U.S. Court of Appeals for the Fourth Circuit - Justia Case Law Summaries

US v. Carson

2026-07-08T10:30:41-08:00

Officers responding to reports of suspected drug activity at a public housing development in Asheville, North Carolina, began surveilling individuals frequenting the area. One individual, Jermaine Derrick Carson, Jr., was observed as a passenger in a vehicle whose driver had a suspended license. Weeks later, during a joint law enforcement operation targeting crime near downtown bars, officers recognized the same vehicle at a gas station and initiated a traffic stop before it returned to the housing complex. During the stop, officers detected the odor of marijuana and observed drug paraphernalia in the car. Carson was frisked and found to possess a loaded firearm. After Carson was indicted for possession of a firearm by a convicted felon in the United States District Court for the Western District of North Carolina, he moved to suppress the firearm, arguing that the traffic stop was unlawfully prolonged and that the frisk lacked reasonable suspicion. A magistrate judge held an evidentiary hearing, during which officers testified and body camera footage was reviewed. The magistrate judge recommended denial of the suppression motion, finding the officers had probable cause to search the vehicle after the detection of marijuana and that the frisk was lawful. The district court adopted the recommendation, denied the motion, and subsequently accepted Carson’s conditional guilty plea, sentencing him to 24 months imprisonment. The United States Court of Appeals for the Fourth Circuit reviewed the district court’s decision, applying de novo review for legal questions and clear error for factual findings. The court held that the officers had independent reasonable suspicion—specifically, the detection of marijuana odor—which justified the extension of the stop and the search. Additionally, the frisk was permissible due to reasonable suspicion of illegal drugs in the vehicle. The Fourth Circuit affirmed the district court’s denial of Carson’s suppression motion. View "US v. Carson" on Justia Law

Kuiper v. Mena

2026-07-08T10:30:40-08:00

During the Salvadoran civil war in March 1982, Mario Adalberto Reyes Mena, then a colonel in the Salvadoran Security Forces, allegedly ordered the ambush and killing of four Dutch journalists, including Jan Kuiper. The journalists were reporting on the conflict and had published material critical of the Salvadoran government. According to findings by a United Nations Truth Commission and a U.S. military investigation, the ambush was premeditated and orchestrated by Reyes Mena, with the intention of silencing unfavorable media coverage. Years later, Reyes Mena was indicted and convicted in absentia in El Salvador for these killings, while residing in Virginia. Gert Kuiper, Jan Kuiper’s brother, subsequently filed a civil action against Reyes Mena in the United States District Court for the Eastern District of Virginia, pursuant to the Torture Victim Protection Act of 1991. He sought declaratory and monetary relief for the extrajudicial killing of his brother. Reyes Mena moved to dismiss the case, asserting conduct-based foreign official immunity under international common law. The district court denied the motion, holding that foreign official immunity does not extend to violations of jus cogens norms, such as extrajudicial killings, even if performed in an official capacity. The United States Court of Appeals for the Fourth Circuit reviewed the district court’s denial of immunity on interlocutory appeal. The Fourth Circuit held that, under both international and domestic law, foreign officials are not entitled to conduct-based foreign official immunity for violations of jus cogens norms, including extrajudicial killings, regardless of whether such acts were performed in an official capacity. The court affirmed the district court’s order denying Reyes Mena immunity and remanded the case for further proceedings. View "Kuiper v. Mena" on Justia Law

South Carolina State Conference of the NAACP v. Weaver

2026-07-08T10:30:40-08:00

A South Carolina budget provision, known as the “Proviso,” prohibits public schools from using state funds to teach certain concepts related to race and sex. Several Black students, the South Carolina State Conference of the NAACP (SC NAACP), and author Ibram Kendi challenged the Proviso, alleging it led to the removal of an Advanced Placement African American Studies (AP AAS) course and one of Kendi’s books from school libraries. The students and SC NAACP asserted that eliminating the AP AAS course infringed upon students’ First Amendment right to receive information, while Kendi claimed the book’s removal constituted viewpoint discrimination. Plaintiffs further alleged that the Proviso was void for vagueness and violated the Equal Protection Clause. The United States District Court for the District of South Carolina dismissed the complaint for lack of Article III standing. The court concluded that the individual students did not allege a concrete injury as they had not actually enrolled in AP AAS, and found that even a student who had enrolled failed to establish that her injury was traceable to the Proviso rather than an unrelated curriculum review. The district court also held that Kendi’s injury was not redressable because the school district cited an alternative, unchallenged rationale for removing his book. The United States Court of Appeals for the Fourth Circuit affirmed in part, reversed in part, vacated in part, and remanded. It affirmed dismissal with respect to a student who had graduated and another who had not taken concrete steps to enroll in AP AAS. However, it held that SC NAACP adequately alleged standing for at least one member with an ongoing injury, and Kendi sufficiently alleged standing for his viewpoint discrimination claim. The court vacated dismissal of other claims and remanded for the district court to address unresolved standing and merits questions. View "South Carolina State Conference of the NAACP v. Weaver" on Justia Law

Deal v. City of Monroe

2026-07-08T10:30:40-08:00

Kenneth Deal was appointed to the City of Monroe, North Carolina’s board of adjustment, a quasi-judicial municipal body responsible for handling certain appeals and permits. After completing one three-year term, he was reappointed to a second term. However, during this second term, the City Council voted to remove him from the board without cause or prior notice. Deal was not present at the meeting where the removal occurred, nor was he informed that his removal would be considered. Deal filed suit in the United States District Court for the Western District of North Carolina, alleging that the City violated his procedural due process rights when it deprived him of his board seat without notice or an opportunity to be heard. He sought relief under 42 U.S.C. § 1983 and requested a declaratory judgment to void his removal. Deal moved for partial summary judgment on liability, while the City sought summary judgment on all claims. The district court granted summary judgment in favor of the City, concluding that Deal did not have a constitutionally protected property interest in his board seat because the City Council retained discretion to remove board members at any time, with or without cause. On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s summary judgment ruling de novo. The Fourth Circuit affirmed the district court’s decision, holding that Deal lacked a constitutionally protected property interest in his seat. The court reasoned that because the City had broad discretion under its code and state law to appoint, remove, or even abolish the board, Deal’s interest in his seat did not amount to a legitimate claim of entitlement protected by the Fourteenth Amendment. The court rejected Deal’s reliance on state cases and found that local discretion was dispositive, affirming the district court’s judgment. View "Deal v. City of Monroe" on Justia Law

Martinez v. Blanche

2026-07-08T10:30:39-08:00

A Salvadoran national entered the United States without authorization in 2016 and was later placed in removal proceedings. He sought relief from removal by applying for asylum, withholding of removal, and protection under the Convention Against Torture (CAT), claiming a history of violent encounters with the Zetas cartel and presenting evidence of threats and violence against himself and his family. He also admitted to a 2023 conviction for assault and battery against a family member in Virginia. An Immigration Judge (IJ) heard testimony from the petitioner and expert witnesses and reviewed documentary evidence. The IJ found the petitioner not credible, citing implausible elements in his testimony and inconsistencies with other evidence. The IJ denied all forms of relief, concluding that the petitioner was ineligible for asylum and withholding of removal due to his conviction for a “particularly serious crime” and that he failed to establish a sufficient likelihood of torture to warrant CAT protection. The Board of Immigration Appeals (BIA) adopted and affirmed the IJ’s decision in full. The United States Court of Appeals for the Fourth Circuit reviewed both the IJ’s and BIA’s decisions. The court held that the IJ and BIA failed to apply the proper legal standard in determining whether the Virginia conviction was a “particularly serious crime,” specifically by not conducting the required two-step analysis in the correct order. This error required vacatur and remand for further proceedings. However, the court found the adverse credibility determination was supported by substantial evidence and that the denial of CAT relief was not an abuse of discretion. The petition was therefore granted in part, denied in part, and the BIA’s order was vacated and remanded. View "Martinez v. Blanche" on Justia Law

Steen v. Dismukes

2026-07-08T10:30:39-08:00

George Steen, a foster parent, was convicted by a North Carolina jury of sexually abusing a young foster child, M.S., who had lived with Steen and his wife for several years. The prosecution relied heavily on M.S.’s detailed descriptions of the alleged abuse, arguing such knowledge was unlikely unless M.S. had experienced the acts. The defense countered by attempting to show M.S.’s reputation for untruthfulness and identifying alternative sources for his sexual knowledge, including prior experiences with his biological family and other incidents. Despite this, the jury found Steen guilty on three counts of sexual offenses against a child. Following his conviction, Steen sought relief in the North Carolina state courts, arguing ineffective assistance of counsel under the Sixth Amendment, as articulated in Strickland v. Washington. He focused on his attorney’s failure to uncover and present specific social services records, counselor’s notes, and medical records that, he claimed, further supported his theory that M.S. fabricated the allegations and had other sources of sexual knowledge. The state trial court denied relief, finding Steen failed to demonstrate both deficient performance and resulting prejudice. The North Carolina Court of Appeals affirmed, assuming deficient performance but holding Steen could not show prejudice because the additional records were cumulative of evidence already before the jury. Steen then filed for federal habeas relief in the United States District Court for the Western District of North Carolina. That court denied relief but erroneously deferred to the trial court’s analysis of deficient performance rather than the appellate court’s reasoning on prejudice. On appeal, the United States Court of Appeals for the Fourth Circuit clarified that only the last reasoned decision of the North Carolina Court of Appeals was entitled to deference under 28 U.S.C. § 2254(d). The Fourth Circuit held that this court had reasonably found no prejudice, and thus affirmed the denial of habeas relief. View "Steen v. Dismukes" on Justia Law

US v. Williams

2026-07-08T10:30:38-08:00

Police officers responded to an anonymous 911 call reporting that individuals inside a white Mercedes sedan parked near the pool area of an apartment complex might be selling or possessing narcotics. The officers received this information through their department’s computer-aided dispatch system. Upon arrival, the officers stopped their marked police vehicles in the roadway, positioning themselves such that one car was partially in front of the Mercedes and another behind. They exited their vehicles, approached the Mercedes, and immediately smelled marijuana. Williams, the defendant, admitted to smoking marijuana, after which he and the other occupants were directed to exit the vehicle. In the ensuing search, officers found a handgun, and Williams admitted ownership. The United States District Court for the Western District of North Carolina denied Williams’ motion to suppress the evidence found during the search. The district court found that Williams was not seized when the officers stopped their cars, reasoning that there was physical room for him to leave and a reasonable person would have felt free to do so. The court further concluded that the officers had reasonable suspicion to seize Williams after smelling marijuana and that the search was supported by probable cause. Williams was subsequently convicted of being a felon in possession of a firearm after a bench trial. On appeal, the United States Court of Appeals for the Fourth Circuit held that Williams was seized for Fourth Amendment purposes when the officers blocked his vehicle with their marked patrol cars, as a reasonable person would not have felt free to leave under the circumstances. The court further held that the officers lacked reasonable suspicion to justify this seizure based solely on the anonymous tip and the fact the encounter occurred in a high-crime area. The court reversed the district court’s denial of the suppression motion, vacated Williams’ conviction, and remanded for further proceedings. View "US v. Williams" on Justia Law

Doe 1 v. Office of the Director of National Intelligence

2026-07-08T10:30:38-08:00

Nineteen career employees of the Central Intelligence Agency and the Office of the Director of National Intelligence, who had temporarily held positions related to diversity, equity, inclusion, and accessibility (DEIA), were notified of their impending termination following two executive orders issued by President Trump that directed federal agencies to eliminate all DEIA-related offices and positions. These terminations were implemented in the context of reduction in force (RIF) actions, with the agencies complying with memoranda from the Office of Personnel Management instructing the immediate elimination of such roles. The agencies made clear they would not provide the employees with opportunities for reassignment or the ability to appeal their terminations, procedures to which the employees claimed entitlement under the agencies’ internal Termination Regulation. The United States District Court for the Eastern District of Virginia first denied a temporary restraining order on the basis that the employees had not yet invoked their rights to reassignment or appeal. After the employees attempted to exercise these rights and were denied, the district court granted a preliminary injunction requiring the agencies to follow their own Termination Regulation, specifically the provisions allowing for reassignment and internal appeal, finding the employees were likely to succeed on their due process claims and would suffer irreparable harm without relief. On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s grant of a preliminary injunction. The Fourth Circuit held that the district court did not abuse its discretion in concluding that the employees had a property interest in the reassignment and appeal rights provided by the Termination Regulation and that denial of these rights without due process likely violated the Fifth Amendment. The Fourth Circuit also found no error in the district court’s findings regarding irreparable harm, the balance of equities, or the public interest, and concluded the scope of the injunction was appropriate. View "Doe 1 v. Office of the Director of National Intelligence" on Justia Law

Roberts v. Engelke

2026-07-08T10:30:38-08:00

An inmate at Red Onion State Prison in Virginia, who is a Sunni Muslim, requested accommodations to observe both the Ramadan fast and to maintain a diet prepared according to Jewish Kashrut law, as he sincerely believed both were religious requirements. The prison had an Orthodox Jewish Kosher Diet (OJKD) and a Common Fare menu, but in 2020 could not provide a version of the OJKD that also allowed for Ramadan fasting on short notice. The inmate was offered a choice between maintaining the OJKD without fasting or switching to the Common Fare menu to fast, but with restrictions on switching back. He tried to fast by saving OJKD meals for sunset, but this led to food poisoning. By 2021, the prison had created a Ramadan-compliant OJKD. The United States District Court for the Western District of Virginia granted summary judgment to the prison officials on all claims. The court held that the officials were protected by Eleventh Amendment immunity for damages in their official capacities and found that damages were not available under RLUIPA. The court also found the request for injunctive relief moot after the policy change. The remaining claims for damages under the Constitution were dismissed on qualified immunity grounds, as the court determined the rights were not clearly established or that there was no constitutional violation. On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the denial of a discovery motion and agreed that injunctive and declaratory relief were moot, and that summary judgment was proper on the Establishment Clause and Equal Protection claims. However, the Fourth Circuit held that the inmate’s right to a religious diet consistent with his sincerely held beliefs was clearly established and that the district court erred by failing to apply the proper standard to his Free Exercise claim. The court reversed in part, vacated in part, and remanded for the district court to consider whether the failure to accommodate in 2020 was reasonably related to legitimate penological interests under the Turner standard. View "Roberts v. Engelke" on Justia Law

US v. Covington

2026-07-02T10:30:51-08:00

W.W., an incarcerated person, died after experiencing a severe medical crisis while in Bureau of Prisons custody. Shronda Covington was the highest-ranking official on duty at the time and had the authority to call a physician or send W.W. to the hospital; evidence showed that she was informed of W.W.’s distress but allegedly failed to intervene. Tonya Farley, a BOP nurse, examined W.W., observed troubling symptoms, but instead of seeking appropriate medical attention, contacted a psychologist and submitted a report stating no signs of acute distress. Both Covington and Farley later made statements to investigators that were allegedly false regarding their actions during the crisis. After an investigation, Covington and Farley were charged in the United States District Court for the Eastern District of Virginia. Covington was convicted by a jury of violating 18 U.S.C. § 242 (willfully depriving W.W. of his constitutional rights, with the jury finding bodily injury but not death resulted), as well as making false statements under 18 U.S.C. § 1001. Farley was convicted of making false statements under 18 U.S.C. § 1001 but acquitted of the Section 242 charge and another false report charge. Both defendants were sentenced to terms of incarceration and home detention. Farley contested the inclusion of her acquitted conduct in calculating her Guidelines range. The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that Section 242’s “bodily injury results from” language requires proof of both but-for and proximate causation. The district court erred by not instructing the jury on proximate cause for Covington’s Section 242 conviction, so that conviction and both defendants’ sentences were vacated and remanded for further proceedings. The court affirmed both defendants’ convictions for making false statements under Section 1001, rejecting all other challenges. View "US v. Covington" on Justia Law

Langford v. Stonebreaker

2026-07-02T10:30:50-08:00

After a robbery at a Chinese restaurant owner’s home in South Carolina, three masked men assaulted the family and stole their earnings. The victims could not identify the attackers, and no forensic evidence was left behind. Weeks later, a tip led investigators to three suspects, including K.C. Langford, who was arrested and indicted along with two co-defendants. Langford’s trial was delayed for nearly two years, partly due to difficulties in securing an interpreter for the victims and because one co-defendant, Alvin, initially refused to testify after being pressured by Langford and another defendant. The trial eventually proceeded, with Alvin testifying against Langford. Langford was convicted of criminal conspiracy, armed robbery, first-degree burglary, and kidnapping. After conviction, Langford appealed to the South Carolina Supreme Court, which affirmed his convictions. The court found that although the prosecutor’s control over the trial docket violated the state constitution, Langford suffered no prejudice from it. Applying the Barker v. Wingo framework, the court determined the nearly two-year delay did not violate Langford’s Sixth Amendment right to a speedy trial, considering the reasons for the delay and lack of prejudice to Langford’s defense. Langford’s postconviction relief application in the Court of Common Pleas was denied, as the court found no ineffective assistance of counsel regarding a hearsay issue in the trial. The South Carolina Court of Appeals denied certiorari. Langford’s co-defendant, Bryan, received postconviction relief in a separate proceeding. Langford then sought federal habeas corpus relief in the United States District Court for the District of South Carolina, which granted the writ on claims of speedy trial violation and ineffective assistance of counsel. The United States Court of Appeals for the Fourth Circuit reversed, holding that the South Carolina courts’ decisions were not unreasonable applications of clearly established federal law nor based on unreasonable factual determinations. The Fourth Circuit ordered reversal of the district court’s grant of habeas corpus. View "Langford v. Stonebreaker" on Justia Law

Rhoads v. Riddell

2026-07-02T10:30:50-08:00

A woman was detained in a county detention center for thirty days in 2019. During her detention, she developed a painful and visibly swollen abscess on the side of her head. She repeatedly reported her symptoms and submitted grievances, seeking medical help, but did not receive adequate treatment. Correctional officers escorted her to solitary confinement after she protested her lack of medical care, making her unable to access the grievance system. She continued to experience severe symptoms, ultimately requiring emergency hospitalization and surgery after being found unconscious. The United States District Court for the District of South Carolina initially granted summary judgment to five correctional officers, finding they were entitled to qualified immunity because there was insufficient evidence of their subjective knowledge and disregard of a risk to the detainee’s health. Upon a motion for reconsideration, the district court found disputed material facts regarding two supervisory officers’ knowledge of her condition and their actions, determining these disputes precluded summary judgment on qualified immunity. The United States Court of Appeals for the Fourth Circuit reviewed the district court’s denial of summary judgment de novo. The Fourth Circuit held that, in June 2019, a pretrial detainee’s right to adequate medical care and freedom from deliberate indifference to serious medical needs was clearly established in the circuit. The court found that supervisory correctional officers could not ignore repeated warnings and visible signs of severe medical need, nor could they rely indefinitely on medical personnel’s decisions when evidence of inadequate care was apparent. The Fourth Circuit affirmed the district court’s decision, concluding that the officers were not entitled to qualified immunity at the summary judgment stage because the law provided fair warning that their conduct could violate the detainee’s constitutional rights. View "Rhoads v. Riddell" on Justia Law

