United States v. Glenn Griffin — 2d Cir. (Oct 21, 2026)

The Sixth Circuit hears Kristina McClure’s appeal over her brother Colton’s death after detention in Trumbull County, Ohio. Colton entered the jail visibly intoxicated. During his detention, he showed prolonged agitation and difficulty standing. Staff performed intake checks and placed him under observation, but his estate says a later requested medical examination was never completed. He was eventually taken to a hospital, where he died. Kristina, his sister and estate administrator, sued jail officials and medical providers. The district court granted the defendants summary judgment, ending the claims without a trial. The appeal asks whether the evidence, viewed in the estate’s favor, could allow a jury to find a constitutional violation. It is not a jury verdict about whether the defendants caused his death. Deliberate indifference requires knowing of a substantial risk of serious harm and disregarding it, not simply providing negligent care. The Sixth Circuit recently restored that actual-knowledge standard in Poynter. Knowledge can be inferred from circumstances; an official need not admit recognizing the risk. The panel will consider whether the district court should apply the standard again on remand, meaning a return to the lower court. Adam Winn, for the estate, will argue that the prolonged symptoms and the officers’ own testimony permit a jury to find they recognized a need for care. John McLandrich, for the officers, will argue that they did not recognize a medical emergency and sought medical assistance. John Latchney, for the medical defendants, will argue that an examination could not safely be completed and that the conduct was not unconstitutional. For the officers, qualified immunity also asks whether the right was clearly established when these events occurred. The judges will separately consider Ohio medical-malpractice claims. Supplemental jurisdiction allows a federal court to hear related state-law claims. But after dismissing all federal claims, it may decline to decide the state claims. The parties disagree about whether the district court should have decided them here.

The Second Circuit considers who should receive the proceeds of Cecile Gold’s life insurance policy. In 2007, the policy was arranged through a trust, with borrowed money paying the premiums. It later passed to outside investors. After Gold died in 2022, her estate and Wells Fargo, acting for an investment fund, claimed the death benefit. The lower court found that the arrangement was intended from the outset to benefit strangers without an insurable interest. But it still ruled against the estate because Gold had participated in, and benefited from, the arrangement. Her estate now appeals. An insurable interest is a recognized stake in someone’s continued life, such as a family relationship or financial interest. The requirement guards against insurance being created as a wager on a stranger’s death. That is different from selling a policy that was valid when issued. Wisconsin law does not automatically invalidate a policy for lacking insurable interest. Instead, section 631.07 allows a court to redirect the money to someone equitably entitled to it. Equitable entitlement means the claimant must establish a fair legal basis for receiving the proceeds, not merely point out the original policy’s defect. Matthew Bleich, for the estate, will argue that using Gold’s participation to bar recovery undermines the law’s protection against wagering. Andrew Dykens, for Wells Fargo, will argue that the estate stands in Gold’s position and cannot collect after she participated and benefited. The doctrine of unclean hands can deny equitable relief because of a claimant’s own wrongdoing connected to the transaction. The dispute is what conduct should trigger that bar, and how it fits this statute.

The Ninth Circuit hears Herbert Redholtz’s challenge to searches of his email. He pleaded guilty to distributing, receiving and possessing child sexual abuse material. He admitted using his personal email account to store and exchange the material. The appeal concerns whether the government obtained and kept that evidence lawfully. His lawyer seeks suppression, meaning exclusion of evidence from the criminal case. The discussion turns on two warrants, issued five years apart. James Flynn, for Redholtz, will argue that investigators kept a copy of the email account without completing the first warrant’s required separation of relevant and unrelated records, or obtaining an extension. Amanda Elbogen, for the United States, will argue that the investigation paused and a new warrant lawfully authorized the later search. These are contested accounts of what the warrants allowed. There is also a dispute about the original basis for searching. A hash is a digital signature used to compare images. A match can link an image to a reference image; the parties disagree about what the judge was told about how the reference material had been classified. Probable cause requires a fair probability that evidence of a crime will be found, not proof beyond a reasonable doubt. It must rest on information presented to the judge, not facts learned later. The Fourth Amendment protects against unreasonable searches and seizures. The panel will ask whether limits in an email warrant constrain how long the government may hold data, and whether a later warrant resolves any earlier violation. The judges will also ask whether any violation calls for excluding the evidence. A prosecution’s deadline, or statute of limitations, is different from the constitutional limits on the search itself.

The Sixth Circuit considers a man’s death in a Michigan county jail. Christopher Fisher arrived at the Clinton County jail appearing normal and denying drug use. Later, video showed him becoming unsteady and struggling to stay awake. He was found unresponsive the next morning; an autopsy attributed his death to methamphetamine and fentanyl overdose. His estate says jail officers should have recognized a medical emergency and obtained help. The officers dispute what they saw and knew. The district court allowed the claim against two officers to continue, finding factual disputes rather than deciding they were liable. Those officers appealed the denial of qualified immunity. That protection bars a civil damages claim unless the officers violated a right that was clearly established at the time. Here, that means asking both whether their response violated the Constitution and whether existing law clearly warned them that this conduct was unlawful. A recent Sixth Circuit decision, Poynter, makes actual knowledge central. Deliberate indifference requires knowing of a substantial risk of serious harm and disregarding it, not simply failing to exercise reasonable care. The judges will consider whether to return this case to the district court to apply that standard, or resolve the immunity question now. On this appeal, disputed facts must be viewed in the estate’s favor; that is not a finding that its account is true. Kevin Campbell will argue for the officers that the behavior shown was not the unmistakable emergency seen in earlier cases, and that those decisions did not clearly establish liability here. Christopher Desmond, for Fisher’s estate, will argue that the officers’ training, their proximity to the cell and the video permit a jury to infer they recognized the danger. The disagreement is about what each officer knew, and what the law required them to do.

The D C Circuit considers a dispute about oversized packages and the Postal Service’s duty to follow its own rules. Mark Edwards had received large parcels at his front door. The Postal Service ended that delivery, citing how far his home was from the carrier’s route. Edwards said the change violated the Postal Operations Manual and unfairly treated him differently from neighbors. He asked the Postal Regulatory Commission to order delivery resumed. The Commission examined and rejected his discrimination claim, but said it lacked authority to hear a separate claim that the Postal Service had violated the Manual. That authority, or jurisdiction, is the focus of this argument. Permission to hear the claim would not itself mean Edwards wins or gets home delivery restored. Section Thirty-Six Sixty-Two allows complaints about specified statutes, or regulations promulgated under them. Promulgated means formally issued. One listed provision, Section Four Oh One, paragraph Two, gives the Postal Service general rulemaking power. Both sides accept that the Manual is a Postal Service regulation. They disagree about which regulations Congress made enforceable through this complaint process. Kathleen Choi is a court-appointed amicus, a lawyer assisting the court, in support of Edwards. She will argue that the statute covers the Manual because it was issued under the Postal Service’s rulemaking authority. The Commission’s lawyer will urge a narrower reading: rules implementing the particular statutes Congress listed, not every operational rule the Postal Service adopts. Edwards seeks a remand, meaning a return to the Commission to consider his claim.