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

US v. Rund

2026-09-04T10:30:09-08:00

Richard Rund, a U.S. citizen and businessman, failed to report his interest in multiple foreign bank accounts over several years, specifically from 2003 to 2008, 2013, and 2014. He maintained accounts in his own name and in the names of various businesses and entities, including FOB Instruments Ltd., York Luen, and Far East Ventures Ltd. Despite knowing about his obligation to file annual FBARs (Reports of Foreign Bank and Financial Accounts), Rund omitted many accounts from his filings or failed to file altogether. He later participated in the IRS’s Offshore Voluntary Disclosure Program but was removed from it. Throughout the period, Rund experienced personal and health challenges, but continued to work with tax professionals. The United States District Court for the Eastern District of Virginia reviewed the government’s civil suit to reduce IRS-assessed penalties to judgment after Rund did not pay the $2,915,633 assessed for his willful FBAR violations. After discovery, the district court granted summary judgment for the government, finding that Rund had a financial interest in the accounts, knew of his reporting requirements, and intentionally or recklessly disregarded them. The court also held that the Excessive Fines Clause of the Eighth Amendment did not apply to civil FBAR penalties and, even if it did, the penalties were not excessive. Judgment was entered against Rund for the full penalty plus interest. The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The court affirmed summary judgment, holding that Rund’s FBAR violations were willful as a matter of law under the civil recklessness standard set out in United States v. Horowitz, 978 F.3d 80 (4th Cir. 2020). The court further held that the $2.9 million penalty did not violate the Excessive Fines Clause, as it was not grossly disproportional to the gravity of Rund’s willful, repeated violations. The judgment was affirmed. View "US v. Rund" on Justia Law

US v. Arevalo Arias

2026-09-03T10:30:10-08:00

In the summer of 2019, a series of violent crimes occurred in Woodbridge, Virginia, involving multiple murders linked to members of the Sitios Locos Salvatrucha (STLS) clique of MS-13. After investigations, a group of defendants was indicted on charges including racketeering, violent crimes in aid of racketeering (VICAR), murder, witness tampering, and drug-related offenses. Several defendants pled guilty and cooperated with authorities, while others, including three individuals central to this appeal, proceeded to trial. The prosecution relied heavily on testimony from a cooperating witness who described the structure of the gang and detailed the defendants’ involvement in four murders. The United States District Court for the Eastern District of Virginia severed the trial due to complexity, ultimately trying three defendants together. After closing arguments, the district court found one defendant’s closing argument improper and instructed the jury to disregard it entirely. The jury returned guilty verdicts on all counts for two defendants and on most counts for the third. The convicted defendants raised various challenges, including claims of improper jury instructions, limitations on cross-examination, alleged due process violations related to evidence preservation and witness deportation, and the propriety of certain special jury findings. On appeal, the United States Court of Appeals for the Fourth Circuit held that the district court’s instruction to the jury to disregard the entire closing argument of one defendant was a prejudicial abuse of discretion, vacated the conviction as to that defendant, and remanded for further proceedings. However, the Fourth Circuit affirmed the convictions of the other two defendants, finding that the curative instruction was sufficient to cure any possible prejudice and rejecting the remaining challenges to the trial court’s rulings. View "US v. Arevalo Arias" on Justia Law

Calhoun v. Commissioner of Social Security

2026-09-03T10:30:09-08:00

The plaintiff applied for supplemental security income, asserting that a combination of physical and mental impairments, including obesity, blood clots, migraines, high blood pressure, agoraphobia, anxiety, and depression, rendered her unable to work. She had received special-education services in high school and subsequently attempted, but did not complete, a cosmetology program. Her anxiety and agoraphobia were managed with medication, and treatment records frequently noted normal mental status. In connection with her claim, she was evaluated by a psychological consultant who diagnosed agoraphobia and opined severe impairment in her ability to interact and tolerate work-related stress. State-agency consultants reviewed the record and found moderate or lesser limitations, concluding she could perform simple, repetitive tasks with limited social interaction. An Administrative Law Judge (ALJ) denied her claim following a hearing, finding she retained the residual functional capacity to perform a range of light, unskilled work, and relying on testimony from a vocational expert. The ALJ found the psychological consultant’s opinion less persuasive than those of the state-agency reviewers, and determined the plaintiff could stand and walk for more than four hours per workday. The ALJ identified jobs she could perform even with a four-hour standing and walking limitation. The Appeals Council denied review, and the United States District Court for the Western District of North Carolina granted summary judgment to the Commissioner. The United States Court of Appeals for the Fourth Circuit reviewed the district court’s judgment under a deferential substantial-evidence standard. The court held that the ALJ applied the correct legal standards, adequately explained her evaluation of medical opinions and educational findings, and that substantial evidence supported those conclusions. Any error in the standing-and-walking finding was deemed harmless because the occupations identified at step five accommodated a four-hour limitation. The court affirmed the district court’s judgment. View "Calhoun v. Commissioner of Social Security" on Justia Law

Wilkins-Bailey v. Essity Professional Hygiene North America, LLC

2026-08-31T11:01:24-08:00

A woman employed as a Sales Administrator at a global hygiene company in North Carolina was terminated after refusing to comply with her employer’s COVID-19 vaccination policy. The company had instituted a policy requiring all U.S. office and sales employees to be fully vaccinated against COVID-19 unless they qualified for an exemption. The employee, citing her religious beliefs, requested a religious accommodation to abstain from vaccination, and communicated her objections to the company’s Human Resources department. Her request was denied, with the company characterizing her reasons as secular and stating that granting an exemption would pose an undue hardship. After she confirmed she would not comply, her employment was terminated. The United States District Court for the Western District of North Carolina granted summary judgment for the employer on all claims. The court found that while the employee’s beliefs were sincere, they were not religious in nature, and did not “go to an essential part of a religious faith.” The court also found that the employee failed to establish a prima facie case of race discrimination under Title VII and Section 1981, holding that there were no valid comparators to support her claim. 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 employee’s refusal to be vaccinated was plausibly connected to her religious beliefs and constituted an essential part of her faith within her own scheme of things, thus satisfying Title VII’s requirement that beliefs be “religious in nature.” The court reversed and remanded the district court’s judgment on the religious discrimination claim for further proceedings. However, it affirmed the district court’s grant of summary judgment on the race discrimination claim, finding the employer’s stated reason for denial was not pretext for racial discrimination. View "Wilkins-Bailey v. Essity Professional Hygiene North America, LLC" on Justia Law

Brown v. Federal Communications Commission

2026-08-25T12:00:07-08:00

Four candidates for federal office challenged a Public Notice issued by the Media Bureau of the Federal Communications Commission (FCC) that interpreted federal law to require broadcasters to offer the lowest unit charge (LUC) advertising rates not only to candidates for public office but also to political parties and joint fundraising committees with non-candidate members during pre-election periods. The candidates argued that this expanded interpretation unlawfully diluted their statutory right to LUC rates by extending it to entities whose spending cannot be considered spending by or on behalf of a candidate under campaign finance law. Prior to seeking judicial review, the candidates filed an Application for Review with the FCC, urging the Commission to set aside the Media Bureau’s Public Notice as a novel and unlawful interpretation of the LUC requirement. The Commission took no action on the application for several months, even as the relevant election period approached. The candidates then filed a Petition for Review with the United States Court of Appeals for the Fourth Circuit, seeking expedited consideration. While the case was pending, the FCC Chairman circulated a proposed order to the other commissioners to dismiss the candidates’ application as an improper vehicle for review, and the Media Bureau denied a similar reconsideration petition from another party, maintaining that the Public Notice merely reiterated existing guidance. The United States Court of Appeals for the Fourth Circuit determined it had jurisdiction, finding that the Public Notice was a final order of the Commission and that the Commission had constructively denied the candidates’ application by failing to act. On the merits, the court concluded that the LUC statute unambiguously limits the lowest unit charge to legally qualified candidates for public office and does not extend this benefit to political parties or joint fundraising committees with non-candidate members. The court granted the Petition for Review and set aside the FCC’s Public Notice as unlawful. View "Brown v. Federal Communications Commission" on Justia Law

US v. Smith

2026-08-25T10:30:48-08:00

After police responded to a theft report at a convenience store in Chesterfield County, Virginia, Markel Trevon Smith and another individual were detained. A search of their vehicle revealed four firearms, including a Glock pistol equipped with a device converting it into a machinegun. This Glock bore three serial numbers: two had been scratched, leaving only partial digits visible, while one serial number remained fully legible. The firearm was traced using the unaltered serial number. Smith was indicted in the United States District Court for the Eastern District of Virginia for possession of a machinegun in violation of 18 U.S.C. § 922(o). He moved to dismiss, arguing that § 922(o) violated the Second Amendment, but the district court denied the motion. Smith then pled guilty. At sentencing, the court adopted the Presentence Report’s recommendation to apply a four-level enhancement under U.S. Sentencing Guidelines § 2K2.1(b)(4)(B)(i), which increases the offense level if any firearm has a serial number modified so that the original information is illegible or unrecognizable to the unaided eye. The district court reasoned that altering any serial number on the firearm warranted the enhancement, and sentenced Smith to 57 months’ imprisonment. On appeal, the United States Court of Appeals for the Fourth Circuit affirmed Smith’s conviction, holding that § 922(o) does not violate the Second Amendment, either facially or as applied to Smith, because machineguns are not in common use for lawful purposes. However, the Fourth Circuit found that the district court erred in applying the serial number enhancement. The court held that the enhancement only applies where modifications render the firearm as a whole untraceable, which was not the case since one serial number remained fully legible. The appellate court therefore reversed the application of the enhancement, vacated Smith’s sentence, and remanded for resentencing without the enhancement. View "US v. Smith" on Justia Law