Doe v. Office of the Director of National Intelligence

2026-07-02T10:30:50-08:00

Nineteen career intelligence officers employed by the Central Intelligence Agency and the Office of the Director of National Intelligence were informed that their positions would be terminated. These officers had been temporarily assigned to roles related to diversity, equity, inclusion, and accessibility (DEIA). Their terminations were the result of new executive orders issued at the start of President Trump’s second term, which directed federal agencies to eliminate DEIA programs and related positions. The Office of Personnel Management issued memoranda implementing these directives, instructing agencies to place DEIA employees on administrative leave and to conduct reductions in force (RIFs) targeting DEIA positions. The agencies provided no indication that the terminations were based on misconduct or poor performance. The officers sought relief in the United States District Court for the Eastern District of Virginia, arguing that the agencies violated their Fifth Amendment due process rights by refusing to follow internal regulations that guaranteed them opportunities for reassignment and internal appeal when facing RIF terminations. The district court first denied a temporary restraining order but later granted a preliminary injunction after the agencies refused to provide the procedural rights specified in their own regulations. The court found the officers were likely to succeed on their claims, would suffer irreparable harm without relief, and that the balance of equities and public interest favored the injunction. On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the preliminary injunction under an abuse of discretion standard. The court held that the district court acted within its discretion, finding the officers had a property interest in the specific procedural rights guaranteed by agency regulation. The court affirmed that the agencies were required to adhere to their own procedures regarding reassignment and internal appeal before effecting the officers’ terminations, upholding the preliminary injunction. View "Doe v. Office of the Director of National Intelligence" on Justia Law

King v. Blackwood

2026-07-02T10:30:50-08:00

Maurice King, an inmate convicted on federal drug charges and awaiting sentencing, was housed in a segregation unit at the Orange County Detention Center. On the evening of March 4, 2020, King was assaulted by other inmates in his cell. Surveillance footage showed multiple inmates entering and leaving his cell before and after the attack. Officers Berry and Linster, responsible for security rounds, failed to visually inspect King’s cell during their rounds, despite hearing noises of distress, including moaning and labored breathing. After listening to concerning sounds over the cell intercom and suspecting King had been assaulted, the officers delayed checking on him for approximately twenty minutes to avoid additional paperwork associated with an early security round. When they finally entered, King was found seriously injured and later died at the hospital. King’s estate sued several parties, including Orange County, the Sheriff, and detention officers, asserting federal claims under 42 U.S.C. § 1983 for deliberate indifference, along with state-law claims. The United States District Court for the Middle District of North Carolina, adopting in part the magistrate judge’s recommendations, denied summary judgment on qualified immunity grounds for Officers Berry and Linster. The court found sufficient evidence for a reasonable jury to conclude that the officers consciously disregarded a substantial risk to King’s health. The United States Court of Appeals for the Fourth Circuit reviewed the denial of qualified immunity. The Fourth Circuit held that, accepting the district court’s factual findings, a reasonable jury could determine that Officers Berry and Linster violated clearly established constitutional law by intentionally delaying medical attention for King after suspecting he had been assaulted. The court affirmed the denial of qualified immunity for those officers, dismissed the appeals related to Monell and bond claims for lack of appellate jurisdiction, and limited its review to the qualified immunity issue. View "King v. Blackwood" on Justia Law

Riley v. Blanche

2026-07-02T10:30:49-08:00

A man born and raised in Jamaica entered the United States as a teenager on a temporary visa and later overstayed. After being convicted of drug and firearm offenses, he was taken into custody by the Department of Homeland Security and ordered removed to Jamaica. He sought deferral of removal under the Convention Against Torture (CAT), claiming that a powerful Jamaican drug dealer with ties to local authorities had already killed two of his cousins and would likely kill him if he returned. His mother and sister, still in Jamaica, corroborated these fears through affidavits describing threats and police indifference. The Immigration Judge (IJ) found the man’s testimony credible, determined he faced a particularized risk of torture with the acquiescence of Jamaican authorities, and granted deferral of removal under the CAT. On appeal by the government, the Board of Immigration Appeals (BIA) reversed, concluding that the threat was too speculative and the evidence insufficient to show government acquiescence. The man petitioned the United States Court of Appeals for the Fourth Circuit for review. Initially, the Fourth Circuit dismissed the petition as untimely. The Supreme Court affirmed the untimeliness but clarified that the filing deadline was not jurisdictional and could be waived. Because the government waived the timing objection, the Supreme Court remanded the case. Upon remand, the government raised a new jurisdictional argument. The Fourth Circuit allowed the petitioner to amend his petition to include review of his original removal order, curing any potential jurisdictional defect. The court then reviewed the merits and held that the BIA improperly applied a de novo review rather than the required clear-error standard to the IJ’s factual findings. The Fourth Circuit granted the amended petition, vacated the BIA’s order, and remanded for proceedings consistent with the correct standard of review. View "Riley v. Blanche" on Justia Law

US v. Holley

2026-07-01T10:30:24-08:00

Brad Acy Holley, who was serving a 127-month federal sentence after pleading guilty to methamphetamine conspiracy, suffered from significant health issues, including polycystic kidney disease and end-stage renal disease requiring dialysis. Following his declining health and ongoing treatments in a federal medical facility, Holley sought compassionate release, arguing that his condition constituted an extraordinary and compelling reason for a sentence reduction. He also asserted that he was not receiving necessary specialized medical care in prison, particularly a kidney transplant, and requested appointment of counsel and an expert witness to assist with his motion. The United States District Court for the Southern District of West Virginia denied Holley’s requests, finding that his medical condition, while serious, was being adequately managed in prison and did not qualify as a terminal illness or otherwise meet the threshold for extraordinary and compelling reasons for compassionate release. The court also declined to appoint counsel or an expert, determining that neither was warranted under the circumstances. Holley appealed these decisions. The United States Court of Appeals for the Fourth Circuit reviewed the district court’s decisions for abuse of discretion. The appellate court held that the district court did not abuse its discretion in denying compassionate release, finding the court properly relied on Holley’s individualized medical records rather than generalized statistics, and reasonably concluded Holley was not suffering from a terminal illness with an end-of-life trajectory. The Fourth Circuit also held that Holley was not legally entitled to appointed counsel or an expert witness for his compassionate release motion, as there were no exceptional circumstances justifying such appointments. Accordingly, the Fourth Circuit affirmed the district court’s judgment in all respects. View "US v. Holley" on Justia Law

Morgan v. City of Charlotte

2026-06-29T11:01:25-08:00

Bobby Morgan, who suffers from bipolar and schizoaffective disorders, was involved in an altercation with his neighbors, during which he threatened to shoot them and displayed what appeared to be a functional pistol. After retreating to his home, Bobby fired his gun multiple times, prompting a police standoff. Despite attempts to deescalate, Bobby continued firing—later revealed to be with a prop gun that could only shoot blanks but appeared real. Officers responded with gunfire, striking Bobby three times. Bobby survived after receiving medical care. Felicia Morgan, his mother and legal guardian, sued the City of Charlotte and several officers, alleging excessive force under the Fourth Amendment and failure to reasonably accommodate Bobby’s disabilities in violation of the Americans with Disabilities Act (ADA). The United States District Court for the Western District of North Carolina granted summary judgment to the defendants. The court found that from the perspective of a reasonable officer, Bobby posed an imminent threat of serious physical harm due to his erratic and repeated firing of a realistic-looking gun in a residential area. The court also determined that the officers acted reasonably in attempting to accommodate Bobby’s mental conditions, given the exigent circumstances and the risks posed to officers and civilians. On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the claims de novo, applying the objective reasonableness standard for excessive force and the requirement of reasonable accommodation under the ADA. The Fourth Circuit affirmed the district court’s decision, holding that the officers’ use of force was justified given the threat Bobby posed and that the City and its officers acted reasonably under the circumstances. The Court concluded that unfortunate events do not automatically create legal liability when officers reasonably perceive an imminent threat and take appropriate action. View "Morgan v. City of Charlotte" on Justia Law

US v. Bendann

2026-06-25T10:30:26-08:00

A middle-school teacher at an all-boys preparatory school in Baltimore developed a close relationship with a minor student, serving as his advisor, coach, and frequent driver. Over time, this relationship escalated into grooming and sexual exploitation, including coercing the student into running naked, engaging in sexually explicit acts that were filmed, and threats to expose the student through social media. The teacher continued the abusive conduct over several years, leveraging explicit images to maintain control and compliance, even after the student graduated. The case came to light after other students reported suspicious behavior, leading to a police investigation and a search of the teacher’s home and electronic devices. The United States District Court for the District of Maryland oversaw pretrial proceedings and the trial itself. The defendant moved to suppress evidence from his iPhone, arguing that law enforcement had unlawfully obtained his passcode, and requested a competency evaluation due to reported suicidal ideation. The district court denied both requests, finding the passcode was entered voluntarily and that the defendant was competent to stand trial. After a six-day trial, the jury convicted the defendant on all counts, including child exploitation, possession of child sexual abuse material, and cyberstalking. The court sentenced him to 35 years’ imprisonment and lifetime supervised release, rejecting arguments regarding the admissibility of victim-impact statements at sentencing. The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the district court did not abuse its discretion in denying a competency evaluation, properly found the defendant’s entry of the iPhone passcode voluntary and not the result of interrogation, and correctly handled the Jencks Act material issue. It also found no error in allowing the victim’s parents to present impact statements at sentencing. Accordingly, the Fourth Circuit affirmed the convictions and sentence. View "US v. Bendann" on Justia Law

FS Medical Supplies, LLC v. Tanner Pharma UK Limited

2026-06-25T10:30:26-08:00

During the onset of the COVID-19 pandemic, a limited liability company (LLC), FS Medical Supplies, entered into a contract to supply personal protective equipment and related products to TannerGAP, Inc. and Tanner Pharma UK Limited for distribution. FS Medical later discovered that the Tanner entities had contracted directly with one of its suppliers, prompting FS Medical to sue for breach of contract. Initially, FS Medical brought suit in California state court, but the defendants removed the case to federal court, where it was dismissed for lack of personal jurisdiction. FS Medical then filed two actions in the United States District Court for the Western District of North Carolina, asserting diversity jurisdiction under 28 U.S.C. § 1332(a)(3). FS Medical alleged that its members were citizens of Texas and California, and later acknowledged that one member was a citizen of China. The defendants included both U.S. citizens domiciled in North Carolina and a United Kingdom corporation. After limited discovery and amendment of the complaint, the district court, following a magistrate judge’s recommendation, dismissed the actions for lack of subject matter jurisdiction, concluding that the presence of both domestic and foreign members in the plaintiff LLC destroyed diversity jurisdiction. On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the dismissal de novo. The court held that, under § 1332(a)(3), complete diversity requires at least one U.S. citizen on each side of the action. Because FS Medical, as an LLC, had both domestic and foreign members at the time the complaints were filed, and because there were foreign defendants as well, the suit was not between “citizens of different States.” The Fourth Circuit affirmed the district court’s dismissal and declined to grant relief under North Carolina’s savings statute, finding it lacked jurisdiction to do so. View "FS Medical Supplies, LLC v. Tanner Pharma UK Limited" on Justia Law

Ingram v. Hamilton

2026-06-24T10:31:20-08:00

A maximum security prison in Virginia faced a surge in near-fatal drug overdoses among inmates in May and June 2023. In response, prison officials implemented a policy requiring every inmate who accessed the no-contact video visitation rooms to undergo a strip search both before and after each visit. Marcus Ingram, an inmate who used these rooms to call his wife, was subjected to 26 strip searches in a single month as a result. The policy was based on uncorroborated tips from inmates suggesting that contraband was being circulated through these rooms, despite no evidence of any actual contraband being found in connection with the video visitation rooms. Ingram filed a pro se lawsuit under 42 U.S.C. § 1983 in the United States District Court for the Western District of Virginia against the prison warden and the officer who conducted most of the searches. He alleged violations of his Fourth and Eighth Amendment rights, along with a claim of supervisory liability against the warden. The district court granted summary judgment to the defendants on the basis of qualified immunity, holding that the searches were reasonable due to the drug problem and that there was no evidence of harassment or intimidation. The court also dismissed the supervisory liability claim as there was no underlying constitutional violation. On appeal, the United States Court of Appeals for the Fourth Circuit assumed without deciding that some of the strip searches may have violated the Fourth Amendment. However, it held that the right at issue was not clearly established at the time, as neither controlling precedent nor a consensus of persuasive authority made the unconstitutionality of the policy beyond debate. Therefore, the Fourth Circuit affirmed the district court’s grant of qualified immunity to the defendants. View "Ingram v. Hamilton" on Justia Law

McMaster v. Department of Labor

2026-06-24T10:31:20-08:00

South Carolina has administered its own workplace safety program under federal law for decades. In July 2016, the Occupational Safety and Health Administration (OSHA) issued an interim final rule requiring states with their own plans to increase monetary penalties in line with federal levels. South Carolina did not adjust its penalties, and OSHA’s annual monitoring reports repeatedly noted this issue without finding formal noncompliance until 2022. That year, OSHA formally found South Carolina noncompliant and recommended legislative changes to bring the state into alignment with federal standards. Previously, in 2022, South Carolina officials challenged only OSHA’s 2022 inflation adjustment in the United States District Court for the District of South Carolina. The district court held that the 2022 adjustment was not a final agency action and dismissed the claim. In 2023, South Carolina brought a new suit in the same court, this time challenging the 2016 interim final rule under the Administrative Procedure Act (APA). The Department of Labor moved to dismiss, arguing the claims were untimely under the APA’s six-year statute of limitations. The district court agreed, finding that any injury occurred when the 2016 rule was promulgated and dismissed the APA claims as time-barred. On appeal, the United States Court of Appeals for the Fourth Circuit reviewed whether the APA claims were timely. The court held that a claim accrues when the plaintiff is injured by a final agency action, which, in this case, was when the 2016 rule was published. The court determined that South Carolina could have filed suit as early as 2016 and was therefore outside the six-year limitations period. The court also noted that South Carolina may still raise its substantive arguments if an enforcement action is initiated. The Fourth Circuit affirmed the district court’s dismissal. View "McMaster v. Department of Labor" on Justia Law

Gordon v. Heath

2026-06-24T10:31:19-08:00

Two Black officers, Don Gordon and Terrell Jones, were assigned to a Maryland State Police multi-agency drug task force. They allege they were consistently excluded from meetings and communications where overtime and desirable assignments were distributed to white officers. This exclusion resulted in lost work opportunities and compensation. The situation escalated when a supervisor, Corporal Oros, sent a racially and sexually offensive image involving George Floyd to the group shortly after Floyd’s death, and Sergeant Heath, a co-leader of the unit, took no corrective action. The officers assert that these actions and inactions created a racially hostile work environment, leading to feelings of mistrust and concern for their safety on the job. After filing charges with the U.S. Equal Employment Opportunity Commission and receiving right-to-sue letters, Gordon and Jones brought suit in the United States District Court for the District of Maryland. The district court dismissed their race discrimination claims but permitted the Title VII hostile work environment claim against the Maryland State Police and the § 1981 hostile work environment claims against Sergeant Heath and Corporal Oros (in their individual capacities) to proceed. The district court denied qualified immunity to Sergeant Heath at the pleading stage. The United States Court of Appeals for the Fourth Circuit reviewed Sergeant Heath’s interlocutory appeal concerning qualified immunity. The court held that the plaintiffs’ complaint plausibly alleged Sergeant Heath’s participation in and tacit authorization of a racially hostile work environment. The court further ruled that the right to be free from such a racially hostile work environment was clearly established at the time of the events described. Therefore, the Fourth Circuit affirmed the district court’s denial of qualified immunity to Sergeant Heath. View "Gordon v. Heath" on Justia Law

US v. Melaku

2026-06-17T10:30:44-08:00

The defendant engaged in a series of shootings at military-related sites in Northern Virginia in late 2010, and was apprehended in June 2011 at Arlington National Cemetery, carrying materials linked to his offenses. He later pleaded guilty to three charges: injuring government property, using a firearm during a crime of violence, and attempting to injure a veteran’s memorial. As part of a Rule 11(c)(1)(C) plea agreement, he accepted a twenty-five year sentence and waived his right to appeal within statutory limits. After being found competent despite a schizophrenia diagnosis, he was sentenced accordingly and did not initially appeal. Years later, the defendant sought relief under 28 U.S.C. § 2255. The United States Court of Appeals for the Fourth Circuit previously vacated his firearm conviction under 18 U.S.C. § 924(c) and remanded for resentencing on the remaining counts. On remand, the United States District Court for the Eastern District of Virginia held a new competency hearing and discussed whether to postpone sentencing to monitor medical compliance. Ultimately, the court declined a lengthy postponement due to statutory and constitutional concerns, resentenced the defendant to consecutive maximum terms totaling 240 months, and ordered a pre-release hearing to plan for his transition. The United States Court of Appeals for the Fourth Circuit reviewed four challenges to the resentencing. Two claims were deemed forfeited for not being raised at sentencing, and the remaining two failed under the abuse-of-discretion standard. The court held that the defendant did not demonstrate a plain error under Tapia v. United States regarding the imposition of a sentence to promote rehabilitation or medical compliance. The court further found the sentence to be both procedurally and substantively reasonable, and rejected arguments regarding the district court’s authority to order a pre-release hearing. The judgment of the district court was affirmed. View "US v. Melaku" on Justia Law

Aljizzani v. Middle East Broadcasting Networks, Inc.

2026-06-17T10:30:44-08:00

Two journalists, both of Iraqi national origin, worked for a Virginia-based media company operating Arabic-language broadcasts targeting the Middle East and North Africa. The company maintained a mandatory Code of Ethics and social media policy requiring its journalists to remain neutral both in their reporting and in personal social media posts. Both journalists violated these policies by posting political content on social media, and after refusing direct orders to remove the posts, each was terminated. They alleged that the company enforced its policies more harshly against Iraqi journalists than non-Iraqi journalists and that their terminations were discriminatory under Title VII of the Civil Rights Act of 1964. Each journalist filed a separate lawsuit in the United States District Court for the Eastern District of Virginia, asserting claims of national origin discrimination. Both district courts granted the employer’s motions to dismiss, finding that the complaints failed to allege sufficient facts to plausibly support a claim of discrimination. Specifically, the courts found that neither plaintiff identified non-Iraqi employees who engaged in similarly insubordinate conduct—such as violating the same policies after direct warnings—yet were treated more favorably. On appeal, the United States Court of Appeals for the Fourth Circuit reviewed both cases de novo. The court affirmed the district courts’ decisions, holding that the plaintiffs’ complaints did not state plausible claims for relief under Title VII. The court found that the facts alleged showed the plaintiffs were terminated for insubordination and repeated policy violations, not because of their national origin, and that the comparator allegations were too generalized to support an inference of discrimination. The court also held that the district court did not abuse its discretion in denying one plaintiff leave to amend, as no request for leave was made and amendment would have been futile. The judgments of dismissal were affirmed. View "Aljizzani v. Middle East Broadcasting Networks, Inc." on Justia Law

Bacardi and Company Limited v. Squires

2026-06-16T10:30:30-08:00

The dispute centers on the HAVANA CLUB trademark, originally registered in the United States in 1976 by a Cuban state-owned company, Cubaexport. Due to changes in U.S. law, renewal of the trademark registration required a specific license from the Treasury’s Office of Foreign Assets Control (OFAC) after 1998. In December 2005, Cubaexport submitted its renewal application and payment to the United States Patent and Trademark Office (PTO) without the required OFAC license. OFAC later notified the PTO that the payment was unauthorized, leading to the PTO’s refund of the fee and refusal to renew the registration. Cubaexport unsuccessfully litigated against OFAC and, in 2015, reapplied for the license, which OFAC granted retroactively in 2016, authorizing the 2005 payment. After the PTO Director accepted Cubaexport’s renewal filing based on the retroactive OFAC license, Bacardi sued the PTO and its Director in the United States District Court for the Eastern District of Virginia. Bacardi argued the PTO lacked statutory authority to renew the expired registration and acted arbitrarily and capriciously. The district court initially dismissed the case, finding judicial review precluded by the Lanham Act, but the United States Court of Appeals for the Fourth Circuit reversed and remanded. On remand, Cubaexport intervened, and after cross-motions for summary judgment, the district court granted judgment for the defendants, finding the OFAC license validated the payment and that any deficiency was cured during the petition process. Reviewing the district court’s summary judgment de novo, the United States Court of Appeals for the Fourth Circuit held that the PTO Director acted within statutory authority, as the retroactive OFAC license validated the 2005 payment, satisfying the renewal requirements. The court also held the Director’s explanation for the renewal was reasonable and not arbitrary or capricious. The Fourth Circuit affirmed the district court’s judgment. View "Bacardi and Company Limited v. Squires" on Justia Law

