
DIFTCL: Federal Narrative Summaries
AI-narrated summaries of individual federal appellate decisions, explained in plain English for working lawyers and legal operators.
Episodes
Reading the feed…

AI-narrated summaries of individual federal appellate decisions, explained in plain English for working lawyers and legal operators.
Reading the feed…
Court: United States Court of Appeals for the First Circuit Filed: 2026-08-28 The First Circuit affirmed the district court’s grant of summary judgment to defendants Broan-NuTone LLC and Jakel Motors Incorporated in a diversity action alleging that a defective bathroom exhaust fan caused a residential fire. The court held that Citation Insurance Company, as subrogee, failed to establish a genuine dispute of material fact regarding breach of implied warranty of merchantability under Massachusetts law for both manufacturing and design defect theories. The court applied the standard of review de
Court: United States Court of Appeals for the Tenth Circuit Filed: 2026-08-28 Docket: 6:11-CV-00029-DES) The Tenth Circuit dismissed the appeal for lack of appellate jurisdiction because the district court’s order was not a final, appealable decision. The court held that under 28 U.S.C. § 1291, a post-judgment civil contempt order is not final until the district court makes a specific finding of contempt and imposes a specific, unavoidable sanction. Because the challenged order merely required the appellants to show cause for an alleged violation or agree to abide by an injunction without impo
Court: United States Court of Appeals for the Tenth Circuit Filed: 2026-08-28 The tenth-circuit denied in part and dismissed in part Lillian Jhoan Lazo-Villalta’s pro se petition for review of the Board of Immigration Appeals’ decision affirming an immigration judge’s denial of her applications for asylum, withholding of removal, and protection under the Convention Against Torture (CAT). The court dismissed the petitioner’s challenge to the denial of her asylum application on the basis that it was untimely. While Lazo-Villalta argued she qualified for an exception to the one-year filing deadli
Court: United States Court of Appeals for the First Circuit Filed: 2026-08-28 The First Circuit affirmed the district court’s denial of Matthew McDonald’s 28 U.S.C. § 2255 motion and denied his request for a certificate of appealability (COA). The court held that McDonald’s conviction for using a firearm during a crime of violence remains valid because any error in jury instructions regarding an invalid predicate offense (Hobbs Act robbery conspiracy) was harmless under the *Brecht v. Abrahamson* standard, as the record showed no grave doubt that the jury relied on valid predicates (armed bank
Court: United States Court of Appeals for the Tenth Circuit Filed: 2026-08-28 Docket: 1:18-CV-02329-RM-CYC) The tenth-circuit dismissed the appeal for lack of subject-matter jurisdiction because the district court’s June 18, 2025 order was not a final decision under 28 U.S.C. § 1291. The court held that an award of attorneys’ fees is not final and appealable until it is reduced to a “sum certain.” Since the district court granted a motion for sanctions but did not fix the amount of the additional fee award, leaving further proceedings in the district court to determine that sum, the order did
Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-08-28 Docket: 1:22-cr-20079-FAM-3 The eleventh-circuit affirmed the convictions of Luis Alfonso Nunez, Mario Tovar, and Geraldo Rodriguez for conspiracy to possess with intent to distribute cocaine and possession with intent to distribute five or more kilograms of cocaine aboard a vessel subject to United States jurisdiction, as well as Geraldo Rodriguez’s sentence. The court rejected the defendants’ constitutional challenges to their convictions under the Maritime Drug Law Enforcement Act (MDLEA), holding that binding
Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-08-28 Docket: 1:22-cr-20079-FAM-3 The eleventh-circuit affirmed the convictions of Luis Alfonso Nunez, Mario Tovar, and Geraldo Rodriguez for conspiracy to possess with intent to distribute and possession with intent to distribute five or more kilograms of cocaine aboard a vessel subject to United States jurisdiction under the Maritime Drug Law Enforcement Act (46 U.S.C. §§ 70503(a)(1), 70506(b)). The court rejected the defendants’ constitutional challenges based on the Felonies Clause, holding that Colombia’s exclusive
Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-08-28 Docket: 5:20-cr-00007-JA-PRL-1 The eleventh-circuit affirmed Reginald Smith’s conviction for being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1) and his sentence enhanced under the Armed Career Criminal Act (ACCA), 18 U.S.C. § 924(e). The court rejected Smith’s constitutional challenges, holding that § 922(g)(1) does not violate the Second Amendment or the Commerce Clause because felons are disqualified from exercising Second Amendment rights and the firearm in question traveled in interstate comm
Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-08-28 Docket: 1:22-cr-20079-FAM-3 The eleventh-circuit affirmed the convictions of Luis Alfonso Nunez, Mario Tovar, and Geraldo Rodriguez for conspiracy to possess with intent to distribute cocaine and possession with intent to distribute cocaine aboard a vessel subject to United States jurisdiction under the Maritime Drug Law Enforcement Act (MDLEA). The court rejected the defendants’ constitutional challenges based on the Felonies Clause of Article I, Section 8, holding that binding precedent establishes that exclusiv
Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-08-28 Docket: 0:01-cr-06095-DMM-1 The eleventh-circuit affirmed the district court’s denial of Wilbert McKreith’s motion to reduce his sentence under 18 U.S.C. § 3582(c)(1)(A). The court held that McKreith failed to satisfy the statutory requirement that a defendant not present a danger to the safety of any other person or the community, which is a necessary condition for compassionate release. The court applied a de novo standard to review eligibility and an abuse of discretion standard to review the district court’s f
Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-08-28 Docket: 2:23-cr-00117-RAH-SMD-1 The eleventh-circuit affirmed the defendant’s conviction for conspiring to distribute fentanyl, holding that his claim of ineffective assistance of counsel could not be addressed on direct appeal because the record was insufficiently developed. The court applied the standard established in *United States v. Verbitskaya*, which prohibits reviewing ineffective assistance claims on direct appeal except in rare instances where the record is fully developed to allow for a proper determin
Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-08-28 Docket: 3:23-cr-00096-MCR-1 The eleventh-circuit affirmed the defendant’s 180-month sentence for receiving child pornography, holding that his prior conviction for lewd or lascivious battery under Florida Statutes section 800.04(4)(A) qualified as a predicate offense under 18 U.S.C. section 2252A(b)(1), thereby triggering the fifteen-year mandatory-minimum sentence. Applying the categorical approach, the court reviewed whether the elements of the state conviction matched the generic federal definition of “abusive
Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-08-28 Docket: 0:24-cv-62189-RNS The eleventh-circuit affirmed the district court’s denial of Enode Duvercy’s 28 U.S.C. § 2255 motion, holding that appellate counsel’s failure to advise a defendant of his right to petition the U.S. Supreme Court for a writ of certiorari does not constitute ineffective assistance of counsel under the Sixth Amendment. The court applied the standard from *Strickland v. Washington*, which requires a showing of deficient performance and prejudice, but ruled that no constitutional right to cou
Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-08-28 Docket: 2:24-cv-00467-GMB The eleventh-circuit vacated the district court’s dismissal of Tamika Momanyi’s Title I and corresponding Title V claims under the Americans with Disabilities Act (ADA) and remanded those specific counts for dismissal without prejudice, while affirming the dismissal of all other claims. The court held that the Board of Trustees of the University of Alabama is an arm of the state entitled to Eleventh Amendment sovereign immunity against Title I ADA claims, as Congress did not abrogate this
Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-08-28 Docket: 3:05-cr-00339-VMC-MCR-1 The Eleventh Circuit affirmed the district court’s denial of Patrick Porter’s motion for compassionate release under 18 U.S.C. § 3582(c)(1)(A). The court held that Porter was ineligible for sentence reduction because he relied on non-retroactive changes in the law resulting from the First Step Act to argue his sentence was unusually long. Relying on the Supreme Court’s decision in *Rutherford v. United States*, 608 U.S. ___ (2026), the Eleventh Circuit ruled that a non-retroactive c
Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-08-28 Docket: 2:23-cr-00187-MHT-SMD-1 The Eleventh Circuit affirmed the defendant’s convictions for possession with intent to distribute methamphetamine and fentanyl, and for knowingly maintaining a drug premises. The court held that the district court correctly denied the defendant’s three pretrial motions. First, regarding the motion to suppress evidence from a traffic stop, the court applied the objective standard established in *Whren v. United States*, ruling that probable cause existed because the officer witnesse
Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-08-28 Docket: 2:24-cv-01484-RDP The eleventh-circuit affirmed the district court’s judgment upholding the Social Security Administration’s denial of Robert Battle’s applications for disability insurance benefits and supplemental security income. The court applied the standard of review requiring affirmation if the Commissioner’s decision is supported by substantial evidence and correct legal standards were applied, reviewing both the Commissioner’s legal conclusions and the district court’s determination de novo. The co
