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No. 25-6912October Term 2025Dismissed

Docket 25-6912October Term 2025 (2025–2026)

Thomas Bartholomew Simpson, Petitioner v. Joseph Walters, Director, Virginia Department of Corrections

from the United States Court of Appeals for the Fourth Circuit.

Case status

Current stage
Dismissed
Latest event
Dismissed
Decision timing
No window until argument is scheduled.
Case Accepted
Arguments
Decision Released
What it's about

from the United States Court of Appeals for the Fourth Circuit.

Question presented

1. Whether it requires the circuit court to probe lay witness testimony or specialist forensic analysis testimony to overcome foundational objections at a criminal trial to admission of text messages in order to protect Due Proces rights to a fair hearing in accordance with the Constitutional protections? 2. Whether prosecutorialmisconduct occurred by the state and lay witness giving improper expert testimony as to the foundation of the text messages in violation of Due Process? 3. Whether prosecutorial misconduct occurred by allowing witness to deny defendant the right to effectively cross-examination by giving misl&adihggjury of hisgcharacter and trustworthlyness?

Case path

United States Court of Appeals for the Fourth Circuit / Dismissed

Area

Dismissed Supreme Court case

Briefing

What it's about

Simpson is asking the Supreme Court to review a criminal-case dispute about whether text messages were admitted on an adequate foundation. He also argues that due process was violated by alleged prosecutorial misconduct, improper witness testimony, and limits on effective cross-examination.

Argument

The case is pending on a petition for certiorari (the Court's decision to hear the case), and oral argument has not been scheduled.

Impact

The case could affect how courts handle text-message evidence when a defendant says the proof behind it is too weak. For example, it matters when a trial judge must decide whether lay testimony is enough or whether more specialized forensic analysis is needed before jurors see the messages.

What is Thomas Bartholomew Simpson asking the Supreme Court to review?

He challenges how text messages were admitted at trial and says due process required stronger foundation, proper witness limits, and effective cross-examination.

Who could be affected if Simpson v. Walters is heard?

Criminal defendants, prosecutors, and trial judges could be affected when text messages are challenged and courts must decide what testimony is enough.

What happens next in Simpson v. Walters?

The justices must decide whether to grant certiorari (hear the case) or take another scheduling step. No oral argument is scheduled yet.

Grounding

Grounding
Primary materials plus reporting.
Note
Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.
Checked
Jul 23, 2026
Primary materials5
Context reporting3