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Affirms LWOP Sentence for Samuel Dugan Under Three-Strikes Law

The Court of Appeals of Washington, Division One, affirmed Samuel Leon Dugan's life-without-possibility-of-parole (LWOP) sentence under the Persistent Offender Accountability Act (POAA) three-strikes law. Dugan challenged the POAA as unconstitutional as applied, arguing racial disproportionality, and claimed his Sixth Amendment right to jury determination of prior conviction timing was violated. The court rejected both arguments, applying de novo review and presuming the statute constitutional. The trial court's finding that Dugan is a persistent offender with two prior most-serious-offense convictions (second-degree assault in 2002, first-degree burglary in 2005) was upheld.

Priority review Enforcement Criminal Justice
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State v. Blackburn - Affirmed in Part, Reversed in Part

The Washington Court of Appeals affirmed most of Blackburn's convictions for incest and rape of a child while reversing Count 8 for insufficient evidence. The court agreed that law enforcement violated Blackburn's state constitutional privacy rights by obtaining his bank card and purchase history without a warrant under article I, section 7, but held the error was harmless. The case was remanded for resentencing on counts 2, 3, 5, 6, and 7.

Priority review Enforcement Criminal Justice
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Loop v Loop Appeal Affirmed as Frivolous

The Court of Appeals of Washington, Division One affirmed the trial court's entry of final orders confirming an arbitration award in the marital dissolution of John Torsten Loop and Lisa Michelle Loop. The appellate court found John Loop's appeal to be frivolous and awarded Lisa attorney fees and costs. The court also upheld CR 11 sanctions of $1,000 imposed on John for filing a frivolous motion to void a prior contempt order.

Priority review Enforcement Family Law
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Stuart Morrow v. State of WA Dept. of Licensing

The Court of Appeals of Washington reversed a King County Superior Court decision and reinstated an administrative license suspension for Stuart Morrow following his DUI arrest. The court held that the superior court erred in finding insufficient evidence of compliance with WAC 448-16-060 governing breath test calculations. The court found that the Department of Licensing met its prima facie case, and the breath test results were properly admitted under RCW 46.61.506.

Priority review Enforcement Transportation
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In the Matter of the Parental Rights to M.A.A.K.

The Court of Appeals of Washington, Division One, affirmed the trial court's termination of R.K.'s parental rights to M.A.A.K. The court rejected R.K.'s claim that the trial court violated her right to a public trial by closing the courtroom four times during proceedings, finding the closures served a legitimate purpose. The court also rejected R.K.'s claim that the trial court abused its discretion by denying her motion for new counsel, and upheld the finding that DCYF offered all necessary services in a timely and meaningful manner despite R.K.'s non-compliance.

Priority review Enforcement Civil Rights
CJEU Press Releases
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EU Court Rules on Filter Cigarettes, ISO Standards, and Directive Compliance

The CJEU ruled in Case C-155/24 that individuals must have free, effective, non-discriminatory access to ISO standards referenced in EU tobacco directive 2014/40/EU to verify whether filter cigarettes comply with maximum emission levels for tar, nicotine, and carbon monoxide. The Court held that the EU legislature must bear the costs of free access to such standards, particularly where they are protected by intellectual property rights. The foundation cannot rely on measurement methods other than those prescribed by the ISO standards, even though those standards have not been published in the Official Journal.

Priority review Enforcement Public Health
CJEU Press Releases
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Commission v Hungary — Hungary Found in Breach of EU Law Over Anti-LGBTI+ Legislation

The CJEU sitting as the Full Court ruled in Case C-769/22 that Hungary breached EU law through Law No LXXIX of 2021, which restricts content portraying or promoting deviation from gender identity or homosexuality, associating those persons with persons convicted of paedophilia. The Court found violations of the freedom to provide services under the e-Commerce Directive, Services Directive and Audiovisual Media Services Directive, of multiple fundamental rights under the EU Charter including non-discrimination based on sex or sexual orientation, human dignity, and private and family life, and — for the first time in a member state infringement action — of Article 2 TEU listing the foundational values of the Union.

Priority review Enforcement Civil Rights
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Center For Biological Diversity v. U.S. Fish and Wildlife Service et al

The Center for Biological Diversity filed a civil complaint against the U.S. Fish and Wildlife Service and additional defendants in the Northern District of California on April 21, 2026. The complaint, assigned case number 1:26-cv-03333, is based on federal question jurisdiction and concerns environmental matters. The filing initiates federal litigation requiring the government defendants to respond to the plaintiff's claims.

