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Apr 30 2026
4th Cir. 25-2317 Per Curiam

SAMUEL K. REID, SR v. PENNYMAC LOAN SERVICES, LLC; SAMUEL I. WHITE, P.C

The Fourth Circuit affirmed the district court's dismissal of a pro se borrower's complaint but modified the order to dismiss without prejudice. The court held that dismissals based on the Rooker-Feldman doctrine, which addresses subject matter jurisdiction defects, must be without prejudice because a court lacking jurisdiction cannot adjudicate claims on the merits.

Civil Contract Motion to Dismiss
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Apr 30 2026
4th Cir. 25-2285 Per Curiam

John Michael Scardina v. Elaine Folk Marshall; Jennifer Griffin

The Fourth Circuit affirmed the dismissal of a pro se civil action but modified the ruling to reflect that the dismissal for lack of subject matter jurisdiction must be without prejudice. The court held that a court lacking jurisdiction has no power to adjudicate a claim on the merits, requiring the dismissal to allow for potential refiling if jurisdiction can be established.

Civil Other Civil
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Apr 30 2026
5th Cir. 25-20166 Per Curiam

Glen Sumner v. State Farm Lloyds

The Fifth Circuit affirmed the district court's grant of summary judgment in favor of State Farm Lloyds regarding insurance claims stemming from Hurricane Nicholas damage. The panel found no error in the lower court's determination that the insurer properly fulfilled its obligations and dismissed the plaintiff's procedural challenges.

Civil Insurance Summary Judgment
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Apr 30 2026
11th Cir. 4:21-cr-00008-SDG-WEJ-1 Unpublished

UNITED STATES OF AMERICA v. JEFFERY DEROY LEWIS

The Eleventh Circuit affirmed the denial of Jeffery Lewis's motions to withdraw his guilty plea, ruling that the district court did not plainly err in accepting it. The court held that Lewis was competent to plead guilty and fully understood the consequences, including the potential for a consecutive sentence based on methamphetamine involvement.

Criminal Drug Trafficking
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Apr 30 2026
5th Cir. 25-40619 Per Curiam

Peter Quansah v. MSC Mediterranean Shipping Company SA

The Fifth Circuit affirmed summary judgment for a vessel owner, holding that a longshoreman failed to provide sufficient evidence of a latent defect in a walkway railing. The court ruled that without proof the owner knew of the danger, the vessel did not breach its narrow safety duties under the Longshore and Harbor Workers' Compensation Act.

Admiralty / Maritime Civil Summary Judgment
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