Moonshine (Illegal Liquor) in Virginia

demonstration of moonshine making at Richmond Folk Festival, 2013
demonstration of moonshine making at Richmond Folk Festival, 2013

"Moonshine" is untaxed liquor. It can be manufactured from corn or other grains, but when they are not available potatoes or other starch-rich foods can be fermented to produce alcohol. In jail, raisins and other foods are used to make "jailhouse hooch."

Moonshine production starts with the mixing of grains, water, and yeast. Sugar can be added to provide more carbohydrates as food for the yeast, which convert the carbohydrates into alcohol and carbon dioxide. Carbon dioxide is boiled away as a waste product when making distilled liquor, but trapped to keep the fizz in beer and sparking wine (champagne).

Different moonshiners had their own recipes, often kept as close family secrets, for the percentages of different materials to mix together.

After between four days and two weeks of fermentation, the foam "cap" at the top of the mixture fades away. The liquid beer in the barrel will be 6-12% alcohol. The residue of grains at the bottom of the barrel might be processed a second time to extract any remaining carbohydrates, but eventually that slop is either discarded or used as livestock feed.

The liquid mash is poured into an enclosed boiler (designs varied) and heated. At 173°F, the alcohol vaporizes. That vapor rises to the top of the boiler and separates from the water, which does not boil until it reached 212°F. The alcohol vapor is captured in a pipe (the "worm") and cooled, condensing and dripping slowly into containers placed at the end of the piping.1

Legal production of different types of alcohol has increased substantially in the 21st Century. In 2012, the Virginia Department of Alcoholic Beverage Control had issued licenses for legal distilleries located in Albemarle County, Culpeper County, Fairfax County, Franklin County, James City County, Loudoun County, Norfolk, Richmond, Spotsylvania County, and Virginia Beach. Other distilleries existed in the state, but they were making illicit and untaxed moonshine.

By 2026, there were nearly 150 establishments with an Industry Distillery License issued by the Virginia Alcoholic Beverage Control Authority.2

The Bowman distillery in Spotsylvania County is the oldest legal distillery in Virginia, licensed at the end of Prohibition. The original distillery was built on the family's Sunset Hills Farm in 1935. As Reston developed and land values increased, the Bowman family moved the distillery to Spotsylvania County in 1988. It now produces Virginia Gentleman bourbon as well as other liquor in a converted clothing factory (the old FMC Cellophane plant that once produced the inner linings for men's suits) located downstream of Fredericksburg.3

Illegal distilleries or "stills" are concentrated in the rural mountainous counties. For years, far more sugar was sold in Franklin County than the local residents could ever eat.

Liquor manufactured without state permission is not taxed and is dramatically less expensive. Some moonshine might be shared with friends, families, and trusted customers near where it is manufactured, but the customers for moonshiners are primarily "nip joints" (unlicensed bars) in urban areas such as Richmond, Baltimore and Philadelphia. Untaxed liquor is typically sold at 50% of the cost of taxed products.

Moonshine has been sold since Prohibition to individuals in a Mason jar normally used for canning, sometimes with a peach on the bottom to give it a little bourbon-like color. For larger volume sales to nip joints, plastic one-gallon jugs are used to transport the alcohol.

"White lightning" is a clear fluid with an alcohol content comparable to grain alcohol, often above 100 proof. (200 proof is 100% alcohol.) It takes like unflavored vodka, and during Prohibition the cocktail/mixzed drink became popular to disguise the taste.4

Moonshine is not aged; unlike bourbon production, no wooden barrels are involved. Moonshine is sold as fast as the liquor is made, and has a raw burning flavor. The taste may be rough, but the alcoholic kick can be felt quickly. Mixing moonshine into a cocktail helps to disguise the rawness.

The quality of moonshine can be assessed by its ability to "hold a bead," so a bubble at the surface on the edge of a glass jar stays intact. High surface tension indicates a high percentage (proof) of alcohol, rather than a watered-down product. If the bead bursts too quickly, indicating a low-proof product, buyers of illegal moonshine should not expect to get their money back by calling the Better Business Bureau or the Virginia Department of Agriculture and Consumer Services.