Priority review Enforcement Environmental Protection
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Michael Fearnley Placed on Disability Inactive Status

The Tennessee Supreme Court entered an order on April 20, 2026 transferring attorney Michael Fearnley's law license to disability inactive status pursuant to Section 27.4 of Tennessee Supreme Court Rule 9. Mr. Fearnley is prohibited from practicing law while on disability inactive status and must comply with Section 28 obligations and responsibilities. Reinstatement requires demonstrating to the Tennessee Supreme Court that the disability has been removed in accordance with Section 27.7.

Priority review Enforcement Employment & Labor
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Lytle v. Lind - Split-Rail Fence Unreasonably Interfered With Easement Right-of-Way

The Maine Supreme Judicial Court reversed a York County Superior Court partial summary judgment in Lytle v. Lind, holding that a split-rail fence installed by the Linds within a ten-foot-wide right-of-way easement unreasonably interfered with the neighbors' easement rights as a matter of law. The fence ran parallel to the common boundary along the center of the right-of-way, dividing it into two portions and obstructing the path used by neighbors to access the Webhannet River with water-sports equipment.

Priority review Enforcement Real Estate
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Bai v. Mullin et al

Yu Bai filed a civil complaint in the United States District Court for the Northern District of California against defendants including Mullin et al. The case, docketed as 3:26-cv-03332, was filed on April 20, 2026, and is classified under Nature of Suit as Other Immigration Actions with the U.S. Government as defendant.

Priority review Enforcement Immigration
Indiana AG - Newsroom
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Nearly 30 Products Recalled in March, Indiana AG Alerts Hoosiers

Attorney General Todd Rokita alerted Indiana residents to nearly 30 consumer products recalled by the U.S. Consumer Product Safety Commission during March 2026. The recalled items span multiple categories including outdoor equipment, children's toys and sleepwear, furniture, and power tools. Recalled products pose hazards including fall risks, laceration hazards, choking hazards, fire and burn hazards, and tip-over hazards that can result in serious injury or death.

Priority review Notice Consumer Protection
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RTM v Bonne Terre Limited - Data Protection Appeal

The UK Court of Appeal (Civil Division) dismissed an appeal by RTM against Bonne Terre Limited and Hestview Limited, with the Information Commissioner intervening. The matter originated in the High Court's Media and Communications List before Mrs Justice Collins Rice. The judgment, delivered on 21 April 2026 by Dame Victoria Sharp, Lord Justice Lewison, and Lord Justice Warby, resolves a data protection dispute. The court affirmed the first-instance ruling, rejecting RTM's grounds of appeal.

Priority review Enforcement Data Privacy
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Manchester University NHS Foundation Trust v M

The High Court of Justice Family Division issued a judgment in case [2026] EWHC 812 (Fam) on 2 April 2026 at the Manchester Civil Justice Centre. The case involves Manchester University NHS Foundation Trust as claimant against respondents M, F, and G (a minor represented by her Children's Guardian). The Honourable Mr Justice Hayden presided over the proceedings.

Priority review Enforcement Healthcare
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Thompson and Carlo v Commissioner of Police of the Metropolis

The High Court of Justice issued a judgment in the judicial review proceedings Shaun Thompson and Silkie Carlo v The Commissioner of Police of the Metropolis. Lord Justice Holgate and Mrs Justice Farbey presided over the case in the Administrative Court. The Equality and Human Rights Commission intervened in the proceedings.

Priority review Enforcement Civil Rights
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Re N (Paternity: Unregulated Sperm Donor)

The High Court of Justice Family Division, before the President of the Family Division, issued a judgment on 21 April 2026 in the matter of Re N, addressing paternity questions arising from an unregulated sperm donor arrangement under the Family Law Act 1986.

Priority review Enforcement Civil Rights
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Hyatt v. Owens – Division I Civil Appeal from Whatcom County

The Washington Court of Appeals, Division I, issued an opinion in Hyatt v. Owens (Docket 87907-3) on April 20, 2026. The appeal was taken from Whatcom County Superior Court (Docket 18-2-00610-1, Judgment filed January 10, 2025) by appellants Michael A. Owens and Angelo Tsoukalas, with respondent Arthur Hyatt appearing pro se. The panel consisted of Judge Cecily Hazelrigg (author), with Judges Janet Chung and Ian Birk concurring.