Piedra v. Blanche

2026-08-24T10:30:43-08:00

A woman who immigrated to the United States as a child and later became a lawful permanent resident was convicted in North Carolina state court of two counts of common-law forgery and, in a separate proceeding, possession of marijuana. Years after serving her sentences, she was placed in removal proceedings when reentering the U.S. after a trip to Mexico. She conceded that her convictions made her inadmissible but sought a discretionary waiver that could allow her to remain in the country. While her removal case was pending, she successfully moved in state court to have her marijuana conviction vacated and the charge dismissed. The Immigration Judge denied her application for a waiver, concluding, among other things, that she could not show her marijuana offense involved 30 grams or less, did not prove extreme hardship, and was not entitled to relief as a matter of discretion. The judge did, however, grant her voluntary departure. On appeal, the Board of Immigration Appeals (BIA) independently determined that, under its established framework from Matter of Pickering, a conviction vacated for reasons other than substantive or procedural defect—such as to avoid immigration consequences—still counts for immigration purposes. The BIA found her vacated conviction still disqualified her from a waiver and denied her motion to remand for further proceedings. The United States Court of Appeals for the Fourth Circuit reviewed the BIA’s decision de novo. The court held that, under 8 U.S.C. § 1182(a)(2)(A)(i), a person whose state conviction has been vacated and the charge dismissed is not an “alien convicted of” that offense for immigration purposes. The court rejected the BIA’s Pickering framework as inconsistent with the statute. The petition for review was granted in part regarding the vacated conviction but denied as to the challenge to voluntary departure regulations, which the court found reasonable. View "Piedra v. Blanche" on Justia Law

Billesdon v. Wells Fargo Securities, LLC

2026-08-21T10:30:33-08:00

A senior employee at a major financial institution managed a significant medical disability for nearly thirty years. Initially, he did so without formal accommodations and excelled, rising to a top leadership position. After a serious health setback in 2017 required him to adopt a new medical protocol, his need for flexibility at work increased, particularly in terms of immediate and unpredictable bathroom access. During the COVID-19 pandemic, remote work made this manageable. He moved back to the company’s headquarters in 2020, relying on assurances from his then-manager that he could work from home when needed. In 2021, with management changes and a planned return to office, he formally requested a permanent remote-work accommodation. Senior management, who were aware of his disability, reacted with skepticism and ultimately included him in a reduction in force, terminating his employment before the office fully reopened. The United States District Court for the Western District of North Carolina heard his claims under the Americans with Disabilities Act (ADA) for failure to accommodate, discriminatory discharge, and retaliation, as well as a claim for wrongful discharge under North Carolina law. A jury found for the plaintiff on all claims, awarding substantial damages, including back pay, front pay, emotional distress, and punitive damages. The district court denied the employer’s motions for judgment as a matter of law or a new trial and entered judgment on the verdict, later remitting punitive damages under the ADA to comply with statutory caps and awarding prejudgment interest under state law. The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the verdict only as to the ADA retaliation claim, holding that substantial evidence supported a finding that the employee’s request for accommodation was a but-for cause of his discharge. However, the court reversed the verdicts on the failure-to-accommodate and disability-discrimination claims, finding insufficient evidence that any reasonable accommodation was denied or that the discharge was because of the disability itself. The court remanded for entry of judgment as a matter of law on those claims, vacated certain damages, and ordered adjustment of the back-pay award unless the plaintiff accepted a remittitur. The matter was remanded for further proceedings consistent with these rulings. View "Billesdon v. Wells Fargo Securities, LLC" on Justia Law

Central Appalachian Coal Company v. DOWCP

2026-08-20T10:30:36-08:00

A former underground coal miner developed severe respiratory problems, including chronic cough and significant limitations in daily activities, following nearly 12 years of employment in West Virginia coal mines. After his symptoms worsened post-employment, he filed a claim for benefits under the Black Lung Benefits Act in 2020. Medical testing revealed persistent lung function impairment, and four pulmonary specialists—two for the miner and two for his former employer—offered differing opinions on the cause of his disability. The miner’s experts attributed his impairment to legal pneumoconiosis resulting from coal mine dust exposure, while the company’s experts diagnosed asthma unrelated to mining. A United States Department of Labor administrative law judge (ALJ) heard the case. The parties stipulated to the miner’s work history, and the company was named the responsible operator. The ALJ found the miner’s experts’ opinions more persuasive, particularly because they addressed the regulatory definitions and considered the possibility that coal dust exposure worsened his condition. The ALJ concluded the miner had legal pneumoconiosis arising from his coal mine employment, was totally disabled, and that pneumoconiosis substantially contributed to his disability. The company’s experts were found less persuasive for not adequately addressing the regulatory definition or the potential contribution of coal dust. The Benefits Review Board (BRB) affirmed the ALJ’s decision, concluding that substantial evidence supported all findings. The United States Court of Appeals for the Fourth Circuit reviewed the company’s petition. The court held that the ALJ and BRB did not err in their factual findings or legal analysis. It found sufficient evidence that the miner had legal pneumoconiosis caused by coal mine employment and that the disease substantially contributed to his total disability. The Fourth Circuit denied the petition for review, affirming the award of black lung benefits to the miner. View "Central Appalachian Coal Company v. DOWCP" on Justia Law

Hayat v. Diaz

2026-08-20T10:30:36-08:00

Police in Montgomery County, Maryland, responded to a high-priority call reporting that a Black male had placed three children into the trunk of a black Tesla, possibly indicating a kidnapping. Officers quickly traced the vehicle and address to Fareed Hayat. Upon arriving at his home, they found Hayat and his wife on the porch and initiated questioning. Hayat acted evasively, did not answer whether he had been at the location in question, cut off his wife’s conversation with officers, and attempted to retreat into his house, insisting the police could not enter. The officers prevented him from closing the door, entered the front hall, handcuffed Hayat, and checked on the children’s welfare. After confirming no kidnapping had occurred, the officers released Hayat. Hayat subsequently filed a lawsuit in the United States District Court for the District of Maryland against the officers, the Chief of Police, and Montgomery County. He alleged violations of his Fourth and Fourteenth Amendment rights, as well as various federal and state law claims. The district court dismissed most claims and granted summary judgment to the defendants on the remaining claims, finding that the officers had a reasonable suspicion justifying a Terry stop prior to Hayat’s retreat into his home. The court also held that the officers were justified in entering the home to complete the stop and to confirm the children’s welfare, given the exigency created by Hayat’s conduct. On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The Fourth Circuit held that the officers had reasonable articulable suspicion to justify a Terry stop based on corroborated eyewitness accounts and Hayat’s suspicious behavior. The court further held that entry into the home was justified to complete the Terry stop and to ensure the safety of the children, under both the exigent circumstances and “hot pursuit” exceptions to the warrant requirement. The court concluded that Hayat’s Fourth Amendment rights were not violated. View "Hayat v. Diaz" on Justia Law

O'Connor v. Fairfax Taxi, Inc.

2026-08-19T10:30:39-08:00

Two South Korean citizens, Dr. Sung-Chul Jung and Ms. Hyo Jung Kim, were passengers in a Virginia taxicab driven by Amoah Gyimah when it collided head-on with a Volkswagen on the George Washington Memorial Parkway. The crash killed Gyimah and Kim and severely injured Jung. Both Jung and the Volkswagen driver, Eric Jewett, were left with no memory of the event. No witness could identify which car crossed the center line. The United States Park Police concluded Jewett was at fault, but Jung and Kim’s estate nonetheless sued Gyimah’s estate for negligence and also sued Fairfax Taxi, the company under whose certificate Gyimah operated, on several theories of derivative liability. Initially, the plaintiffs filed suit in the Circuit Court of Fairfax County. That court dismissed some claims and denied others, finding, among other things, that operating a taxi was not an activity posing an unreasonable risk, and thus not a non-delegable duty. Plaintiffs then nonsuited and refiled in the United States District Court for the Eastern District of Virginia, which granted judgment on the pleadings for Fairfax Taxi and later excluded plaintiffs’ accident reconstruction expert for procedural and evidentiary deficiencies. The district court also granted summary judgment for Gyimah’s estate, holding the plaintiffs could not show, without resort to speculation, how or why the accident occurred, as Virginia law requires. The United States Court of Appeals for the Fourth Circuit affirmed the district court’s rulings. The court held that the district court properly exercised diversity jurisdiction, that exclusion of the plaintiffs’ expert was within its discretion, and that summary judgment was warranted because plaintiffs had not produced sufficient evidence to show Gyimah’s negligence caused the crash. As a result, the derivative claims against Fairfax Taxi also failed. View "O'Connor v. Fairfax Taxi, Inc." on Justia Law