State and Federal government agencies try to stop illegal production of alcohol in part to ensure that liquor is safe as well as taxed. Back in the early 1900's, when car radiators were used to condense the vaporized alcohol into a liquid, lead from the solder in the radiator ended in some moonshine at levels high enough to blind or kill the consumer.5

Moonshiners were most vulnerable to arrest when shipping their product to customers. The origins of NASCAR are linked with the development of skilled driving to elude revenue agents and transport the untaxed, illegal liquor from the mountains to the final market in coastal cities.

Franklin County in the Blue Ridge was considered the center of moonshining in Virginia in the 1900's. Moonshining was concentrated in the mountains for several reasons, but primarily because there's a centuries-old tradition of converting corn crops into whiskey to simplify transport for sale outside of the region. Race car drivers now circling around NASCAR tracks can trace the heritage of that sport to drivers carrying moonshine from mountain stills to market, using cars souped up to outrun government revenue agents.

NASCAR driver Junior Johnson described how he was motivated to modify cars to increase their speed while carrying a heavy load of Mason jars filled with illegal liquor:6

Moonshiners put more time, energy, thought and love into their cars than any racer ever will... Lose on the track and you go home. Lose with a load of whiskey and you go to jail.

not every moonshine transporter escaped the police
not every moonshine transporter escaped the police
Source: Library of Congress, Policeman standing alongside wrecked car and cases of moonshine (November 16, 1922)

The economic advantages of converting wheat and corn into liquid alcohol have been clear for centuries in Virginia. The roads in the Blue Ridge and on the Appalachian Plateau have always been poor due to the high cost of construction. Starting in the 1700,'s, farmers in the mountains who raised more than enough corn to feed their families and livestock found the cost of transporting their surplus crop to a market was too expensive. Once the bulky corn was concentrated into liquor and placed into barrels, the farmers could transport it and still make a profit - unless taxed too heavily.

in the 1900's, moonshine stills were located primarily in the mountains
in the 1900's, moonshine stills were located primarily in the mountains
Source: Library of Congress, Old "moonshine" still, Mt. Weather, VA (1914)

Whiskey taxes helped the first president of the United States define the power of the Federal government.

The farmers of Western Pennsylvania rebelled in 1794 against a Federal tax on whiskey, imposed by Congress at Alexander Hamilton's suggestion. The Federal government needed revenue to pay for the Revolutionary War debts absorbed by the Federal government from the states, in the compromise that had resulted in the capital being located on the Potomac River.

Two Virginians were key in suppressing the Whiskey Rebellion. George Washington assembled an army of over 10,000 troops - the largest force of "revenuers" ever created- to suppress what was portrayed as an armed rebellion against the new Federal government. The creation of the Confederacy in 1860-61 was not the first sectional threat to fragment the union of the United States.

The force that President Washington assembled was far more than necessary. Washington, Adams, and Hamilton wanted to ensure that the supremacy of the Federal government was clearly recognized.

Virginia Governor Henry "Light Horse Harry" Lee actually led the troops from Bedford, Pennsylvania into the western part of the state. At that point, the rebellion dissolved and pardons were quickly issued for most participants.7

Moonshining does occur indoors today, in city basements as well as outdoors in mountains hollows. There are more job opportunities in the cities, so there is less incentive for people in urban areas to tackle the hard work of making illegal whiskey there.

the folklore of moonshining focuses on settings in the mountains
the folklore of moonshining focuses on settings in the mountains
the folklore of moonshining focuses on settings in the mountains
Source: Library of Congress, Bud Getchin's ten-year-old has a scared-rabbit look-- he knows that he is confronting them Revenues and Home of a moonshiner

The distillation process requires substantial heat to boil the mash and vaporize the alcohol to separate it from the water in the mash. In the 1900's, mountaineers could use wood; it was a cheap and readily available fuel. One reason for "moonshining" at night, in mountain hollows illuminated just by moonlight, was to hide smoke from the eyes of informers and tax agents. Today, propane tanks offer a smoke-free alternative.

The term "moonshiner" is not uniquely Appalachian, though for many people the term conjures up an image of mountain hillbillies wearing overalls and holding a Mason jar or jug. Smugglers of brandy in the 1700's on the coast of England also took advantage of moonlight, and were known as "moonlighters" dealing with "moonshine."

