Apr 28 2026
4th Cir. 25-6963 Per Curiam

TONY BRYAN SMITH v. COMMONWEALTH OF VIRGINIA

The Fourth Circuit denied a certificate of appealability and dismissed Tony Bryan Smith's habeas appeal because he failed to meet the statutory requirements for challenging a procedural dismissal. The court found that Smith did not demonstrate that the district court's ruling on the successive nature of his petition was debatable or that he substantially showed a denial of a constitutional right.

Apr 28 2026
4th Cir. 25-6683 Per Curiam

UNITED STATES OF AMERICA v. BERNARD CELESTINE

The Fourth Circuit affirmed the denial of Bernard Celestine's motions for sentence reduction and compassionate release while dismissing his appeal regarding a successive habeas claim. The court held that Celestine failed to challenge the procedural dismissal of his § 2255 motion in his informal brief, thereby failing to demonstrate the requisite substantial showing of a constitutional right denial.

Apr 27 2026
5th Cir. 25-40571 Per Curiam

Semien v. Bergman

The Fifth Circuit affirmed the dismissal of Erwin Eugene Semien's civil rights complaint, ruling that he abandoned several claims and failed to adequately allege constitutional violations. The court held that Semien did not state a claim for due process or equal protection because he lacked a protected property interest and failed to identify specific comparators.

Apr 27 2026
1st Cir. 25-1291 Panel Decision

ARTHUR MILES v. WARDEN FREDDIE BOWERS

The First Circuit vacated the dismissal of Arthur Miles' habeas petition, ruling that the Bureau of Prisons cannot deny First Step Act time credits for work performed in a county jail prior to transfer to a federal facility. The court held that the BOP's regulations contradicting the statutory definition of when a sentence commences are invalid and that a risk assessment is not a prerequisite for earning credits.