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Carter v. Dupuy - Excessive Force, Qualified Immunity

The Fifth Circuit reversed the district court's denial of summary judgment for defendants Chad Dupuy and Sheriff Jason Ard on plaintiff Amanda Carter's Fourth Amendment excessive force claim. The court held that Dupuy's actions—grasping Carter's arm, attempting to drag her through the doorway, and briefly pushing her out of the office—constituted de minimis force that was not clearly excessive or unreasonable under the circumstances. The court applied the Graham v. Connor totality-of-circumstances test, finding Dupuy entitled to qualified immunity because no constitutional violation occurred when the force was minimal, lasted at most four seconds, and ceased immediately once Carter was outside.

Circuit Splits from March 2026: Appellate Court Disagreements on Qualified Immunity, ADA, First Step Act

The Congressional Research Service published a Legal Sidebar summarizing circuit splits that emerged from U.S. Courts of Appeals decisions in March 2026. Three circuit conflicts are discussed: the Eleventh Circuit's split with the Fifth and Tenth Circuits on qualified immunity and personal liability under 42 U.S.C. § 1981 and the FMLA; the Eleventh Circuit's split with the Fifth Circuit on Olmstead claims under Title II of the ADA for individuals at risk of institutionalization; and the Second Circuit's split with the Ninth Circuit on whether First Step Act time credits can reduce the period of supervised release under 18 U.S.C. § 3632(d)(4). The report does not create new obligations but tracks appellate disagreement on federal law interpretation.

Chevron USA Inc. v. Plaquemines Parish - Federal Officer Removal Jurisdiction

The Supreme Court reversed the Fifth Circuit, holding that Chevron's wartime crude-oil production sufficiently relates to its wartime avgas refining under the federal officer removal statute. The Court interpreted the 'relating to' standard broadly, finding Chevron's crude oil production was indispensable to its military avgas refining contract, permitting removal to federal court despite the suit targeting production methods rather than refining directly.

Symonette v. Symonette - Affirmed

The Fifth District Court of Appeal of Florida affirmed the Circuit Court for Lake County in Symonette v. Symonette, Case No. 5D2025-1780. The appellant Thomas B. Symonette was represented by counsel from Emrick Family Law Firm; the appellee Mary M. Bradley (n/k/a Mary Symonette) was represented by counsel from The Carlyle Appellate Law Firm. The per curiam affirmance was issued without a written opinion.

Matthew Lucas Wade v. State of Florida - Criminal Appeal Affirmed

The Fifth District Court of Appeal of Florida affirmed Matthew Lucas Wade's conviction from Citrus County Circuit Court. The per curiam decision states only 'AFFIRMED' with Justices Edwards, Boatwright, and Maciver concurring. No written opinion was issued.

Zakariya Daud Clarke v. State of Florida — Postconviction Appeal Affirmed

The Fifth District Court of Appeal of Florida affirmed a Rule 3.850 postconviction order from the Circuit Court for Clay County, Case No. 5D2025-0067. The appellant, Zakariya Daud Clarke, appeared pro se. The judgment was affirmed with no published opinion; no substantive legal holdings were issued.

Micaiah Lufcy v. Sarah Lufcy N/K/A Sarah Tolfa

The Fifth District Court of Appeal of Florida affirmed a Circuit Court ruling in a domestic relations case between Micaiah Lufcy and Sarah Lufcy (n/k/a Sarah Tolfa). The appellate court, per curiam, upheld the lower court's decision without issuing a written opinion explaining its reasoning. All three participating justices concurred.

Timothy Barrett Sr v. State of Florida - 3.850 Postconviction Appeal Affirmed

The Fifth District Court of Appeal of Florida affirmed the Circuit Court for Lake County's denial of Timothy Barrett Sr.'s Florida Rule of Criminal Procedure 3.850 postconviction motion. The appellant appeared pro se; the State did not file a response brief. The appellate panel issued a per curiam affirmance with no written opinion beyond the disposition.

Trust Dispute Affirmed - Case 5D2025-0354

The Fifth District Court of Appeal of Florida affirmed the Circuit Court for Brevard County in a trust dispute, Case No. 5D2025-0354, involving William Ivan as trustee of the Bonnie Holder Ivan Trust and appellees Jeff Holder, Andrew Holder, and nominal parties. The per curiam opinion, consisting solely of the word 'AFFIRMED,' was issued April 21, 2026, with Justices Jay, Makar, and Kilbane concurring. No substantive legal analysis or reasoning was included in the appellate disposition.