Virginia outlawed the production of liquor in 1914. After Prohibition ended in 1931, state police and Federal agents were the primary "revenuers" seeking to enforce the law. Local officials, including elected sheriffs, were often associated with moonshiners and not inclined to enforce liquor laws. Rival operators would provide information to the agents in order to limit competition, revealing the locations of stills and the times when liquor was being transported.

state and Federal agents relied upon tips to find stills and capture moonshine being transported to market
state and Federal agents relied upon tips to find stills and capture moonshine being transported to market
Source: Library of Congress, Wanted information for you the taxpayer on the locations of bootleg stills (1949?)

Disguising the locations of stills included some ingenious creativity:8

In several instances stills were also set up in underground chambers covered with sod. Perhaps the most infamous of these was set up in Franklin County in the late 1970s. Moonshiners bulldozed a room-sized hole in a field, covered it with a sod roof, placed painted cinderblocks on top as fake headstones, mowed the “cemetery” regularly, and put flowers on some “graves.” Raiding the still in 1979, revenue agents estimated it ran for one or two years before they discovered it.

Amos Law was one of the most renowned moonshiners in Franklin and Pittsylvania counties. He sold to customers in Philadelphia, New York and Baltimore. He was charged with perjury after state and Federal agencies cooperated in Operation Lightning Strike. The agents broke up three moonshining rings that produced nearly 500,000 gallons of untaxed liquor between 1992-1999.

Amos Law claimed he had never hauled sugar or jugs for anybody. The jury found him not guilty, after his lawyer claimed he was confused by the question and that:9

You will find that Amos Law could not even spell the name of the street he lived on.

Amos Law trained his twin boys in the moonshining business. Son Henry eventually chose to get the necessary state permits and open a legal distillery in Franklin County to produce Law's Choice Wheat Whiskey.

Some traditional moonshiners became celebrities. In the docuseries "Moonshiners," the Discovery Channel highlighted Henry Law's stories of manufacturing illicit liquor from corn, wheat, barley, rye, and sugar in the Blue Ridge arount Rocky Mount, together with his sons.

The television show was one of many that emphasized the romantic culture of moonshining, but also revealed the challenging logistics and economics of the business. The Virginia Alcoholic Beverage Control Authority cooperated in the production of the Discovery Channel series, not expecting it to suggest that the activities reflected actual moonshining operations still occurring without the knowledge of the state agency.

state-run liquor stores in Virginia now sell Laws Choice whiskey - and collect all required taxes
state-run liquor stores in Virginia now sell Laws Choice whiskey - and collect all required taxes
Source: Virginia Alcoholic Beverage Control Authority, Law's Choice Wheat Whiskey

Henry Law used small-batch recipes from his father and grandfather, processed through two "doublers" or "thumper" barrels with a 60 feet long "worm" made of 2-inch copper pipe to condense the alcohol vapor. Rather than produce just 160-proof liquor and then dilute it with water, he mixed the lower-alcohol whiskey that was first to condense with the higher-alcohol last part of the run to get the 90-proof product he desired.

Henry Law was a third-generation distiller, but the first to produce legal and taxed liquor. The name Law's Choice echoed a decision he made after first asking his father to teach him the moonshining business, which at one point landed him in jail. Amos Law warned his son Henry about the risks of violating the state's alcohol laws:10

You're going to have gold around your neck, but shackles around your feet.

By the 1990's, large-scale moonshining operations were generating millions of dollars in revenue. Between 1999-2001, state and Federal agents implemented Operation Lightning Strike. The initiative abandoned the relatively mild enforcement procedures traditionally used to end illegal alcohol production, which was family-oriented and run by local individuals rather than members of the mob in big cities.

Operation Lightning Strike treated the business as equivalent to trafficking in drugs. Agents raided moonshine operations in Southwest Virginia, especially in Craig and Franklin counties. One target was the Helms Farmers Exchange in Rocky Mount, the town in Franklin County that is known as "the moonshine capital of the world." Over a four year period, the Helms Farmers Exchange had purchased over 500,000 one-gallon plastic jugs capable of holding $7 million worth of moonshine.

In the 1930's, moonshiners were "good ol' boys" using 50-gallon stills to make small batches. In the 1990's, they were using multiple 800-gallon stills to manufacture thousands of gallons of untaxed liquor each month. To avoid being captured by Federal agents, the moonshiners used night-vision goggles and two-way radios.

Harsh penalties to those convicted included seizing property and using laws against money-laundering to triple the potential time in jail to 15 years. The objective was to end the big business moonshine operations:11

Operation Lightning Strike revealed a multi-million-dollar ring supplying sugar and materials to make thousands of gallons of moonshine. Thirty people were charged and the local business source – reported to have sold enough sugar and materials to make 1.5 million gallons of illicit whiskey – was shut down.