Grant v. Belangia

2026-08-18T10:30:31-08:00

A group of registered voters in South Carolina, all under the age of sixty-five, challenged a provision of state law that restricts “no excuse” absentee-by-mail voting to voters sixty-five years of age or older. These plaintiffs argued that the statute unconstitutionally discriminates against them on account of age, in violation of the Twenty-Sixth Amendment, and also violates the Equal Protection Clause of the Fourteenth Amendment. The law at issue allows voters sixty-five and older to vote absentee by mail for any reason, while voters under sixty-five can only do so if they meet specific, narrow criteria such as disability, military service, or certain employment conflicts. The case was initially heard in the United States District Court for the District of South Carolina, where the court granted summary judgment in favor of the defendants—the South Carolina State Election Commission and related officials—on both constitutional claims. The district court found that the plaintiffs did not demonstrate a violation of either the Twenty-Sixth Amendment or the Equal Protection Clause. The plaintiffs appealed this decision. The United States Court of Appeals for the Fourth Circuit reviewed the appeal. This court held that the plaintiffs have standing and that South Carolina’s age-based absentee-by-mail voting scheme violates the Twenty-Sixth Amendment because it abridges the right to vote on account of age by providing greater ballot access to older voters. However, the court affirmed the district court’s decision to dismiss the Equal Protection claim, as age is not a suspect classification under the Equal Protection Clause and the plaintiffs did not challenge the law under rational basis or Anderson-Burdick scrutiny. The Fourth Circuit reversed the district court’s judgment on the Twenty-Sixth Amendment claim, affirmed the Equal Protection ruling, and remanded the case for appropriate remedy. View "Grant v. Belangia" on Justia Law

Yearly Meeting of the Religious Society of Friends v. Department of Homeland Security

2026-08-18T10:30:31-08:00

The case concerns a challenge brought by several houses of worship from Quaker, Sikh, and Cooperative Baptist Fellowship religious traditions to a new policy adopted by the Department of Homeland Security (DHS) in January 2025. This policy rescinded longstanding guidelines that limited immigration enforcement actions at or near houses of worship, replacing them with a directive that left the decision to conduct enforcement actions largely to the discretion of immigration officers without specific guidelines or required supervisory approval. The plaintiffs alleged that the new policy has already caused, and will continue to cause, a decline in attendance at their worship services and ministries, thereby impeding their ability to exercise their religion communally and to minister to immigrant communities. Previously, the United States District Court for the District of Maryland granted the plaintiffs’ motion for a preliminary injunction, ordering DHS to follow its prior 2021 guidelines that limited immigration enforcement at or near the plaintiffs’ houses of worship. The district court found that the plaintiffs had standing and were likely to succeed on the merits of their claims under the Religious Freedom Restoration Act (RFRA), and that they would suffer irreparable harm without interim relief. On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s decision. The Fourth Circuit held that the plaintiffs had met the requirements for standing, including injury-in-fact, traceability, and redressability, based on evidence of actual and likely future declines in attendance linked to the new policy. The court further concluded that the district court did not abuse its discretion in finding that the plaintiffs were likely to succeed on the merits of their RFRA claim, as the new policy substantially burdened their religious exercise. The government’s arguments under strict scrutiny were found to be waived, as they were not properly raised below. The Fourth Circuit affirmed the district court’s preliminary injunction. View "Yearly Meeting of the Religious Society of Friends v. Department of Homeland Security" on Justia Law

Sanchez v. Mullin

2026-08-14T10:30:44-08:00

The case involves several married couples, each consisting of a U.S. citizen and a noncitizen spouse who is subject to a final order of removal. The noncitizen spouses are seeking lawful permanent residency through a process that requires them to first file a family-based petition, then seek special permission to reapply for admission, and finally apply for a provisional unlawful presence waiver. The waiver, if granted, would allow the noncitizen to leave the country to complete consular processing without triggering a lengthy inadmissibility bar. Several noncitizen plaintiffs were arrested by ICE at their immigration interviews, causing others to avoid or delay their own interviews out of fear of arrest and removal. The United States District Court for the District of Maryland certified a class of similarly situated couples and granted summary judgment in favor of the plaintiffs. The district court held that the government lacked authority to arrest or remove noncitizens during the provisional waiver process, finding this violated the relevant regulations, the Administrative Procedure Act, and the Due Process Clause. The court issued class-wide declaratory and injunctive relief, barring the government from interfering with plaintiffs’ participation in the waiver process through arrest or removal. Upon review, the United States Court of Appeals for the Fourth Circuit vacated the district court’s judgment and remanded for further proceedings. The Fourth Circuit held that the relevant regulations do not bar the government from arresting or removing noncitizens during the provisional waiver process and that the plaintiffs do not have a protected interest in accessing the process without risk of removal. The court also found the factual record insufficient to support the alternative theory that the government uses the waiver process to target noncitizens for removal. Thus, the award of summary judgment to the plaintiffs was vacated. View "Sanchez v. Mullin" on Justia Law

US v. Roney

2026-08-14T10:30:44-08:00

A man who had been found not guilty by reason of insanity for sending threats to his former lawyer was committed to a federal medical facility for treatment of his mental illness. After several years, the director of the facility determined that he could be conditionally released under a prescribed regimen of psychiatric care, provided he complied with certain conditions, including a prohibition on possessing weapons. The district court ordered his conditional discharge subject to these terms. Some years later, the man traveled out of state and committed an armed robbery, violating the condition that barred him from possessing weapons. Following the robbery, the U.S. Probation Office sought to revoke his conditional discharge, citing three grounds: committing new criminal conduct, possessing a weapon, and leaving the state without permission. Of these, only the prohibition on weapon possession was actually a condition of his discharge order. The United States District Court for the District of South Carolina agreed with the government’s argument that it could revoke conditional discharge for this violation and subsequently revoked his conditional discharge. On appeal, the United States Court of Appeals for the Fourth Circuit considered whether revocation under 18 U.S.C. § 4243(g) can be based only on violations of the prescribed regimen of medical, psychiatric, or psychological care or treatment, or whether it may also be based on violations of ancillary conditions. The Fourth Circuit held that § 4243(g) permits revocation only for failing to comply with the prescribed regimen. However, the court determined that the no-weapons condition was part of the prescribed regimen, not an ancillary condition, because it was included in the regimen developed and certified by the facility director and approved by the court as necessary for treatment and public safety. Accordingly, the court affirmed the revocation of conditional discharge. View "US v. Roney" on Justia Law

US v. Franklin

2026-08-14T10:30:44-08:00

A postal service employee in Fayetteville, North Carolina, was stopped by police for a traffic violation. During the stop, officers discovered drug paraphernalia and, upon searching the vehicle, found 48 United States Treasury checks not made out to him, with 47 checks in the trunk and one, which had been altered, in his backpack. The backpack also contained marijuana, a large amount of cash, and a loaded firearm. A subsequent traffic stop and a search of his home uncovered further evidence of altered and stolen checks. In total, he was linked to 51 stolen checks, with a significant intended loss, and was later indicted on charges of theft of mail matter by a postal service employee and possession of stolen mail. He pleaded guilty to both charges. The United States District Court for the Eastern District of North Carolina, relying on the Presentence Report, calculated his Sentencing Guidelines range and applied a two-level firearm enhancement under USSG § 2B1.1(b)(16)(B), finding that his offense involved possession of a firearm in connection with the offense. The court sentenced him to 48 months’ imprisonment, above the bottom of the applicable range. The defendant did not object to the firearm enhancement at sentencing. On appeal, the United States Court of Appeals for the Fourth Circuit reviewed only the procedural reasonableness of the sentence. The Fourth Circuit held that the district court erred by applying the firearm enhancement without making required factual findings linking the firearm to the theft or possession offenses. The appellate court found that this error was plain, affected the defendant’s substantial rights, and seriously affected the fairness of the proceedings because it could not determine if the district court would have imposed the same sentence absent the error. The Fourth Circuit vacated the sentence and remanded for resentencing with instructions for the district court to make specific factual findings regarding the firearm enhancement. View "US v. Franklin" on Justia Law

US v. Griffin

2026-08-14T10:30:43-08:00

Law enforcement officers sought and obtained a no-knock search warrant for a residence in an area known as Kent Bottom, Maryland, based on an affidavit describing the area's reputation for drug activity, criminal histories of individuals associated with the area, and surveillance of suspected drug transactions near the property. The affidavit included descriptions of drug-related incidents from as far back as 2006 involving the residence, as well as more recent but less direct observations of possible drug activity in the general vicinity of the house. The more recent surveillance involved suspected hand-to-hand transactions outside the residence and people entering and leaving the property, but did not directly connect current criminal activity to the interior of the home. After the search, officers recovered drugs and a firearm from a vehicle parked outside the residence. The defendant, who was found inside the house, was charged with several drug and firearm offenses. He moved to suppress the evidence, arguing that the warrant lacked probable cause because the affidavit failed to establish a meaningful connection between the alleged criminal activity and the specific residence. The United States District Court for the District of Maryland denied the motion, reasoning that the history and geography of drug activity in Kent Bottom, along with the observed conduct near the residence, provided a sufficient basis for probable cause. The United States Court of Appeals for the Fourth Circuit reversed. It held that the warrant affidavit did not provide a substantial basis for probable cause to search the residence because the facts were either too old, not specifically tied to the home, or both, and therefore failed to establish a fair probability that evidence of a crime would be found inside the house at the time of the search. The court also determined that the good-faith exception did not apply, as the affidavit was so lacking in indicia of probable cause that no reasonable officer could rely on it. The court reversed the district court’s denial of the motion to suppress, vacated the conviction, and remanded for further proceedings. View "US v. Griffin" on Justia Law

Gilead Sciences, Inc. v. Meritain Health, Inc.

