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ADAM GERICS,
Plaintiff-Appellant,
v.
ALEX TREVINO, also known as Felix Trevino; JOSEPH HALL; CITY OF FLINT, MICHIGAN; BOBBY FOWLKES,
Defendants-Appellees.
   No. 19-1955
Appeal from the United States District Court
for the Eastern District of Michigan at Detroit.
No. 2:15-cv-12922—Gershwin A. Drain, District Judge.
Decided and Filed: September 11, 2020
Before: DONALD, THAPAR, and NALBANDIAN, Circuit Judges.


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OPINION
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NALBANDIAN, Circuit Judge. Robert Frost once wrote, with a great deal of irony, that good fences make good neighbors. His point being that fences often create, and do not mend, divisions. But he likely didn’t have neighbors like Adam Gerics in mind. That Gerics did not get along with his neighbor Timothy Monahan is an understatement. But Gerics took those poor neighborly relations to another level by continuously and publicly shouting expletives and insults at Monahan over the course of three to five months before getting arrested for doing so. After the state court quashed the criminal charges against him, Gerics sued the arresting officer and others for damages in federal court. Gerics and Defendants cross-moved for summary judgment—arguing, as relevant here, about whether there was probable cause for Gerics’s arrest. The trial court denied both motions and set the case for trial. The jury eventually found in Defendants’ favor. Gerics now appeals the district court’s denial of summary judgment. Although we think that the probable-cause issue was not one for the jury, we DISMISS the appeal for lack of jurisdiction.



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HANOVER AMERICAN INSURANCE COMPANY,
Plaintiff-Appellee,
v.
TATTOOED MILLIONAIRE ENTERTAINMENT, LLC and CHRISTOPHER C. BROWN (19-5550 & 19-5551); JOHN FALLS (19-5483); DANIEL R. MOTT (19-5562),
Defendants-Appellants.
   Nos. 19-5483/5550/5551/5562
Appeal from the United States District Court
for the Western District of Tennessee at Memphis.
No. 2:16-cv-02817—Jon Phipps McCalla, District Judge.
Argued: July 28, 2020
Decided and Filed: September 11, 2020
Before: GUY, BOGGS, and WHITE, Circuit Judges.


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OPINION
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BOGGS, Circuit Judge. The House of Blues music studio in Memphis suffered a burglary and arson in November 2015. Chris Brown owned the House of Blues through Tattooed Millionaire Enterprises (TME). He and two tenants, John Falls and Daniel Mott, submitted insurance claims for the loss. But Brown submitted fraudulent documents in connection with this claim. That led to an insurance-fraud lawsuit and, eventually, this trio of appeals.

Two of the appeals are straightforward to resolve. Brown was found liable by a jury after admitting on the stand that he had forged documents submitted in his insurance claim. He now makes three weak arguments about the judge’s management of the trial and the admission of evidence. Mott lodges a two-line pro se brief that raises no issues on which relief can be granted. In each of these cases, we affirm the court below.

Falls’s case is different. Falls prevailed before the jury, only to have the judge set aside the verdict and direct a judgment for the insurance company under Federal Rule of Civil Procedure 50(b). Rule 50 is structured in two parts: (a) provides for the making of a motion for judgment as a matter of law at trial, and (b) provides for “Renewing the [50(a)] Motion after Trial.” But Hanover had failed to make a motion at trial for a directed verdict as to Falls under Federal Rule of Civil Procedure 50(a). Somewhat surprisingly, we have not expressly decided whether a party can make a Rule 50(b) motion if it has not previously made a Rule 50(a) motion. For the reasons discussed below, we now hold that this is impermissible. Therefore, Hanover forfeited its ability to “renew” a motion for a directed verdict after trial under Rule 50(b). We thus reverse the district court and remand with orders to reinstate the jury verdict as to Falls.



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RONRICO SIMMONS, JR.,
Petitioner-Appellant,
v.
UNITED STATES OF AMERICA,
Respondent-Appellee.
   No. 19-1757
Appeal from the United States District Court
for the Eastern District of Michigan at Bay City.
Nos. 1:14-cr-20628; 1:18-cv-12557—Thomas L. Ludington, District Judge.
Argued: August 5, 2020
Decided and Filed: September 11, 2020
Before: ROGERS, KETHLEDGE, and NALBANDIAN, Circuit Judges.


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OPINION
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NALBANDIAN, Circuit Judge. Deadlines matter, especially in habeas cases. So we require good excuses to overcome them. One valid excuse is when the government itself creates an unconstitutional impediment to a prisoner’s timely filing of a motion to vacate his sentence under 28 U.S.C. § 2255. That is what RonRico Simmons argues happened to him here. But he fails to allege facts that would establish that the supposed impediment to his late filing actually prevented him from filing earlier. Without a valid excuse, he filed his § 2255 motion too late. We AFFIRM.