Overby v. Anheuser-Busch, LLC

2026-06-15T11:00:26-08:00

Hourly workers at a brewing company’s Williamsburg, Virginia facility alleged that the company failed to pay them for various pre- and post-shift activities, including donning and doffing personal protective equipment, complying with COVID-19 protocols, attending shift-handoff meetings, and handling tools. The company used an electronic badge system for entry but compensated employees based on scheduled shift hours, not actual time on site. Different employees performed these tasks at different times and locations, with some tasks done at home, some during shift hours, and some on the premises outside shift hours. The company committed to pay for all hours actually worked, provided employees notified management about extra time worked. The plaintiffs filed suit under the Virginia Wage Payment Act, the Virginia Overtime Wage Act, and the Fair Labor Standards Act, seeking class certification for wage and hour claims. The United States District Court for the Eastern District of Virginia certified the class, finding that common questions predominated, such as whether the company’s policy resulted in uncompensated mandatory work. The district court’s class definition included all hourly employees at the facility within the relevant timeframe, and it denied the company’s motion to decertify the FLSA collective action. The United States Court of Appeals for the Fourth Circuit reviewed the case. It held that the district court erred by certifying the class without adequately considering significant variations among employees regarding their pre- and post-shift activities, the timing and location of those activities, and the applicable legal standards over time. The appellate court found that the class definition was overly broad and failed to account for differences among employees. Consequently, the Fourth Circuit vacated the class certification order and remanded for further proceedings, allowing the district court to consider narrower subclasses or to deny certification entirely. The appeal regarding the FLSA collective action was dismissed for lack of jurisdiction. View "Overby v. Anheuser-Busch, LLC" on Justia Law

Dan River Basin Association v. Virginia Department of Environmental Quality

2026-06-11T10:30:37-08:00

A group of environmental organizations challenged the decision by the Virginia Department of Environmental Quality (VDEQ) to grant a water quality certification for the Southgate Project, a proposed pipeline crossing parts of Virginia and North Carolina. The organizations argued that the certification was improperly issued because VDEQ failed to adequately address the pipeline developer’s past record of environmental violations and did not include all necessary conditions to ensure compliance with water quality standards. VDEQ had previously approved the developer’s erosion and sediment control plans, received public comments, and ultimately issued the certification after addressing those comments. After VDEQ issued the certification, the petitioners sought review in the United States Court of Appeals for the Fourth Circuit and filed a motion to stay the certification pending judicial review, pointing to the imminent start of pipeline construction. Their main contentions were that VDEQ did not rationally justify its prediction that the pipeline would not violate water quality standards, especially given the developer’s history of noncompliance, and that the certification failed to explicitly require compliance with certain state environmental plans and agreements. The United States Court of Appeals for the Fourth Circuit considered the motion for a stay and denied it. The court found that the petitioners had not made a strong showing that they were likely to succeed on the merits of their claims. The court noted that VDEQ provided a detailed explanation for its decision, including differences between the current project and past projects, and incorporated relevant environmental plans by reference in the certification. The court also determined that the remaining factors supporting a stay did not outweigh the petitioners’ failure to demonstrate likely success on the merits. The motion for a stay pending review was therefore denied. View "Dan River Basin Association v. Virginia Department of Environmental Quality" on Justia Law

Sierra Club v. North Carolina Department of Environmental Quality

2026-06-11T10:30:36-08:00

A proposed pipeline project, known as the Southgate Project, is planned to traverse portions of North Carolina and Virginia. This project is an extension of an existing pipeline system, and its construction has generated substantial environmental and legal concerns. The Mountain Valley Pipeline, LLC, sought a water quality certification from the North Carolina Department of Environmental Quality (NCDEQ), which is required under the Clean Water Act for such projects. After considering public comments, a public hearing, and a report from its hearing officer, NCDEQ issued the necessary certification in November 2025, finding that the project, if conducted according to specified conditions, would comply with state water quality standards. Previously, in 2020, NCDEQ had denied a water quality certification for the project, but that decision was vacated by the United States Court of Appeals for the Fourth Circuit in 2021. After the main pipeline was completed in 2024 and project plans were revised to reduce its length in North Carolina, NCDEQ reviewed and ultimately granted the new application. Environmental groups then petitioned the United States Court of Appeals for the Fourth Circuit for review of NCDEQ’s decision, and, as construction appeared imminent, sought a stay to prevent the project from proceeding while the case was pending. The United States Court of Appeals for the Fourth Circuit denied the motion for a stay, applying the traditional four-factor test for such relief. The court held that the petitioners did not make a strong showing that they were likely to succeed on the merits of their challenges to NCDEQ’s decision, particularly given the deference owed to the agency’s expertise under the Administrative Procedure Act. As a result, the motion for preliminary relief was denied, though the underlying merits of the challenge remain for later determination. View "Sierra Club v. North Carolina Department of Environmental Quality" on Justia Law

United States v. Chollet

2026-06-09T10:30:39-08:00

Three individuals—two tax attorneys, who were partners in a Missouri law firm, and an insurance broker from North Carolina—created and marketed a “Gain Elimination Plan” (GEP) to clients across various states, including North Carolina. The plan purported to enable clients to reduce taxable income by paying business expenses to limited partnerships largely owned by charities. In practice, the government established that these partnerships never actually existed, no services were provided, and the deductions claimed were based on fabricated transactions. The attorneys and the broker helped clients file tax returns with false deductions, resulting in over $22 million in unpaid taxes. The insurance broker also supplied false information to obtain life insurance policies for the plan, sharing commissions with the attorneys. One of the attorneys used the plan to reduce her own reported income, and the attorneys prepared tax returns for the broker that underreported his income. A jury in the United States District Court for the Western District of North Carolina convicted all three defendants of conspiracy to defraud the government and multiple counts related to the preparation and filing of false tax returns. The district court sentenced them to imprisonment, supervised release, and restitution. The defendants appealed, challenging the prosecution’s authorization, venue, evidentiary rulings, jury instructions, and sufficiency of the evidence. The United States Court of Appeals for the Fourth Circuit affirmed the convictions and sentences. The court held that the prosecution was properly authorized under the Appointments Clause and relevant statutes, venue in the Western District of North Carolina was proper because conduct elements of the offenses occurred there, and the “literal truth” defense did not apply to false totals derived from fabricated deductions. The appellate court also found no reversible error regarding evidentiary rulings, jury instructions, or the sufficiency of the evidence supporting the conspiracy and false return charges. View "United States v. Chollet" on Justia Law

US v. Watson

2026-06-08T11:01:14-08:00

After pleading guilty to two felony charges, an individual was sentenced to prison and a term of supervised release. Upon his release, he violated several conditions of his supervision almost immediately. As a result, the United States District Court for the District of South Carolina revoked his supervised release, sentencing him to 41 months in prison followed by a lifetime of supervised release, with a specific condition of nearly 21 months (629 days) of home detention. Following the revocation hearing, the defendant filed a motion for reconsideration, arguing that the home detention term exceeded what the law allows when combined with his prison sentence. He pointed to 18 U.S.C. § 3563(b)(19), which states that home detention “may be imposed only as an alternative to incarceration,” and argued that since the statutory maximum for incarceration under 18 U.S.C. § 3583(e)(3) is 48 months, only 7 additional months of home detention could be imposed. The district court denied this motion, reasoning that home detention is distinct from incarceration and thus did not need to be included in the statutory calculation. On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s ruling. The Fourth Circuit held that under § 3563(b)(19), home detention may only be imposed as a direct substitute for incarceration, on a one-for-one basis, and that the combined total of incarceration and home detention cannot exceed the statutory maximum term of incarceration (48 months in this case). Because the district court imposed a total combined sentence of approximately 62 months (41 months imprisonment plus nearly 21 months home detention), the sentence exceeded statutory limits. The Fourth Circuit vacated the sentence and remanded the case for resentencing in accordance with this interpretation. View "US v. Watson" on Justia Law

Sligo Creek Center v. Health and Human Services

2026-06-05T10:30:43-08:00

After two employees and a former resident at a Medicare-participating nursing home in Maryland were diagnosed with active tuberculosis in 2015, county health officials determined that the facility was at high risk for transmission. The officials directed the facility’s staff to take responsibility for testing and follow-up for residents. The facility carried out skin tests and chest x-rays, identifying several residents with latent tuberculosis, but did not proceed to evaluate or treat those residents for latent TB, nor did it document reasons for not treating them. Over a year later, a state health agency investigated and concluded that the facility failed to ensure proper follow-up and documentation, violating federal infection control regulations. The Department of Health and Human Services (HHS) agreed, found that the noncompliance created “immediate jeopardy,” and imposed a per-day civil monetary penalty. The facility challenged the findings and penalty before an administrative law judge, who rejected its arguments and upheld both the finding of noncompliance and the penalty. The Departmental Appeals Board affirmed the administrative law judge’s decision. On review, the United States Court of Appeals for the Fourth Circuit considered whether the Seventh Amendment entitled the facility to a jury trial in HHS’s administrative proceedings for monetary penalties. The court held that there is no Seventh Amendment right to a jury trial in this context because the enforcement action at issue involves “public rights,” not common law claims. The court reasoned that Congress created novel statutory obligations for Medicare-participating facilities, not merely reclassified common law causes of action, and that these obligations are enforced through an administrative scheme distinct from common law torts or contract actions. The court also found that HHS’s actions were neither arbitrary nor capricious and that its decision was supported by substantial evidence. The petition for review was denied. View "Sligo Creek Center v. Health and Human Services" on Justia Law

Deque Systems Inc. v. Browserstack, Inc.

2026-06-05T10:30:42-08:00

Deque Systems Inc., a company specializing in web accessibility software, developed and registered multiple versions of its DevTools and Rules Help Pages products. To access these, users agreed not to copy, reverse-engineer, or otherwise misuse the software or its documentation. In 2021, BrowserStack, a competing firm, sought to develop its own accessibility testing tools. More than 100 BrowserStack employees created accounts with Deque—agreeing to Deque’s terms—and later, BrowserStack released an Accessibility Toolkit, which Deque alleged was developed by unlawfully copying and reverse-engineering DevTools and the Rules Help Pages. Deque filed suit in the United States District Court for the Eastern District of Virginia, claiming copyright infringement, false advertising, breach of contract, and unjust enrichment, and sought injunctive relief, damages, and other remedies. During discovery, Deque repeatedly failed to properly disclose its damages calculations and supporting evidence by the deadlines set in the court’s scheduling order. Despite several opportunities to supplement its disclosures and a late attempt to introduce expert testimony, Deque did not timely provide the required information. BrowserStack moved to exclude Deque’s damages evidence and for summary judgment. The district court granted these motions, finding that Deque’s noncompliance with disclosure rules was neither substantially justified nor harmless, and that Deque presented no evidence supporting injunctive or other relief. On appeal, the United States Court of Appeals for the Fourth Circuit reviewed and affirmed the district court’s judgment. The Fourth Circuit held that the district court did not abuse its discretion in excluding all evidence of Deque’s damages under Federal Rule of Civil Procedure 37(c)(1) due to repeated and unjustified failures to comply with disclosure requirements. The court also held that summary judgment for BrowserStack was warranted because Deque could not establish entitlement to injunctive, declaratory, or monetary relief. View "Deque Systems Inc. v. Browserstack, Inc." on Justia Law

Uddin v. Blanche

2026-06-05T10:30:42-08:00

A lawful permanent resident from Bangladesh, who also held Canadian citizenship, resided in New Jersey where he was indicted in 2018 for distributing, storing, and possessing sexually explicit images of children in violation of New Jersey law. He pleaded guilty in 2019 to knowingly storing or maintaining at least 25 items depicting the sexual exploitation or abuse of a child using a file-sharing program that made the files available to others. Following his conviction and requirement to register as a sex offender, he was detained by U.S. immigration authorities and charged with removability under the Immigration and Nationality Act (INA) on the grounds of an aggravated felony and as having committed a crime of child abuse. An immigration judge in Richmond, Virginia, concluded that his conviction categorically matched a crime of child abuse under the INA, making him removable. The judge also denied his applications for cancellation of removal and adjustment of status as a matter of discretion. The Board of Immigration Appeals affirmed the finding of removability and adopted the immigration judge’s discretionary denials. The petitioner then sought review in the United States Court of Appeals for the Fourth Circuit. The Fourth Circuit held that the New Jersey statute, as it existed at the time of the conduct, qualifies categorically as a crime of child abuse under the INA because knowingly storing child sexual abuse material on a peer-to-peer file-sharing program creates a reasonable probability of harm to a child. The court denied review of the removability finding. Regarding the discretionary denial of cancellation of removal and adjustment of status, the Fourth Circuit determined it lacked jurisdiction to review those determinations, as they were discretionary merits decisions and did not present questions of law. The petition was therefore denied in part and dismissed in part. View "Uddin v. Blanche" on Justia Law

US v. Goode

2026-06-05T10:30:42-08:00

The defendant pleaded guilty in the United States District Court for the Eastern District of North Carolina to charges including conspiracy to distribute controlled substances and unlawful possession of a firearm by a felon. As part of his plea agreement, he waived his right to appeal his conviction or sentence except for claims of ineffective assistance of counsel or prosecutorial misconduct. At sentencing, the district court found that three prior North Carolina convictions—including second-degree murder—qualified as violent felonies under the Armed Career Criminal Act (ACCA), resulting in an enhanced sentence of 360 months’ imprisonment. The defendant withdrew all objections to the presentence report at sentencing and was sentenced accordingly. On appeal to the United States Court of Appeals for the Fourth Circuit, the defendant argued that his North Carolina second-degree murder conviction did not qualify as a violent felony under the ACCA, and also that his firearm conviction was unconstitutional under the Second Amendment. The government moved to dismiss only the Second Amendment challenge based on the appeal waiver, and argued the merits regarding the ACCA issue. The court dismissed the Second Amendment challenge, but deferred ruling on the ACCA claim. The government later attempted to invoke the appeal waiver against the ACCA challenge, but the court found this argument forfeited as the government had already argued the merits without raising the waiver. The United States Court of Appeals for the Fourth Circuit held that the government forfeited its right to enforce the appeal waiver by failing to timely assert it. On the merits, the court held that North Carolina’s second-degree murder statute categorically qualifies as a violent felony under the ACCA, as it requires malice amounting to extreme recklessness akin to knowledge and always involves the use of physical force. The judgment of the district court was affirmed. View "US v. Goode" on Justia Law

Shaw v. Foreman

2026-06-04T11:00:32-08:00

While incarcerated at Sussex 1 State Prison in Virginia, the plaintiff was accused of indecent exposure in July 2017. He consistently denied the charge and urged prison officials to review video footage from a RapidEye camera, which he claimed would show he was elsewhere when the incident occurred. The officials did not review the footage, stating it was of poor quality and not helpful, and ultimately found the plaintiff guilty after a delayed hearing. As a result of this conviction, and considering his prior offenses, the plaintiff’s security classification was increased and he was transferred to a higher-security facility. He requested that the video footage be preserved, but the prison officials failed to do so. The plaintiff filed suit, alleging procedural due process and First Amendment retaliation claims. The United States District Court for the Eastern District of Virginia initially dismissed the due process claim and granted summary judgment on the retaliation claim. On appeal, the United States Court of Appeals for the Fourth Circuit reversed, noting the importance of the missing video evidence to the plaintiff’s case and remanded for further proceedings. During discovery on remand, it became clear that the video footage had not been preserved, leading the plaintiff to move for spoliation sanctions. The magistrate judge began considering the sanctions motion, but the district court granted summary judgment to the defendants on all claims before ruling on the sanctions issue. The United States Court of Appeals for the Fourth Circuit held that the district court abused its discretion by granting summary judgment before addressing the plaintiff’s motion for sanctions related to the missing video footage. Because the footage was central to the claims, the appellate court vacated the district court’s decision and remanded with instructions to fully consider the sanctions motion. View "Shaw v. Foreman" on Justia Law

Jonathan R. v. Morrisey

2026-06-04T11:00:32-08:00

A group of children in West Virginia’s foster care system filed a class action lawsuit against state officials, alleging systemic failures by the state agencies responsible for their care. The plaintiffs claimed the state’s practices resulted in widespread abuses, neglect, inadequate placements, understaffing, and failure to provide necessary physical and mental health services. They alleged violations of their constitutional rights under the Fourteenth Amendment, as well as statutory violations under the Adoption Assistance and Child Welfare Act, the Americans with Disabilities Act, and the Rehabilitation Act. The class action encompassed approximately 6,800 foster children, with additional subclasses for kinship placements, children with disabilities, and those aging out of the system. The United States District Court for the Southern District of West Virginia initially dismissed the case on abstention and mootness grounds, but that decision was reversed by the United States Court of Appeals for the Fourth Circuit in Jonathan R. ex rel. Dixon v. Justice. Upon remand, the district court certified the General Class and ADA Subclass, denied certification of other subclasses, and proceeded with discovery. In February 2025, the district court, acting sua sponte and without notice or briefing, dismissed the case with prejudice for lack of standing, finding that it lacked power under Article III to grant the requested injunctive and declaratory relief and concluding the plaintiffs’ injuries were not redressable. The United States Court of Appeals for the Fourth Circuit reviewed the dismissal de novo. It held that federal courts have the authority and duty to remedy systemic constitutional violations, including through comprehensive injunctive relief and declaratory judgments in institutional reform cases. The court found that the plaintiffs’ injuries were sufficiently concrete and ongoing, and that the requested relief was likely to redress those injuries. The district court’s dismissal was reversed and the case remanded for further proceedings. The Fourth Circuit declined to reassign the case to a new judge and found West Virginia’s cross-appeal on class decertification unreviewable at this stage. View "Jonathan R. v. Morrisey" on Justia Law

United States ex rel. Kyer v. Thomas Health System, Inc.

2026-06-04T11:00:32-08:00

A nurse formerly employed at a West Virginia hospital system brought a qui tam action on behalf of the United States under the False Claims Act. She alleged that the hospital system, its affiliated entities, and a former executive submitted claims to the federal government that were prohibited by the Stark Law and the Anti-Kickback Statute. Specifically, she claimed that the defendants’ compensation and financial arrangements with physicians created unlawful incentives for referrals, resulting in the submission of false claims to Medicare between 2013 and 2022. The complaint included detailed tables of claims and described physician compensation structures, as well as financial transfers between entities within the health system. The United States District Court for the Southern District of West Virginia reviewed the case after the government declined to intervene. The court dismissed the amended complaint for failure to plead fraud with the particularity required by Rule 9(b) of the Federal Rules of Civil Procedure. The district court found that the complaint did not sufficiently allege the necessary elements of a False Claims Act violation, including a plausible connection between physician compensation and prohibited referrals, or that any claims submitted were actually false under the Stark Law or the Anti-Kickback Statute. The district court also denied the plaintiff’s post-judgment motions to vacate the judgment and for leave to amend the complaint, finding that additional amendment would prejudice the defendants after years of litigation and access to substantial discovery. On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s dismissal and denial of leave to amend. The Fourth Circuit held that the complaint did not plead fraud with the required particularity, failed to plausibly allege violations of the Stark Law or the Anti-Kickback Statute, and did not present facts sufficient to support claims of conspiracy or reverse false claims. The court found no abuse of discretion in denying post-judgment relief. View "United States ex rel. Kyer v. Thomas Health System, Inc." on Justia Law

West Virginia Rivers Coalition, Inc. v. The Chemours Company FC, LLC

2026-06-03T10:30:30-08:00

The case centers on the operations of a chemical manufacturing facility in Parkersburg, West Virginia, owned by The Chemours Company. Chemours used hexafluoropropylene oxide dimer acid (HFPO-DA), a member of the PFAS class of chemicals, as a processing aid in polymer production. The company discharged wastewater containing HFPO-DA into the Ohio River under a Clean Water Act (CWA) permit that established specific effluent limits. However, from 2022 onward, Chemours exceeded these limits on multiple occasions. Local water testing showed that HFPO-DA concentrations sometimes surpassed newer, not-yet-enforceable federal health standards but did not exceed West Virginia’s own goals. Chemours entered into an administrative consent order with the EPA to address permit compliance. The United States District Court for the Southern District of West Virginia reviewed a citizen suit brought by West Virginia Rivers Coalition, Inc., seeking a preliminary injunction against Chemours for ongoing permit violations. The district court found that the Coalition had Article III associational standing through a member who avoided boating in the Ohio River due to Chemours’ discharges. The court granted the preliminary injunction, enjoining Chemours from exceeding permit limits and requiring remedial measures. Chemours appealed, challenging both the standing determination and the irreparable harm finding. The United States Court of Appeals for the Fourth Circuit examined both issues. The court agreed that the Coalition had established a substantial likelihood of standing at this stage. However, it found that the district court committed legal errors in its irreparable harm analysis, including incorrectly presuming harm from permit violations and conflating harm to the public with harm to the plaintiff. The Fourth Circuit also found clear error in the factual findings regarding irreparable harm. Accordingly, the Fourth Circuit vacated the preliminary injunction granted by the district court. View "West Virginia Rivers Coalition, Inc. v. The Chemours Company FC, LLC" on Justia Law

Mebane v. GKN Driveline North America, Inc.