Records seized from the Helms Farmers Exchange identified one purchaser, listed as Hat Man, buying far more material than was likely to be needed for any local legitimate business:12

...Hat Man bought 17,925 100-pound bags of sugar, paying close to $700,000, and 2,710 bundles of one-gallon containers for which he paid $42,000. With the sugar, the affidavit said, he could have produced 179,250 gallons of illegal liquor, worth $1.8 million at $10 a gallon.,/dd>

Operation Lightning Strike did not end moonshining in the Blue Ridge. In 2006, state and Federal agents raided a still that was producing over 1,000 gallons a week, generating an estimated $6,000 a week in profits.13

modern illegal stills are industrial operations operated indoors with propane tanks - and occasional fires
modern illegal stills are industrial operations operated indoors with propane tanks - and occasional fires
Source: North Carolina Department of Public Safety, ALE Agents Seize 200-Gallon Illegal Distillery Following Explosion and Fire in Wilkes County

Rather than try to erase their image as a moonshine haven in order to attract new businesses, Franklin, Patrick and Floyd counties have chosen to increase tourism by creating the Mountain Spirit: Virginia's Moonshine Heritage Trail.

The Blue Ridge Institute and Museum at Ferrum College proudly claims to have largest moonshine collection in the world. A still is displayed at Fairy Stone State Park, and the Helms Farmers Exchange was converted into the Moonshine Explosion museum.

In 1930, the building had included the repair shop of the Turner Motor Company. A moonshiner's Model T car was brought in, and the mechanic left it in the garage bay to cool down because the engine was hot from a recent chase by law enforcement. The car, loaded with flammable moonshine, caught fire. It burned through the wooden floor and the wreckage in the basement was used to create a modern museum display.

For the Moonshine Heritage Trail, the Virginia Tourism Corporation emphasizes the rugged character of the people and the mountains:14

Families passed down the art of distillation through generations, creating a rich cultural tradition around the craft. They used shine to barter and trade for life’s necessities, and shine was used for medicinal purposes and of course commerce. Despite the legal challenges of the prohibition era, moonshining persisted, and was ingrained in the fabric of our way of life in a manner that touched everyone.

Those traditions are preserved and celebrated in our festivals and museums, mountain music, craft and even stock car racing – but also our legal craft distilleries that pay homage to the resilience and resourcefulness of our people.

Wine and beer may be manufactured at home for person use. President Carter signed HR1337 on October 14, 1978, which changed Federal laws and legalized home beermaking. By 2026, there was still no equivalent legal authorization for distilling alcohol for personal use.

A federal permit and a separate permit from the Virginia Alcoholic Beverage Control Authority (ABC) are required. Federal law treats distilling without a license as a felony punishable by up to 5 years in prison, a fine of up to $10,000, or both:15

In order to legally distill spirits in the Commonwealth of Virginia, prospective distillers must obtain a Beverage Distilled Spirits Plant permit from the Alcohol and Tobacco and Trade Bureau (TTB) and a distillery license from Virginia ABC.

Two Federal courts reached separate decisions regarding the ability of the Federal government since 1868 to use its taxing authority to require a commercial license for distilling alcohol. In Ream v. U.S. Department of the Treasury, the Sixth Circuit decided the 1868 law was constitutional.

In McNutt v. U.S. Department of Justice, judges in the Fifth Circuit made the opposite decision. They ruled that the Federal constraint exceeded constitutional limits, in part because the two sections of Federal law prohibiting home distillation were not designed to raise revenue:16

Not only do they prohibit at-home distilleries, but in so doing, they amount to an antirevenue provision that prevents distilled spirits from coming into existence... The provisions operate to reduce revenue instead of raising it. This violates the Supreme Court's explanation of how the federal power of taxation work...

...preventing activity lest it give rise to tax evasion places no limit whatsoever on Congress's power under the taxation clause. In contrast, all of the other statutory provisions governing the manufacture, bottling, and labelling of distilled spirits exist to facilitate collection of taxes associated with the activity, not to prevent spirits from being distilled in the first place.

...Because these provisions tax nothing, and are distinct from the regulation of distilling alcoholic products that is permitted by federal tax law, they do not help Congress raise revenue. On the contrary, the statutes reduce revenue by preventing individuals from making distilled spirits.