Priority review Enforcement Judicial Administration
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Marriage of Latour, Division I Appeal

The Washington Court of Appeals Division I filed an opinion on April 20, 2026, in the divorce appeal of In Re The Marriage Of: Isabelle Latour v. Sean Kuhlmeyer (Docket 87019-0). The court panel consisted of Judge Cecily Hazelrigg (author), with Judges Janet Chung and David Mann concurring. The judgment under review was filed June 18, 2024, by Honorable Sean O'Donnell.

Priority review Enforcement Judicial Administration
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State v. Dugan - Criminal Appeal

The Washington Court of Appeals, Division I filed an opinion in State v. Dugan on April 20, 2026. The case is an appeal from a King County Superior Court judgment filed September 15, 2023, with Honorable Kenneth L Schubert presiding. The panel consists of Bill Bowman (author), Janet Chung, and Lori Smith.

Priority review Enforcement Criminal Justice
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In the Matter of Parental Rights to M.A.A.K. (87781-0)

The Washington Court of Appeals Division I issued an opinion in the matter of parental rights concerning minor child M.A.A.K., docket number 87781-0, filed on April 20, 2026. The appeal arose from a judgment or order filed February 12, 2025, under review by Judge Nicole Gaines-Phelps. The court panel consisted of Judge Lori Smith (author), with concurrences from Bill Bowman and Linda Coburn.

Priority review Enforcement Judicial Administration
UK HMCTS
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Khambay v George Eliot Hospital NHS Trust: Employment Tribunal Decision 1308702/2023

The Employment Tribunal issued a decision on 20 February 2026 in the case of Ms A Khambay v George Eliot Hospital NHS Trust (case 1308702/2023). The claim was brought under the Equal Pay Act, Race Discrimination, Religion or Belief Discrimination, and Sex Discrimination jurisdiction codes. The full decisions — a preliminary judgment and a reconsideration judgment — are published via gov.uk and the gov.uk assets service.

Priority review Enforcement Employment & Labor
UK HMCTS
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Mr W Boucher v Tanyard Youth Project Ltd: Employment Tribunal Judgment

Employment Tribunal in England and Wales issued a judgment by consent in the case of Mr W Boucher v Tanyard Youth Project Ltd (case 6004994/2025) on 23 January 2026. The decision addresses claims under contract of employment, unfair dismissal, unlawful deduction from wages, Working Time Regulations, and written statements. The full judgment is available via the UK Government publishing service.

Priority review Enforcement Employment & Labor
UK HMCTS
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R Payne v DHL Services Ltd ET Decision

The Employment Tribunal issued a decision in Mr R Payne v DHL Services Ltd (case 3306439/2024) on 22 January 2026. The case concerned claims of Trade Union Membership and Unfair Dismissal. The full judgment and reasons are available via linked PDF documents on the gov.uk page.

Priority review Enforcement Employment & Labor
UK HMCTS
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A Burke De Frias v Colorfoto Ltd: Maternity Rights Ruling

The Employment Tribunal issued a reserved judgment in A Burke De Frias v Colorfoto Ltd (case 6012536/2025) on 6 January 2026. The decision addresses claims under maternity and pregnancy rights, parental and maternity leave, and sex discrimination jurisdiction codes. HMCTS published the decision summary on 21 April 2026.

Priority review Enforcement Employment & Labor
UK HMCTS
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Mr M Y Medudhula v Lloyds Bank plc: Strike Out

The Employment Tribunal issued a strike-out judgment in case 1603692/2024, Mr M Y Medudhula v Lloyds Bank plc, decided on 6 January 2026 and published 21 April 2026. The claim, brought under public interest disclosure and unfair dismissal jurisdictions, was struck out by the tribunal. The full reasoning of the judgment is available in the linked PDF document.

Priority review Enforcement Employment & Labor
UK HMCTS
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Mr S Pakes v Instant Landscapes Ltd: Employment Tribunal Decision

Employment Tribunal found in favour of Mr S Pakes against Instant Landscapes Ltd in case 3311033/2024. The tribunal determined the respondent breached contract, unfairly dismissed the claimant, and made unlawful deductions from wages. The decision, issued 30 January 2026, constitutes a binding judgment enforceable against the respondent employer.

Priority review Enforcement Employment & Labor
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AG Jackson Wins Court Order Freezing Nexstar-Tegna $6.2B Merger

North Carolina Attorney General Jeff Jackson secured a federal preliminary injunction freezing Nexstar's $6.2 billion acquisition of Tegna. Eight state attorneys general filed a federal antitrust lawsuit against the merger on March 18, 2026. The order requires Nexstar and Tegna to operate as completely separate entities with separate management and separate newsrooms while litigation proceeds.

