

One Taser Deployment, a Fatal Fall, and Qualified Immunity: The Fifth Circuit Draws the Line Between Passive and Active Resistance
Navejas v. City of El Paso, No. 25-51061 (5th Cir. Oct. 8, 2026) United States Court of Appeals for the Fifth Circuit Affirmed — Summary judgment in favor of the officer and municipality. TL;DR The Fifth Circuit upheld qualified immunity for an El Paso police officer who deployed his Taser once against a 70-year-old man suffering from dementia and Alzheimer's disease during a domestic violence investigation. Although the man died after falling following the deployment, the co
9 min read


Smell of Marijuana, Traffic-Stop Timing, and Frisks: Fourth Circuit Upholds Gun Seizure
United States v. Carson, No. 25-4200 (4th Cir. July 8, 2026) TL;DR Police stopped a vehicle because the driver had a suspended license. Within seconds of arriving, another officer smelled marijuana coming from the vehicle and then observed a digital scale with white residue inside. Officers searched the vehicle and ordered the occupants out. One passenger, Jermaine Carson, was frisked. During the frisk, Carson told the officer he had a gun, and officers recovered a loaded Glo
8 min read


Your Phone at the Border: Fourth Circuit Says Manual Searches Require No Suspicion
United States v. Belmonte Cardozo, No. 25-4239 (4th Cir. July 13, 2026) TL;DR A traveler arriving at Washington Dulles International Airport from Bolivia was stopped for a customs inspection. A CBP officer asked him to unlock two iPhones. He complied. The officer manually opened the photo galleries, navigated to the phones’ hidden-photo folders, and discovered illegal images within approximately two minutes. The defendant moved to suppress, arguing that the significant privac
6 min read


