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The Eleventh Circuit vacated an 18-month sentence because the district court failed to provide a specific explanation for imposing a significant upward variance from the Sentencing Guidelines. The court held that when a judge departs from the agreed-upon guidelines range, they must articulate the specific reasons for that departure on the record.
The Eleventh Circuit vacated a district court order that overturned a jury verdict finding an employer liable for retaliation under 42 U.S.C. § 1981. The appellate court held that the district court erred by failing to view the evidence in the light most favorable to the non-moving party when assessing whether the employee's resignation was voluntary.
The Eighth Circuit vacated a district court's dismissal of a prisoner's civil rights action for failure to pay an initial filing fee, ruling that such dismissal constitutes an abuse of discretion when the inmate lacks available funds. The court held that the Prison Litigation Reform Act prohibits barring civil actions solely due to indigence when no assets exist to satisfy the fee requirement.
The Fourth Circuit vacated Sang Thanh Huynh's sentence due to a material discrepancy between the district court's oral pronouncement of supervised release conditions and the written judgment. Even though the Government conceded the error, the Court independently reviewed the record and found that such discrepancies require resentencing under established precedent.
The Third Circuit vacated the District Court's denial of a preliminary injunction because the plaintiffs failed to make a facial showing of subject-matter jurisdiction under the Class Action Fairness Act. The court held that alleging residency is insufficient to establish the diversity of citizenship required for federal jurisdiction in CAFA cases.
The Ninth Circuit affirmed the dismissal of Jun Dam's claims against a bankruptcy trustee and counsel, ruling that Dam lacked prudential standing to assert third-party rights. However, the court vacated the dismissal with prejudice, instructing the district court to dismiss the claims without prejudice due to a lack of subject-matter jurisdiction.
The Eighth Circuit affirmed summary judgment for a Minneapolis police officer who used a less-lethal projectile against a protester during the 2020 riots, ruling the force was objectively reasonable under the Fourth Amendment. The court also upheld the dismissal of the officer's qualified immunity defense and the district court's refusal to exercise supplemental jurisdiction over state law claims.
The Fourth Circuit vacated a district court's denial of a Rule 60(b) motion because the lower court raised the timeliness issue on its own without giving the plaintiff notice. While the court agreed that the one-year deadline applied, it held that timeliness is an affirmative defense that must be raised by the opposing party.
The Eleventh Circuit affirmed the confirmation of a FINRA arbitration award in favor of Wells Fargo, ruling that the arbitrator acted within contractual authority despite the employee's res judicata defense. However, the court vacated the judgment and remanded the case to correct a procedural error where the arbitration award was accidentally omitted from the record.
The Ninth Circuit vacated a district court's summary judgment in a prisoner's civil rights case, ruling that the lower court erred by dismissing the plaintiff's factual declaration as merely self-serving. The appellate court clarified that credibility determinations are functions reserved for a jury, not a judge, at the summary judgment stage.