Priority review Notice Antitrust & Competition
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DOJ Extends ADA Web Accessibility Deadlines for State and Local Governments

The Department of Justice has issued an Interim Final Rule extending the compliance dates for web content and mobile application accessibility requirements under Title II of the Americans with Disabilities Act. Public entities with a total population of 50,000 or more now have until April 26, 2027 (previously April 24, 2026). Public entities with a population under 50,000 or any special district government now have until April 26, 2028 (previously April 26, 2027). The technical standard (WCAG 2.1 Level AA) remains unchanged.

Priority review Rule Civil Rights
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Commissioner of Taxation v Huang (No 2) - Shortfall Penalty Remittal to ART

The Federal Court of Australia set aside part of the Administrative Appeals Tribunal's decision regarding the Commissioner of Taxation's objection to shortfall penalties and remitted the matter to the Administrative Review Tribunal for redetermination. The Court held that the taxpayer bears the burden of proving the shortfall penalty assessments were excessive or incorrect under s 14ZZK(b)(i) of the Taxation Administration Act 1953 (Cth). The ART must determine the matter on existing AAT findings of fact and evidence.

Priority review Enforcement Taxation
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Feng v Minister for Immigration and Citizenship — PIC 4020 False Information Appeal Allowed

The Federal Court of Australia allowed an appeal by Chiu-He Feng against a decision of the Administrative Appeals Tribunal concerning Public Interest Criterion 4020 (PIC 4020). The Court found the Tribunal had erred in its construction of PIC 4020, which requires that information be 'purposely untrue' and that 'an element of fraud or deception' is necessary — not merely indifference to accuracy. The Tribunal's decision of 26 November 2020 is quashed and the matter remitted to the Administrative Review Tribunal for determination according to law. The Minister for Immigration and Citizenship is ordered to pay costs.

Priority review Enforcement Immigration
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Nafar v BT Funds Management Limited [2026] FCA 479

The Federal Court of Australia granted summary judgment in favour of BT Funds Management Limited and AIA Australia Limited, dismissing Mr Nafar's claim for Total and Permanent Disability (TPD) benefits under an insurance policy. The court found that Mr Nafar failed to obtain the required certification from a qualified medical practitioner appointed by the insurer as specified in the policy terms. The proceedings were dismissed and Mr Nafar was ordered to pay the respondents' costs on a party and party basis.

Priority review Enforcement Insurance
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Mokhtari v Piacentini & Son Pty Ltd (No 3) - Further Discovery Ordered

The Federal Court of Australia ordered Piacentini & Son Pty Ltd to provide further discovery to Mirmehdi Mokhtari by 30 April 2026, following an interlocutory application in an employment dispute involving claims of adverse action, coercion, and misleading representations under the Fair Work Act 2009.

Priority review Enforcement Employment & Labor
DOJ News
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Florida Man Pleads Guilty to Ransomware Conspiracy

The DOJ announced that Angelo Martino, 41, of Land O'Lakes, Florida, pleaded guilty to conspiracy to commit ransomware attacks and extortion against U.S. companies. Martino, a former ransomware negotiator at a cyber incident response company, provided BlackCat/ALPHV ransomware actors with confidential victim information including insurance policy limits and internal negotiation positions without authorization. He also conspired with Ryan Goldberg of Georgia and Kevin Martin of Texas to deploy BlackCat ransomware between April and November 2023, extorting approximately $1.2 million in Bitcoin from one victim. Law enforcement seized $10 million in assets from Martino.

Priority review Enforcement Cybersecurity
DOJ News
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Justice Department Files Clean Water Act Complaint Against DC Water for Potomac Interceptor Failure

The Department of Justice, on behalf of EPA, filed a civil complaint in federal court against the District of Columbia Water and Sewer Authority (DC Water) and the District of Columbia for Clean Water Act violations stemming from the January 19, 2026 collapse of the Potomac Interceptor, which discharged more than 200 million gallons of raw, untreated sewage into the Potomac River. The complaint alleges DC Water failed to properly operate and maintain its sewer system in a manner that keeps untreated sewage out of waterways and areas with risk of human contact. The complaint seeks financial penalties, sewer assessment and rehabilitation projects, pollutant mitigation work, and an order requiring DC Water to develop an Enhanced Operations and Maintenance Plan for all its sewer lines.

