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Seventh Circuit Splits Over Whether to Vacate a District Court Order Against Federal Immigration Agencies Upon a Fed. R. App. P. 42(b)(2) Voluntary Motion to Dismiss

In Chicago Headline Club v. Noem, No. 25-3023 (7th Cir. Mar. 5, 2026) (per curiam), a Seventh Circuit panel issues a 2-1 decision ordering that, as part of granting the government’s voluntary dismissal of its appeal under Fed. R. App. P. 42(b), the underlying order on appeal be vacated. The case arose from the surge…

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Second Amendment Claim Against State Court Judge Properly Dismissed for Lack of Adversity Under Article III, Holds Second Circuit

In Kellogg v. Nichols, No. 23-8093 (2d Cir. Mar. 5, 2026), the Second Circuit affirms dismissal of a gun-rights case filed against a state court judge who serves as a statutory firearms licensing officer, both on absolute immunity and Article III grounds. The plaintiffs sued “New York state court Judge Jonathan D. Nichols,” in his…

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Sixth Circuit Reverses a District Court for Exercising Supplemental Jurisdiction and Granting Summary Judgment on a Novel Michigan State-Constitutional Claim

In Williams v. Addison Cmty. Schs., No. 25-1205 (6th Cir. Mar. 2, 2026), the Sixth Circuit issues a rare published opinion reversing a district court for exercising supplemental jurisdiction (28 U.S.C. § 1367(a)), here over a Michigan state-law claim that raised issues of first impression. Plaintiff Williams was removed as President of the Addison Community…

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