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The Seventh Circuit affirmed the dismissal of plaintiffs' substantive due process claims against police officers who shared child pornography images with an untrained auxiliary officer. The court held that while the officers' conduct was improper, no fundamental constitutional right was violated because the delegation of access was not historically prohibited.
The Fourth Circuit affirmed the district court's denial of Eric Lee Smith's motion for a new trial, finding no abuse of discretion in the lower court's ruling. The court held that Smith failed to meet the stringent five-part standard required to prove newly discovered evidence would likely result in acquittal.
The Seventh Circuit affirmed the dismissal of plaintiffs' federal civil rights claims, holding that law enforcement's sharing of child pornography images with an auxiliary officer for identification purposes did not violate a clearly established substantive due process right. The court ruled that while the officer's subsequent misconduct was egregious, the officers' actions were not objectively unreasonable under existing precedent.
The Fourth Circuit affirmed Trent Russell's conviction for wrongfully obtaining health information and destroying records, rejecting claims that his interview was coerced and that the evidence was insufficient. The court held that the screenshot of Justice Ginsburg's medical visits constituted protected health information and that the district court properly limited cross-examination without violating the Confrontation Clause.
The Eleventh Circuit affirmed the dismissal of Larry Clark, Sr.'s federal civil rights claims arising from a long-running rent dispute and eviction proceedings. The court held that the private defendants were not state actors and that the judges were protected by absolute judicial immunity, leaving Clark without a viable federal cause of action.
The Fourth Circuit affirmed Derickson Lawrence's eleven convictions for wire and mail fraud, ruling that the evidence sufficiently proved his intent to defraud cardholders and the government. The court further held that the district court properly joined the fraud schemes and correctly applied a sentencing enhancement for sophisticated means.
The Eleventh Circuit affirmed Roger Lee Caldwell Jr.'s convictions for child pornography offenses, ruling that any error in admitting hearsay testimony from a detective was harmless. The court held that overwhelming independent evidence, including victim testimony and physical DNA, rendered the disputed statements non-prejudicial to the verdict.
The Seventh Circuit affirmed the denial of Bato Petrov's petition for cancellation of removal, holding that he failed to prove the statutory requirement of exceptional and extremely unusual hardship to his U.S. citizen relatives. The court further ruled that the Board of Immigration Appeals acted within its discretion in rejecting Petrov's motion to reopen the case as untimely and insufficiently probative.
The Eleventh Circuit granted appointed counsel's motion to withdraw from representing Daniel Vega Cabrera after an independent review found no arguable issues of merit in the appeal. Consequently, the court affirmed Cabrera's convictions and sentences without holding oral argument.
The Seventh Circuit affirmed the denial of Bato Petrov's petition for cancellation of removal, holding that his evidence failed to meet the statutory standard of exceptional and extremely unusual hardship to his U.S. citizen relatives. The court further ruled that the Board of Immigration Appeals acted within its discretion in denying Petrov's motion to reopen based on newly submitted medical and economic evidence.
