Court: United States Court of Appeals for the First Circuit

Filed: 2026-06-17

The first-circuit issued an errata sheet amending its opinion in *United States v. Pilson* to correct two clerical errors: changing the word “elocution” to “allocution” on page 10, line 7, and changing “free-reign” to “free-rein” on page 23, line 21. The court’s stated basis for this action is to ensure the accuracy of the official record by fixing typographical mistakes in the text of the opinion issued on June 1, 2026. No substantive legal holding or change to the disposition was made; the practical consequence is that the corrected opinion now stands as the authoritative version of the court’s decision.

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 First Circuit

Filed: 2026-06-17

The First Circuit issued an errata sheet to amend its opinion issued on June 11, 2026, in the case of Crawford v. Salve Regina University. The court directed specific textual corrections: deleting the word “claims” on page 13, line 12; replacing the first instance of “of” with “or” on page 19, line 8; and inserting “, a plaintiff” after “statute” on page 24, line 7. These administrative actions clarify the record without altering the court’s substantive holding or disposition regarding the underlying dispute.

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: 2026-06-17

Docket: 4:24-CR-00127-JFH-1)

The Tenth Circuit affirmed the district court’s denial of Gregory Miller’s motion to withdraw his guilty plea and upheld his 360-month sentence for production of child pornography in violation of 18 U.S.C. § 2251(a) and (e). Regarding the motion to withdraw the plea, the court applied the “fair and just reason” standard under Federal Rule of Criminal Procedure 11(d)(2)(B), utilizing the seven factors established in *United States v. Gordon*. The appellate court held that the district court correctly determined Miller failed to establish a fair and just reason because three specific factors weighed against him: his assertion of innocence was not credible, he received ineffective assistance of counsel (a claim the court declined to address on direct appeal due to an underdeveloped record), and his plea was entered knowingly and voluntarily. The court clarified that while *United States v. Carr* suggests a mere subjective assertion of innocence suffices, controlling precedent in *United States v. Hickok* requires the assertion to be credible; Miller’s claim lacked credibility given his prior admission of guilt during the Rule 11 colloquy. Regarding the sentence, the court applied an abuse-of-discretion standard to review both procedural and substantive reasonableness under 18 U.S.C. § 3553(a). The court found the district court did not err procedurally because it adequately explained the sentence by considering the Guidelines range (which recommended 30 years to life, capped at the statutory maximum of 30 years) and the § 3553(a) factors. Substantively, the court affirmed that the 30-year sentence was reasonable, noting that a within-Guidelines sentence carries a rebuttable presumption of reasonableness which Miller failed to overcome by relying on bare national statistics rather than specific comparators regarding his individual history and characteristics. As a practical consequence, the judgment of the district court is final; Miller’s conviction and 30-year prison term stand, and he will proceed with serving his 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 Tenth Circuit

Filed: 2026-06-17

Docket: 5:25-CV-00518-JD)

The Tenth Circuit denied Michael Amir Hall’s request for a certificate of appealability (COA) and dismissed his appeal from the district court’s order dismissing his federal habeas corpus petition as time-barred. While the court granted Hall’s motion to proceed in forma pauperis, it concluded that he failed to make a substantial showing of the denial of a constitutional right required under 28 U.S.C. § 2253(c)(2). The court applied the standard from *Slack v. McDaniel*, which requires a habeas petitioner to demonstrate that “jurists of reason would find it debatable” both whether the petition states a valid claim and whether the district court was correct in its procedural ruling. The district court had dismissed Hall’s petition based on two procedural grounds: the “firm-waiver rule,” because his objections to the magistrate judge’s report were conclusory and unspecific, and the statute of limitations, finding his petition untimely and equitable tolling inapplicable. Regarding the firm-waiver rule, the court held that Hall failed to show plain error or satisfy the “interests of justice” exception because his arguments regarding the timeliness of his habeas filing did not address the specific defects in his objections to the magistrate’s report. Furthermore, even if the exception applied, his objections remained too vague to focus the district court on disputed issues. Regarding equitable tolling, the court found Hall failed to meet the two-prong test established in *McQuiggin v. Perkins*: he did not diligently pursue his rights given the 202 days available to him before a prison lockdown began, and a prison lockdown alone does not constitute an “extraordinary circumstance” sufficient to toll the statute of limitations absent additional proof that it prevented timely filing. Consequently, no reasonable jurist could debate the correctness of the district court’s procedural rulings. The practical consequence is that Hall’s appeal is terminated, his habeas petition remains dismissed with prejudice, and he receives no relief on his constitutional claims regarding probable cause hearings.