2026-08-13T11:00:34-08:00

A biopharmaceutical company that develops and sells prescription medications—including a well-known HIV drug—discovered that U.S. patients were receiving versions of its medication intended only for foreign markets, specifically Turkey. This occurred after a Maryland patient received a Turkish-labeled version of the drug. The medication, while chemically identical to the U.S.-approved version, had packaging, labeling, and patient information in Turkish, omitting U.S. regulatory warnings and instructions. The biopharmaceutical company traced the importation to a group of entities and individuals who facilitated the import and sale of these foreign-market drugs to U.S. consumers, working in cooperation with third-party administrators and pharmacy benefit managers serving self-funded employer health plans. The company filed suit in the United States District Court for the District of Maryland against the entities and individuals involved in the importation, alleging direct and contributory trademark infringement under the Lanham Act. The district court granted a preliminary injunction, enjoining the defendants from importing, advertising, or facilitating the importation and sale of the company’s branded medications intended for foreign markets. The court found the imported drugs were materially different from the U.S. versions due to differences in labeling, warnings, and quality control procedures, and that the defendants had knowledge of these differences. On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The Fourth Circuit held that the imported medications were not “genuine” under the Lanham Act because they materially differed from the U.S. versions and bypassed the company’s quality-control systems. The court found the company likely to succeed on its direct and contributory infringement claims, concluded that irreparable harm was presumed and not rebutted, and determined that the balance of equities and public interest supported the injunction. The district court’s preliminary injunction order was affirmed. View "Gilead Sciences, Inc. v. Meritain Health, Inc." on Justia Law

US v. Flood

2026-08-13T11:00:33-08:00

A defendant was convicted for his role in the kidnapping and killing of an individual, resulting in a mandatory life sentence on the kidnapping charge, in addition to other related convictions. The defendant, along with his co-defendants, faced overwhelming evidence of guilt. Although the government did not seek the death penalty against this defendant, it required any plea agreement to include a truthful proffer and cooperation, specifically testifying against his co-conspirators. After his convictions were affirmed on direct appeal, the defendant filed a motion under 28 U.S.C. § 2255 in the United States District Court for the District of Maryland, arguing that his trial counsel rendered ineffective assistance by failing to pursue a plea agreement that could have resulted in a lesser sentence. The district court sought additional briefing and held a non-evidentiary hearing, but ultimately denied the motion without an evidentiary hearing. The court found that the record conclusively showed the defendant was not entitled to relief, as there was no evidence he would have agreed to the government’s required terms for a plea. On appeal, the United States Court of Appeals for the Fourth Circuit considered whether the district court abused its discretion in denying the § 2255 motion without an evidentiary hearing on the ineffective assistance claim. The Fourth Circuit held that the record, even when viewed in the light most favorable to the defendant, conclusively established he could not prevail. The defendant failed to identify any specific act or omission by counsel constituting deficient performance and did not demonstrate a reasonable probability that he would have accepted a plea requiring cooperation. As a result, the Fourth Circuit affirmed the district court’s denial of the motion without an evidentiary hearing. View "US v. Flood" on Justia Law

Stewart v. GES Recycling South Carolina LLC

2026-08-13T11:00:33-08:00

An African American employee worked as a driver for a metal recycling company in South Carolina for several months in 2017. During his employment, he experienced repeated racial harassment from white coworkers and supervisors, including the frequent use of racial slurs, exposure to racist cartoons, and derogatory comments both in person and on social media. The employee also believed he was denied training and promotional opportunities due to his race. He refrained from making complaints initially out of fear of retaliation, as a manager had previously warned him against associating with African American coworkers who had complained about discrimination. On June 13, 2017, after a racially offensive incident involving his manager, the employee complained directly to the manager about racial harassment and discrimination. He was immediately suspended and, after providing a written statement, was terminated a week later. After his termination, the employee filed suit in the United States District Court for the District of South Carolina, alleging a racially hostile work environment, race discrimination in training and promotion, and retaliatory discharge under 42 U.S.C. § 1981. The district court, adopting the magistrate judge’s recommendation in part, held that the hostile work environment and race discrimination claims were time-barred. The court also granted summary judgment to the employer on the retaliatory discharge claim, concluding that the employee’s termination was due to “belligerent and insubordinate conduct” rather than retaliation and that no reasonable jury could find otherwise. 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 held that genuine disputes of material fact existed as to whether the employer’s stated reason for termination was pretext for retaliation and whether retaliation was a but-for cause of the discharge. The appellate court therefore vacated the summary judgment on the retaliatory discharge claim and remanded the case for further proceedings. View "Stewart v. GES Recycling South Carolina LLC" on Justia Law

US v. Joyner

2026-08-12T10:30:47-08:00

A licensed physician assistant accepted a remote, part-time position with a telehealth company. His role was to review files sent by the company and sign orders for genetic tests for Medicare beneficiaries. Over approximately ten months, he signed orders for more than 600 beneficiaries, despite having spoken with only about 20 of them. For each file, regardless of test approval, he was compensated. These signed orders led laboratories to bill Medicare for over 14,600 tests, totaling more than $10 million. The physician assistant did not personally bill Medicare and resigned after raising concerns about the company’s practices. A grand jury indicted him on healthcare fraud and making false statements related to healthcare matters. In the United States District Court for the Western District of North Carolina, a jury convicted him on all counts. The court sentenced him to 72 months in prison. On appeal, the defendant argued that the district court erred by excluding documents about the company’s internal compliance, quashing subpoenas for witnesses who invoked the Fifth Amendment, allowing a prosecutorial rebuttal he claimed was improper, giving flawed jury instructions, and miscalculating the sentencing guidelines. The United States Court of Appeals for the Fourth Circuit reviewed and rejected all of the defendant’s challenges. The court held that the exclusion of compliance documents was not an abuse of discretion under Rule 403, that the district court properly quashed subpoenas after a sufficient inquiry into the witnesses’ privilege against self-incrimination, and that any arguably improper prosecution remarks did not deprive the defendant of a fair trial. Additionally, the court found no reversible error in the jury instructions, determined that the evidence sufficiently supported the convictions, and affirmed the sentencing methodology. The appellate court affirmed the judgment of the district court. View "US v. Joyner" on Justia Law

Trimble v. Entrata, Inc.

2026-08-11T10:30:42-08:00

A software company operated an online payment portal used by residents, including the plaintiff, to pay rent for Maryland apartments. Each time the plaintiff paid rent through the portal, she was charged a convenience fee. To complete a transaction, users were required to check a box agreeing to the portal’s hyperlinked terms and conditions, which included an arbitration provision, a clause allowing unilateral changes to the agreement, and a notice provision stating that notices would be posted on the portal. The plaintiff, on behalf of herself and similarly situated individuals, filed a class action, alleging that the company unlawfully acted as an unlicensed collection agency by collecting these fees. After the action was removed to the U.S. District Court for the District of Maryland, the company moved to compel arbitration based on the terms and conditions. The plaintiff opposed, arguing that the arbitration agreement was unenforceable under Maryland law because the company’s ability to unilaterally change the terms without advance notice rendered its promise to arbitrate illusory. The district court agreed, finding that the contract was a browsewrap agreement and that the modification and notice clauses allowed the company to change terms at will without meaningful notice or an opportunity for users to opt out before changes became binding. On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s denial of the motion to compel arbitration de novo. The Fourth Circuit held that, under Maryland law, the arbitration agreement was unenforceable for lack of consideration because the company’s promise to arbitrate was illusory. The court reasoned that the change-in-terms clause gave the company unfettered discretion to modify the agreement at any time, without advance notice, thus failing to bind the company meaningfully. The court affirmed the district court’s judgment. View "Trimble v. Entrata, Inc." on Justia Law

