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The Eleventh Circuit dismissed Virgil R. Smith's appeal sua sponte because he filed his notice of appeal more than 30 days after the district court's final judgment. The court held that the statutory deadline for filing an appeal is a jurisdictional limit that cannot be waived, even for pro se litigants.
The Third Circuit affirmed the dismissal of a prisoner's Eighth Amendment and ADA claims regarding his removal from a drug treatment program, ruling that prison officials' good-faith judgments lack the requisite culpable state of mind for constitutional liability. However, the court vacated the dismissal of his state-law negligence claim because the lower court relied on precedent that the Supreme Court has since abrogated.
The Fourth Circuit affirmed the dismissal of a pro se prisoner's complaint, holding that district courts must construe pleadings liberally but are not required to act as legal advocates. The court determined the plaintiff's essential grievance was an Eighth Amendment claim for deliberate indifference, not an Americans with Disabilities Act claim.
The Fifth Circuit dismissed an appeal as frivolous because the appellant failed to demonstrate that the district court erred in certifying the case lacked arguable merit. The court found the challenge to the bankruptcy injunction objectively baseless and denied the motion to proceed in forma pauperis as moot.
The Fifth Circuit affirmed the district court's dismissal of Donna Mortel's housing dispute, ruling that her attempt to serve defendants via email failed to comply with Federal Rule of Civil Procedure 4. The court further held that the district court acted within its discretion to dismiss the case for Mortel's failure to attend a court-ordered status conference.
The Eleventh Circuit dismissed an appeal challenging a magistrate judge's order finding the defendant incompetent to stand trial. The court ruled that the order was not final because the defendant had filed a pending motion to vacate it in the district court.
The Sixth Circuit vacated a district court's dismissal of a § 1983 complaint alleging due process violations in a child custody removal, ruling that the domestic-relations exception does not automatically bar federal constitutional claims. The appellate court remanded the case for further proceedings, determining that the lower court prematurely dismissed the complaint without allowing the plaintiff to prove her federal claims.
The Tenth Circuit reversed the district court's grant of qualified immunity to Officer Betty Shelby, holding that the right to be free from deadly force against an unarmed, nonthreatening suspect was clearly established. The court affirmed the dismissal of Monell claims against the City of Tulsa but remanded for consideration of supplemental jurisdiction over the remaining state-law wrongful death claim.
The Tenth Circuit dismissed a federal criminal appeal because the notice was filed nearly four months after the judgment, violating the strict 14-day deadline. The court held that neither the prison mailbox rule nor a potential district court extension could cure the delay.
The Tenth Circuit denied Kimberly Chancellor's request for a certificate of appealability because he failed to show that reasonable jurists would find the district court's procedural ruling debatable. The court held that his Rule 60(b)(6) motion was substantively an unauthorized second or successive § 2255 claim, which the district court correctly dismissed for lack of jurisdiction.
