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Fourth Circuit: Error in Granting Judgment Prior to Adjudging Spoliation Motion
by David Reutter
The U.S. Court of Appeals for the Fourth Circuit reversed a grant of summary judgment while a dispositive spoliation of evidence motion was pending. The spoliation motion sought sanctions for the failure to produce video of the incident at issue.
While imprisoned in July …
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More from this issue:
- L.A. County Begins Making Nearly $5 Billion in Payouts to Survivors of Sex Abuse in Juvenile Detention, by Chuck Sharman
- “Nothing Short of Disgraceful”: New York Prisoner Wins Injunction Ordering Cancer Treatment Delayed Seven Years, by Chuck Sharman
- Wave of Staff Arrests Exposes Persistent Misconduct at South Carolina Jail, by Jo Ellen Nott
- GAO Report on ICE Jail in Fort Bliss Finds Independent Failures, by Michael Thompson
- North Carolina’s “Iryna’s Law” Leads to Jail Overcrowding, by Michael Thompson
- HRDC Wins Injunction Against Minnesota DOC Policy Banning Its Publications, by Chuck Sharman
- $100,000 Paid to Five Prisoners Assaulted by Centurion Gynecologist at Florida Lockup, by Chuck Sharman
- BOP Denies Providing Substandard Dialysis Treatment Despite Prisoners’ Deaths, Court Filings, Understaffing and Lack of Oversight, by Douglas Ankney
- Pennsylvania Supreme Court Ends Mandatory Life Without Parole Sentence for Felony Murder, by David M. Reutter
- Mississippi DOC Held Mentally Unwell Prisoners in Solitary, Many Died Because of It, by Michael Thompson
- Florida DOC Rebuked for Seizing Prisoner’s Excessive Force Settlement to Cover Incarceration Liens, by Chuck Sharman
- Fourth Circuit: Error in Granting Judgment Prior to Adjudging Spoliation Motion, by David Reutter
- $800,000 Settlement Reached in Hawai‘i Jail Suicide Case, by Chuck Sharman
- $280,000 Paid for South Carolina Detainee’s Death in Charleston Jail, by Chuck Sharman
- Washington DOC Barred from Putting Prisoners on Lockdown and Calling It “Programming”, by Chuck Sharman
- Eight Circuit Reverses Denial of Partial Qualified Immunity in Detainee’s Pepper Ball Claim, Remands Excessive Force Claims, by David Reutter
- Fourth Circuit Affirms Qualified Immunity in Strip Searches Resulting from Anonymous Tips, by David Reutter
- Idaho Legislature Moves to Hide Execution Protocol from Judicial Scrutiny, by Douglas Ankney
- Delaware’s Lack of Prison Healthcare Oversight, by Michael Thompson
- Four Massachusetts Guards Face Charges for Assault on Prisoners During Brawl, by Jo Ellen Nott
- News in Brief
- $5.4 Million Jury Verdict Against Riverside County in Suit Over Jail Fentanyl Death, by Chuck Sharman
- Atlanta Jail Begins Turning Away Misdemeanor Arrestees, by Chuck Sharman
- New ICE Detention Standards Appear Designed to Help GEO Group Avoid Paying Wages, by Chuck Sharman
- Nevada Prisoners, Families Call Out Predatory Tablet Program, by David Reutter
- Report Highlights Repeated Overdoses at Florida County Jail, by Michael Thompson
- Alabama Lawmaker Holds Up $38 Million in Payments to Department of Corrections Attorney Sanctioned for AI-Written Brief, by Chuck Sharman
- Mental Health Diversion from New York State Jails Varies Widely by County, by Michael Thompson
- New Commission to Investigate Death and Abuse of 230 Black Children at Segregated Maryland Reformatory, by Jo Ellen Nott
- New Jersey Court Rules That Denial of Transgender Prisoner’s Transfer Request Violates Neither Discrimination Law nor Equal Protection Clause, by Douglas Ankney
- Last of 11 Guards Sentenced in Death of New York Prisoner, by Chuck Sharman
- Rising Deaths in Los Angeles County Jail Linked to Longer Stays, by Michael Thompson
- What 911 Calls Reveal About Jail Operations, by Michael Thompson
- New Connecticut Law Changes PREA Standards, by Michael Thompson
- States Claim to Invest in “Humane” New Prisons— But Prisons Were Never Humane, by Erica R. Meiners
- Isolation and Medical Neglect at Illinois’ Joliet Treatment Center Drive Prisoners to Set Fatal Fires, by Jo Ellen Nott
- Court Shuts Down Arizona Attempt to Fill Medical Staff Vacancies with Under-Qualified Providers, by Chuck Sharman
- Illinois Prisons Have Gone a Year Without Long-term Healthcare Contract, by Chuck Sharman
- Utah Relocates Prisoners Amid Largescale Wildfire
- Report Highlights Shortage of Wheelchairs at Michigan Women’s Prison, by Michael Thompson
- $500,000 for Mentally Ill Detainee Beaten by Guard at Ohio Jail, by Chuck Sharman
- BOP Deputy Director and Former Prisoner Resigns After Just One Year
- $3 Million Paid by San Diego County for Diabetic Detainee’s Jail Death; NaphCare Settles Separately for Undisclosed Amount, by Chuck Sharman
- California Grand Jury Report on Deaths at Riverside County Jails, by Michael Thompson
- Court-Ordered Report on Jail Voting in Massachusetts Finds Low-Rate, by Michael Thompson