Navarro Cerritos v. Blanche

2026-08-11T10:30:41-08:00

A Salvadoran national fled his home country after enduring repeated violence and threats from the MS-13 gang, including witnessing and suffering brutal attacks as a child and young adult. After initially seeking asylum in the United States and later receiving DACA relief, his status lapsed and he was deported in 2016. Upon his return to El Salvador, he faced renewed threats and violence due to his anti-gang activism, including organizing youth to resist gang recruitment and being publicly targeted by MS-13 and a powerful local figure. Fearing for his life, he re-entered the United States but was soon apprehended, and his removal order was reinstated. In subsequent immigration proceedings, an Immigration Judge (IJ) denied his applications for withholding of removal and protection under the Convention Against Torture (CAT), finding his proposed social group not cognizable, insufficient nexus to a political opinion, and no particularized risk of torture. The Board of Immigration Appeals (the Board) affirmed the IJ’s decision, agreeing with the findings on all grounds. The petitioner was removed to El Salvador and filed a petition for review with the United States Court of Appeals for the Fourth Circuit, although the petition was filed beyond the usual 30-day statutory deadline. The United States Court of Appeals for the Fourth Circuit ruled that it had jurisdiction to review the petition, holding that the 30-day filing deadline under 8 U.S.C. § 1252(b)(1) is subject to equitable tolling and that the circumstances of the case justified such tolling. On the merits, the court found that the lower tribunals had erred in their legal analysis and factual findings regarding the petitioner’s political opinion, the cognizability of his proposed social group, and the assessment of risk under CAT. The court granted the petition for review, reversed in part, vacated in part the Board’s decision, and remanded for further proceedings. View "Navarro Cerritos v. Blanche" on Justia Law

Orellana-Ramos v. Blanche

2026-08-10T10:30:43-08:00

A native and citizen of El Salvador, along with her two minor children, entered the United States without authorization and were placed in removal proceedings. The primary applicant sought asylum and withholding of removal, claiming that she and her children faced persecution in El Salvador due to their membership in their family. She testified that her former partner had an affair, which angered another man, leading that man to threaten her and her children with harm as retribution for the partner’s actions. Despite seeking police protection in El Salvador, she was told no action would be taken unless physical harm occurred, prompting her family to relocate within the country and eventually flee to the United States. An Immigration Judge (IJ) found her testimony credible but denied the applications for asylum and withholding of removal on the grounds that the threats were the result of a “personal dispute” between the two men, not due to a statutorily protected ground such as family membership. The Board of Immigration Appeals (BIA) affirmed the IJ’s decision, finding that the familial relationship was only incidental or subordinate to the threats and not a central reason for the persecution. Reviewing the case, the United States Court of Appeals for the Fourth Circuit determined that both the IJ and the BIA applied the wrong legal standard in their nexus analysis. The Fourth Circuit held that the focus should be on the reason the persecutor targeted the applicant, not the applicant’s partner. The court concluded that the evidence compelled the finding that the threats against the applicant were on account of her family membership—a protected ground. As a result, the Fourth Circuit granted the petition for review and remanded the case for further proceedings. View "Orellana-Ramos v. Blanche" on Justia Law

Haysbert v. Outback Steakhouse of Florida, LLC

2026-08-10T10:30:42-08:00

The case centers on an incident where Joann Wright Haysbert, an academic administrator, slipped and fell while picking up an order at an Outback Steakhouse in Chesapeake, Virginia. She claimed to have suffered a traumatic brain injury and related cognitive impairments as a result of the fall, and brought a negligence lawsuit against Outback and its parent company. The litigation was marked by contentious proceedings, particularly involving her son, Attorney Nazareth Haysbert, who represented her pro hac vice. After Outback removed the case to the United States District Court for the Eastern District of Virginia, the first trial was declared a mistrial due to Attorney Haysbert’s repeated unprofessional conduct, including outbursts before the jury and violations of court instructions. Subsequently, his pro hac vice admission was revoked. The district court granted Dr. Haysbert's motion to dismiss the case without prejudice, but imposed strict limitations on discovery for any potential refiling. When Dr. Haysbert refiled the case, further disputes arose, including the late disclosure of a new expert report and challenges during jury selection. Upon retrial, the district court excluded Dr. Haysbert’s expert witness, Dr. Filler, as a sanction for untimely disclosure of his report, and denied her Batson challenge to Outback’s use of peremptory strikes against Black potential jurors. The jury found for Outback. The United States Court of Appeals for the Fourth Circuit affirmed the district court’s rulings. The court held that Dr. Haysbert lacked standing to challenge the revocation of her attorney’s pro hac vice admission based on his due process rights. The court also found no abuse of discretion in excluding Dr. Filler’s testimony as a sanction or in denying the Batson challenge, concluding that the district court’s factual findings were not clearly erroneous. The judgment in favor of Outback was affirmed. View "Haysbert v. Outback Steakhouse of Florida, LLC" on Justia Law

Kelly v. Altria Client Services, LLC

2026-08-10T10:30:42-08:00

The plaintiff, a former employee of a company participating in a deferred profit-sharing plan, sought to liquidate his 401(k) account in anticipation of a post-election stock market increase. He requested that the plan’s record keeper, Fidelity, complete the liquidation rapidly and in a manner advantageous for tax purposes. The plaintiff claimed that Fidelity’s communications led him to believe he would have quicker access to his funds than ultimately occurred, resulting in a missed investment opportunity. Additionally, he alleged that the plan administrator, Altria, failed to provide him with a copy of the administrative services agreement (ASA) between Altria and Fidelity, which he requested under ERISA. After the plaintiff’s formal complaint was denied by the plan administrator, he appealed to the plan’s management committee, which upheld the denial. He then filed suit in the United States District Court for the Eastern District of Virginia, raising claims for denial of benefits, breach of fiduciary duty, and failure to provide plan documents. The district court granted summary judgment to the defendants on all remaining claims, finding that the plan administrator’s denial was reasonable, that Fidelity was not acting as a fiduciary or had not breached any fiduciary duties, and that the ASA was not a document required to be disclosed under ERISA. The United States Court of Appeals for the Fourth Circuit reviewed the case. The appellate court affirmed the district court’s rulings on the denial of benefits and breach of fiduciary duty claims, concluding that the plan administrator’s decision was reasonable and that Fidelity was not a fiduciary in this context or had not breached any such duty. However, the Fourth Circuit reversed the district court’s decision regarding the ASA, holding that it was a document under which the plan was operated and remanded for consideration of statutory penalties. The court affirmed the award of attorney’s fees to the defendants. View "Kelly v. Altria Client Services, LLC" on Justia Law

The Cincinnati Insurance Co. v. Owens

2026-08-10T10:30:42-08:00

Wayne Hunt, an employee of Wilmington Shipping Company, was involved in a truck accident in 2013 that resulted in the death of Christopher McLean. Three years later, Levi Owens, acting as the personal representative of McLean’s estate, sued Hunt for wrongful death in South Carolina state court. Hunt, who was served through the South Carolina Department of Motor Vehicles as an out-of-state motorist, failed to respond to the lawsuit, leading the state court to enter a default judgment against him. Owens later sought to collect on the judgment and initiated supplemental proceedings, attempting to obtain an assignment of any claims Hunt might have against his insurer, Cincinnati Insurance Company. After Hunt moved to vacate the default judgment, Cincinnati Insurance Company filed a declaratory judgment action in the United States District Court for the District of South Carolina. Cincinnati asserted it had no duty to defend or indemnify Hunt because it was not provided timely notice of the underlying wrongful-death action, as required by its policies. The district court denied Owens’s repeated motions to stay the federal action pending resolution of the post-judgment motions in state court. The court also denied Owens’s request to amend his answer to assert a counterclaim under the MCS-90 endorsement, finding the amendment futile because the endorsement did not apply to Hunt, who was not the named insured. Ultimately, the district court granted summary judgment to Cincinnati, holding that Cincinnati had no duty to defend or indemnify Hunt due to untimely notice and resulting material prejudice. On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The court held that the federal action was justiciable and that the district court did not err or abuse its discretion in refusing to stay the action, in denying the amendment, or in granting summary judgment to Cincinnati Insurance Company. The court also clarified that the MCS-90 endorsement applies only to judgments against the named insured. View "The Cincinnati Insurance Co. v. Owens" on Justia Law

US v. Boyd

2026-08-06T11:00:34-08:00

The case concerns Robert Boyd, who had a history of sexual offenses involving minors. After serving prison time for downloading child sexual abuse material, post-incarceration civil commitment proceedings were initiated against him under the Adam Walsh Child Protection and Safety Act. Boyd was designated a “sexually dangerous person” and committed to the custody of the Attorney General. Eight years later, Boyd was conditionally discharged after the district court concluded he no longer posed a threat if released under a strict treatment regimen. Conditions included supervision, participation in treatment, restrictions on internet usage, and prohibitions on possessing pornography. About a year after his conditional discharge, the Government sought to revoke Boyd’s release, alleging he violated his treatment regimen by possessing an SD card with images deemed pornographic and engaging in risk-related behaviors, such as interactions with underage individuals and unauthorized internet use. The United States District Court for the Eastern District of North Carolina found Boyd in violation, determined he remained sexually dangerous, and revoked his conditional discharge, returning him to federal custody. The United States Court of Appeals for the Fourth Circuit reviewed the district court’s factual findings for clear error and legal conclusions de novo. The court held that revocation of conditional discharge under the Adam Walsh Act requires the Government to prove by a preponderance of the evidence that the individual failed to comply with their prescribed regimen, suffers from a serious mental disorder, and would have serious difficulty refraining from sexually violent conduct if released. The Fourth Circuit affirmed the district court’s findings, concluding there was sufficient evidence Boyd violated his regimen and posed a risk if allowed to remain in the community. The judgment revoking Boyd’s conditional discharge was affirmed. View "US v. Boyd" on Justia Law