2026-06-02T11:01:23-08:00

A former employee brought a class-action lawsuit against his previous employer, alleging that the company’s practices concerning rounding employees’ time entries and automatically deducting meal breaks resulted in violations of the Fair Labor Standards Act and the North Carolina Wage and Hour Act. The employer operated manufacturing facilities in North Carolina and used policies that rounded employee work time and deducted unpaid meal breaks regardless of whether an employee actually took the break. Plaintiffs argued these policies led to unpaid overtime and wages. The United States District Court for the Middle District of North Carolina initially certified two classes under Federal Rule of Civil Procedure 23 and conditionally certified a collective action under the FLSA. However, after further developments and evidence showing that individualized inquiries would be necessary to determine whether employees were harmed by the time-rounding and meal-deduction policies, and that not all employees suffered wage loss, the district court decertified the classes and collective action. Subsequently, the named plaintiffs settled their individual claims with the employer, and the district court dismissed all remaining substantive claims with prejudice. The United States Court of Appeals for the Fourth Circuit was asked to review the district court’s order decertifying the classes and collective action. The court held that because the plaintiff voluntarily settled his individual claims before filing the appeal, he lacked standing to challenge the district court’s decertification order. The court reasoned that once the individual claims underlying the request for class certification are settled or dismissed voluntarily, the plaintiff no longer retains a concrete interest sufficient to satisfy Article III’s case-or-controversy requirement. Accordingly, the Fourth Circuit dismissed the appeal for lack of jurisdiction. View "Mebane v. GKN Driveline North America, Inc." on Justia Law

Alvarado-Paz v. Blanche

2026-06-01T11:01:11-08:00

A woman and her minor child fled El Salvador for the United States after the woman’s father threatened to kill her, following a long history of severe domestic violence within the family. The woman’s mother was murdered by the father’s foster brother, allegedly at the father’s direction. After the murder, the woman and her siblings reported their suspicions to Salvadoran authorities, but law enforcement did not pursue the accused or investigate the family’s allegations. The woman and her child then received threats from masked men, which she believed were connected to her father. Fearing for their lives, they entered the United States without inspection and applied for asylum and withholding of removal under the Immigration and Nationality Act (INA), and for relief under the Convention Against Torture (CAT). An Immigration Judge (IJ) found the woman credible but denied all relief, concluding she had not established persecution on account of a protected ground—rejecting her claims based on political opinion and proposed particular social groups (PSGs), and also finding no government acquiescence for purposes of CAT protection. The Board of Immigration Appeals (BIA) dismissed her appeal, agreeing with the IJ that she had not demonstrated the required nexus between her persecution and any protected ground, and declined to consider some PSG claims, believing they had not been raised before the IJ. The United States Court of Appeals for the Fourth Circuit reviewed the case. It held that the BIA committed reversible error by failing to consider the merits of her claim based on the PSG “Salvadoran women,” as this group had been properly raised before the IJ. The court granted the petition in part, vacated the removal order, and remanded for further proceedings on that issue. However, the court denied the petition regarding all other claims for asylum, withholding of removal, and CAT protection. View "Alvarado-Paz v. Blanche" on Justia Law

US v. Gentner

2026-05-28T10:31:24-08:00

Two executives of a Charlotte-based software company, serving as Chief Executive Officer and Chief Operating Officer, were responsible for the company’s financial affairs, including filing required IRS forms and paying over trust-fund taxes withheld from employees’ wages. Over multiple years, the company failed to pay over these taxes, despite repeated IRS interventions, warnings from advisors, and assurances from the executives that steps were being taken to resolve their liabilities. Despite participation in an IRS Voluntary Disclosure Program and substantial company revenues, the executives continued to pay themselves significant salaries while the unpaid trust-fund tax debt accumulated, ultimately exceeding $500,000. After the company ceased operations, the IRS imposed personal liability and penalties on both executives, who also failed to use available funds to pay overdue taxes. A federal grand jury in the United States District Court for the Western District of North Carolina indicted both executives in January 2023 for five counts of willful failure to pay over trust-fund taxes, in violation of 26 U.S.C. § 7202. After a joint jury trial in March 2024, both were convicted on these counts, though acquitted of filing false tax returns and tax evasion. Their post-trial motions for acquittal and a new trial—based on insufficiency of the evidence and the alleged weight of evidence favoring their cooperation with the IRS—were denied by the district court. The United States Court of Appeals for the Fourth Circuit reviewed the convictions and denial of the new trial motion. The court applied an abuse of discretion standard to the jury instruction and Rule 33 new trial issues, and reviewed legal questions de novo. The Fourth Circuit held that the district court did not abuse its discretion in allowing the jury to review the indictment, providing instructions regarding willfulness and the good faith defense, or denying a new trial, finding that the evidence of willful failure to pay over taxes was overwhelming. The criminal judgments were affirmed. View "US v. Gentner" on Justia Law

US v. Revels

2026-05-27T10:31:06-08:00

Jonathan Revels was involved in a fatal altercation during which he shot and killed Jason Hunt with a revolver. Evidence showed Revels possessed three firearms at various times during the incident: two shotguns and the revolver used in the shooting. He was charged in federal court with a single count of possessing a firearm after a felony conviction, specifically referencing the two shotguns in the indictment, but not the revolver. A jury convicted Revels of this charge, and he was sentenced to 120 months in prison. While an earlier appeal affirmed the conviction, it remanded for resentencing due to a material fact misrepresented by the government at the original sentencing. After the remand from the United States Court of Appeals for the Fourth Circuit, but before resentencing, Revels was convicted in state court of voluntary manslaughter for the killing of Hunt. At resentencing, the United States District Court for the Eastern District of North Carolina applied a cross-reference in the Federal Sentencing Guidelines that enhances sentences if a firearm cited in the offense of conviction was used in connection with another offense, here applying the voluntary manslaughter guideline. The district court imposed a sentence of 84 months. Revels appealed, arguing that the government had not proved the statutory requirements for the enhancement, and that his sentence was both procedurally and substantively unreasonable. The United States Court of Appeals for the Fourth Circuit vacated Revels’ sentence and remanded for resentencing. The court held that the district court did not make sufficient factual findings to support the application of the cross-reference provision in the Sentencing Guidelines, specifically failing to identify which firearm formed the basis for the enhancement or to explain how it was used in connection with the homicide. The court did not decide whether the enhancement could apply, leaving that for the district court on remand. View "US v. Revels" on Justia Law

Messer v. Garrison Investment Group, LP

2026-05-26T11:01:01-08:00

A group of former employees of a company that operated a manufacturing facility in Virginia sued the company after it announced it would close and began terminating employees. They alleged violations of the Worker Adjustment and Retraining Notification Act (WARN Act) due to insufficient notice of the plant closure, and violations of the Employee Retirement Income Security Act (ERISA) relating to the improper termination of a severance plan. The employees initially named an investment group and several related parties as defendants, claiming they were alter egos or successors of the company and should be jointly liable. However, before trial, the employees voluntarily dismissed the investment group and related parties without prejudice, focusing instead on the liability of the company itself. The United States District Court for the Western District of Virginia granted summary judgment in part, including dismissing claims by employees who signed releases, and ultimately entered a money judgment against the company after a bench trial. The employees were unable to collect on this judgment due to the company's insolvency. They then filed a new lawsuit against the investment group and various related parties, seeking to enforce the prior judgment on alter ego and veil piercing theories and claiming federal jurisdiction under the WARN Act and ERISA. The United States Court of Appeals for the Fourth Circuit reviewed the district court's dismissal of the new lawsuit for lack of subject matter jurisdiction. The Fourth Circuit held that federal courts lack subject matter jurisdiction to enforce a prior federal judgment against parties not found liable in the original action, absent independent allegations of new federal statutory violations. The court affirmed the district court's dismissal, concluding that neither federal question jurisdiction nor ancillary jurisdiction applied because the plaintiffs did not allege new violations of the WARN Act or ERISA. View "Messer v. Garrison Investment Group, LP" on Justia Law

US v. Starkey

2026-05-22T10:31:06-08:00

Jaron Starkey pleaded guilty to a federal drug-trafficking offense and was sentenced to 300 months in prison. His sentence was enhanced under the career-offender provision of the United States Sentencing Guidelines, based on two prior felony drug-distribution convictions in Delaware from 2012 and 2019. Starkey challenged the use of these convictions as predicates for the enhancement, contending that the Delaware statutes under which he was convicted criminalized attempted drug distribution, which, according to Fourth Circuit precedent prior to a 2023 Guidelines amendment, would not qualify as “controlled substance offenses” under the Sentencing Guidelines. The United States District Court for the Eastern District of Virginia rejected Starkey’s argument and applied the career-offender enhancement, concluding that his prior Delaware convictions qualified as predicate offenses under the Guidelines. Starkey appealed this determination. The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court’s judgment. The Fourth Circuit held that the Delaware statutes under which Starkey was convicted define “delivery” to include “attempted transfers,” but this does not mean they criminalize attempted delivery as an inchoate offense. Instead, the offense of delivery encompasses completed acts that may include attempted transfers, which are distinct from mere attempts prosecuted under separate attempt statutes. The court found that Delaware law does not prosecute inchoate attempted deliveries under its drug-distribution statutes. Therefore, Starkey’s prior convictions properly qualified as controlled substance offenses for the career-offender enhancement. The Fourth Circuit affirmed the judgment of the district court. View "US v. Starkey" on Justia Law

US v. Scott

2026-05-22T10:31:06-08:00

The defendant pleaded guilty to a federal offense that prohibits possession of a firearm by a convicted felon. During sentencing, his presentence report recommended an enhanced base offense level because of a prior 2008 conviction under Virginia Code § 18.2-53.1 for using a firearm in the commission of a felony, specifically robbery. This enhancement was based on the conclusion that the prior conviction constituted a “crime of violence” as defined by the Federal Sentencing Guidelines. The defendant, through counsel, objected, arguing that his prior conviction did not meet the Guidelines’ definition of a crime of violence, and the parties’ written and oral arguments focused primarily on whether the elements clause or the enumerated offense clause of the Guidelines applied. The United States District Court for the Eastern District of Virginia overruled the defendant’s objection and applied the enhancement, basing its conclusion on the elements clause. The court’s reasoning mirrored the elements clause language, and its supporting citations were to cases addressing that clause or similar provisions. The resulting advisory Guidelines range was higher, and the defendant received a 33-month sentence. On appeal, he argued that the court erred in finding his prior conviction qualified as a crime of violence. The government defended the application of the elements clause and also raised arguments under the enumerated offense clause and harmless error doctrine. The United States Court of Appeals for the Fourth Circuit held that the district court erred in concluding the prior Virginia conviction satisfied the elements clause, adopting circuit precedent holding that Virginia robbery does not categorically require the use, attempted use, or threatened use of physical force against another. The Fourth Circuit found the government had not demonstrated harmless error and declined to affirm based on the enumerated offense clause. The court vacated the sentence and remanded for resentencing. View "US v. Scott" on Justia Law

Sessoms v. USHealth Advisors, LLC

2026-05-21T11:30:39-08:00

In this case, the plaintiff, acting individually and on behalf of a proposed class, alleged that the defendant, a health insurance marketing company, violated the Telephone Consumer Protection Act (TCPA) by sending her a prerecorded telemarketing call without her prior express consent. The defendant argued that the plaintiff had given such consent when she used a third-party “lead generation” website operated by a non-party, where she filled out a form seeking insurance quotes. The online process included an agreement (the “Terms of Use”) with an arbitration clause covering disputes related to the website’s use and consent to be contacted by marketing partners, although the defendant was not named in the agreement. After the plaintiff filed suit in the United States District Court for the Eastern District of North Carolina, the defendant moved to compel arbitration, arguing that it could enforce the arbitration clause as a third-party beneficiary under Delaware law. The district court denied the motion, holding that, although the defendant benefited from the agreement, it was not a third-party beneficiary because the benefit was not central to the contract’s purpose. The court also determined that, under Fourth Circuit precedent, the court—not an arbitrator—must decide whether a non-signatory like the defendant can enforce the arbitration agreement. On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s denial of arbitration de novo. The Fourth Circuit agreed that the district court, not an arbitrator, was the proper forum to decide the defendant’s standing to enforce the arbitration clause. However, the court disagreed with the district court’s interpretation of Delaware law, concluding that the benefit to the defendant was material to the agreement’s purpose, making the defendant a third-party beneficiary. The Fourth Circuit reversed the district court’s order and remanded with instructions to compel arbitration and stay the federal court proceedings. View "Sessoms v. USHealth Advisors, LLC" on Justia Law

McPherson v. Patton

2026-05-21T11:30:39-08:00

Two brothers were convicted in 1995 by a Maryland state jury of conspiracy to murder, following the fatal shooting of Anthony Wooden in Baltimore. The police investigation, led by two detectives, included interviews with several witnesses. Among them was Marcus King, a thirteen-year-old with learning disabilities, who initially denied involvement but, after an unrecorded and allegedly coercive police interrogation, gave a recorded statement implicating himself and the brothers. At the subsequent trial, King recanted his statement, claiming police coercion. The main evidence against the brothers was the testimony of King and another witness, Diane Bailey, whose credibility was also questioned. After serving more than twenty years in prison, the brothers sought relief through the State’s Conviction Integrity Unit, which led to a joint petition with the State for a writ of actual innocence. A Maryland court granted the writ, vacating the convictions. The brothers then filed a civil rights suit in the United States District Court for the District of Maryland against the detectives involved, alleging constitutional violations, including fabrication and suppression of evidence. The district court dismissed all claims except those against two detectives, Patton and Barlow. On their motion for summary judgment, the district court excluded King’s prior trial testimony as inadmissible hearsay and granted summary judgment for the detectives, finding insufficient evidence of fabrication or suppression. On appeal, the United States Court of Appeals for the Fourth Circuit held that the district court abused its discretion in excluding King’s trial testimony, finding the prosecutor’s motive in the original trial sufficiently similar to the detectives’ interests in the civil case for admissibility under Federal Rule of Evidence 804(b)(1). The Fourth Circuit concluded that the brothers presented sufficient evidence to create a genuine dispute of material fact on their fabrication claim but not on the suppression claim, and therefore vacated in part, affirmed in part, and remanded the case for further proceedings. View "McPherson v. Patton" on Justia Law

Rodriguez-Solis v. Blanche

2026-05-21T11:30:35-08:00

The petitioner, a Honduran national, entered the United States in 2010 and was served with a notice of removal for lacking lawful admission or parole. After her first master calendar hearing, she requested and received a transfer to North Carolina. She subsequently retained counsel, who conceded removability and submitted an asylum application. Over several years, her removal proceedings were administratively closed and later reopened at the government’s request, leading to repeated postponements and delays, mostly due to procedural matters and circumstances beyond her control, such as pregnancy and exposure to COVID-19. Just weeks before a key hearing and associated filing deadline, her longtime attorney withdrew, citing lack of cooperation, and the immigration judge allowed this withdrawal without findings or explanation. Following the attorney’s withdrawal, the petitioner sought additional time to secure new counsel, explaining she had only learned of the withdrawal about a month before the hearing and was unable to find an attorney to prepare her case. Despite her objections and the fact this was her first such request, the immigration judge denied her request for a continuance and proceeded with the merits hearing, during which she represented herself. The judge found her testimony not credible and ordered her removal to Honduras. The Board of Immigration Appeals affirmed the judge’s decision, concluding she had “sufficient time to retain counsel” and did not establish a violation of her statutory or due process rights. The United States Court of Appeals for the Fourth Circuit reviewed the Board’s decision and held that the immigration judge violated the petitioner’s statutory right to counsel under the Immigration and Nationality Act by not granting her a reasonable and realistic opportunity to obtain new representation after her attorney’s withdrawal. The court granted the petition for review, vacated the final order of removal, and remanded to the Board to determine whether this violation prejudiced the petitioner. View "Rodriguez-Solis v. Blanche" on Justia Law

Brunenkant v. Suburban Hospital, Inc.

