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Jan 30 2026
4th Cir. 24-7186 Panel Decision

UNITED STATES OF AMERICA v. GARY LEE HODGES

The Fourth Circuit affirmed Gary Lee Hodges's sentence for attempted enticement of a minor, rejecting his argument that sentencing enhancements do not apply when the victim is a fictitious person created by law enforcement. The court held that the term 'minor' in the Sentencing Guidelines is ambiguous and that the Guidelines' commentary defining 'minor' to include fictitious persons is entitled to deference.

Constitutional Habeas Corpus - Federal Prisoner (28 USC 2255) Plain Error Review Sentencing Guidelines
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Jan 29 2026
United States Court… 25-3090 Panel Decision

United States of America v. Joseph Smith

The D.C. Circuit affirmed the district court's denial of a prisoner's motion for free case files, ruling that the argument was waived because it was not raised in the lower court. The court clarified that while there is no constitutional right to free transcripts for preparing § 2255 motions, statutory avenues remain available for indigent prisoners.

Constitutional Habeas Corpus - Federal Prisoner (28 USC 2255)
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Jan 29 2026
4th Cir. 25-1032 2-1

SOUTH CAROLINA STATE CONFERENCE OF THE NAACP; DISABILITY RIGHTS SOUTH CAROLINA; JUSTICE 360 Plaintiffs – v. SOUTH CAROLINA DEPARTMENT OF JUVENILE JUSTICE; EDEN HENDRICK

The Fourth Circuit affirmed the dismissal of an institutional reform lawsuit against South Carolina's Department of Juvenile Justice because the plaintiff advocacy groups lacked Article III standing. The court held that organizations cannot substitute for detained juveniles to drive litigation regarding conditions of confinement.

Civil Civil Rights - Section 1983 Standing
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Jan 29 2026
1st Cir. 25-1219 Panel Decision

ANN MARIE MACCARONE v. SIEMENS INDUSTRY, INC

The First Circuit affirmed the dismissal of a wage-and-hour lawsuit after the plaintiff refused to sign a written settlement agreement that had been orally agreed upon and recited in court. The court held that the plaintiff's subsequent refusal to comply with the court's enforcement order justified dismissal with prejudice under Federal Rule of Civil Procedure 41(b).

Civil Labor
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Jan 28 2026
4th Cir. 24-6996 Per Curiam

UNITED STATES OF AMERICA v. MARCUS ROOSEVELT TAYLOR

The Fourth Circuit affirmed the denial of Marcus Taylor's federal post-conviction relief motion, ruling that his challenges to the sufficiency of evidence were procedurally barred. The court further held that Taylor failed to demonstrate ineffective assistance of counsel or the need for an evidentiary hearing regarding his trial strategy claims.

Constitutional Habeas Corpus - Federal Prisoner (28 USC 2255) Sixth Amendment - Ineffective Assistance of Counsel Summary Judgment
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Jan 28 2026
4th Cir. 23-7016 Panel Decision

TONY DAUGHERTY v. DENNIS DINGUS, Warden

The Fourth Circuit affirmed the denial of habeas relief, holding that a juror's comments about knowing the defendant's family and fearing for their safety were internal to the deliberation process. The court ruled that the West Virginia Supreme Court did not unreasonably apply federal precedent in finding this conduct did not constitute impermissible external influence.

Constitutional Habeas Corpus - State Prisoner (28 USC 2254)
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