PSEG Renewable Transmission LLC v. Arentz Family, LP

2026-08-06T11:00:34-08:00

A transmission development company sought to build a high-voltage transmission line across three Maryland counties to address a regional electricity shortage. After receiving federal approval, the company was required to obtain a Certificate of Public Convenience and Necessity (CPCN) from Maryland's Public Service Commission (PSC) before construction. As part of the CPCN application, environmental and socioeconomic field studies needed to be conducted on properties along the proposed route. The property owners refused access for these surveys, prompting the developer to submit desktop studies instead, which the PSC's Power Plant Research Program (PPRP) found inadequate, deeming the application incomplete. The developer then sought an injunction to enter the properties for the necessary field studies. The United States District Court for the District of Maryland granted the developer's motion for a preliminary injunction, finding that the developer was likely to succeed on the merits under Maryland law, particularly Section 12-111(a) of the Real Property Article, which allows entities with eminent domain powers to access private land for surveys. The court determined that the developer had a viable claim to such power for the purposes of conducting the surveys, even though it could not condemn property until it obtained a CPCN. The court also found irreparable harm due to lost revenues from project delays, that the balance of equities favored the developer, and the public interest supported the injunction. The United States Court of Appeals for the Fourth Circuit reviewed the district court’s decision under an abuse of discretion standard. The Fourth Circuit affirmed, holding that the district court did not abuse its discretion in granting the preliminary injunction. The court concluded that the developer likely possessed the statutory right of access to conduct surveys prior to obtaining a CPCN, and that all four Winter factors for injunctive relief were satisfied. View "PSEG Renewable Transmission LLC v. Arentz Family, LP" on Justia Law

TitleMax of South Carolina, Inc. v. Spicher

2026-08-05T10:30:39-08:00

A South Carolina lender originates loans only within South Carolina but has extended credit to individuals with Pennsylvania addresses. Although the lender does not operate in Pennsylvania, it has engaged in activities connected to Pennsylvania, such as perfecting liens, collecting payments, and repossessing vehicles located in Pennsylvania. The Pennsylvania Department of Banking and Securities investigated the lender’s practices involving Pennsylvania residents, issuing subpoenas and ultimately initiating a formal administrative enforcement proceeding for alleged violations of Pennsylvania’s usury laws. Previously, the United States District Court for the District of Delaware granted summary judgment for the lender, finding Pennsylvania’s subpoena violated the Dormant Commerce Clause. The United States Court of Appeals for the Third Circuit reversed, holding that Pennsylvania could investigate and apply its usury laws to conduct connected to Pennsylvania. Afterward, Pennsylvania enforced its subpoena and initiated the administrative enforcement proceeding. The lender responded by filing suit in the United States District Court for the District of South Carolina, seeking to enjoin both the enforcement proceeding and a new subpoena, raising constitutional claims including those under the Dormant Commerce Clause. The United States District Court for the District of South Carolina dismissed the lender’s complaint, holding that claims related to the enforcement proceeding were barred by issue preclusion or, alternatively, by Younger abstention. Claims challenging the second subpoena were dismissed as unripe due to lack of present injury. On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s dismissal of claims challenging the administrative enforcement proceeding under Younger abstention, finding it was a quasi-criminal civil enforcement proceeding and that state interests and procedures were sufficient. The court also affirmed dismissal of claims challenging the second subpoena on ripeness grounds, but vacated the judgment insofar as those claims were dismissed with prejudice, remanding with instructions to dismiss them without prejudice. View "TitleMax of South Carolina, Inc. v. Spicher" on Justia Law

Dieng v. Orkin, LLC

2026-08-05T10:30:38-08:00

After a workplace injury, an employee developed a disability that prevented him from performing his previous physically demanding job as a pest control technician. He repeatedly requested reassignment to a less demanding “light-duty” position, providing medical documentation and engaging with his employer about his limitations and desire to return to work. Despite these requests, the employer neither responded substantively nor engaged in discussions about available light-duty positions. Over sixteen months, the employee remained on unpaid leave and ultimately resigned after the employer filled several suitable positions without contacting him. The United States District Court for the District of Maryland granted summary judgment in favor of the employer on both claims brought under the Americans with Disabilities Act (ADA). The court found that the employee could not perform the essential functions of his original position with a reasonable accommodation and concluded that placing him on indefinite unpaid leave constituted a reasonable accommodation. It also determined that the unlawful termination claim failed because the employee had voluntarily resigned. The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. It held that genuine issues of material fact remained regarding whether the employer was obligated to reassign the employee to a light-duty position and whether it failed to provide a reasonable accommodation. The court clarified that the ADA requires consideration of whether an employee can perform the essential functions of the desired position, not just the original one, and that indefinite unpaid leave is not a reasonable accommodation when reassignment is possible. However, the court affirmed dismissal of the unlawful termination claim because the employee failed to exhaust administrative remedies on that claim. The Fourth Circuit vacated and remanded the summary judgment on the failure to accommodate claim, but affirmed summary judgment on the unlawful termination claim. View "Dieng v. Orkin, LLC" on Justia Law

Bayramov v. American Credit Acceptance

2026-08-05T10:30:38-08:00

The case concerns two individuals who owned a car loan business in Virginia. Their business, Total Auto Financing, LLC, borrowed significant sums from American Credit Acceptance, LLC, with the loans personally guaranteed by the owners. After a series of renewals and a final short-term extension with restrictive terms, Total Auto defaulted on its debt. Following the default, American Credit replaced Total Auto as the servicer of its loan portfolio with Peritus Portfolio Services II, LLC. The new servicer’s management coincided with a sharp decline in the value and performance of the loan portfolio. The business was eventually forced into bankruptcy, and its main asset was sold at auction for much less than its previous value, leaving the owners personally liable for a large deficiency due to their guarantees. After the bankruptcy filing, the owners, acting in their personal capacities, filed complaints against American Credit and the new servicer (and related parties), alleging a range of claims including breach of fiduciary duty, negligence, unjust enrichment, conspiracy, and others. The United States Bankruptcy Court for the Eastern District of Virginia dismissed both complaints, finding that the claims belonged to the LLC, not the individual owners. The United States District Court for the Eastern District of Virginia affirmed the dismissals. The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. It held that the principle determining who owns a claim—whether the business or its equity holders—means that owners cannot personally sue for injuries suffered by the business, even if they are financially harmed as a result. The court concluded that all claims asserted were either direct claims belonging to the LLC or failed to allege a personal injury distinct from the LLC’s injury. The Fourth Circuit affirmed the district court’s judgment, holding that the individual owners could not bring these claims in their own names. View "Bayramov v. American Credit Acceptance" on Justia Law

Mook v. Hall

2026-08-04T10:30:53-08:00

The plaintiff, a former Assistant Commonwealth’s Attorney for the City of Martinsville, Virginia, sought leave under the Family and Medical Leave Act (FMLA) in November 2021 to care for his mother. He submitted an FMLA certification form, personally completing the section meant for a medical provider and subsequently obtaining a nurse’s signature. After submitting the form to his employer, concerns arose regarding the authenticity of the certification, specifically whether the medical provider was aware of signing a FMLA-related document. The plaintiff was questioned by his supervisor about the circumstances and ultimately terminated after declining to resign. The United States District Court for the Western District of Virginia reviewed the plaintiff’s claim that his FMLA rights had been interfered with when his employer contacted his mother’s medical provider for authentication before giving him an opportunity to cure any alleged deficiency. The district court assumed qualified immunity was a defense to FMLA interference claims, but denied the defendant’s summary judgment motion, ruling that federal regulations clearly established the right to a cure period before such contact. The United States Court of Appeals for the Fourth Circuit reviewed the interlocutory appeal, focusing on whether it was clearly established in November 2021 that an employer was prohibited from contacting a certifying medical provider for authentication without first offering the employee an opportunity to cure any inauthenticity. The Fourth Circuit found that the relevant FMLA regulations were not sufficiently clear to place this right “beyond debate” and concluded that a reasonable official could interpret the regulations as not requiring a cure period for authenticity concerns. The Fourth Circuit vacated the district court’s judgment and remanded the case for further proceedings on whether qualified immunity is available as a defense to FMLA interference claims. View "Mook v. Hall" on Justia Law

Driggs v. CIA

2026-08-04T10:30:53-08:00

A group of plaintiffs submitted a request under the Freedom of Information Act (FOIA) to the Central Intelligence Agency (CIA), seeking documents related to American prisoners of war and government recovery efforts. Among other records, they sought access to a report jointly authored by the CIA and Department of Defense in response to a U.S. Senator’s criticism of a National Intelligence Estimate. The CIA responded by releasing some documents in full, some in part—including a redacted version of the requested report—and withholding others entirely. The plaintiffs challenged the CIA’s refusal to search its operational files and the adequacy of the agency’s redactions to the report. After receiving the FOIA request, the plaintiffs sued the CIA in the United States District Court for the Eastern District of Virginia. The district court treated the plaintiffs’ argument about the CIA’s obligation to search operational files as a motion to compel such a search and denied it, finding the plaintiffs had not met the statutory burden to show improper withholding or misplacement of documents. The court also determined that the CIA’s affidavits adequately justified the redactions under FOIA exemptions and granted summary judgment in favor of the CIA. On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the denial of the motion to compel and the grant of summary judgment de novo. The court held that the CIA was not required to search its operational files because the plaintiffs failed to provide sufficient evidence of improper withholding or misplacement of records. Additionally, the court held that the CIA’s affidavits provided adequate, specific justifications for the redactions under the national security and statutory exemptions to FOIA. The Fourth Circuit affirmed the district court’s judgment in full. View "Driggs v. CIA" on Justia Law