2026-05-21T11:30:35-08:00

The plaintiff, a lawyer, visited Suburban Hospital in Maryland in October 2015 with abdominal pain and other symptoms. He was diagnosed with gallbladder disease and underwent surgery performed by Dr. Daee, who was presented to him as a hospital agent or employee. Complications from that surgery led to a second operation at a different hospital a month later, where alleged medical malpractice was discovered. During subsequent litigation, the plaintiff learned in May 2022 that Dr. Daee was not a hospital employee but an independent contractor, and that the hospital may have misrepresented this relationship. The plaintiff first filed a medical malpractice action against the hospital and Dr. Daee in the United States District Court for the District of Maryland in 2020. In 2022, after discovering new information, he tried to amend his complaint to add fraud and conspiracy claims, but the district court denied this request. He then filed a separate lawsuit in May 2023, alleging fraudulent misrepresentation and conspiracy to commit fraud regarding the hospital’s representations about Dr. Daee’s status. The hospital moved to dismiss, arguing the claims were barred by Maryland’s five-year statute of limitations for medical malpractice under the Health Care Malpractice Claims Act. The district court agreed and dismissed the complaint. The United States Court of Appeals for the Fourth Circuit reviewed the appeal. The court held that the district court applied the incorrect statute of limitations. It determined that the plaintiff’s fraud and conspiracy claims were not traditional malpractice claims and should be governed by Maryland’s general three-year statute of limitations for civil actions, not the five-year period for medical malpractice. The Fourth Circuit vacated the district court’s dismissal order and remanded the case for further proceedings, without deciding whether the claims were timely under the correct statute. View "Brunenkant v. Suburban Hospital, Inc." on Justia Law

Jackson v. Protas, Spivok & Collins LLC

2026-05-18T10:30:34-08:00

Donte Jackson received a $30,000 loan from WebBank, which was later sold to Velocity Investments, LLC. After Jackson defaulted on the loan, Velocity, represented by the law firm Protas, Spivok & Collins LLC (PSC), sued Jackson in Maryland state court to collect the debt. Velocity eventually dismissed the state court suit with prejudice. Subsequently, Jackson brought a class action lawsuit against both Velocity and PSC, alleging that their practice of suing on time-barred debts was unlawful. In the United States District Court for the District of Maryland, both Velocity and PSC moved to compel arbitration based on an arbitration clause in Jackson’s original promissory note. The district court found that Velocity, as a subsequent holder of the note, was a party to the arbitration agreement but had waived its right to arbitrate by filing suit in state court. The court ruled that PSC was not a party to the agreement, as it did not fit the contractual definition of an entity “servicing” the note, which the court interpreted in accordance with Maryland law. Only PSC appealed the denial of its motion to compel arbitration. The United States Court of Appeals for the Fourth Circuit reviewed the district court’s ruling de novo. The Fourth Circuit held that PSC, as the law firm representing Velocity, was not a party to the arbitration agreement because it did not “service” the note in the relevant contractual sense, which involves collecting and maintaining a payment schedule for the loan. The court concluded that the arbitration agreement covered only creditors and loan servicers, not lawyers. The Fourth Circuit affirmed the district court’s denial of PSC’s motion to compel arbitration. View "Jackson v. Protas, Spivok & Collins LLC" on Justia Law

LaRosa v. Commissioner of Internal Revenue

2026-05-18T10:30:33-08:00

Catherine LaRosa and her late husband filed joint tax returns for several years. Following IRS assessments for underpayment for the years 1981–1983, and overpayment for 1984–1985, the parties reached a settlement in which both owed each other money. The LaRosas paid the IRS the net amount, including interest and penalties, but later sought a refund, arguing the IRS had miscalculated the interest. In 1994, the IRS issued a refund after recalculating the interest, but later determined that the refund was incorrect and sued to recover it. The United States District Court for the District of Maryland granted summary judgment to the government, ordering repayment, and the United States Court of Appeals for the Fourth Circuit affirmed. The LaRosas did not repay the refund for over twenty years. In 2019, the government attempted to foreclose on the LaRosas’ home to collect the judgment. At this point, LaRosa sought “innocent spouse” equitable relief from the IRS under 26 U.S.C. § 6015(f)(1), which allows the IRS to relieve a taxpayer from liability for any unpaid tax in certain circumstances. The IRS refused to process her request, asserting that no amount was currently owed and that Section 6015(f) did not authorize relief for erroneous refunds. LaRosa then sought review in the United States Tax Court, which granted summary judgment to the IRS, holding that the erroneous refund did not create an “unpaid tax” or “deficiency” eligible for relief under Section 6015(f). On appeal, the United States Court of Appeals for the Fourth Circuit held that an erroneous refund of underpayment interest does create a liability for “unpaid tax” eligible for equitable relief under Section 6015(f)(1). The court vacated the Tax Court’s judgment and remanded for further proceedings. The holding was limited to underpayment interest and did not address other issues, which were left for the Tax Court to consider on remand. View "LaRosa v. Commissioner of Internal Revenue" on Justia Law

US v. Straite

2026-05-18T10:30:33-08:00

In this case, the defendant participated in two incidents at a North Carolina bank: an armed robbery in which employees were assaulted with firearms, and a subsequent attempted armed robbery where the group was foiled when the bank manager recognized them and secured the building. The defendant was convicted by a jury of both armed bank robbery and attempted armed bank robbery under 18 U.S.C. § 2113(a) and (d), as well as for brandishing firearms during these crimes in violation of 18 U.S.C. § 924(c)(1)(A)(ii). Following his conviction and sentence, which were affirmed by the United States Court of Appeals for the Fourth Circuit in 2014, the defendant filed several postconviction motions in the United States District Court for the Middle District of North Carolina. These were denied. On appeal, the Fourth Circuit granted a certificate of appealability limited to the question of whether the defendant’s conviction for attempted armed bank robbery qualified as a “crime of violence” for purposes of supporting his related conviction under Section 924(c). The United States Court of Appeals for the Fourth Circuit reviewed de novo whether attempted armed bank robbery under 18 U.S.C. § 2113(d) categorically constitutes a crime of violence under 18 U.S.C. § 924(c)(3). The court held that because Section 2113(d) requires either assaulting another person or putting another’s life in jeopardy by use of a dangerous weapon or device during the course of an attempted bank robbery, the offense necessarily entails the use, attempted use, or threatened use of physical force. The court also found that the statute requires intentional, rather than merely reckless, conduct. Therefore, the court affirmed that attempted armed bank robbery under Section 2113(d) is categorically a crime of violence and affirmed the district court’s decision. View "US v. Straite" on Justia Law

In re: Express Scripts, Inc.

2026-05-15T10:30:35-08:00

A large group of cities, towns, and counties in West Virginia sued a pharmacy benefit manager, alleging that it contributed to the oversupply of opioids in their communities, thus creating a public nuisance. The local governments sought an injunction requiring the defendant to fund the abatement of the ongoing public nuisance and to compensate them for the costs of rectifying it. This proposed “abatement fund” was described as covering not just eliminating the oversupply itself, but also providing addiction treatment, education, and community rehabilitation. The United States District Court for the Northern District of West Virginia denied the defendant’s demand for a jury trial, determining that the Seventh Amendment did not confer a right to a jury trial because this was a governmental public nuisance action seeking only abatement, which the court characterized as an equitable remedy. The district court also ordered a bifurcated bench trial on the public-nuisance claim, with a potential statewide abatement phase, and denied the defendant’s motions for reconsideration or for interlocutory appeal. The United States Court of Appeals for the Fourth Circuit reviewed the case on a petition for a writ of mandamus. The Fourth Circuit held that the Seventh Amendment entitles the defendant to a jury trial because the relief sought by the local governments included a classic legal remedy—compensation for downstream harms resulting from the alleged public nuisance, such as addiction treatment and community rehabilitation. The court explained that, at the time of the Founding, only courts of law—not equity—could award such monetary relief for the consequences of a public nuisance. Therefore, the defendant was entitled to a jury trial on the public-nuisance claim, and the petition for mandamus was granted in part. View "In re: Express Scripts, Inc." on Justia Law

Retail Energy Advancement League v. Brown

2026-05-15T10:30:35-08:00

Maryland enacted legislation regulating how retail electricity suppliers may market “green power” to consumers, seeking to address concerns that consumers were misled by claims about renewable energy. The statute prohibits suppliers from using terms such as “clean,” “green,” or “100% renewable” unless at least 51% of the energy is backed by renewable energy credits (RECs) from within a specific regional grid (the PJM region). Additionally, suppliers are required to include disclosures explaining the nature of RECs and their relationship to renewable electricity, with the exact disclosure language later specified by the Maryland Public Service Commission (PSC). Retail Energy Advancement League and Green Mountain Energy Company brought a facial First Amendment challenge against these provisions and sought a preliminary injunction in the United States District Court for the District of Maryland. The district court denied the injunction, applying intermediate scrutiny to the speech restriction and concluding that the plaintiffs were unlikely to prevail on the merits. The court also found that the statute’s disclosure requirements likely survived constitutional review. On appeal, the United States Court of Appeals for the Fourth Circuit found that the plaintiffs demonstrated a likelihood of success in showing the speech restriction was unconstitutional even under intermediate scrutiny, because the restriction did not materially advance Maryland’s asserted interest in preventing consumer deception and was not adequately tailored. The Fourth Circuit reversed the district court’s denial of a preliminary injunction as to the speech restriction and ordered an injunction against enforcement of that provision. However, regarding the compelled disclosure requirement, the Fourth Circuit remanded the case for the district court to review the constitutionality of the new PSC-promulgated disclosure language in the first instance. View "Retail Energy Advancement League v. Brown" on Justia Law

Winnebago Tribe of Nebraska v. United States Department of the Army

2026-05-14T10:30:35-08:00

Two children from the Winnebago Tribe of Nebraska were forcibly taken from their homes in the late 1800s and placed in a federal Indian boarding school on a United States Army base. Both died at the school, allegedly because of abusive conditions, and were buried on the grounds without the consent of their families or the tribe, contrary to their tribal and religious customs. Decades later, the Army relocated the remains, along with others, to the Carlisle Barracks Post Cemetery, again without consent. The Winnebago Tribe sought the return of the boys’ remains for proper reburial, invoking the Native American Graves Protection and Repatriation Act (NAGPRA). The United States District Court for the Eastern District of Virginia dismissed the Tribe’s action for failure to state a claim. The court reasoned that NAGPRA’s repatriation requirement only applies to Native American remains that are part of a federal agency’s or museum’s “holdings or collections,” and concluded that remains interred in a cemetery do not qualify. The court found that the relevant statutory and regulatory language, as well as the legislative history, supported this interpretation. The United States Court of Appeals for the Fourth Circuit reviewed the case and disagreed with the district court’s interpretation. The Fourth Circuit held that, under the ordinary meaning of “holdings or collections,” as well as the applicable statutory context and regulatory definitions, the remains of the two boys, purposefully accumulated and held by the Army in the cemetery, are covered by NAGPRA’s repatriation requirement. The court emphasized that its holding does not extend to consensually buried remains or require agencies to inventory unknown remains. The judgment of the district court was vacated and the case remanded for further proceedings. View "Winnebago Tribe of Nebraska v. United States Department of the Army" on Justia Law

Lewis v. Circle K Stores Inc.

2026-05-13T10:30:24-08:00

Jonathan Lewis was injured when he slipped and fell on a painted line in the parking lot of a convenience store in South Carolina. The fall occurred after a store employee had cleaned the area using water and a powdered concrete cleaner, but no warning signs, cones, or safety vests were present, despite company policy. Lewis injured his right leg, undergoing surgery and incurring significant medical expenses. He had a prior history of injury to the same tendon, but the circumstances of the fall were undisputed: he slipped immediately after stepping on the wet surface as he exited the store. Lewis filed a premises liability suit against the store, alleging negligence in failing to warn about or remedy the hazardous condition. The case was removed to the United States District Court for the District of South Carolina. After discovery, the district court granted summary judgment to the store. It held: first, that the wet and cleaned surface was an “open and obvious” hazard, removing the store’s duty to warn; second, that there was no evidence the store could have foreseen the specific risk; and third, that Lewis failed to offer expert testimony establishing causation for his injury. The district court also denied Lewis’s Daubert and spoliation motions. On appeal, the United States Court of Appeals for the Fourth Circuit reversed the grant of summary judgment, holding that genuine disputes of material fact remained regarding whether the hazard was “open and obvious” and whether expert testimony was required to establish causation. The court vacated the district court’s Daubert and spoliation rulings, remanding for further proceedings. The main holding is that, under South Carolina law, questions of breach and causation in slip-and-fall cases with these facts are for the jury, and expert testimony is not always required for causation in such cases. View "Lewis v. Circle K Stores Inc." on Justia Law

Hall v. Fleming

2026-05-13T10:30:24-08:00

A Virginia college student applied for a state tuition grant program that provides financial assistance to residents attending accredited private, nonprofit colleges in Virginia. The program disqualifies students whose primary major falls under “religious training or theological education,” as classified by certain federal instructional codes. After enrolling at Liberty University as a Music Education major and being notified of her eligibility for the grant, she changed her major first to “Youth Ministries” and later to “Music & Worship”—both considered religious vocational programs under the state’s rules. As a result, she was found ineligible for the grant for two academic years. The student filed suit in the United States District Court for the Eastern District of Virginia, alleging that the grant program’s exclusion of her religious vocational major violated her First Amendment right to free exercise of religion. The defendant, the director of the state higher education council, moved to dismiss, arguing that the United States Supreme Court’s decision in Locke v. Davey directly controlled and foreclosed her claim. The district court agreed, finding her situation essentially identical to the plaintiff’s in Locke, and concluded that subsequent Supreme Court decisions—Trinity Lutheran Church of Columbia, Inc. v. Comer, Espinoza v. Montana Department of Revenue, and Carson ex rel. O.C. v. Makin—had not overruled Locke. The court dismissed her claim with prejudice. On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s dismissal de novo. The appellate court held that Locke v. Davey remains binding precedent, and that the Supreme Court’s more recent decisions reaffirmed rather than abrogated it. The Fourth Circuit therefore affirmed the district court’s dismissal, upholding the constitutionality of the grant program’s exclusion of religious vocational majors. View "Hall v. Fleming" on Justia Law

US v. Mhana

2026-05-12T10:30:32-08:00

Rami Mhana operated businesses that purchased fraudulently obtained Apple iPhones and other electronics at below-market prices, paying in cash and often shipping these goods overseas in bulk. His suppliers included individuals who acquired electronics using stolen personal information to make purchases from major retailers and wireless carriers. Mhana did not verify his suppliers’ identities or the legitimacy of the goods, nor did he provide receipts. He also paid third-party services to unlock phones, enabling their use on any network. The government’s investigation began after a ruptured overseas shipment revealed the scheme, ultimately leading to the discovery of thousands of fraudulent transactions. A federal grand jury in the United States District Court for the Western District of North Carolina indicted Mhana on multiple counts, including transportation of stolen goods, conspiracy, and money laundering. Following a six-day trial, the jury convicted him on all charges. The indictment included a forfeiture notice, and the jury found a nexus between certain property and Mhana’s crimes. The district court initially granted a preliminary order of forfeiture but, at sentencing, declined to enter a final forfeiture judgment, citing concerns about double payment with restitution. The district court entered final judgment, prompting Mhana to appeal his convictions and the government to cross-appeal the forfeiture ruling. The United States Court of Appeals for the Fourth Circuit reviewed the case. It affirmed Mhana’s convictions, finding no reversible error in the district court’s evidentiary rulings, and determined that any assumed errors were harmless given the overwhelming evidence of guilt. However, the appellate court reversed the district court’s denial of forfeiture, holding that forfeiture is mandatory under federal law when the statutory prerequisites are satisfied, even if restitution is also imposed, and remanded the case for entry of a forfeiture judgment. View "US v. Mhana" on Justia Law

US v. Davis

2026-05-12T10:30:32-08:00

The defendant was arrested in March 2021 for unlawfully possessing a firearm as a convicted felon after a police encounter outside a convenience store. During the arrest, he resisted and threatened officers, and was found in possession of a loaded ghost gun and distributable amounts of fentanyl. He was charged with possession of ammunition as a convicted felon and possession with intent to distribute fentanyl, ultimately pleading guilty to the ammunition charge. At sentencing, the court weighed the seriousness of his offense and history, including his mental health issues and young age, and imposed a within-Guidelines sentence of 70 months' imprisonment. After sentencing, a retroactive amendment to the Federal Sentencing Guidelines (Amendment 821) reduced the impact of "status points," lowering the defendant's criminal history category and decreasing his advisory Guidelines range from 57-71 months to 51-63 months. In March 2024, he moved for a sentence reduction under 18 U.S.C. § 3582(c)(2), citing rehabilitation efforts while incarcerated. The government opposed, documenting three disciplinary violations by the defendant in prison, including threatening prison staff. The United States District Court for the Eastern District of Virginia found the defendant eligible for a reduction but denied the motion, concluding that the relevant § 3553(a) factors and his disciplinary record weighed against a reduction. The United States Court of Appeals for the Fourth Circuit reviewed the denial for abuse of discretion. The court held that a sentence reduction motion does not trigger a plenary resentencing or require a detailed explanation for retaining a sentence above the amended Guidelines range. The district court’s acknowledgment and consideration of relevant factors sufficed. The Fourth Circuit affirmed the district court’s decision, finding no abuse of discretion and that the presumption of judicial consideration was not rebutted. View "US v. Davis" on Justia Law

American Acceptance Corporation of SC v. Gietz

2026-05-12T10:30:32-08:00

AAC, a company that finances motorcycle purchases and holds security interests in the vehicles, acquired installment contracts for two motorcycles owned by individuals involved in a criminal case. After one owner, Brock, was killed during a gang shootout, and the other, Andrzejewski, was arrested and charged in connection with the incident, the Lexington County Sheriff’s Department seized both motorcycles as evidence. AAC was not notified of the seizures or the motorcycles’ location and learned about the events through news reports. AAC contacted the Sheriff’s Department seeking information and access to the motorcycles but was told that the vehicles would not be returned until the criminal proceedings concluded. AAC initially filed claim and delivery actions in the Lexington County Circuit Court, but the court dismissed these actions for improper service, noting it would not order release of evidence during a pending murder case. AAC then brought suit in the Lexington County Court of Common Pleas under state law and 42 U.S.C. § 1983, alleging procedural due process violations. The Sheriff’s Department removed the case to the United States District Court for the District of South Carolina, which dismissed AAC’s federal claim, holding that the seizure was lawful and that AAC’s property interests must yield to the state’s duty to preserve evidence for criminal proceedings. The district court remanded the state law claims. The United States Court of Appeals for the Fourth Circuit reviewed the district court’s dismissal de novo. The Fourth Circuit held that when property is seized in connection with a criminal investigation, the Fourth Amendment defines the process that is due, and compliance with its requirements satisfies procedural due process. The court found the seizures lawful and determined that no additional process was required for AAC as a lienholder. The court affirmed the district court’s order granting the defendants’ motion to dismiss. View "American Acceptance Corporation of SC v. Gietz" on Justia Law

Mullen v. Town of Sunset Beach

2026-05-07T11:30:21-08:00

A woman sued a North Carolina town, alleging that a police officer employed by the town had sexually assaulted her while on duty. She claimed that the officer coerced her into sexual acts during visits to her home, sometimes in exchange for leniency regarding traffic violations. The officer had previously passed a background check, though some concerns were raised about his temperament and integrity, and a domestic violence complaint had been filed against him but was dismissed. The police department had no specific written policy prohibiting sexual misconduct, but did have general rules regarding officer conduct. During the officer’s employment, he was disciplined for minor infractions, but no complaints of sexual misconduct were received. The plaintiff reported the alleged assault more than a year after the officer resigned. The United States District Court for the Eastern District of North Carolina granted summary judgment to the town. The court found there was insufficient evidence to show that the town’s police department was deliberately indifferent to the risk of sexual assault by its officers, or that any failure in its policies, training, or supervision caused the plaintiff’s injuries. The court also granted summary judgment on state law claims for negligent hiring, supervision, and retention, concluding there was no evidence that the town knew or should have known that the officer was unfit for employment. On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The Fourth Circuit held that the plaintiff failed to establish municipal liability under 42 U.S.C. § 1983 because there was no evidence of a pattern of similar constitutional violations or deliberate indifference by policymakers. The court also affirmed the dismissal of state law claims, finding no evidence that the town was negligent in hiring, supervising, or retaining the officer. View "Mullen v. Town of Sunset Beach" on Justia Law

Diahn v. Blanche

2026-05-05T10:30:29-08:00

A man born in Cote d’Ivoire to Liberian refugee parents entered the United States as a child but did not acquire lawful permanent resident status. After being convicted of certain crimes in Pennsylvania, he faced removal proceedings to Liberia, a country he had never visited and where he feared persecution due to his bisexual identity and lack of family connections. Throughout his removal proceedings, he was incarcerated and unrepresented, which limited his understanding of the legal process and his ability to submit evidence supporting his claims for relief, including asylum, withholding of removal, and protection under the Convention Against Torture. During his hearings, the Immigration Judge (IJ) provided confusing instructions about where to submit evidence, leading the petitioner to send supporting documents to the wrong court. He was not properly informed of his right to present witnesses and was not clearly instructed on the legal standards for his claims. The IJ denied all relief and ordered his removal, and the Board of Immigration Appeals (the Board) dismissed his appeal, holding that he had either waived certain claims or failed to meet legal requirements. The Board also denied his motions to reopen, finding them untimely and concluding that equitable tolling was unwarranted. The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the IJs and the Board failed in their statutory duty to develop the record, especially given the petitioner’s pro se and detained status. The court found that the petitioner was prejudiced by the lack of guidance and opportunity to present evidence and witnesses and that procedural deficiencies amounted to a denial of a fundamentally fair hearing. The Fourth Circuit granted the petition for review, vacated the Board’s order, and remanded for further proceedings. View "Diahn v. Blanche" on Justia Law

Malone v. United States Patent & Trademark Office

2026-05-05T10:30:28-08:00

A volunteer affiliated with a nonprofit focused on innovation requested documents under the Freedom of Information Act (FOIA) from the United States Patent and Trademark Office (PTO). The request sought information related to an adversary proceeding before the Patent Trial and Appeal Board (PTAB), particularly concerning the panel of judges assigned, changes to the panel, and drafts of the written decision. The proceeding involved a motion for recusal due to a judge’s stock ownership and subsequent reassignment of panel members. The FOIA request specifically targeted documents reflecting the identities and opinions of involved judges, membership of the Circulation Judge Pool, legal bases for judge participation, and information about stock holdings. The PTO produced about 1,500 pages of documents but withheld drafts of decisions and related communications, citing FOIA Exemption 5, which covers predecisional and deliberative documents. The United States District Court for the Eastern District of Virginia reviewed cross-motions for summary judgment and ruled in favor of the PTO, finding that the withheld documents were both predecisional and deliberative. The court rejected arguments that the communications constituted unlawful ex parte communications or government misconduct, determining there was no basis under FOIA to compel disclosure. The court also concluded that the plaintiff’s broader claims were not appropriately raised in a FOIA action. On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The appellate court held that the PTO properly withheld the drafts and related communications under Exemption 5, finding them categorically predecisional and deliberative. The court further determined that intra-agency circulation of draft opinions among judges did not constitute ex parte communications and that FOIA does not provide a government misconduct exception for Exemption 5. View "Malone v. United States Patent & Trademark Office" on Justia Law

US v. Hatchet Speed

2026-05-05T10:30:28-08:00

A former software developer and naval reservist from Virginia, the defendant became the subject of a federal investigation after participating in the events of January 6, 2021, for which he was later pardoned. In the following months, he purchased several firearms and accessories, including devices labeled as “solvent traps” from an online retailer. These devices, although purportedly for cleaning firearms, were constructed in a manner similar to silencers, with features such as threaded ends and internal baffles. The defendant discussed with an undercover FBI employee how these devices could be converted into silencers, despite not possessing the necessary tools for such modification. The United States District Court for the Eastern District of Virginia heard the case after a federal grand jury indicted the defendant for possessing unregistered silencers in violation of the National Firearms Act (NFA). The defendant moved to dismiss the indictment, contending that the statutory definition of a silencer was unconstitutionally vague and that his conviction would violate the Second Amendment. The district court denied these motions and, after a mistrial, the second jury found the defendant guilty on all counts. He was sentenced to 36 months in prison. The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the district court’s jury instructions accurately reflected the statutory definition of a silencer, which does not require operability or exclude dual-use devices. The court found sufficient evidence for the conviction, as the devices’ design and the defendant’s statements supported their classification as silencers. The court also determined the NFA was not unconstitutionally vague as applied. Finally, the court concluded that, even if silencers are protected by the Second Amendment, the NFA’s shall-issue registration regime is presumptively constitutional and the defendant had not shown otherwise. The conviction was affirmed. View "US v. Hatchet Speed" on Justia Law

Spurlock v. Wexford Health Sources, Inc.

