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Mar 6 2026
11th Cir. 6:22-cr-00148-PGB-LHP-6 Per Curiam

UNITED STATES OF AMERICA v. DICKENSON ELAN

The Eleventh Circuit affirmed Dickenson Elan's RICO conspiracy conviction and 135-month sentence, rejecting challenges to evidence admission and sufficiency of proof. The court held that the district court properly applied sentencing enhancements based on the total economic loss of the tax fraud scheme and did not abuse its discretion in imposing the sentence despite Elan's claims of hardship from future removal to Haiti.

Criminal Drug Trafficking Guidelines Departure Plain Error Review
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Mar 6 2026
3rd Cir. 2:22-cv-01791 Panel Decision

THERESA A. GALLAGHER v. CENTRAL VALLEY SCHOOL DISTRICT

The Third Circuit affirmed the District Court's grant of summary judgment to the Central Valley School District, ruling that the plaintiff failed to prove age discrimination under the ADEA and PHRA. The court held that the school district's reasons for hiring a younger candidate were legitimate and that the plaintiff's evidence of pretext amounted to mere speculation.

Civil Civil Rights - Employment Summary Judgment
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Mar 6 2026
9th Cir. 2:22-cv-06206-ODW-ADS Unpublished

JOSE LUIS AYALA v. ROBERTO A. ARIAS, Warden

The Ninth Circuit affirmed the denial of a state prisoner's habeas petition, ruling that his request to represent himself was made too close to trial to be considered timely under federal law. The court held that the California Court of Appeal reasonably applied Supreme Court precedent by finding the request untimely when made on the eve of trial.

Constitutional Habeas Corpus - State Prisoner (28 USC 2254)
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Mar 6 2026
9th Cir. 1:22-cr-00062-JLT-SKO-4 Unpublished

UNITED STATES OF AMERICA v. ALMA GARZA

The Ninth Circuit affirmed Alma Garza's conviction for drug conspiracy and possession, ruling that a less-than-three-day warrantless detention of a mailed package was reasonable under the Fourth Amendment. The court held that investigators acted diligently and that an evidentiary hearing was unnecessary given the lack of specific factual allegations from the defense.

Criminal Sentencing Guidelines
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Mar 6 2026
Fed. Cir. 25-1672 Panel Decision

In re HBN SHOE, LLC

The Federal Circuit affirmed the Patent Trial and Appeal Board's rejection of a patent application for a cleated athletic shoe as obvious under 35 U.S.C. § 103. The court held that the claimed design, which features a concave depression to facilitate foot movement during exercise, was an unpatentable combination of prior-art references.

Civil Intellectual Property
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Mar 6 2026
Fed. Cir. 24-1544 Panel Decision

Wyoming Trust Co. v. United States

The Federal Circuit affirmed the dismissal of a takings claim filed by landowners who were prohibited from mining coal under the Surface Mining Control and Reclamation Act. The court held that the claim was time-barred because it accrued in 2016 when the government determined the coal had a value of zero, well before the lawsuit was filed in 2023.

Constitutional Fifth Amendment - Takings
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