Priority review Enforcement Environmental Protection
UK CMA Cases
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Seras / Enva Dedicated Waste Wood Business Merger Inquiry

The Competition and Markets Authority (CMA) has opened a Phase 1 merger inquiry into the anticipated acquisition by Seras Energy Ltd of G.I. Hadfield & Son Limited, a dedicated waste wood business. The CMA is inviting comments from any interested party on the impact the transaction could have on competition in the UK. The statutory deadline for comments is 6 May 2026.

Priority review Consultation Antitrust & Competition
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Consecutive Sentence Vacated for Missing R.C. Findings

The Ohio Court of Appeals, Fifth District, vacated and remanded a consecutive sentence imposed on Carl S. Williams for failing to make all findings required by R.C. 2929.14(C)(4). The defendant received an eight-year aggregate sentence for six counts of Receiving Stolen Property, two counts of Forgery, and one count of Breaking and Entering. The trial court made some but not all statutory findings before imposing consecutive sentences.

Priority review Enforcement Criminal Justice
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Mahadev Logistics v. Columbus Truck, Bailment Damages Remanded

The Ohio Court of Appeals Fifth District partially reversed and remanded a trial court judgment in a bailment dispute between Mahadev Logistics LLC and Columbus Truck & Equipment Centers LLC. The appellate court agreed with Appellant that the trial court erred in calculating damages, finding the methodology (subtracting original repair estimate from post-theft repair costs) improperly failed to account for additional claimed damages including towing expenses, missing parts, replacement keys, and lost profits from six months of non-use valued at $90,000. The case was remanded for further proceedings on the unreviewed damage components.

Priority review Enforcement Judicial Administration
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State v. Phelps — Appeal Affirmed, Counsel Granted Withdrawal Under Anders

The Ohio Court of Appeals, Fifth Appellate District, affirmed the judgment of the Fairfield County Common Pleas Court overruling a motion for judicial release. Appellate counsel filed an Anders brief asserting the appeal was wholly frivolous; the court independently reviewed the record, agreed, granted counsel's motion to withdraw, and affirmed. The court further held it lacked authority under R.C. 2701.03 to review the trial court's recusal decision.

Priority review Enforcement Criminal Justice
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Sephora Adopts Safeguards for Anti-Aging Products Marketed to Children

Attorney General William Tong announced that Sephora has adopted new safeguards regarding marketing anti-aging skincare products to children, resolving a Connecticut investigation. The settlement requires Sephora to obtain product warnings from suppliers about suitability for children under 13, display warnings on product pages, train employees, and maintain a website resource about unsuitable products. The investigation was prompted by concerns that anti-aging products containing retinol and acids may be harmful to children's skin.

Priority review Notice Consumer Protection
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Texas Global Equity Fund XII, LLC v. Breckenridge Development 2019, LLC - Garnishment

The Texas Court of Appeals, 3rd District at Austin, reversed the district court's order dissolving prejudgment writs of garnishment obtained by Texas Global Equity Fund XII, LLC (TGE) against 22 entities in connection with a $7 million loan to Breckenridge Development 2019, LLC (BD19). The court found that TGE had established statutory grounds for garnishment and that BD19's extrinsic grounds for dissolution lacked any basis in law or fact. The court rendered judgment reinstating the writs of garnishment and remanded the case for further proceedings.

Priority review Enforcement Banking
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Frank Estrada, III v. The State of Texas - Protective Order Violation Affirmed

Frank Estrada III was convicted in Travis County, Texas of violating a protective order twice within twelve months. The Texas Court of Appeals, 3rd District affirmed the conviction and six-year sentence, rejecting challenges to evidentiary rulings and juror selection. The case arose from Estrada's violation of a 2022 agreed protective order despite having been found to have committed family violence.

Priority review Enforcement Criminal Justice
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Benjamin Sandoval Diaz v. Todd Blanche - Immigration Petition Denied

The Fourth Circuit denied Benjamin Sandoval Diaz's petition for review of a Board of Immigration Appeals decision, affirming the denial of his application for cancellation of removal. The court upheld the finding that Diaz failed to establish good moral character because he testified under oath to felony cocaine offenses under North Carolina law, despite the charges being later dismissed. The court rejected Diaz's argument that the Immigration Judge failed to properly apply BIA precedent in Matter of K.

Priority review Enforcement Immigration
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Seungho Park v. Ellie Shin Civil Case Affirmed

The Fourth Circuit affirmed the district court's order denying Seungho Park's request for attorney's fees and damages pursuant to a settlement agreement under the Fair Labor Standards Act, 29 U.S.C. § 201 et seq., as well as the court's denial of reconsideration. The appellate court reviewed the record and discerned no reversible error. Oral argument was dispensed with.