Court: United States Court of Appeals for the First Circuit Filed: 2026-08-28 The First Circuit affirmed the conviction of Germaine Vélez-Ramírez, a member of the Puerto Rico Police Drug Unit, for violating 18 U.S.C. § 666(a)(1)(B) by accepting a bribe in exchange for corruptly influencing a governmental transaction. The court held that there was sufficient evidence to support the jury’s finding that the value of the government “transaction” Vélez agreed to provide—obtaining the dismissal of a criminal charge for an arrestee—met the statutory $5,000 threshold. Applying de novo review to the de
Court: United States Court of Appeals for the Sixth Circuit Filed: 2026-08-28 The Sixth Circuit affirmed the defendant’s 195-month sentence for possessing cocaine with intent to distribute and possessing a firearm in furtherance of a drug-trafficking offense, rejecting his challenge to the career-offender sentencing enhancement. The court held that the district court correctly applied U.S.S.G. § 4B1.1 because the government satisfied all three requirements: the defendant was over eighteen at the time of the instant offense, the instant offense was a controlled substance offense, and he had two
Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-08-28 Docket: 4:24-cv-00009-RSB-CLR The eleventh-circuit affirmed the district court’s grant of summary judgment to Retractable Technologies, Inc., dismissing Maryann Rudzinskas’s claims for negligent manufacturing and negligent failure-to-warn under Georgia law. The court held that the district court did not abuse its discretion in excluding the testimony of Rudzinskas’s expert witness, Dr. John Odom, regarding the design and manufacturing defects of the VanishPoint syringes. Applying Federal Rule of Evidence 702 and *
Court: United States Court of Appeals for the Fourth Circuit Filed: 2026-08-28 The Fourth Circuit affirmed the district court’s judgment dismissing the plaintiff’s amended complaint and denying his motion to consolidate. The court held that the appellant forfeited appellate review of these issues because he failed to file specific objections to the magistrate judge’s recommendation regarding the dismissal and failed to challenge the dispositive bases for that dismissal in his informal briefs. Applying Fourth Circuit Rule 34(b) and precedent requiring parties to alert the district court of the
Court: United States Court of Appeals for the Seventh Circuit Filed: 2026-08-28 The Seventh Circuit affirmed the district court’s grant of judgment on the pleadings in favor of Nuance Communications, Inc., dismissing Norma Cisneros’s claims under the Illinois Biometric Information Privacy Act (BIPA). The court held that Nuance is exempt from BIPA’s requirements because it falls within the definition of a “financial institution” or its affiliate under 740 ILCS 14/25(c), which incorporates the Gramm-Leach-Bliley Act. Specifically, the court applied the Federal Reserve Board’s regulation (12 C.F.
Court: United States Court of Appeals for the Seventh Circuit Filed: 2026-08-28 The seventh-circuit affirmed the district court’s dismissal of Amanda Sima’s second amended complaint for failure to state a claim upon which relief can be granted. The court held that Sima failed to adequately plead the element of causation required for a legal malpractice claim under Ohio law, which governs the dispute pursuant to the engagement agreement’s choice-of-law provision. To succeed on a legal malpractice claim in Ohio, a plaintiff must allege (1) an attorney owed a duty, (2) a breach of that duty, and
Court: United States Court of Appeals for the Seventh Circuit Filed: 2026-08-28 The seventh-circuit affirmed the district court’s grant of summary judgment in favor of Deputy Carl Gloede in a § 1983 failure-to-protect action brought by pretrial detainee Randy Talley. The court held that Talley failed to establish a violation of his rights under the Fourteenth Amendment, which governs claims by detainees on probation holds when the applicable standard is unsettled between the Eighth and Fourteenth Amendments. To succeed, a plaintiff must demonstrate that the officer made an intentional decision
Court: United States Court of Appeals for the Eighth Circuit Filed: 2026-08-28 The eighth-circuit affirmed the district court’s order denying Charlie Harper’s motion to dismiss his indictment for unlawful possession of a firearm and ammunition as a felon under 18 U.S.C. § 922(g)(1). The court held that Harper’s arguments challenging the statute’s constitutionality on its face and as applied to him under the Second Amendment are foreclosed by binding circuit precedent, specifically citing *United States v. Torres*, *United States v. Wako*, and *United States v. Jackson*. Consequently, Harper’s