2026-05-04T10:30:28-08:00

Three individuals suffering from opioid use disorder (OUD) alleged that while incarcerated in facilities where a private medical contractor provided care, they were denied medically accepted screening and treatment for their condition. They claimed that the medical contractor excluded opioid dependence screening and treatment from its otherwise comprehensive services, forcing affected individuals to undergo withdrawal, even when arriving with a valid prescription for medication-assisted treatment. The plaintiffs asserted that these policies were motivated by cost-saving considerations and persisted even after the contractor was aware of the prevailing medical standards and associated constitutional risks. The United States District Court for the Southern District of West Virginia reviewed the case, which was filed as a class action under 42 U.S.C. § 1983. The plaintiffs sought to certify two classes: one requesting injunctive relief to require the contractor to provide proper screening and treatment, and another seeking damages for past deprivation of such care. The district court certified both classes after narrowing their definitions to ensure ascertainability and found that the requirements of Federal Rule of Civil Procedure 23 were met. Wexford Health Sources, Inc., the defendant, challenged the certification, particularly arguing against the validity, typicality, and commonality of the classes, as well as the predominance and superiority requirements for the damages class. The United States Court of Appeals for the Fourth Circuit reviewed the district court's decision. The Fourth Circuit remanded the case to the district court to determine, in the first instance, whether the named plaintiffs had standing to represent the class seeking injunctive relief, given that standing was first raised on appeal and required fact-specific findings. The Fourth Circuit affirmed the district court’s certification of the damages class, finding no abuse of discretion in its conclusions regarding ascertainability, the Rule 23(a) requirements, predominance, and superiority. View "Spurlock v. Wexford Health Sources, Inc." on Justia Law

Poppleton Now Community Association, Inc. v. La Cite Development, LLC

2026-05-04T10:30:28-08:00

The case concerns efforts by the City of Baltimore to redevelop 13.8 acres in the Poppleton neighborhood through an agreement with a private developer. To facilitate the project, the city used eminent domain to acquire hundreds of properties, which were then transferred to the developer at an allegedly favorable price. Over the years, the project was beset by delays and amendments, resulting in only minimal development and leaving much of the area vacant and in disrepair. Plaintiffs, consisting of neighboring property owners and a community organization, claimed the city’s actions reduced their property values and exposed them to environmental nuisances. The United States District Court for the District of Maryland dismissed the plaintiffs’ claims. It found they lacked Article III standing for their Fifth Amendment takings claim because their own properties were not subject to eminent domain, and held that their private nuisance claim failed to state a claim under Maryland law. The court reasoned that the plaintiffs’ injuries, stemming from the taking of their neighbors’ properties, did not give them standing to challenge the use of eminent domain, and that their allegations of nuisance were insufficiently specific or actionable under state law. On appeal, the United States Court of Appeals for the Fourth Circuit agreed that both claims must be dismissed but for different reasons. The court held that the plaintiffs had Article III standing for the takings claim because they alleged concrete injury through diminished property values. However, it concluded the takings claim failed on the merits since the plaintiffs did not own any property actually taken. The court also ruled that, because all federal claims were dismissed at an early stage, the district court should have declined supplemental jurisdiction over the state law nuisance claim and dismissed it without prejudice. The declaratory judgment request failed as all substantive claims were dismissed. The Fourth Circuit vacated in part and remanded with instructions. View "Poppleton Now Community Association, Inc. v. La Cite Development, LLC" on Justia Law

ColonialWebb Contractors Company v. Hill Phoenix, Inc.

2026-05-04T10:30:28-08:00

This case concerns a dispute between two companies regarding contracts for the purchase of industrial refrigeration equipment. In late 2020, ColonialWebb Contractors Company placed purchase orders with Hill Phoenix, Inc. for projects in Colorado and Michigan. Dissatisfied with the equipment received, ColonialWebb filed two nearly identical breach of contract lawsuits against Hill Phoenix in a Virginia state court. The complaints were filed on the same day and assigned consecutive docket numbers. However, ColonialWebb did not promptly serve either complaint. When Hill Phoenix eventually learned of both cases, it mistakenly believed they were duplicate filings of the same action due to receiving two copies of what appeared to be the same complaint, differing only in docket number. Believing only one action existed, Hill Phoenix filed a single notice of removal to federal court, referencing both cases and requesting consolidation. The clerk’s office for the United States District Court for the Eastern District of Virginia opened a single federal case, effectively consolidating the two actions. ColonialWebb responded with a motion to remand, arguing that a forum selection clause required the disputes to be litigated exclusively in Virginia state court. While ColonialWebb mentioned improper consolidation, its remand motion was based solely on the forum selection clause. The district court, acting on its own initiative, remanded the matter to state court, finding that the consolidation of the state cases was improper but not addressing the merits of the forum selection clause argument. The United States Court of Appeals for the Fourth Circuit reviewed the district court’s remand order. It held that the district court erred by remanding the case sua sponte for a procedural defect that was not raised by timely motion, as required by statute. The Fourth Circuit reversed the remand order and returned the matter to the district court for further proceedings. View "ColonialWebb Contractors Company v. Hill Phoenix, Inc." on Justia Law

United States v. Lefemine

2026-05-01T11:01:07-08:00

Steven Clark Lefemine participated in an anti-abortion protest at a reproductive healthcare facility in Columbia, South Carolina, where he intentionally blocked the entrance by sitting in front of the doorway, preventing patients and staff from entering. After refusing requests to move, the police were called, and Lefemine was arrested. He was initially charged with trespassing under state law, for which he was fined, and subsequently indicted by a federal grand jury for violating the Freedom of Access to Clinic Entrances Act (FACE Act) under 18 U.S.C. § 248. In the United States District Court for the District of South Carolina, Lefemine was first charged under a provision of the FACE Act carrying a maximum penalty of one year in prison. However, the government amended the penalty sheet—an auxiliary document to the indictment—to reflect a lower maximum penalty: six months’ imprisonment and/or a fine of $10,000. The indictment was also amended to conform to this reduced penalty. Lefemine’s counsel acknowledged and consented to these amendments. The district court denied Lefemine’s request for a jury trial, finding that the charged offense was a “petty” offense not subject to the Sixth Amendment right to a jury trial, and proceeded with a bench trial that resulted in Lefemine’s conviction. On appeal to the United States Court of Appeals for the Fourth Circuit, Lefemine argued that he was entitled to a jury trial both because of the original indictment and because Congress intended all FACE Act violations to require a jury trial. The Fourth Circuit held that the amendments did not require resubmission to a grand jury and that the maximum penalty Lefemine faced rendered the offense “petty” under Supreme Court precedent. The court affirmed that the first-time, nonviolent exception under the FACE Act does not require a jury trial, joining the Second, Seventh, and Eleventh Circuits, and affirmed the district court’s judgment. View "United States v. Lefemine" on Justia Law

US v. Lodge

2026-04-30T10:31:31-08:00

Law enforcement officers pursued the defendant, Austin Lodge, after a traffic stop in Clarksburg, West Virginia. During the pursuit, Lodge attempted to place a camouflage backpack inside a residence where his children’s grandmother lived, but was turned away by the occupant. He then fled to the backyard and discarded the backpack next to a shed. Lodge was apprehended without the backpack. Later, officers searched the area, found the bag, and searched it without a warrant, uncovering controlled substances. Lodge admitted ownership of the backpack but argued that his actions were meant to conceal, not abandon, the bag because it was left on familiar, semi-private property. The United States District Court for the Northern District of West Virginia first reviewed Lodge’s motion to suppress evidence obtained from the warrantless search. The case was referred to a magistrate judge, who conducted an evidentiary hearing and found that Lodge had abandoned the bag, thus forfeiting any reasonable expectation of privacy in its contents. The district court adopted these findings and denied the suppression motion, concluding that Lodge’s conduct amounted to abandonment, relying on the Fourth Circuit’s precedent in United States v. Small. On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s findings for clear error and the legal conclusions de novo. The appellate court emphasized that abandonment is a factual finding based on the objective circumstances known to officers at the time. The Fourth Circuit held that the district court’s finding—that Lodge abandoned the backpack when he discarded it after being denied entry at the residence—was not clearly erroneous. Because Lodge abandoned the backpack, he lacked a reasonable expectation of privacy in it, and the denial of the motion to suppress was affirmed. The court declined to resolve whether a different result would obtain if the property had not been abandoned but was merely concealed on private property. View "US v. Lodge" on Justia Law

US v. Williamson

2026-04-30T10:31:31-08:00

A defendant was charged with distributing fentanyl and possessing a firearm in furtherance of a drug trafficking crime. During jury selection, one of the prospective jurors, a retired police chief with decades of law enforcement experience, disclosed his background in policing and drug task force work, but did not reveal that he had previously been the target of a federal investigation into corruption involving local officials. When asked if he or his family had been involved in any controversy or litigation with a federal agency, the juror answered “no.” The defendant was convicted on all counts. After trial, defense counsel discovered the juror’s undisclosed involvement as a target in a prior federal investigation. The defendant moved for a new trial in the United States District Court for the Southern District of West Virginia, arguing that the juror’s dishonesty during voir dire deprived him of an impartial jury. The district court held an evidentiary hearing, found that the juror had given dishonest answers to material questions, but concluded that there was no evidence of actual bias or that the juror should have been struck for cause if he had answered truthfully. The court denied the motion for a new trial. On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s denial for abuse of discretion. The Fourth Circuit held that the district court did not commit manifest error in finding no actual bias and did not abuse its discretion in concluding that the juror’s prior experience did not require exclusion under any per se rule of implied or inferred bias. The court affirmed the district court’s decision, holding that under the standard of review, the defendant was not deprived of a trial by an impartial jury. View "US v. Williamson" on Justia Law

Ruffin v. Davis

2026-04-29T11:01:11-08:00

A police officer in Columbia, South Carolina, shot and killed a high school senior, J.R., during the COVID-19 curfew. The officer was responding to a report of teenagers looking into cars and saw J.R. walking alone. When the officer approached, J.R. ran away. The officer chased J.R. and, during the pursuit, observed that J.R. was armed. Despite repeatedly commanding J.R. to stop, get on the ground, and show his hands, J.R. did not comply. At one point, J.R. crouched near a fence, picked up his gun, and then ran again. The officer fired multiple shots, ultimately striking J.R. in the forehead and killing him. J.R.’s mother, acting as his personal representative, sued the officer under 42 U.S.C. § 1983, asserting that the use of deadly force violated J.R.’s Fourth Amendment rights. The United States District Court for the District of South Carolina denied the officer’s motion for summary judgment based on qualified immunity, finding that although J.R. was armed, ignored commands, and turned to face the officer, there was no undisputed evidence that J.R. made a threatening movement with his weapon. The court concluded that genuine disputes of material fact remained and that it was clearly established law that deadly force could not be used under these circumstances. On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The Fourth Circuit held that, at the time of the shooting, clearly established law prohibited a police officer from using deadly force against a fleeing, armed suspect who did not make a furtive or threatening movement with his weapon. The court concluded that the officer was not entitled to qualified immunity and allowed the case to proceed. View "Ruffin v. Davis" on Justia Law

Goddard v. Burnett

2026-04-28T10:31:13-08:00

A debtor filed for Chapter 13 bankruptcy in North Carolina while earning significant income and owning three luxury vehicles acquired in the years leading up to his petition. He had accumulated over $84,000 in unsecured debt, much of it from personal loans taken around the same time as his vehicle purchases. In his proposed bankruptcy plan, he aimed to retain all three vehicles by having the trustee pay off the secured car loans, while paying unsecured creditors less than 8% of what they were owed and discharging the remainder after five years. The United States Bankruptcy Court for the Eastern District of North Carolina rejected his plan. The court found that, despite technical compliance with the disposable income requirements of 11 U.S.C. § 1325(b), the plan failed the good-faith requirement of § 1325(a)(3). The court determined the plan was structured to allow the debtor to keep luxury items at the expense of unsecured creditors and that he was not making an honest effort to repay those creditors. The United States District Court for the Eastern District of North Carolina affirmed this decision, agreeing that the bankruptcy court properly considered good faith as a separate and independent requirement for plan confirmation. On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The Fourth Circuit held that compliance with § 1325(b)'s means test does not shield a Chapter 13 plan from review under the good-faith standard of § 1325(a)(3). The court emphasized that technical compliance with the means test does not preclude a finding of bad faith if the plan abuses the purposes or spirit of Chapter 13. The court found no clear error in the bankruptcy court’s factual findings and affirmed the denial of plan confirmation. View "Goddard v. Burnett" on Justia Law

United States v. Allen

2026-04-28T10:31:13-08:00

Late at night in downtown Raleigh, police were investigating a stolen vehicle when Milton Allen repeatedly interfered with the officers’ work, ignoring their commands and disrupting the scene while riding his bicycle. Allen’s actions, which included impeding traffic and resisting multiple direct orders to leave, led officers to attempt an arrest. During the arrest, Allen resisted and struggled with officers, who eventually subdued him using handcuffs and ankle restraints. While Allen was restrained but still squirming, officers searched two cross-body bags he had been wearing and found firearms, illegal drugs, cash, and related items. Based on these discoveries, Allen was charged with firearm and drug offenses. The United States District Court for the Eastern District of North Carolina reviewed Allen’s motion to suppress the evidence found in the bags. The district court found that the search of the bags was not a lawful search incident to arrest because Allen was already secured and could not access the bags, relying on United States v. Davis and Arizona v. Gant. The court also rejected the government’s argument that the evidence would inevitably have been discovered under established inventory search policies, concluding that the government had not sufficiently demonstrated that the policies were particular enough to limit officer discretion or that the bags would have inevitably been searched. On appeal, the United States Court of Appeals for the Fourth Circuit addressed whether the evidence should have been suppressed. The Fourth Circuit held that the search of Allen’s bags would inevitably have occurred pursuant to standardized inventory search policies of both the Raleigh Police Department and Wake County Detention Center, which required the search of all arrestees’ personal property and limited officer discretion. The Fourth Circuit concluded that the evidence would have been lawfully discovered and thus should not have been suppressed, reversing the district court’s order. View "United States v. Allen" on Justia Law

Harrold v. Hagen

2026-04-28T10:31:13-08:00

In December 2021, an individual with a lower leg amputation and a history of medical episodes broke into a car dealership in Chesterfield County, Virginia. After the alarm was triggered, police—including an officer and his police K-9—responded to the scene. The individual hid in a storage room, unarmed and passively waiting to be arrested. When the officer and his leashed K-9 located him lying in a submissive, fetal-like position, the officer allegedly gave no orders or warnings before directing the dog to attack. The K-9 inflicted severe injuries, including to sensitive areas of the individual’s body, resulting in significant blood loss and destruction of his prosthetic leg. Following the incident, the individual was charged with trespassing and vandalism, but no violent offenses. The individual filed suit in the United States District Court for the Eastern District of Virginia, asserting a Fourth Amendment excessive force claim under 42 U.S.C. § 1983, as well as related state law claims. The officer moved to dismiss, arguing that the use of force was objectively reasonable and that qualified immunity applied because the right in question was not clearly established. The district court ruled that the complaint plausibly alleged a Fourth Amendment violation but concluded that the specific right was not clearly established, granting the officer qualified immunity and dismissing the federal claim. The court declined to exercise supplemental jurisdiction over the state law claims. The United States Court of Appeals for the Fourth Circuit reviewed the case and held that, as of 2013, it was clearly established that a non-threatening, unarmed, and passively-resisting suspect had a right to be free from unnecessary, gratuitous, and disproportionate force by deployment of a police K-9. The court vacated the district court’s judgment and remanded for further proceedings. View "Harrold v. Hagen" on Justia Law

Navarro v. United States Center for SafeSport

2026-04-27T10:31:06-08:00

Three equestrian trainers, each subjected to sanctions by the United States Center for SafeSport (SafeSport) for past misconduct, sought to challenge those sanctions. Navarro and Giorgio were permanently banned after SafeSport learned of their prior guilty pleas to child sexual abuse, while Shaffer received a suspension and probation following SafeSport’s investigation of complaints against her. Navarro and Giorgio pursued arbitration and internal grievance procedures that ultimately confirmed SafeSport’s sanctions. Shaffer declined to arbitrate, citing the cost. All three alleged that SafeSport’s procedures violated their constitutional rights because they were barred from Olympic sports without a prior hearing, and further argued that SafeSport, a private body, unconstitutionally exercises governmental authority. After their grievances and appeals were rejected by the United States Equestrian Federation (USEF) and the United States Olympic & Paralympic Committee (USOC), the trainers filed suit in the United States District Court for the Western District of Virginia. The district court dismissed their claims, holding that the trainers lacked standing to sue the USOC, that Shaffer failed to exhaust administrative remedies, that Appellees were not state actors and thus not subject to the Fifth Amendment, and that SafeSport’s powers did not violate the private non-delegation doctrine. The United States Court of Appeals for the Fourth Circuit reviewed the case. It affirmed the district court’s rulings that the trainers lacked standing to sue the USOC, that the Appellees were not state actors subject to the Due Process Clause, and that the court lacked jurisdiction over the private non-delegation claim. However, it reversed the district court’s finding on administrative exhaustion, holding that Shaffer was not obligated to arbitrate her constitutional claims before seeking relief in federal court. Thus, the judgment was affirmed in part and reversed in part. View "Navarro v. United States Center for SafeSport" on Justia Law