Priority review Enforcement Employment & Labor
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United States v. Lewis-Langston - ACCA Enhancement Harmless Error

The Fourth Circuit affirmed a defendant's 200-month ACCA-enhanced sentence for felon-in-possession of a firearm, finding that the district court erred under Erlinger v. United States by deciding at sentencing whether the defendant's three prior violent felonies were committed on different occasions. The court held this error was harmless because the defendant received adequate notice of potential ACCA exposure in his plea agreement and plea colloquy, did not seek to withdraw his guilty plea, and did not meaningfully contest the accuracy of his presentence report establishing the predicate offenses occurred on different dates. The court applied the harmless-error framework from United States v. Brown, 136 F.4th 87 (4th Cir. 2024), finding the evidence supporting the different-occasions finding was exceptionally strong.

Priority review Enforcement Criminal Justice
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Spivey v. Breckon - Bivens Claims Dismissed

The Fourth Circuit affirmed the dismissal of a federal prisoner's Bivens action against Bureau of Prisons employees, holding that the district court correctly concluded a Bivens remedy was unavailable. The court found that the prisoner's claims for inadequate medical care and excessive force presented new Bivens contexts beyond those recognized by the Supreme Court, and special factors counseled against extending an implied damages remedy under the Constitution.

Priority review Enforcement Civil Rights
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United States v. Holley - Sentence Affirmed on Grouping and Consecutive Sentencing Challenges

The Fourth Circuit affirmed Xavier Holley's 480-month sentence for attempted Hobbs Act robbery and conspiracy, rejecting his challenges to the district court's grouping of counts and its authority to impose consecutive sentences. The appellate court held that any grouping error was harmless because the offense level remained at 45 regardless of grouping, and that consecutive sentences for conspiracy and attempted robbery are permissible under 18 U.S.C. § 3584(a) per this circuit's precedent in United States v. Oliver.

Priority review Enforcement Criminal Justice
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HV JVCo I LLC v. Open On Sunday LLC - Music Royalty Interest Dispute

Delaware Superior Court issued a decision after bench trial in a dispute between HV JVCo I LLC and Open On Sunday LLC over music royalty assets belonging to Fugees member Prakazrel Samuel Michel ("Pras"). The central issue was which party holds superior interest in Royalty Assets subject to a secured transaction executed in January 2022. The case turned on whether Pras's signature using a name variant ("Samuel Prakazrel Michel" vs. his legal name "Prakazrel Samuel Michel") affected the enforceability of the lien on the Royalty Assets.

Priority review Enforcement Securities
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People v. Bertsch and Hronis, Death Penalty Appeal

The California Supreme Court issued an opinion on April 20, 2026, resolving an automatic appeal of a death judgment in People v. Bertsch and Hronis, Case S093944. The case originated from trial court proceedings under case number 94F07295. As an automatic appeal in a capital case, this final judgment may establish precedent affecting future death penalty proceedings in California.

Priority review Enforcement Criminal Justice
Hawaii Supreme Court
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State v. Bunag — Consecutive Sentencing Record Requirements

The Hawaii Supreme Court reversed Alden Bunag's consecutive sentence and remanded for resentencing, holding that the trial court failed to independently articulate on-the-record reasons for the consecutive sentence at sentencing. The court committed two errors: first, the Intermediate Court of Appeals improperly relied on a written order filed four days after the defendant appealed to cure deficient courtroom reasoning; second, the trial court improperly deferred to the prosecutor's arguments rather than stating its own independent rationale. The ruling affirms that sentencing courts must state specific reasons for consecutive sentences on the record at the time of sentencing, and post-sentencing written orders cannot substitute for inadequate oral reasoning.

Priority review Enforcement Criminal Justice
Hawaii Supreme Court
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State v. Pua, 3rd Circuit Hawaii - Appeal Dismissed

The Hawaii Intermediate Court of Appeals dismissed Defendant-Appellant Drosstain Pua's appeal without prejudice, finding the court lacks appellate jurisdiction because the Notice of Appeal was not filed within the 30-day deadline required by HRAP Rule 4(b)(1) and ineffective assistance of counsel is not plain from the record. Both prior counsel Heimgartner and appointed counsel Hironaka stated that Pua did not express a desire to appeal until after the deadline had expired. The court noted Pua may seek relief by petition under Hawaii Rules of Penal Procedure Rule 40.

Priority review Enforcement Judicial Administration

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