US Courts

Benga v. Allina Health - Medical Malpractice / Expert Testimony Exclusion

The Minnesota Court of Appeals reversed summary judgment and remanded a medical malpractice case (A25-0526) against Allina Health System, finding the district court erred in excluding expert testimony under Minnesota Rule of Evidence 702. The case involves a child who suffered permanent brachial plexus injuries during a shoulder dystocia delivery in November 2020. The appellate court determined the excluded expert testimony was necessary to establish the standard of care and causation.

Anthony Graham habeas corpus appeal denied, Minnesota Court affirms 30th Mar

Anthony Graham habeas corpus appeal denied, Minnesota Court affirms 30th Mar

Wallace v. John Stewart Co. & Redwood Gardens - Civil Rights Accommodations

Plaintiff David Wallace filed a clarification of defendant names in the pending civil rights case Wallace v. John Stewart Co. & Redwood Gardens (Case No. 3:25-cv-04433-WHO) in the Northern District of California. The clarification was filed on March 31, 2026, and follows the filing of a fourth amended complaint.

Daugherty v. Dingus - Habeas Corpus (Jury Impartiality)

The Fourth Circuit affirmed the denial of Tony Daugherty's habeas petition, upholding the West Virginia Supreme Court of Appeals' determination that a juror's comments during deliberations (expressing knowledge of defendant's family and fear of consequences if acquitted) did not constitute impermissible external influence under 28 U.S.C. § 2254 standards.

Skidmore v. Schinke - Employment Retaliation/Vacated Remanded

The Fourth Circuit vacated the district court's dismissal of Jeremy Skidmore's employment retaliation claim against Michael Schinke and Gail Saul and remanded for further proceedings. The appellate court held that the district court improperly applied the fraudulent joinder standard when evaluating diversity jurisdiction, finding that Skidmore had a viable claim under Virginia's Bowman statute against the in-state defendant.

Jackson v. Dameron - Prisoner Civil Rights Medical Care Claim

Fourth Circuit affirmed dismissal of a pro se prisoner's § 1983 civil rights claim alleging inadequate medical care at Augusta Correctional Center. The court held the district court properly construed the complaint without becoming the plaintiff's advocate. Judge Floyd dissented, arguing the allegations were sufficient to proceed.

Byers v. United States - Section 2255 Habeas Relief

The Fourth Circuit vacated the District of Maryland's orders denying Patrick Albert Byers Jr.'s 2016 motion and remanded with directions to dismiss for lack of jurisdiction. The appellate court determined that Byers's motion, which the district court had characterized as a Rule 60(b) motion, was actually a second or successive 28 U.S.C. § 2255 motion requiring prior authorization from the Fourth Circuit that Byers never obtained. The court also denied authorization for Byers to file a successive § 2255 motion.

Norman Richardson v. United States - FTCA Negligence Appeal

The Fourth Circuit vacated the magistrate judge's summary judgment order in Richardson v. United States and remanded for further proceedings. The court found that both parties erroneously argued Maryland law applied to Richardson's Federal Tort Claims Act negligence claim when D.C. law should have governed because the underlying events occurred in the District of Columbia. The appellate court declined to apply D.C. law for the first time on appeal, instead ordering the lower court to address the choice-of-law issue in the first instance.

United States v. Spencer - Supervised Release Revocation

The Fourth Circuit affirmed the district court's revocation of Anthony P. Spencer's supervised release. Spencer, a convicted felon who possessed a firearm in violation of 18 U.S.C. § 922(g)(1), had his supervised release revoked after being arrested for state law offenses. The appellate court rejected Spencer's argument that the district court improperly relied on certified state court documents without independently determining whether he committed the underlying offenses. Spencer was sentenced to 24 months imprisonment with no further supervised release.

USA v. McMillan - Bank Fraud Conviction Affirmed

The Fourth Circuit affirmed Jalen Craig McMillan's conviction for conspiracy to commit bank fraud, three counts of bank fraud, and aggravated identity theft. McMillan received 54 months imprisonment, five years supervised release, and was ordered to pay $165,891.68 in restitution for a scheme involving stolen identities at the credit union where he worked.