Rhino Energy, LLC v. DOWCP

2026-04-23T10:30:26-08:00

A miner who worked in West Virginia coal mines for nearly four decades applied for benefits under the Black Lung Benefits Act after retiring in 2015. From mid-2012 through December 2014, he worked for Rhino Energy, LLC as a subcontractor in mines owned by Wildcat Energy, LLC. When Rhino’s subcontract ended, he joined Wildcat’s payroll and continued working at Wildcat until his retirement in October 2015. The dispute centers on which employer—Rhino or Wildcat—should be responsible for paying his black lung benefits. After the miner filed his claim, the district director of the Office of Workers’ Compensation Programs designated Rhino as the responsible operator, finding that Wildcat had not employed the miner for the full year required by regulations and thus was not a potentially liable operator. The district director did not address Wildcat’s financial capacity, nor did he issue a Coverage Statement regarding Wildcat’s insurance status. Rhino contested its designation, arguing Wildcat should be responsible, including as a successor operator, but the district director and subsequently the Administrative Law Judge (ALJ) reaffirmed Rhino’s liability, focusing on the duration of Wildcat’s employment. The Benefits Review Board upheld the ALJ’s decision, agreeing that Wildcat had not employed the miner for a year and noting Rhino had not demonstrated Wildcat’s financial capability. The United States Court of Appeals for the Fourth Circuit reviewed the Board’s order. It held that under the correct interpretation of the regulations, Wildcat had employed the miner for the requisite year based on working days, and because the district director did not issue a Coverage Statement, Wildcat was presumed financially capable of paying benefits. The court determined Wildcat should have been designated as the responsible operator, but because regulations prohibit imposing liability on another operator at this stage, it vacated the Board’s order and remanded with instructions for the Black Lung Disability Trust Fund to pay the miner’s benefits. View "Rhino Energy, LLC v. DOWCP" on Justia Law

Nichols v. Bumgarner

2026-04-22T10:30:26-08:00

Patrick Nichols, while being arrested by two police officers in Bethesda, Maryland on outstanding warrants for theft, forgery, and burglary, alleges that he was subjected to excessive force. According to Nichols, one officer slammed him to the ground, breaking his left forearm in two places, while the other placed a knee on his throat, causing him to fear for his life and temporarily lose the ability to breathe. Nichols claims he did nothing to threaten the officers and that their use of force was unprovoked. Following his arrest, he required medical treatment for his injuries and continues to experience pain and stress. Nichols, proceeding pro se and incarcerated, initially filed a complaint naming only Officer Bumgarner in the caption, though he described the involvement of a second officer, Schmidt, in the body of his complaint. The United States District Court for the District of Maryland dismissed Nichols’s complaint without prejudice, finding it lacked sufficient factual detail. Nichols then filed an amended complaint, again naming only Bumgarner in the caption but specifically describing Schmidt’s actions in the body. The district court dismissed the amended complaint as well, again for lack of specificity and treated the action as brought solely against Bumgarner, never acknowledging Schmidt as a defendant. The United States Court of Appeals for the Fourth Circuit reviewed the case. It found that the district court erred in treating the complaint as only against Bumgarner rather than both officers, given the content of the complaints and the pro se status of Nichols. The Fourth Circuit also held that Nichols’s amended complaint stated a plausible excessive force claim under the Fourth Amendment, given the serious injuries alleged and the facts construed in Nichols’s favor. The appellate court vacated the district court’s dismissal and remanded the case for further proceedings. View "Nichols v. Bumgarner" on Justia Law

Benson v. Warden FCI Edgefield

2026-04-22T10:30:26-08:00

A federal prisoner was sentenced in December 2020 and, due to pending charges in another jurisdiction, was held at a detention center in Rhode Island rather than being promptly transferred to his designated Bureau of Prisons (BOP) facility in South Carolina. During this period of post-sentencing detention, the prisoner claims to have participated in programs under the First Step Act (FSA), thereby accruing approximately 150 days of time credits, which could reduce his time in custody. However, the BOP did not recognize these credits because he had not undergone a formal risk and needs assessment—the BOP’s prerequisite for awarding such credits—until his eventual arrival at the designated facility in March 2022. After exhausting administrative remedies, the prisoner filed a pro se habeas petition in the United States District Court for the District of South Carolina, seeking recognition of his alleged FSA credits. The magistrate judge, without briefing or discovery, recommended dismissal. The district court adopted this recommendation, concluding that the BOP’s regulation reasonably required an initial assessment before credits could be earned, and applied Chevron deference to uphold the agency's interpretation. The district court also found no evidence the prisoner had “successfully participated” in qualifying programs before arrival at the BOP facility and dismissed the petition without prejudice, refusing to require a government response. On appeal, the United States Court of Appeals for the Fourth Circuit vacated the district court’s judgment and remanded. The Fourth Circuit held that the case was not moot, as the prisoner could still benefit from the FSA credits if his risk status changed or a warden approved his release. The court further held that, in light of the Supreme Court’s decision in Loper Bright Enterprises v. Raimondo, which overturned Chevron deference, the district court must independently determine whether the BOP’s interpretation of “successful participation” aligns with the best reading of the statute. View "Benson v. Warden FCI Edgefield" on Justia Law

Doe v. Mast

2026-04-22T10:30:25-08:00

An Afghan infant was orphaned and injured during a joint U.S.-Afghan military operation and received emergency care at a U.S. military hospital. A U.S. Marine Corps Judge Advocate, Major Joshua Mast, and his wife, Stephanie Mast, initiated custody proceedings and ultimately obtained a Virginia adoption order for the child. Separately, the U.S. Embassy gave custody to a man claiming to be the child's uncle, and the infant was subsequently cared for by John and Jane Doe, who later evacuated from Afghanistan to the United States with the child during Operation Allies Refuge. After arriving in the U.S., the Masts took custody of the child. The Does then challenged the adoption in Virginia state court, but the Supreme Court of Virginia rejected their challenge. Following the state proceedings, the Does filed a federal lawsuit in the U.S. District Court for the Western District of Virginia, seeking, among other things, a protective order to prevent the defendants from disclosing their identities. The district court granted the protective order, concluding that disclosing the Does’ identities would pose a substantial risk to their safety and that of their family in Afghanistan. The order prohibited the defendants and their representatives from revealing any information that could directly or indirectly identify the Does or their family members unless a non-disclosure agreement was executed. After the Does engaged with the media while maintaining anonymity, the Masts moved to vacate or modify the protective order, arguing it was an unconstitutional restraint on speech. The district court denied the motion and held Joshua Mast in contempt for violating the order. On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s order. The Fourth Circuit held that the protective order, while a content-based prior restraint, fit within a narrow exception because it was narrowly tailored to serve the government’s compelling interest in national security—specifically, the protection of individuals perceived as U.S. collaborators. The court found the order survived strict scrutiny and was not unconstitutionally vague. View "Doe v. Mast" on Justia Law

US v. Mills

2026-04-20T10:30:33-08:00

The defendant was serving a term of supervised release after prior convictions for drug and firearm offenses. While on supervision, he was alleged to have committed new offenses, including strangulation and assault and battery of a family member, based on an incident with his then-girlfriend, Jessica Rodriguez, in May 2021. Ms. Rodriguez did not report the incident to law enforcement until over a year later, in June 2022, saying she had become fearful of the defendant. The evidence at the revocation hearing included her testimony, corroboration by her daughter, text messages in which the defendant appeared to admit and apologize for the conduct, and photographs of Ms. Rodriguez’s injuries. The defendant denied strangling or striking Ms. Rodriguez, offering an alternative explanation for the events, but the district court found his testimony not credible. Previously, the United States District Court for the Eastern District of Virginia had revoked the defendant’s supervised release and imposed an 18-month sentence after similar violations. The new violations resulted in another revocation petition, but the resolution of the matter was delayed for several years due to continuances while related state charges were pending. Ultimately, in January 2025, the district court held hearings, credited the testimony of Ms. Rodriguez and her daughter, and found by a preponderance of the evidence that the defendant had violated the mandatory condition not to commit new crimes. The court sentenced him to 24 months in prison. On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s revocation of supervised release, holding there was no clear error in finding the violations or in crediting the complainant’s testimony after considering all relevant evidence. However, the Fourth Circuit vacated the 24-month sentence and remanded for resentencing, because the district court failed to address the defendant’s non-frivolous argument that he should receive credit for an additional 19 months he spent on supervised release while the revocation petition was pending. View "US v. Mills" on Justia Law

Spivey v. Breckon

2026-04-20T10:30:33-08:00

A federal inmate brought an action for damages against several officials at a federal prison, claiming they provided delayed or inadequate medical treatment and used excessive force against him during his incarceration. His allegations included delayed dental care, insufficient response to rectal bleeding, denial of participation in a mental health class, and the use of restraints and physical force during an incident involving his cellmate. He asserted that these actions violated his constitutional rights under the Eighth, Fourth, and Fifth Amendments. The United States District Court for the Western District of Virginia dismissed his complaint, holding that a damages remedy under Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics was not available for his claims. The court reasoned that his claims, both for inadequate medical care and excessive force, presented new contexts beyond those recognized in previous Supreme Court cases and that special factors counseled against extending a judicially implied damages remedy. The inmate appealed from the district court’s judgment. The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the inmate’s inadequate medical treatment claims presented a new context distinct from Carlson v. Green, as the facts involved less severe circumstances and implicated broader, systemic prison management issues rather than deliberate malfeasance. The court further found that special factors, including Congress’s silence and provision of alternative remedies, counseled against extending Bivens. Regarding the excessive force claims, the Fourth Circuit found that the Supreme Court’s intervening decision in Goldey v. Fields expressly foreclosed recognizing a Bivens remedy in this context. Thus, the Fourth Circuit affirmed the district court’s dismissal, holding that a Bivens remedy was unavailable for the plaintiff’s claims. View "Spivey v. Breckon" on Justia Law

Diaz v. Blanche

2026-04-20T10:30:32-08:00

A noncitizen who had unlawfully entered the United States in 1997 was arrested in North Carolina in 2015 and charged with three felony drug offenses: possession of cocaine with intent to deliver, sale of cocaine, and delivery of cocaine. The charges were later dismissed in exchange for his cooperation with law enforcement. Meanwhile, during pending criminal proceedings, the Department of Homeland Security initiated removal proceedings on the ground that he was inadmissible as a noncitizen present without admission or parole. The noncitizen conceded removability and applied for cancellation of removal, arguing that his removal would cause hardship to his family. The Immigration Judge (IJ) conducted hearings at which the noncitizen, represented by counsel, testified under oath to facts constituting the drug offenses. The IJ found that these admissions established the essential elements of the charged offenses and that the noncitizen had failed to demonstrate good moral character, a requirement for cancellation of removal. In so ruling, the IJ determined that the procedural safeguards from the Board of Immigration Appeals (BIA) decision Matter of K- were satisfied, as the noncitizen had testified voluntarily, under oath, and with counsel present. The IJ denied cancellation of removal and ordered removal to Mexico. The noncitizen appealed to the BIA, arguing that the IJ misapplied Matter of K- and that his admissions did not establish all elements of the offenses, specifically knowledge of the substance as cocaine. The BIA dismissed the appeal, finding that the admissions were valid and that the elements of the North Carolina drug law were met. The United States Court of Appeals for the Fourth Circuit reviewed both the IJ’s and BIA’s decisions, holding that Matter of K- did not require reversal under these circumstances and that the noncitizen’s admissions precluded a finding of good moral character. The petition for review was denied. View "Diaz v. Blanche" on Justia Law

US v. Martin

2026-04-17T10:30:34-08:00

Nathaniel Martin was a passenger in a vehicle stopped by a United States Forest Service law enforcement officer in the Monongahela National Forest after the vehicle was found illegally parked on a single-lane bridge. The officer, Joshua Radford, initially cited the parking violation as the reason for the stop. However, as soon as the stop began, Radford immediately shifted focus, asking about firearms in the vehicle and then further questioning both the driver and Martin regarding other possible contraband. Firearms were discovered, and Martin was eventually arrested after a check revealed prior felony convictions. Notably, the officer did not issue a citation for the parking offense, and the initial minutes of the stop were not captured on bodycam video. After more than two years, Martin was charged in the United States District Court for the Southern District of West Virginia with being a felon in possession of a firearm. He moved to suppress the evidence and his statements, arguing that the stop violated his Fourth Amendment rights because the officer had abandoned the original purpose of the stop. The district court denied the motion to suppress, finding that the officer’s actions remained within the permissible scope of the stop and did not unlawfully extend it. Martin then entered a guilty plea, preserving his right to appeal the suppression ruling. The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the officer’s immediate pivot from addressing the parking violation to investigating potential criminal activity was not reasonably related in scope to the original justification for the stop. The court distinguished this situation from prior precedent by noting the absence of circumstances suggesting officer safety concerns. The court reversed the district court’s denial of the suppression motion and vacated Martin’s guilty plea. View "US v. Martin" on Justia Law

Eichin v. Ethicon Endo-Surgery, LLC

2026-04-17T10:30:33-08:00

The plaintiff underwent a surgical procedure involving multiple surgical staplers, one of which was used to create an anastomosis that subsequently leaked. In October 2021, the plaintiff filed a products liability suit against several manufacturers of surgical staplers. Over the course of pretrial proceedings, the United States District Court for the District of South Carolina issued multiple scheduling orders, ultimately extending the plaintiff’s expert disclosure deadline to March 15, 2024. The plaintiff failed to disclose any experts by this deadline. Twenty days later, the plaintiff moved to extend the expert disclosure deadline, citing delays in obtaining discovery and the model number of the stapler at issue. The district court denied the plaintiff’s motion to amend the scheduling order, finding that he had not shown “good cause” under Federal Rule of Civil Procedure 16(b)(4), and entered summary judgment for the defendants due to the absence of expert testimony needed to support the plaintiff’s claims. The court noted that the plaintiff had not acted diligently, as required by Rule 16(b)(4), and had not filed a motion to compel or otherwise timely challenged the adequacy of discovery responses. The district court also relied on the plaintiff’s own representations regarding when he learned the model number of the stapler. On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the denial of the motion to amend for abuse of discretion and the grant of summary judgment de novo. The appellate court held that the district court correctly applied Rule 16(b)(4)’s “good cause” standard to the request to extend the expert disclosure deadline and did not abuse its discretion in finding a lack of diligence. Because the plaintiff failed to offer expert evidence, the court affirmed summary judgment for the defendants. Thus, the Fourth Circuit affirmed the district court’s rulings in full. View "Eichin v. Ethicon Endo-Surgery, LLC" on Justia Law

Milligan v. Merrill Lynch, Pierce, Fenner & Smith, Inc.

2026-04-17T10:30:33-08:00

A financial advisory employee of a large securities firm participated in a compensation program called the WealthChoice Awards, which provided annual contingent cash awards to select high-performing advisors. To earn these awards, an advisor had to meet certain revenue thresholds and remain employed at the company for eight years after the award was granted. A notional, unfunded account tracked a benchmark investment, but no funds were set aside for the advisor during the vesting period. If the advisor left the company before vesting, the award was typically forfeited. After vesting, payment was mandatory and made promptly, usually while the advisor was still employed. The stated purpose of the program was to incentivize retention and productivity, not to provide retirement income. After voluntarily resigning and forfeiting unvested awards, the employee filed a putative class action in the United States District Court for the Western District of North Carolina. He alleged that the WealthChoice Awards program was an “employee pension benefit plan” under the Employee Retirement Income Security Act of 1974 (ERISA), and that it violated ERISA’s vesting and anti-forfeiture rules. The district court granted summary judgment to the employer, finding that the program was a bonus plan exempt from ERISA. On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s grant of summary judgment de novo. The Fourth Circuit held that the WealthChoice Awards program is a bonus payment plan and not an ERISA-covered pension benefit plan. The court reasoned that the program’s primary purpose was to enhance retention and productivity, eligibility was limited, the awards were not funded with deferred employee income, and payment was not systematically deferred until employment termination or retirement. The judgment of the district court was affirmed. View "Milligan v. Merrill Lynch, Pierce, Fenner & Smith, Inc." on Justia Law

Byers v. Painter

2026-04-17T10:30:33-08:00

Charles Byers was shot and killed by Corporal Gordon Painter, a Chesterfield County police officer, after an emergency call reported that Byers had tried to break into two homes and vandalized one. Byers, who suffered from schizoaffective disorder, was seen wandering barefoot in a neighborhood holding a hatchet. When police arrived, Byers refused multiple commands to drop the hatchet, but kept the weapon lowered at his side and did not make threatening movements. After a taser was deployed without effect, Officer Painter fired three shots at Byers, who was about 25 feet away with his head turned away. Byers then turned to flee, and Officer Painter fired additional shots, striking Byers in the back and causing his death. Byers' parents, as co-administrators of his estate, sued Officer Painter under 42 U.S.C. § 1983 for excessive force in violation of the Fourth Amendment, and for negligence under Virginia law, in the United States District Court for the Eastern District of Virginia. The district court denied Officer Painter’s motion to dismiss the § 1983 claim on qualified immunity grounds, finding that Byers did not pose an immediate threat at the time he was shot, and granted the motion to dismiss the negligence claim. Officer Painter appealed the denial of qualified immunity. The United States Court of Appeals for the Fourth Circuit reviewed the district court's denial of qualified immunity de novo, applying recent Supreme Court guidance that requires courts to consider the totality of the circumstances, not just the moments before deadly force is used. The Fourth Circuit held that, even considering the totality, Officer Painter’s use of deadly force was not objectively reasonable under the Fourth Amendment, and that the violation was clearly established at the time. The court affirmed the district court’s denial of Officer Painter’s motion to dismiss on qualified immunity grounds. View "Byers v. Painter" on Justia Law

Dorrbecker v. Howard

2026-04-17T10:30:32-08:00

A former United States Navy Captain was convicted by a general court-martial of attempted sexual assault of a child, attempted sexual abuse of a child, and other offenses. The events leading to the charges occurred while he was stationed at a U.S. military base in Italy, where he engaged in electronic communications with a 14-year-old girl, S.M. After the girl’s parents, who worked for the Naval Criminal Investigative Service (NCIS), became aware of the contact, NCIS initiated an investigation. An NCIS agent posed as S.M. online, leading to sexually explicit exchanges and ultimately a sting operation in which the accused arrived at a house expecting to meet S.M., but was arrested. The general court-martial found the accused guilty on several specifications, and he was sentenced to eight years’ confinement and dismissed from the Navy. On appeal, the Navy-Marine Corps Court of Criminal Appeals affirmed his convictions, rejecting his argument that his intent to commit the offenses was only conditional and thus insufficient for attempt under the Uniform Code of Military Justice (UCMJ). The Court of Appeals for the Armed Forces denied further review. The accused then petitioned for a writ of habeas corpus in the United States District Court for the District of South Carolina, arguing that the military courts lacked subject-matter jurisdiction under the UCMJ and that the NATO Status of Forces Agreement (SOFA) with Italy deprived the United States of jurisdiction. The district court dismissed the petition. On appeal, the United States Court of Appeals for the Fourth Circuit affirmed. The court held that the military courts had subject-matter jurisdiction under the UCMJ, and the petitioner’s arguments regarding conditional intent went to the merits, not jurisdiction. The court also held that the NATO SOFA did not deprive the military courts of jurisdiction and could not be enforced by the petitioner in this context. The judgment of the district court was affirmed. View "Dorrbecker v. Howard" on Justia Law

