Correspondent
Capitol Hill correspondent, covers legislative and political stories.
The Fifth Circuit affirmed the denial of Jorge Galvan-Martinez's motion to suppress evidence, ruling that a Border Patrol agent had reasonable suspicion to stop his vehicle. The court held that the totality of circumstances, including proximity to the border and recent illegal activity, supported the stop under established legal standards.
The Eleventh Circuit affirmed the dismissal of an inmate's Eighth Amendment claim because he failed to exhaust administrative remedies under the Prison Litigation Reform Act. The court held that the prison's grievance process remained available to the plaintiff despite his inability to use writing utensils and a limit on pending grievances.
The Sixth Circuit affirmed Michael Williams's within-Guidelines sentence for violating his supervised release, rejecting his claim that the district court impermissibly relied on retributive factors. The court held that the district court properly considered the breach of trust and the need for deterrence when imposing consecutive sentences for the new offense and the revocation.
The Tenth Circuit affirmed the dismissal of Derrick Dewayne Parker's civil rights lawsuit, ruling that his claims challenging his criminal conviction were barred because the conviction remained valid. The court further held that judges and prosecutors were protected by absolute immunity, and other allegations failed to state a plausible constitutional violation.
The Fifth Circuit affirmed Toshemie Wilson's conviction for sexually exploiting children, rejecting arguments that a lay witness improperly offered expert testimony and that the evidence was insufficient. The court held that Agent Blythe's testimony regarding device origins and data extraction fell within permissible lay knowledge under Federal Rule of Evidence 701.
The Eleventh Circuit affirmed the revocation of Joshua Williams's supervised release, ruling that the district court properly admitted hearsay evidence and that the record contained sufficient proof of the alleged violations. The court held that the defense's failure to object to the evidence waived the right to challenge the admission under the *Frazier* balancing test.
The United States Court of Appeals for the Eleventh Circuit dismissed an appeal filed by a criminal defendant proceeding pro se. The court ruled that it lacked jurisdiction because the district court's order denying a motion to dismiss was not a final judgment.
The Sixth Circuit reversed the denial of qualified immunity for officers who used force to handcuff a large suspect actively resisting arrest for violent felonies. The court held that no clearly established law prohibited the officers' actions because the suspect's physical defiance created a unique factual context not covered by prior precedent.
The Sixth Circuit vacated the district court's denial of early termination of supervised release, ruling that a rigid fifty-percent completion custom violates statutory requirements. The court held that judges must conduct an individualized assessment of statutory factors rather than relying on a blanket time-served rule.
The Sixth Circuit vacated the district court's denial of early termination of supervised release, ruling that a rigid fifty-percent completion rule constitutes an abuse of discretion. The court held that 18 U.S.C. § 3583(e)(1) requires an individualized assessment of statutory factors rather than a mechanical time threshold.