...Logically, the Necessary and Proper Clause cannot expand the reach of the taxing power to criminalize conduct that could produce taxable revenue under the pretext that generating revenue for the federal government will be enhanced.

A decision by the US Supreme Court will be required to determine the constitutionality of the Federal law prohibiting home distilling.

The "ABC" of Legal Liquor in Virginia

Distilleries in Virginia

Prohibition in Virginia

as World War II was ending in Europe, the war on moonshine continued in Dickinson County
as World War II was ending in Europe, the war on moonshine continued in Dickinson County
Source: Library of Congress, Dickenson County herald (June 7, 1945)

Links

regions of Virginia outside of the Blue Ridge also highlight moonshine to stimulate tourism
regions of Virginia outside of the Blue Ridge also highlight moonshine to stimulate tourism
Source: City of Manassas, Steins, Vines and Moonshine Trail

References

1. "Moonshine: Blue Ridge Style," Blue Ridge Institute and Museum, Ferrum College, https://www.ferrum.edu/brim/exhibits/moonshine-blue-ridge-style/ (last checked September 20, 2026)
2. "2012 Establishments by License Category - Cities" and "2012 Establishments by License Category -Counties," 2012 Annual Report, Virginia Department of Alcoholic Beverage Control, http://www.abc.state.va.us/admin/annual/annual.htm; "Find a License," Virginia Alcoholic Beverage Control Authority, https://www.abc.virginia.gov/licenses/find-a-license (last checked September 19, 2026)
3. "Spirited museum in the works," Fredericksburg Free Lance-Star, October 3, 2010, http://fredericksburg.com/News/FLS/2010/102010/10032010/579324 (last checked October 27, 2013)
4. "Nip Joints," Virginia Department of Alcoholic Beverage Control, http://www.abc.state.va.us/facts/nipjoint.html (no longer online); "Cocktail History in America: Prohibition (1910s-1933)," Virginia Tech, https://guides.lib.vt.edu/c.php?g=387023&p=3016455; "NASCAR's Moonshine Roots," NASCAR, February 10, 2023, https://www.nascarhall.com/blog/nascars-moonshine-roots; "White Lightning: What Was, What Is, What Really Isn't," Blue Ridge Country, April 25, 2013, https://blueridgecountry.com/general/moonshining-what-was-what-is-what-really-isnt/; "Moonshine: Blue Ridge Style," Blue Ridge Institute and Museum, Ferrum College, https://www.ferrum.edu/brim/exhibits/moonshine-blue-ridge-style/ (last checked September 20, 2026)
5. "Distillation Safety – Things To Know Before You Start Distilling," Moonshine Distiller, December 31, 2013, https://moonshinedistiller.com/distilling-info/distillation-safety/ (last checked November 20, 2023)
6. "NASCAR's Moonshine Roots," NASCAR, February 10, 2023, https://www.nascarhall.com/blog/nascars-moonshine-roots (last checked November 20, 2023)
7. "The Whiskey Rebellion," Mount Vernon, http://www.mountvernon.org/educational-resources/encyclopedia/whiskey-rebellion (last checked October 27, 2013)
8. "Moonshine: Blue Ridge Style," Blue Ridge Institute and Museum, Ferrum College, https://www.ferrum.edu/brim/exhibits/moonshine-blue-ridge-style/; "U.S. Cracks Down on Rise In Appalachia Moonshine," New York Times, March 23, 2000, https://www.nytimes.com/2000/03/23/us/us-cracks-down-on-rise-in-appalachia-moonshine.html (last checked September 20, 2026)
9. "Franklin County moonshine legend Amos Law dies at 83," The Roanoke Times, February 11, 2019, https://www.roanoke.com/news/local/franklin_county/franklin-county-moonshine-legend-amos-law-dies-at/article_97cb9edd-7d66-504c-bf2b-17a4694c8a84.html (last checked April 5, 2020)
