Circuit Courts of Appeal Archives

Cameras, Commands, and Constitutional Boundaries: Second Circuit Examines Massimino v. Benoit

The United States Court of Appeals for the Second Circuit recently issued an opinion in Massimino v. Benoit, addressing whether officers can be granted qualified immunity for conducting an investigative detention of someone who is exercising their First Amendment right to record police activity from a public location. Summary of the Facts In October 2018, Keith Massimino conducted a “First Amendment audit” outside of

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When Terms of Service Act as Consent: Seventh Circuit Considers Cloud Storage in United States v. Blocker, 174 F.4th 587 (7th Cir. 2026)

The United States Court of Appeals for the Seventh Circuit recently examined United States v. Blocker, 174 F.4th 587 (7th Cir. 2026). This case highlights that agreeing to terms of service can constitute valid consent for a company to scan files and report illegal material to authorities. Summary of the Facts This case involves Dropbox, a commonly used cloud storage service that allows users

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No Excuses, No Ambiguity: Court Rules Traffickers Liable Even Without Actual Knowledge of Victim’s Age

The United States Court of Appeals for the Second Circuit recently released an opinion in United States v. Concepcion, No. 23-6337 (2nd Cir. 2025), a case that considers the scope of sex trafficking statutes and the application of mens rea terms. In October 2019, Martin Concepcion met Camilla Rodriguez, a 16-year-old runaway, near a Bronx bodega. Concepcion and his roommates invited Rodriguez, who claimed to be 18, to a liquor store and

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Bytes and Bounds: Holcomb’s Warning Against Unfettered Electronic Searches

The United States Court of Appeals for the Ninth Circuit issued a decision in United States v. Holcomb, 23-469 (9th Cir. 2025), where the Court considered “whether an individual can be prosecuted for despicable criminal conduct based on evidence obtained in violation of the United States Constitution. Ultimately, the Circuit wrote, “In the circumstances of this case, respect for the Constitution and the rule

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Dividing Lines: The Fourth Circuit’s Take on Geofence Warrants in United States v. Chatrie Amid Growing Circuit Split

In July 2024, the United States Court of Appeals for the Fourth Circuit issued an opinion in United States v. Chatrie, a case that could potentially make its way up to the Supreme Court of the United States, providing the High Court an opportunity to settle an existing circuit split over the constitutionality of geofence warrants as an investigative technique used by law enforcement.¹

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Midnight Missteps: The Limits of Reasonable Suspicion in Milla v. Brown

In the recent case Milla v. Brown, the United States Court of Appeals for the Fourth Circuit examined Fourth Amendment claims lodged against two officers for detaining and searching the plaintiff and his vehicle without adequate reasonable suspicion to justify the detention. After receiving an anonymous tip about a nearby stabbing, police in Fairfax, Virginia, responded to a gas station, which was reported to

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Clarifying Consensual Encounters and the Attenuation Doctrine: Analyzing Evidence Admissibility in United States v. Cade

The Seventh Circuit Court of Appeals recently considered United States v. Cade, a case that considers the Attenuation Doctrine in the context of a vehicle search and incriminatory statements. This case arose after the defendant, Brandon Cade, and a friend, T.J., caught the attention of two Chicago police officers while on patrol in a marked squad car. This interaction led officers to search the

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The Ninth Circuit Navigates the Thin Line Between Excessive Force and Family Rights in Waid v. County of Lyon

The Ninth Circuit Court of Appeals has recently rendered a decision in the case of Waid v. County of Lyon, a case that centers on claims of excessive force used by two law enforcement officers. This case emerged from an incident involving the officers’ response to a 911 call reporting domestic violence, which tragically resulted in the shooting of Robert Anderson. This case arose

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Sixth Circuit Upholds Evidence in US v. Daniel: Examining the Good-Faith Exception in Probable Cause

Today’s case comes to us from the Sixth Circuit Court of Appeals decision in US v. Daniel [1]. For today’s training, we will consider an officer’s reasonable reliance on probable cause in the context of a search warrant, while exploring the boundaries of the good-faith exception. This case made its way to the Sixth Circuit after the defendant, Alejandro Daniel, was indicted for conspiracy

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Deadlifts, De-escalation & Deadly Force: Ninth Circuit’s Deliberation on Qualified Immunity Amidst Gym Confrontation in Smith v. Agdeppa

The Ninth Circuit Court of Appeals, in the case of Smith v. Agdeppa, recently explored the parameters of qualified immunity in a case where two police officers faced an intense confrontation with a suspect at a Los Angeles Gym.1 The subsequent use of deadly force by Officer Edward Agdeppa led to legal action by the deceased’s mother, Paulette Smith. She contended that her son’s

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