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: 2026-06-17

Docket: 1:23-cv-00368-CLM

The Eleventh Circuit vacated the district court’s order dismissing the plaintiff’s complaint and remanded the case for further proceedings. The court held that the student-plaintiff, C.W., plausibly alleged claims under Title IX of the Education Amendments of 1972 against the school district and under the Equal Protection Clause (via 42 U.S.C. § 1983) against the football coach, Steve Smith. Regarding the Title IX claim, the court applied the four-part test for student-on-student sexual harassment established in *Davis v. Monroe County Board of Education*: (1) the recipient receives federal funds; (2) an appropriate person has actual knowledge; (3) the recipient is deliberately indifferent to known acts of harassment; and (4) the harassment is severe, pervasive, and objectively offensive enough to deny equal access to education. The court rejected the district court’s conclusion that the harassment was not sex-based, ruling that Title IX prohibits discrimination based on failure to conform to sex stereotypes and inherently sexual same-sex harassment. The court found that allegations of “keying” (forced anal penetration with a key), nipple twisting, butt slapping, and verbal taunts designed to emasculate the plaintiff constituted actionable sexual harassment under both theories. Furthermore, the court determined that the school district’s perfunctory response—imposing only “observation” on the perpetrators after being notified of an attempted sexual assault—satisfied the deliberate indifference standard. Regarding the Equal Protection claim against Coach Smith, the court applied the deliberate indifference standard for individual liability under § 1983. The court found that C.W. plausibly alleged that Smith knew of the harassment and acquiesced in it by failing to take meaningful action to stop the “keying” practice and by communicating to the team that the plaintiff was “soft,” thereby encouraging further harassment. The court also held that Smith was not entitled to qualified immunity because clearly established law, specifically *Hill v. Cundiff*, put a reasonable official on notice that doing nothing in response to a reported sexual assault constitutes an Equal Protection violation. The practical consequence is that the case proceeds to trial or further litigation, allowing the plaintiff to pursue damages for sex discrimination and constitutional violations, overturning the lower court’s dismissal based on the insufficiency of the complaint regarding same-sex harassment and deliberate indifference.

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: 2026-06-17

Docket: 1:24-mi-00083-LMM

The Eleventh Circuit affirmed the district court’s order dismissing Tamika Seay’s pro se complaint under 42 U.S.C. § 1983 as frivolous and denying her motion to proceed in forma pauperis. The court held that the district court did not abuse its discretion in concluding that Seay failed to allege sufficient facts to state a plausible claim for relief, particularly given the prior filing restriction imposed on her. The court applied an abuse of discretion standard to review the dismissal under 28 U.S.C. § 1915(e)(2)(B)(i) and the denial of leave to amend. While pro se pleadings are liberally construed, the court reiterated that courts cannot rewrite deficient pleadings or serve as de facto counsel. The opinion clarified that a complaint is frivolous if it lacks arguable merit in law or fact, including when it seeks monetary relief against an immune defendant or fails to state a claim. Specifically regarding the underlying allegations involving child custody proceedings and prosecutorial immunity, the court noted that prosecutors are absolutely immune for activities intimately associated with the judicial phase of the criminal process and that the domestic-relations exception limits federal jurisdiction over certain custody matters. Furthermore, the court found that granting leave to amend would have been futile because the complaint remained legally insufficient and conflicted with the existing filing injunction designed to prevent vexatious litigation. As a result of this decision, Seay’s appeal is dismissed, the district court’s order remains in effect, and she is barred from proceeding with her § 1983 claims or filing further complaints without prior court approval under the terms of the pre-filing injunction.

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: 2026-06-17

Docket: 2:24-cv-00154-MHT-CWB

The eleventh-circuit affirmed the district court’s dismissal with prejudice of Diane Bates’s amended complaint and its denial of her motion for reconsideration. The court applied an abuse of discretion standard to review the dismissal, holding that the complaint constituted an impermissible “shotgun pleading” under Federal Rule of Civil Procedure 8(a)(2). The opinion found that the 35-count filing was replete with conclusory, vague, and immaterial facts buried beneath rambling irrelevancies, failing to provide defendants with adequate notice of the claims against them or to distinguish which defendants were responsible for specific acts. Because Bates elected to stand on her deficient pleading after being ordered by a magistrate judge to file a second amended complaint to cure these defects, the district court acted within its discretion to dismiss the case with prejudice. Consequently, the dismissal stands and no further amendment is permitted.

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: 2026-06-17

Docket: 2:25-cv-00396-MHT-KFP

The eleventh-circuit affirmed the district court’s dismissal of Rosie Lee Murphy’s civil rights suit for lack of subject matter jurisdiction but vacated and remanded the case with instructions to clarify that the dismissal is without prejudice. The court held that the district court correctly determined it lacked diversity jurisdiction under 28 U.S.C. § 1332 because Murphy failed to establish citizenship requirements, and lacked federal question jurisdiction under 28 U.S.C. § 1331 because her claims were wholly insubstantial and frivolous. Applying the standard that a claim is frivolous if it lacks an arguable basis in law or fact, the court found Murphy’s allegations—ranging from psychological damage to “casting spells”—were fantastical, had no relationship to constitutional provisions, and failed to allege that private defendants were state actors subject to suit under 42 U.S.C. § 1983. While affirming the dismissal on these jurisdictional grounds, the court ruled that dismissals for lack of jurisdiction are not judgments on the merits and must be entered without prejudice pursuant to Federal Rule of Civil Procedure 41(b). Consequently, the case is remanded solely to allow the district court to amend its order to reflect a dismissal without prejudice, while Murphy’s pending motions are denied.

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