10. "Offering 'Law's Choice," Franklin News-Post, July 3, 2017, https://www.thefranklinnewspost.com/news/offering-law-s-choice/article_49ccac48-5fed-11e7-bfa9-53486a5e5e97.html; "Franklin County moonshine legend Amos Law dies at 83," The Roanoke Times, February 11, 2019, https://www.roanoke.com/news/local/franklin_county/franklin-county-moonshine-legend-amos-law-dies-at/article_97cb9edd-7d66-504c-bf2b-17a4694c8a84.html; "Once an outlaw, a moonshiner reckons with a changing craft," Washington Post, September 5, 2026, https://www.washingtonpost.com/nation/2026/09/05/familys-moonshine-survived-raids-prison-can-its-outlaw-spirit-endure/; "White Lightning: What Was, What Is, What Really Isn't," Blue Ridge Country, April 25, 2013, https://blueridgecountry.com/general/moonshining-what-was-what-is-what-really-isnt/ (last checked September 20, 2026) 11. "U.S., Va. Agents Raid Moonshine Operation," Washington Post, May 9, 1999, https://www.washingtonpost.com/archive/local/1999/05/09/us-va-agents-raid-moonshine-operation/fe9a6d87-54f1-460d-a89c-3ef1f4f6eccf/; "U.S. Cracks Down on Rise In Appalachia Moonshine," New York Times, March 23, 2000, https://www.nytimes.com/2000/03/23/us/us-cracks-down-on-rise-in-appalachia-moonshine.html; "Who deserves the title of moonshine capital? Join the debate in Martinsville," Cardinal News, April 3, 2024, https://cardinalnews.org/2024/04/03/who-deserves-the-title-of-moonshine-capital-join-the-debate-in-martinsville/; "Anyone can claim it but only one can be it: Franklin County takes moonshine capital title," Cardinal News, April 5, 2024, https://cardinalnews.org/2024/04/05/anyone-can-claim-it-but-only-one-can-be-it-franklin-county-takes-moonshine-capital-title/ (last checked September 20, 2026)
12. "U.S. Cracks Down on Rise In Appalachia Moonshine," New York Times, March 23, 2000, https://www.nytimes.com/2000/03/23/us/us-cracks-down-on-rise-in-appalachia-moonshine.html (last checked September 20, 2026)
13. "Va. moonshiners, agents still tangle in cat-and-mouse game," , January 12, 2008, https://www.southcoasttoday.com/story/news/nation-world/2008/01/13/va-moonshiners-agents-still-tangle/52650857007/ (last checked September 20, 2026)
14. "'A dying art': New moonshine trail to offer an intoxicating taste of the region's storied history," Cardinal News, May 7, 2024, https://cardinalnews.org/2024/05/07/moonshine-trail-will-offer-a-taste-of-the-illicit-liquors-history-and-of-the-spirit-itself/; "Virginia's Mountain Spirit - Moonshine Heritage," Life in SoVA, https://www.lifeinsova.com/mountainspirittrail/ (last checked September 20, 2026)
15. "The Long Journey to Homebrew Legalization," American Homebrewers Association, https://homebrewersassociation.org/news/long-journey-homebrew-legalization/; "Distillery," Virginia Alcoholic Beverage Control Authority, https://www.abc.virginia.gov/licenses/val/definitions/distillery; "Section 4.1-314. Keeping, possessing, or storing still or distilling apparatus without a permit; penalty," Title 4.1. Alcoholic Beverage and Cannabis Control - Subtitle I. Alcoholic Beverage Control Act - Chapter 3. Prohibited Practices; Penalties; Procedural Matters - Article 1. Prohibited Practices Generally, Code of Virginia, https://law.lis.virginia.gov/vacode/title4.1/chapter3/section4.1-314/; "Home Distilling," Alcohol and Tobacco and Trade Bureau, Department of Homeland Security, https://www.ttb.gov/regulated-commodities/beverage-alcohol/distilled-spirits/penalties-for-illegal-distilling; "Tax Rates," Alcohol and Tobacco and Trade Bureau, Department of Homeland Security, https://www.ttb.gov/taxes/tax-audit/tax-and-fee-rates#ds (last checked September 20, 2026)
16. "Breaking News- Home Distilling May Head to the Supreme Court!," Hobby Distillers Association, July 20, 2026, https://hobbydistillersassociation.com/2026/07/20/breaking-news-home-distilling-may-head-to-the-supreme-court/; "McNutt v. U.S. Department of Justice," US Fifth Circuit Court of Appeals, April 10, 2026, p.12, p.13, p.17, p.22, https://www.ca5.uscourts.gov/opinions/pub/24/24-10760-CV0.pdf (last checked September 20, 2026)


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