- Michigan DOC Legal Payouts Top $7 Million in FY 2025, Less than One Percent of $2.15 Billion Operating Budget, by Jo Ellen Nott
- California’s Use of Jailhouse Stings Comes Under Scrutiny, by Michael Thompson
- Florida Kills Two Prisoners on Same Day, Both Elderly, by Jo Ellen Nott
- Troubled Illinois Lockup Sees Guard Abuses, Prisoners on Hunger Strike, by Jo Ellen Nott
- Ohio Finds Guards and Medical Staff Failed to Render Life-Saving CPR to Detainee, by Jo Ellen Nott
- $11 Million Paid by Boston to Exonerated Prisoner for 37-Year Wrongful Incarceration, by Chuck Sharman
- Federal Court Upholds Consultants’ Finding that Oklahoma Is Not Honoring Its Consent Decree to Provide Mental Health Treatment, by Douglas Ankney
- Oklahoma Prisoners Made Political Calls for Conservative Super PAC
- $75 Million CoreCivic Contract to Reopen Minnesota Private Prison Creates Resistance from Activists and Lawmakers, by Jo Ellen Nott
- From the Editor, by Paul Wright
- The GEO Group Pays California $104,510 to Settle Workplace Safety Charges at ICE Detention Facility—Where Local Cops Won’t Investigate Crimes, by Chuck Sharman
- Hawai‘i Pays $600,000 for Prisoner’s Withdrawal Death, by Chuck Sharman
- Severely Ill Prisoners in Hawai‘i Denied Early Release Due to State Policy, by Michael Thompson
More from David Reutter:
- Eight Circuit Reverses Denial of Partial Qualified Immunity in Detainee’s Pepper Ball Claim, Remands Excessive Force Claims, Sept. 1, 2026
- Nevada Prisoners, Families Call Out Predatory Tablet Program, Sept. 1, 2026
- Fourth Circuit: Error in Granting Judgment Prior to Adjudging Spoliation Motion, Sept. 1, 2026
- Fourth Circuit Affirms Qualified Immunity in Strip Searches Resulting from Anonymous Tips, Sept. 1, 2026
- Tenth Circuit: Colorado Governor Unentitled to Eleventh Amendment Immunity on Claim Related to DOC Religious Policies, Aug. 1, 2026
- Michigan Appeals Court: Witnesses Cannot be Forced to Wear Jail Clothes at Trial, Aug. 1, 2026
- Sixth Circuit Affirms Denial of State-Law Qualified Immunity in Scabies Case, Aug. 1, 2026
- Fourth Circuit Revives Disabled Prisoner’s Claim for Denial of Out-of-Cell Exercise Time, Aug. 1, 2026
- Sixth Circuit Announces State-Law Exceptions to Appeal Deadlines Preserve “Pending” Status Under AEDPA, Holding Belated-Appeal Procedures Toll Federal Habeas Limitations Period, April 1, 2026
- Florida Supreme Court Announces Rule 3.170(f)’s Good-Cause Plea-Withdrawal Standard Does Not Apply at Post-Appeal Resentencing, April 1, 2026
More from these topics:
- California Court of Appeal Finds Trial Court Abused Discretion in Denying Prisoner Compassionate Release and Reverses Order, Oct. 1, 2026. Abuse of Discretion Standard, Insufficiency of the Evidence, Statutory Construction/Interpretation, Compassionate Release.
- Eleventh Circuit Revives Pro Se Litigant’s § 1983 Lawsuit Despite His Three Strike Status Under the PLRA, Oct. 1, 2026. Filing Fees (PLRA), Frivolous Litigation (PLRA), Complaints, Abuse of Discretion Standard, Pro Se Issues.
- Tenth Circuit Vacates Award of Costs to Prison Officials, Revives Prisoner’s Claim Alleging Denial of Access to Functioning Toilets and Exposure to Other Prisoners’ Feces, Oct. 1, 2026. Plumbing, Sanitation, Summary Judgment, Costs, Deliberate Indifference.
- Eleventh Circuit Reinstates Alabama Prisoner’s Excessive Prison Violence Claim, Oct. 1, 2026. Failure to Protect (General), Staffing, Security Systems, Summary Judgment, Deliberate Indifference.
- Ninth Circuit Reverses Dismissal of Prisoner’s ADA Complaint Alleging Denial of Toileting and Hygiene Services, Oct. 1, 2026. Disabled Prisoners, Hygiene Supplies, Summary Judgment, Americans with Disabilities Act, Deliberate Indifference.
- Florida DOC Rebuked for Seizing Prisoner’s Excessive Force Settlement to Cover Incarceration Liens, Sept. 1, 2026. Summary Judgment, Settlements, Seizure of Prisoner Funds, Trust Accounts, 42 U.S. Code § 1983, civil action for deprivation of rights.
- Idaho Legislature Moves to Hide Execution Protocol from Judicial Scrutiny, Sept. 1, 2026. Disclosure of Records, Discovery, Public Records, State Legislation, Method of Execution.
- $500,000 for Mentally Ill Detainee Beaten by Guard at Ohio Jail, Sept. 1, 2026. Guard Brutality/Beatings, Summary Judgment, Settlements, 42 U.S. Code § 1983, civil action for deprivation of rights, Monell Liability.
- Ohio Supreme Court Announces Postconviction DNA-Testing Orders Need Only Identify Statutory Reason to Satisfy R.C. 2953.73(D) “Reasons” Requirement, Sept. 1, 2026. DNA Testing/Samples, Abuse of Discretion Standard, Statutory Construction/Interpretation.
- Seventh Circuit Upholds Summary Judgment Against Former Illinois Prison Guards Challenging Termination for Violating Use of Force Policy, Aug. 1, 2026. Guard Misconduct, Pepper Spray/Tear Gas, Summary Judgment, Employee Litigation, Vagueness/Overbreadth.

