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The Eleventh Circuit affirmed the denial of a motion to compel arbitration, ruling that Zeus Networks failed to provide sufficient inquiry notice for its terms of service. The court held that a small, gray hyperlink buried beneath prominent red action buttons was not conspicuous enough to bind a user to a mandatory arbitration agreement under Florida law.
The Fourth Circuit affirmed the district court's dismissal of John Rodgers Burnley's civil rights complaint as duplicative. The court found no reversible error in the lower court's procedural ruling and dispensed with oral argument.
The Fourth Circuit remanded a habeas case to determine if a late notice of appeal should be excused because the petitioner claimed he never received notice of the district court's judgment. The court treated the petitioner's letter as a motion to reopen the appeal period under Federal Rule of Appellate Procedure 4(a)(6).
The Eleventh Circuit affirmed the denial of Denzil Stewart's motion for a new trial based on newly discovered evidence. The court held that the evidence merely constituted cumulative impeachment of a cooperating witness and was insufficient to likely change the trial's outcome given the overwhelming proof of guilt.
The Fourth Circuit denied Debra Nelson's petition for a writ of prohibition, ruling that such relief is an extraordinary remedy unavailable when adequate appellate review exists. The court held that the writ cannot substitute for a direct appeal in her underlying employment discrimination case.
The D.C. Circuit affirmed the dismissal of a citizen suit under the Toxic Substances Control Act because the plaintiff organizations failed to establish associational standing. The court held that the organizations could not represent their employees or supporters as members under Article III requirements.
The Tenth Circuit reversed a district court's dismissal of a prisoner's Eighth Amendment claim, holding that the lower court erred by relying on a Martinez Report to resolve factual disputes during the screening stage. The appellate court clarified that while such reports may help identify frivolous claims, they cannot be used to dismiss a complaint for failure to state a claim when the report conflicts with the plaintiff's pleadings.
The Fourth Circuit affirmed the dismissal of Richard Vandale Clowney's Section 1983 complaint because his appellate objections to the magistrate judge's recommendation lacked the required specificity. Although Clowney filed objections on time, they were too generalized to alert the district court to the true legal grounds for his appeal, resulting in a waiver of substantive review.
The Ninth Circuit reversed summary judgment for Dr. Dale Woolridge, holding that conducting a forensic medical exam on a child without parental consent or a court order violates clearly established constitutional rights absent exigent circumstances. The court also reversed summary judgment for investigator Gerardo Talamantes on judicial deception claims, finding a genuine dispute of material fact regarding the materiality of his statements to the juvenile court.
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.
