Verdict . News

Fifth Circuit Court of Appeals

5th Circuit Certifies LLC Exemption Question to Texas Supreme Court

The U.S. Court of Appeals for the Fifth Circuit has certified a crucial bankruptcy law question to the Texas Supreme Court in *Canada v. Sherman*, asking whether interests in limited liability companies under Texas law qualify as exempt property in federal bankruptcy proceedings.

•Fifth Circuit certifies LLC exemption question to Texas Supreme Court in Canada v. Sherman case

•Issue centers on whether Texas LLC interests are protected from creditors in federal bankruptcy

Sixth Circuit Court of Appeals

6th Circuit Rules in Michigan Prisoner Habeas Case Borns v. Chrisman

The U.S. Court of Appeals for the Sixth Circuit issued a published opinion February 11 in Clarence Borns v. Troy Chrisman, a habeas corpus case involving a Michigan state prisoner convicted of assault with intent to murder and illegal gun possession. The appellate court's decision to recommend the case for publication indicates its precedential value for future prisoner rights litigation.

•Sixth Circuit published precedential opinion in Michigan prisoner's habeas corpus case

•Case involves convictions for assault with intent to murder and illegal gun possession

Sixth Circuit Court of Appeals

6th Circuit: District Courts Must Rule on ALJ Decisions Before Remand

The Sixth Circuit Court of Appeals ruled that federal district courts cannot remand Social Security disability cases to the Social Security Administration without first explicitly affirming, modifying, or reversing the Administrative Law Judge's decision. The court vacated a lower court's remand order in *Pamela J. Follen v. Commissioner of Social Security*.

•Sixth Circuit ruled district courts must explicitly affirm, modify, or reverse ALJ decisions before remanding Social Security cases

•Court vacated district court's remand order for failing to make required statutory determination

Seventh Circuit Court of Appeals

7th Circuit Affirms Equal Coverage Priority in Fatal Truck Crash Case

The U.S. Court of Appeals for the Seventh Circuit affirmed a district court ruling that Great West Casualty Company and Nationwide Agribusiness Insurance Company have equal payment priority for coverage in a fatal tractor-trailer collision that killed Patrick J. Brennan near Sycamore, Illinois.

•Seventh Circuit affirmed equal payment priority between Great West Casualty and Nationwide Agribusiness for fatal truck crash coverage

•The dispute arose from a June 2021 collision near Sycamore, Illinois that killed Patrick J. Brennan in a side-impact crash

Ninth Circuit Court of Appeals

9th Circuit Denies GEO Group Rehearing in Washington Detention Law Case

The Ninth Circuit Court of Appeals denied GEO Group's petition for panel rehearing and en banc review in a case challenging Washington's House Bill 1470, which regulates conditions at immigration detention facilities. The court previously vacated a lower court's preliminary injunction that would have blocked enforcement of the state law.

•Ninth Circuit denied GEO Group's petition for panel rehearing and en banc review of Washington's HB 1470

•Court previously vacated preliminary injunction blocking state law protecting civil detainees at immigration facility

Eleventh Circuit Court of Appeals

11th Circuit Rules on FLSA Settlement Standards in CBD Franchise Case

The U.S. Court of Appeals for the Eleventh Circuit issued a published decision in *Thomas O'Neal v. American Shaman Franchise Systems, Inc.*, addressing how Fair Labor Standards Act claims can be settled when combined with other legal claims. The case involves a franchisee dispute with the CBD American Shaman franchise system.

•Eleventh Circuit clarifies FLSA settlement standards when combined with other legal claims

•Case involves CBD American Shaman franchise system and employment-related dispute

Federal Circuit Court of Appeals

Federal Circuit Rules on Vaccine Injury Claim in Gamboa-Avila v. HHS

The U.S. Court of Appeals for the Federal Circuit issued a decision in *Gamboa-Avila v. HHS*, a case involving a National Vaccine Injury Compensation Program claim alleging that a pneumococcal vaccine caused Guillain-Barré Syndrome. The court addressed causation standards for off-Table vaccine injury cases.

•Federal Circuit addressed causation standards for off-Table vaccine injury claims under the National Vaccine Injury Compensation Program

•Petitioner alleged pneumococcal conjugate vaccine caused Guillain-Barré Syndrome but failed to prove causation at trial level

State Court

New York Court of Appeals

NY Court of Appeals Reverses Tenant Rights Decision in Aras v. B-U Realty

The New York Court of Appeals reversed a lower court decision in Aras v. B-U Realty Corp., clarifying that tenants need not prove all elements of common-law fraud to invoke the fraud exception under rent stabilization law. The February 11, 2026 ruling builds on the court's 2025 Burrows decision.

•Court of Appeals reversed lower court decision, finding improper application of fraud exception standards

•Tenants need only show "sufficient indicia of fraud" rather than prove all elements of common-law fraud

State Court

New York Court of Appeals

NY Court of Appeals Reverses Zoning Variance Decision in Lake Luzerne

The New York Court of Appeals reversed an Appellate Division ruling and reinstated a lower court decision that upheld a zoning board's denial of an area variance application. The state's highest court found that the Town of Lake Luzerne Zoning Board of Appeals acted rationally in denying Lisa Williams' variance request.

•Court of Appeals reversed Appellate Division and reinstated zoning board's denial of area variance

•Zoning board's decision deemed rational and not arbitrary or capricious under Town Law standards