Keita v. Blanche

2026-08-04T10:30:52-08:00

A woman born in Guinea, who entered the United States on a student visa and later overstayed, faced removal proceedings initiated by the Department of Homeland Security. She is a single mother raising two U.S. citizen daughters. Her primary concern was that, if removed to Guinea, her daughters would face the risk of female genital mutilation, as she herself did as a child. She sought relief through two applications: one for asylum, withholding of removal, and protection under the Convention Against Torture, and another for cancellation of removal. Both applications focused on the potential harm to her daughters if they accompanied her to Guinea. An Immigration Judge (IJ) held a hearing and granted her withholding of removal to Guinea, meaning she could not be sent there as long as the threat persisted, but could potentially be removed to another country. The judge asked the parties to brief whether this grant of withholding made her ineligible for cancellation of removal, and never held the promised follow-up hearing. In a written decision, the IJ denied cancellation on factual grounds, finding no qualifying hardship to her daughters since removal to Guinea was off the table. The Board of Immigration Appeals (BIA) affirmed, reasoning that the only hardship identified was tied to Guinea, and that the woman had been given a sufficient opportunity to present her claim through briefing. The United States Court of Appeals for the Fourth Circuit reviewed the case, applying de novo review to legal questions and substantial evidence review to factual determinations. The court held that the BIA erred in finding the woman had a sufficient opportunity to present evidence and argument regarding hardship from removal to a third country. The court vacated the BIA’s order and remanded for further proceedings. The petition for review related to reconsideration was dismissed as moot. View "Keita v. Blanche" on Justia Law

Carter v. Cabell

2026-08-04T10:30:52-08:00

Benjamin Carter, a Virginia state prisoner housed in the Restrictive Housing Unit at Sussex State Prison, alleged that prison officials subjected him to unconstitutional conditions of confinement, particularly harmful due to his serious mental illnesses. He also claimed that after he submitted an informal complaint seeking reclassification and transfer out of restrictive housing, officials retaliated against him by denying his requests and making threatening statements. Carter attempted to address these issues through the Virginia Department of Corrections' grievance process, submitting informal complaints and regular grievances about both the conditions and the alleged retaliation. His grievances were rejected and appeals denied. Carter initially filed a federal complaint about his conditions of confinement before the administrative process was completed, then filed an amended complaint after exhausting the grievance process, raising both Eighth and First Amendment claims. The United States District Court for the Eastern District of Virginia screened Carter’s complaints and dismissed his Eighth Amendment claim against the VDOC Director for failure to state a claim, finding no plausible supervisory liability. The court then granted summary judgment to the remaining defendants, holding that Carter had not exhausted administrative remedies as required by the Prison Litigation Reform Act (PLRA) when he filed his original complaint, and concluded he could not cure this by exhausting before filing an amended complaint. The court also held, in the alternative, that Carter failed to state retaliation claims against two defendants. The United States Court of Appeals for the Fourth Circuit reviewed the case. It held that Carter properly exhausted his First Amendment retaliation claims because he completed the administrative process before filing the amended complaint in which those claims were first raised, and the PLRA does not bar claims first pleaded in an amended complaint after exhaustion. The court vacated the district court’s dismissal of Carter’s Eighth Amendment claims, remanding for the district court to determine whether administrative remedies were truly “available” to Carter. The court also vacated the district court’s dismissal of retaliation claims against two defendants, finding Carter’s complaint stated plausible claims. The judgment was vacated and remanded for further proceedings. View "Carter v. Cabell" on Justia Law

Spencer v. Glaser

2026-08-04T10:30:52-08:00

A man named Sylvester Demetrius Selby was shot and killed by Deputy Edward Glaser III of the Dare County Sheriff’s Office in North Carolina, after Selby, who was wounded and holding a knife and an apple, failed to comply with repeated commands to drop the knife. After initially exiting his home, Selby did not surrender but instead jumped down the porch steps toward the deputies while still holding the knife. Following the first shot, Selby dropped the knife and apple, flailed on the ground, and then attempted to stand up and flee, at which point he lunged in the direction of Deputy Glaser, who fired two additional shots, resulting in Selby’s death. Legacy Spencer, administrator of Selby’s estate, filed suit in the United States District Court for the Eastern District of North Carolina against Deputy Glaser (individually) and the Dare County Sheriff (officially), alleging violations of the Fourth Amendment (excessive force) and North Carolina state law (assault, battery, and wrongful death). The defendants moved to dismiss. The district court, referencing body camera footage that contradicted certain key factual allegations in the complaint, determined the use of force was objectively reasonable under the circumstances and dismissed all claims for failure to state a claim. It also found qualified immunity barred the federal claims and public official immunity barred the state claims against Deputy Glaser. The claims against the sheriff failed because they were premised on Glaser's reasonable actions. On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the dismissal de novo. The court held that it was proper to consider the body camera videos at the dismissal stage where they blatantly contradicted the complaint’s allegations. The court concluded that Deputy Glaser’s use of force was reasonable and did not violate the Fourth Amendment or state law, affirming the district court’s judgment and dismissing all claims. View "Spencer v. Glaser" on Justia Law

US v. Clay

2026-08-03T10:30:32-08:00

The defendant, formerly Chief of Police in Gauley Bridge, West Virginia, was convicted by a jury of multiple offenses related to the sex trafficking of a minor, C.H., aged seventeen at the time. He offered money to C.H.’s stepmother to facilitate sexual acts with C.H., which were carried out while he was in uniform and at locations chosen for their isolation. C.H. was coerced into participation by threats regarding her living situation and financial necessity. After C.H. turned eighteen, she reported the conduct to law enforcement, prompting an investigation and subsequent indictment. The United States District Court for the Southern District of West Virginia presided over the proceedings. During pretrial and trial stages, the defendant raised several issues, including alleged violations of the Speedy Trial Act, sufficiency of evidence regarding interstate nexus and coercion, and potential conflicts of interest involving his defense counsel’s interactions with witnesses. The district court denied motions seeking dismissal for speedy trial violations, found the evidentiary record sufficient, and allowed the defendant to waive any conflict after thorough inquiries and advisements. After conviction, the district court imposed a downward-variant sentence of 25 years’ imprisonment and ten years’ supervised release, overruling objections to sentencing enhancements. The United States Court of Appeals for the Fourth Circuit reviewed the appeal. The court held that: (1) the district court did not abuse its discretion in accepting the defendant’s waiver of potential conflict of interest with counsel; (2) no Speedy Trial Act violation occurred, as pretrial motions tolled the clock; (3) the evidence was sufficient to establish both interstate nexus and coercion under 18 U.S.C. § 1591; and (4) the district court did not clearly err in applying sentencing enhancements for use of a computer and undue influence. The Fourth Circuit affirmed both the conviction and sentence. View "US v. Clay" on Justia Law

Crosby v. Colleton County Sheriff's Office

2026-07-31T11:30:35-08:00

A man’s wife called 911 to request a welfare check after her husband threatened to harm himself. The dispatcher relayed to law enforcement that the man had made similar threats in the past, was not acting like himself, and was last known to be at a riverfront house. When the responding officer arrived, he found the man’s vehicle at the property but received no response to repeated knocks and announcements at multiple doors. The officer entered the house several times after announcing himself, ultimately discovering a suicide note and pill bottle. Upon further entry, the officer encountered the man in his bedroom. After a brief exchange in which the man repeatedly ordered the officer to leave, the man retrieved a rifle and advanced toward the officer, ignoring commands to stop. The officer fired, fatally wounding the man. The personal representative of the man’s estate filed suit in South Carolina state court against the responding officer, the county sheriff, and the sheriff’s office, alleging violations of the Fourth Amendment for unlawful entry and excessive force, as well as a claim for failure to train. The case was removed to the United States District Court for the District of South Carolina. The district court granted summary judgment to the defendants on all federal claims, holding that the officer’s entries and use of force were objectively reasonable and that he was entitled to qualified immunity. The court also found no basis for municipal liability and remanded the state-law claims to state court. On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The Fourth Circuit held that the officer’s warrantless entries were justified under the emergency aid exception, given the objectively reasonable belief that the man was at risk of serious harm. The court also concluded that the use of deadly force was objectively reasonable under the circumstances. Accordingly, all federal claims were properly dismissed. View "Crosby v. Colleton County Sheriff's Office" on Justia Law