US v. Hernandez

2026-04-17T06:00:56-08:00

A noncitizen from El Salvador entered the United States and was released on bond after expressing fear of returning home. Removal proceedings were held before the Executive Office for Immigration Review (EOIR), but he failed to appear at a hearing and was ordered removed in absentia in 2019. The order became final immediately upon entry. Over three years later, the Department of Homeland Security (DHS) issued a warrant for his removal after he was arrested for an unrelated offense. He was placed in Immigration and Customs Enforcement (ICE) custody, but escaped before his scheduled deportation. After being apprehended, he was indicted for escape and for corruptly obstructing a pending proceeding under 18 U.S.C. § 1505. The United States District Court for the Eastern District of Virginia acquitted him on the escape charge but convicted him under § 1505, finding that the execution of an EOIR-issued removal order by ICE was part of a “pending proceeding” before EOIR. The district court denied the defendant’s motion for acquittal, reasoning that the statute’s term “proceeding” should be interpreted broadly to include ICE’s execution of the removal order, as this act was under the authority and direction of the EOIR order. On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the statutory interpretation issue de novo. The appellate court held that, under the plain text and statutory context, ICE’s execution of a removal order after EOIR has issued a final order does not constitute a “pending proceeding . . . being had before” EOIR under § 1505. The court further found that ICE enforcement actions are not “proceedings” within the meaning of § 1505, but rather are akin to routine law enforcement activity. Accordingly, the Fourth Circuit reversed the district court’s judgment, vacated the conviction, and remanded for further proceedings. View "US v. Hernandez" on Justia Law

US v. Lawrence

2026-04-14T10:30:38-08:00

The defendant owned and operated a company that provided paycard services to restaurant employees, allowing them to receive wages on debit cards. Over time, he misused the funds entrusted to his company by transferring payroll money to his personal brokerage account and engaging in risky options trading, without disclosing these actions to his clients. When losses mounted and funds were missing, he misled both the client company and cardholders about the shortfall, imposed new fees retroactively, and restricted access to account information under the guise of privacy concerns. After the business relationship ended and his company lost its only client, he applied for a Paycheck Protection Program loan using falsified bank records, misrepresenting his company’s operations, and diverted those funds to his brokerage account as well. The United States District Court for the Eastern District of Virginia indicted him on multiple counts of wire and mail fraud based on both the paycard and PPP loan schemes. He moved to sever the count relating to the PPP loan, arguing that combining the two schemes in one trial was improper and prejudicial, but the district court denied severance, finding the counts properly joined and prejudice curable. After a jury convicted him on all counts, the district court applied a sentencing enhancement for the use of sophisticated means, resulting in an 87-month prison sentence. On appeal, the United States Court of Appeals for the Fourth Circuit held that the evidence was sufficient to support the jury’s finding of fraudulent intent and that the sophisticated-means sentencing enhancement was supported by the record. The court also found that joinder of the paycard and PPP fraud schemes was proper, as there were material overlaps in method and evidence, and affirmed the district court’s discretion in denying severance. The judgment was affirmed. View "US v. Lawrence" on Justia Law

US v. Jones

2026-04-14T10:30:38-08:00

After pleading guilty in 2014 to Hobbs Act robbery and brandishing a firearm during and in relation to the robbery, the defendant was sentenced to consecutive prison terms and concurrent terms of supervised release. Following his release in early 2024, he soon violated several conditions of his supervised release, including testing positive for illicit drugs on multiple occasions, violating location restrictions, and leaving the judicial district without permission. The Probation Officer filed a petition for revocation alleging four violations, including drug testing failures and other conduct, and submitted a supplemental report that incorrectly classified the drug-related violation as a more serious offense. The United States District Court for the Middle District of North Carolina held a revocation hearing at which the defendant admitted the charged conduct. The court dismissed the felony possession allegation but found that the most serious remaining violation was the drug testing violation. Without explanation, the court classified this as a Grade B violation under the Sentencing Guidelines, resulting in a Guidelines range of 8 to 14 months. The court then imposed a sentence of 19 months’ imprisonment with additional terms of supervised release, exceeding the Guidelines range and possibly the statutory maximum. On appeal, the United States Court of Appeals for the Fourth Circuit found that the district court erred in characterizing the drug testing violation as a Grade B violation, rather than the less severe Grade C violation that the record supported. The appellate court held that this misclassification was plain error affecting the defendant’s substantial rights and impacted the fairness of the proceedings. The Fourth Circuit vacated the district court’s judgment and remanded the case for resentencing under the correct Guidelines classification. The court also directed the district court to consider whether the new sentence complies with the statutory limits on supervised release. View "US v. Jones" on Justia Law

US v. Russell

2026-04-14T10:30:38-08:00

A hospital employee discovered that someone had posted on social media a screenshot from the hospital’s internal system, revealing Supreme Court Justice Ruth Bader Ginsburg’s name, dates of ten medical visits, and the types of services she received. The post, which first appeared on an anonymous online forum, fueled conspiracy theories regarding the Justice’s health. The hospital investigated and identified two employees who had inappropriately searched for the Justice’s information, ultimately focusing on Trent Russell, who worked for a non-profit with access to patient records. Forensic analysis linked Russell’s home computer to the search, and evidence showed he formatted his hard drive after his access was revoked. He was charged with unlawfully obtaining health information, unlawfully destroying records, and disclosing health information. The United States District Court for the Eastern District of Virginia denied Russell’s motion to suppress statements made to federal agents during an interview at his workplace. The court found no coercion despite the presence of his employer’s CEO. The court also limited cross-examination of an agent regarding Russell’s explanations for the search, sustaining a hearsay objection but allowing other avenues to explore bias. At trial, the jury convicted Russell of obtaining individually identifiable health information and destroying records, but acquitted him of disclosing health information. The district court sentenced him to 24 months’ imprisonment. The United States Court of Appeals for the Fourth Circuit reviewed the case. It held that Russell’s interview statements were voluntary, as there was no evidence of coercion or threats. The court found no abuse of discretion in the district court’s limitation of cross-examination, and any error was harmless given the other evidence of bias. It also held that the information Russell obtained qualified as “individually identifiable health information” under federal law. The Fourth Circuit affirmed the judgment in full. View "US v. Russell" on Justia Law

Rice v. Adams

2026-04-14T10:30:38-08:00

A woman named Cynthia Rice died while in custody at a detention center after experiencing opioid withdrawal. Her estate, through the personal representative, sued several detention officers, alleging that they acted with deliberate indifference to her serious medical needs in violation of the Fourteenth Amendment. According to the complaint, Rice informed unidentified officers and medical staff of her heroin addiction and withdrawal symptoms upon booking. Medical staff performed intake and scheduled a detox check, but the complaint alleged that custody staff ignored her pleas for help and failed to provide necessary care. The complaint did not specify what any individual officer did or knew, instead grouping the officers together and making general allegations about their conduct. The United States District Court for the District of Maryland denied the officers’ motion to dismiss, concluding that the plaintiff had stated a viable claim under 42 U.S.C. § 1983 and that the officers were not entitled to qualified immunity at the pleading stage. The officers then appealed the denial of qualified immunity, which is immediately appealable when it involves issues of law. The United States Court of Appeals for the Fourth Circuit reviewed the case and reversed the district court’s decision. The court held that the complaint failed to state a claim against the named officers because it did not make specific, defendant-by-defendant factual allegations connecting any officer to deliberate indifference to Rice’s medical needs. The court emphasized that collective and undifferentiated allegations against a group of officers are insufficient to state a plausible claim under § 1983. As a result, the Fourth Circuit reversed the district court’s denial of the motion to dismiss and remanded the case for further proceedings. View "Rice v. Adams" on Justia Law

Gardner v. Blanche

2026-04-14T10:30:37-08:00

A native and citizen of Jamaica entered the United States as a child and overstayed his visa. Years later, he was placed in removal proceedings and sought cancellation of removal. The Department of Homeland Security argued that he was ineligible for cancellation because he had two prior convictions for crimes involving moral turpitude. The dispute centered on whether a 2009 North Carolina misdemeanor larceny charge, which resulted in a “Prayer for Judgment Continued” (PJC) conditioned on completion of community service, counted as a conviction under federal immigration law. The Immigration Judge determined that the 2009 PJC qualified as a conviction for immigration purposes because the state court imposed a requirement to complete community service, which the judge found to be a form of punishment. As a result, the Immigration Judge ruled that the applicant was ineligible for cancellation of removal. The Board of Immigration Appeals affirmed the Immigration Judge’s decision in its own written opinion. The United States Court of Appeals for the Fourth Circuit reviewed both the Immigration Judge’s and the Board’s decisions. The Fourth Circuit held that a North Carolina PJC conditioned on completion of community service constitutes a conviction under 8 U.S.C. § 1101(a)(48)(A) because the community service requirement is a punitive sanction, not merely administrative or compensatory. The court explained that the imposition of discretionary community service is intended to discipline or deter and thus qualifies as punishment. Accordingly, the court denied the petition for review, holding that the petitioner’s 2009 PJC is a conviction for purposes of federal immigration law and renders him ineligible for cancellation of removal. View "Gardner v. Blanche" on Justia Law

Cook v. Chapter 13 Trustee

2026-04-13T12:31:16-08:00

The case concerns an individual who filed for Chapter 13 bankruptcy in the Eastern District of Virginia to address approximately $333,000 in personal debt. After his initial proposed repayment plan was denied by the bankruptcy court due to concerns about good faith and failure to meet the statutory “liquidation test,” the debtor submitted additional plans. Each of his second and third proposals was also denied. The bankruptcy court ultimately confirmed his fourth plan, which required significantly larger payments. After the fourth plan was confirmed and payments began, the debtor objected, arguing that the bankruptcy court should have confirmed his first plan. Following confirmation of the fourth plan, the debtor appealed to the United States District Court for the Eastern District of Virginia. He contended that the bankruptcy court erred in denying his first plan. The district court, however, dismissed the appeal as equitably moot, concluding that the requested relief could not be practically or equitably granted after the fourth plan’s confirmation and partial performance. The United States Court of Appeals for the Fourth Circuit reviewed the case. The Fourth Circuit held that the doctrine of equitable mootness—which allows courts to dismiss bankruptcy appeals when practical relief is no longer available—was misapplied in this straightforward, limited-asset Chapter 13 case. The court found that adjusting the debtor’s payments prospectively remained feasible, and the relevant factors weighed against applying equitable mootness. On the merits, the Fourth Circuit affirmed the bankruptcy court’s denial of confirmation of the first proposed plan, concluding there was no clear error in its finding that the plan was not proposed in good faith due to inaccuracies and inconsistencies in the debtor’s submissions and testimony. The Fourth Circuit reversed the district court’s dismissal and affirmed the bankruptcy court’s judgment. View "Cook v. Chapter 13 Trustee" on Justia Law

Payne v. Moser

2026-04-13T12:31:16-08:00

A police operation was planned in Fairfax County, Virginia, based on information from an informant that Jeffery Payne was dealing drugs and often carried a gun. Detectives scheduled a controlled drug buy in a shopping center parking lot, intending to arrest Payne if he appeared. When Payne arrived but sensed something was wrong, he attempted to leave. Detectives in unmarked vehicles pursued him. As Payne neared an exit, Sergeant Moser ordered the detectives to block Payne’s car. Detectives used vehicle maneuvers to stop Payne, including ramming his car, which spun out and was immobilized. Seconds later, Sergeant Moser shot Payne through the back window, believing Payne was reaching for a gun; Payne was later found to be unarmed. The United States District Court for the Eastern District of Virginia granted summary judgment in favor of Sergeant Moser, finding there were no genuine disputes of material fact and that Moser’s actions were objectively reasonable as a matter of law. The district court focused exclusively on the shooting, not addressing Payne’s claims about the vehicle maneuvers. On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The Fourth Circuit concluded that the record contained genuine disputes of material fact regarding whether Sergeant Moser used excessive force—both by directing the use of vehicle maneuvers to stop Payne and by shooting him. The court held that, viewing the evidence in the light most favorable to Payne, Sergeant Moser’s conduct was not objectively reasonable as a matter of law. The Fourth Circuit vacated the district court’s grant of summary judgment and remanded the case for further proceedings, including consideration of whether Sergeant Moser is entitled to qualified immunity. View "Payne v. Moser" on Justia Law

Geneva Enterprises, LLC v. Chavez

2026-04-10T10:30:29-08:00

A group of former employees initiated a mass arbitration against their previous employers, alleging violations of the Virginia Wage Payment Act and, for one claimant, the Fair Labor Standards Act. The employers contended that not all claimants were bound by arbitration agreements and that procedural requirements for arbitration had not been met, leading them to refuse payment of required arbitration initiation fees. In response, the employers filed suit in the Circuit Court of Fairfax County, seeking to enjoin the arbitrations and obtain a declaratory judgment on the arbitration agreements’ scope. The employees removed the case to the United States District Court for the Eastern District of Virginia, where they also filed a petition to compel arbitration and stay the proceedings. The United States District Court for the Eastern District of Virginia denied the employers’ request to enjoin the arbitrations and granted a stay of the court proceedings pending arbitration. The district court did not compel arbitration outright, reasoning that the matters had already been referred to arbitration. When the employers continued to refuse payment of arbitration fees, the employees returned to the district court seeking an order to lift the stay, compel arbitration, and require the employers to pay the fees. The court again declined, maintaining its previous order referring the case to arbitration and keeping the stay in place. The United States Court of Appeals for the Fourth Circuit reviewed the employees’ interlocutory appeal challenging the district court’s denial of their renewed motion. The Fourth Circuit held that it lacked appellate jurisdiction under section 16 of the Federal Arbitration Act because the district court’s order was either an order granting a stay pending arbitration or directing arbitration to proceed—neither of which is appealable at this stage. Accordingly, the appeal was dismissed for lack of appellate jurisdiction. View "Geneva Enterprises, LLC v. Chavez" on Justia Law

American Federation of State, County and Municipal v. Social Security Administration

2026-04-10T10:30:28-08:00

The plaintiffs, three organizations representing millions of Americans, challenged the Social Security Administration’s (SSA) decision to grant personnel from the newly created U.S. DOGE Service access to non-anonymized, highly sensitive personal information held by the SSA. This access was authorized following an executive order charging DOGE with improving government technology. Career officials at the SSA resigned in protest, and a new acting administrator approved DOGE’s access. The plaintiffs argued that merely providing this access, regardless of actual misuse or disclosure, was itself unlawful and an intrusion upon the privacy of their members. The United States District Court for the District of Maryland conducted extensive hearings and granted a preliminary injunction blocking DOGE’s access to the data. The Supreme Court subsequently stayed this injunction, pending appellate and possible further Supreme Court review. The case came before the United States Court of Appeals for the Fourth Circuit, which had jurisdiction pursuant to 28 U.S.C. § 1292(a)(1). The United States Court of Appeals for the Fourth Circuit held that the plaintiffs had Article III standing, as the unauthorized access to their sensitive information closely resembled the common law tort of intrusion upon seclusion. However, the Fourth Circuit vacated the preliminary injunction, holding that the plaintiffs had not established that they were likely to suffer irreparable harm in the absence of preliminary relief, as required by the second factor of the Winter test for preliminary injunctions. The court reasoned that monetary damages and reparative permanent injunctions were potentially available remedies, and the record did not show that new or additional irreparable harm would occur during the litigation. The case was remanded to the district court for further proceedings. The main holding is that the preliminary injunction was vacated because the plaintiffs did not show likely irreparable harm. View "American Federation of State, County and Municipal v. Social Security Administration" on Justia Law

O.W. v. Carr

2026-04-09T11:00:26-08:00

A 13-year-old male student at a Virginia Beach middle school received a sexually explicit photo from a female classmate and, several months later, showed the image to other students during the school day. After teachers reported the incident, the assistant principal removed the student from class, questioned him, and searched his phone’s photo gallery. The school resource police officer was notified and began a criminal investigation. The student ultimately showed the explicit photo to the officer, was read his Miranda rights, arrested, and charged in juvenile court with possession of child pornography. The juvenile court found sufficient evidence for guilt but deferred disposition; the charge was dismissed after the student completed court-imposed conditions. The student, through his mother and later counsel, sued the assistant principal, the school resource officer, the Virginia Beach School Board, and the City of Virginia Beach in the United States District Court for the Eastern District of Virginia. He alleged violations of his Fourth, Fifth, and Fourteenth Amendment rights, as well as conspiracy and Monell claims. The district court granted summary judgment to all defendants, finding the phone search reasonable under New Jersey v. T.L.O., the confession voluntary, no evidence of unlawful conspiracy, and no underlying constitutional violations to support Monell liability. On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The court affirmed the district court’s judgment, holding that the assistant principal’s search of the student’s phone was justified at its inception and reasonable in scope under T.L.O., and that Riley v. California did not displace this standard in the school context. The court also held the student’s confession was voluntary under the Fifth and Fourteenth Amendments, found no evidence of a conspiracy to violate constitutional rights, and determined Monell liability could not attach absent an underlying constitutional violation. The court therefore affirmed summary judgment for all defendants. View "O.W. v. Carr" on Justia Law

Perry v. Marteney

2026-04-08T10:30:26-08:00

A married couple, acting on behalf of their minor child, challenged West Virginia’s compulsory vaccination law after their daughter was disenrolled from a public virtual school because she was not fully vaccinated. The parents sought a religious exemption from the vaccination requirement, but were informed that only medical exemptions—based on specific medical contraindications or precautions certified by a physician—are permitted under state law. After being denied a religious exemption, the parents filed suit, claiming that the absence of a religious exemption violated their First Amendment right to freely exercise their Christian faith. They requested a preliminary injunction to allow their daughter’s re-enrollment in the virtual academy during the litigation. The United States District Court for the Northern District of West Virginia granted the preliminary injunction, finding that the parents were likely to succeed on their free exercise claim. The district court applied the test from Employment Division, Department of Human Resources of Oregon v. Smith, concluding that the vaccination law was not generally applicable, and thus subject to strict scrutiny, which it found the law did not survive. On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s grant of preliminary relief. The Fourth Circuit held that West Virginia’s compulsory vaccination law is a neutral and generally applicable measure enacted under the state’s police power to protect public health, as recognized in longstanding Supreme Court precedent including Jacobson v. Massachusetts and Prince v. Massachusetts. The court found that the medical exemption process does not constitute a “mechanism for individualized exemptions” that would undermine general applicability under cases such as Fulton v. City of Philadelphia. The Fourth Circuit concluded that the law is subject to rational basis review, which it easily satisfies, and that the Free Exercise Clause does not require religious exemptions simply because medical exemptions exist. The court reversed the district court’s preliminary injunction and remanded the case. View "Perry v. Marteney" on Justia Law

Wolf Run Mining Company v. DOWCP

2026-04-07T10:30:32-08:00

A miner filed a claim for benefits under the Black Lung Benefits Act, asserting total disability due to lung disease following over two decades of coal mine employment. The miner had a significant history of cigarette smoking, but no evidence of clinical pneumoconiosis was present. The dispute centered on whether his disabling pulmonary impairment—despite his smoking history—was legally attributable to his coal mine dust exposure. An Administrative Law Judge (ALJ) first reviewed the claim and found that the miner had worked in coal mines for 27 years and suffered from a totally disabling pulmonary impairment. These facts entitled the miner to a statutory presumption that his disability was caused by pneumoconiosis. The ALJ determined that the mining company, as the responsible employer, failed to rebut this presumption. The ALJ discredited the employer’s medical experts, who attributed the impairment solely to smoking, because their opinions did not properly consider the additive effects of smoking and coal dust, as recognized by the Department of Labor’s Preamble to its Black Lung regulations. The Benefits Review Board affirmed the ALJ’s decision. The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the ALJ correctly applied the law by requiring the employer to rebut the presumption, and properly evaluated the medical evidence in light of the regulatory guidance. The court found that the ALJ’s decision was supported by substantial evidence and that there was no legal error in the treatment of expert opinions or the regulatory preamble. The Fourth Circuit denied the mining company’s petition for review, leaving the award of benefits to the miner in place. View "Wolf Run Mining Company v. DOWCP" on Justia Law