Apr 15 2026
10th Cir. 5:25-CV-03008-JWL Panel Decision

GRATTON CURTIS ODELL v. FORD COUNTY SHERIFF'S DEPARTMENT; BRYAN STAMMER; MATTHEW BOLMER; STEPHEN M LIGON

The Tenth Circuit reversed a district court's dismissal of a prisoner's excessive force claim, holding that video evidence did not blatantly contradict the plaintiff's allegation of twenty-three taser strikes. The court further ruled that the district court abused its discretion by dismissing the case under Heck v. Humphrey without providing the plaintiff notice to address the bar under his own version of events.

Apr 14 2026
11th Cir. 1:23-cv-03073-SDG Per Curiam

ANDY DESTY v. GEORGIA DEPARTMENT OF HUMAN SERVICES/CHILD SUPPORT SERVICES

The Eleventh Circuit affirmed the dismissal of a pro se plaintiff's claims against the Georgia Department of Human Services, holding that the agency is protected by Eleventh Amendment sovereign immunity. The court concluded that DHS functions as an arm of the state when enforcing child support laws and that neither the FDCPA nor Section 1983 abrogated this immunity.

Apr 14 2026
5th Cir. 25-30688 Per Curiam

Whitman v. Lambright

The Fifth Circuit affirmed the denial of a preliminary injunction, holding that the Rooker-Feldman doctrine stripped the federal court of jurisdiction. The court ruled that the plaintiff's claims were an impermissible attempt to overturn a state child-support judgment rather than a challenge to ongoing constitutional violations.

Apr 14 2026
5th Cir. 25-10539 Per Curiam

Keeter v. Sadlar

The Fifth Circuit affirmed summary judgment for a prison official in a civil rights case, ruling that the inmate failed to prove deliberate indifference regarding his housing assignment. The court applied plain error review due to the appellant's failure to object to the magistrate judge's report and found no clear error in the district court's dismissal of the claim.

Apr 14 2026
4th Cir. 24-2026 Panel Decision

Rice v. Adams

The Fourth Circuit reversed the denial of qualified immunity for detention officers, holding that the plaintiff failed to plead facts connecting specific officers to the inmate's death. The court ruled that collective allegations against a group of officers are insufficient to establish individual liability under the Fourteenth Amendment.

Apr 14 2026
7th Cir. 25-1919 Panel Decision

Jane Doe 1 v. Steven V. Sloan

The Seventh Circuit affirmed the dismissal of a § 1983 claim alleging that police officers violated the substantive due process rights of child pornography victims by sharing their images with an untrained auxiliary officer. The court held that no fundamental liberty interest exists under the Fourteenth Amendment to prevent the government from sharing such materials with individuals assisting in an investigation, even if those individuals lack proper authority.

Apr 14 2026
7th Cir. 25-1918 Panel Decision

Jane Doe 1 v. Steven V. Sloan

The Seventh Circuit affirmed the dismissal of plaintiffs' substantive due process claims against police officers who shared child pornography images with an untrained auxiliary officer. The court held that while the officers' conduct was improper, no fundamental constitutional right was violated because the delegation of access was not historically prohibited.

Apr 14 2026
7th Cir. 25-1917 Panel Decision

Jane Doe 1 v. Sloan

The Seventh Circuit affirmed the dismissal of plaintiffs' federal civil rights claims, holding that law enforcement's sharing of child pornography images with an auxiliary officer for identification purposes did not violate a clearly established substantive due process right. The court ruled that while the officer's subsequent misconduct was egregious, the officers' actions were not objectively unreasonable under existing precedent.

Apr 14 2026
11th Cir. 1:22-cv-03620-TCB Per Curiam

Larry Clark, Sr. v. LC Halsten LLC d.b.a. The Halsten At Vinings Mountain

The Eleventh Circuit affirmed the dismissal of Larry Clark, Sr.'s federal civil rights claims arising from a long-running rent dispute and eviction proceedings. The court held that the private defendants were not state actors and that the judges were protected by absolute judicial immunity, leaving Clark without a viable federal cause of action.