse under federal immigration law. As a result of this ruling, the petition for review is denied, and the Board of Immigration Appeals’ decision removing Diaz-Boyzo from the United States stands.

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