Whateley v. Lackey

2026-07-31T11:30:35-08:00

Curtis Whateley, a Virginia resident, applied for a personalized license plate with the characters “FTP&ATF,” intending the message “Fuck the Police & Alcohol, Tobacco, and Firearms.” The Virginia Department of Motor Vehicles (DMV) initially issued the plate but subsequently recalled it after a complaint about its vulgarity and perceived encouragement of violence. Whateley appealed the DMV’s decision through its internal administrative process without success and then filed suit against the DMV Commissioner, arguing that the recall violated his First Amendment rights by restricting his political expression. The United States District Court for the Western District of Virginia granted the Commissioner’s motion to dismiss, finding that the personalized license plate was government speech, not subject to ordinary First Amendment protections. The district court relied primarily on the Supreme Court’s decision in Walker v. Texas Division, Sons of Confederate Veterans, Inc., which held that specialty license plate designs in Texas constituted government speech. The court acknowledged differences between Texas's specialty plates and Virginia's personalized character combinations but determined that Walker supported treating Virginia’s plates as government speech. On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s dismissal de novo. The Fourth Circuit concluded that the personalized character combinations on Virginia’s vanity plates constitute private speech rather than government speech. The court applied the factors outlined in Walker and subsequent Supreme Court cases, finding that the history, public perception, and extent of government control over the messages indicated private expression. Therefore, the Fourth Circuit vacated the district court’s dismissal and remanded the case for further proceedings, holding that Virginia’s regulation of personalized plate messages is subject to First Amendment scrutiny. View "Whateley v. Lackey" on Justia Law

Vapor Technology Association v. Wooten

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

Several vape industry businesses and a vape user challenged a North Carolina law that restricts the sale of vape products lacking approval from the Food and Drug Administration (FDA). North Carolina’s statute, enacted in 2024, requires manufacturers to certify annually to the North Carolina Department of Revenue that their vape products either have FDA approval, were on the market by August 8, 2016 with a timely FDA application, or are exempt due to superficial changes. Products not listed in the resulting state directory cannot be sold in North Carolina, and violations can result in fines, product seizure, or lawsuits for deceptive trade practices. Before reaching the United States Court of Appeals for the Fourth Circuit, the plaintiffs sued North Carolina officials in the United States District Court for the Eastern District of North Carolina, arguing that the state law was preempted by federal law and violated the Equal Protection Clause. They sought a preliminary injunction to block enforcement of the law, relying only on the preemption argument. The district court denied the motion, finding that the plaintiffs had standing due to the threat of economic harm but were unlikely to succeed on the merits because the federal Tobacco Control Act did not preempt North Carolina’s regulation of vape product sales. The United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The court held that the commercial plaintiffs had standing due to the risk of substantial economic harm from enforcement of the law. On the merits, the court concluded that North Carolina’s law was not preempted by the relevant federal statutes. The state law was found to regulate sales, an area expressly preserved for state regulation by the federal Tobacco Control Act’s savings clause, and did not amount to impermissible enforcement of the FDA’s exclusive authority under federal law. The denial of a preliminary injunction was therefore affirmed. View "Vapor Technology Association v. Wooten" on Justia Law

Harris Investment Holdings, LLC v. BFJ of USA, LLC

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

A Georgia limited liability company purchased property in Greensboro, North Carolina, next to a gas station and convenience store owned by the defendants. After environmental testing revealed hazardous chemicals in the soil and groundwater on the company’s property, the company installed a vapor barrier and sought to recover the associated costs from the gas station owner and its members under both CERCLA and North Carolina law. The evidence showed that both properties had a long history of commercial and automotive use, with various underground storage tanks having been installed, removed, or closed in place over several decades. Notably, a waste-oil tank installed in the 1950s was closed in 1996 after evidence of petroleum and other contaminants was found in the soil. The United States District Court for the Middle District of North Carolina granted summary judgment to the defendants on all claims. The court held that the plaintiff had not produced sufficient evidence that the contamination on its property was caused by releases from the defendants’ property, and that any released substances were covered by CERCLA’s petroleum exclusion. The court also excluded the plaintiff’s expert’s later declaration referencing chromium contamination, finding it was untimely new opinion testimony. On appeal, the United States Court of Appeals for the Fourth Circuit held that the district court erred in granting summary judgment. The Fourth Circuit clarified that the petroleum exclusion in CERCLA covers unadulterated petroleum and its fractions, but not petroleum contaminated with hazardous substances not normally found in such products. The appellate court found that evidence regarding the leaking waste-oil tank raised a factual question as to whether a contaminant outside the petroleum exclusion was released. The Fourth Circuit vacated the summary judgment and the exclusion of certain evidence, and remanded for further proceedings. View "Harris Investment Holdings, LLC v. BFJ of USA, LLC" on Justia Law

US v. Jaqu

2026-07-27T11:01:34-08:00

The defendant was convicted by a jury of multiple drug-trafficking and firearm offenses following a three-day trial, during which he was represented by court-appointed counsel. After the trial and before sentencing, the defendant filed a notice expressing his desire to remove his counsel and represent himself at sentencing. At a subsequent hearing, despite being advised against self-representation, the defendant maintained his wish to proceed pro se for sentencing. The sentencing hearing had not yet been scheduled at the time of his request. The United States District Court for the District of South Carolina denied the defendant’s request to represent himself at sentencing, finding it untimely because it was made several months after the jury verdict and after objections to the presentence report had been filed. The court relied on precedent that allows for denial of self-representation requests made after the commencement of trial and appointed new counsel to represent the defendant at sentencing. The defendant was ultimately sentenced with an enhancement under the Armed Career Criminal Act, and he appealed, arguing that his Sixth Amendment right to self-representation was violated. The United States Court of Appeals for the Fourth Circuit held that the district court erred in denying the defendant’s request to represent himself at sentencing on the basis of untimeliness. The appellate court clarified that a request to proceed pro se at sentencing, made after trial but before sentencing, is not untimely if sentencing has not yet been scheduled and the request does not disrupt proceedings. The court vacated the judgment and remanded the case for resentencing, instructing the district court to conduct a proper Faretta hearing to determine whether the waiver of counsel is knowing, intelligent, and voluntary. The court did not address arguments related to the Armed Career Criminal Act enhancement. View "US v. Jaqu" on Justia Law

US v. Melvin

2026-07-27T11:01:34-08:00

The defendant pleaded guilty to one count of being a felon in possession of a firearm. The Probation Office prepared a presentence report that identified four prior convictions as potential predicates for a sentencing enhancement under the Armed Career Criminal Act (ACCA), which imposes a mandatory minimum sentence if a defendant has at least three qualifying convictions. The defendant timely objected to three of the four proposed predicates. At sentencing, the district court sustained two of the defendant’s objections, leaving only two qualifying convictions. In response, the government, for the first time at the sentencing hearing, proposed a new predicate conviction that had not been raised earlier. Over defense counsel’s objection, the district court allowed a continuance for consideration of the new predicate, ultimately agreed with the government, and applied the ACCA enhancement, resulting in a 188-month sentence. The United States District Court for the Eastern District of North Carolina ruled in favor of the government’s late proposal for a new predicate offense, despite the defendant’s objections that the government had not complied with procedural rules. The defendant appealed the sentence. During the appeal, the government initially responded to the merits of the defendant’s claims rather than invoking an appeal waiver. Only after new briefing did the government attempt to assert the appeal waiver, but the appellate court found this procedural argument had been forfeited due to the government’s earlier actions. The United States Court of Appeals for the Fourth Circuit held that the district court erred by allowing the government to introduce a new ACCA predicate after the deadline for objections in Federal Rule of Criminal Procedure 32(f) without a showing of good cause. The court found the procedural error was not harmless because it resulted in a substantially longer sentence. The Fourth Circuit vacated the defendant’s sentence and remanded for resentencing without the ACCA enhancement. View "US v. Melvin" on Justia Law

Fuentes v. Citizenship and Immigration Services

2026-07-24T10:30:33-08:00

Two naturalized U.S. citizens, who previously obtained lawful status through the Special Immigrant Juvenile (SIJ) program after state courts found parental abuse, neglect, or abandonment, sought to confer immigration benefits to their noncitizen mothers. Both mothers’ applications were denied by United States Citizenship and Immigration Services (USCIS), invoking an exclusion clause in the SIJ statute, 8 U.S.C. § 1101(a)(27)(J)(iii)(II), and an implementing regulation prohibiting parents of SIJ recipients from receiving immigration benefits based on parentage. The plaintiffs challenged both USCIS’s interpretation of the exclusion clause and the constitutionality of the clause, arguing it violated equal protection. The United States District Court for the Eastern District of Virginia, reviewing cross-motions for summary judgment, ruled in favor of USCIS. The court held that the regulation was consistent with the plain text of the exclusion clause and rejected the equal protection claim, concluding that plaintiffs lacked a direct constitutional injury and, in the alternative, that the exclusion survived rational basis review. Plaintiffs appealed, maintaining their APA and equal protection challenges. The United States Court of Appeals for the Fourth Circuit reviewed the district court’s decision de novo. The Fourth Circuit held that the exclusion clause’s plain text establishes a permanent bar, preventing any parent of an SIJ recipient from receiving immigration benefits based solely on parentage, regardless of whether the parent was abusive or not. The court also held that USCIS’s regulation is consistent with the statute. On the equal protection claim, the Fourth Circuit found differential treatment but determined that the exclusion clause survives rational basis review, as it is rationally related to protecting children from harm. The judgment of the district court was affirmed. View "Fuentes v. Citizenship and Immigration Services" on Justia Law

Suri v. Trump

2026-07-23T12:30:21-08:00

An Indian national entered the United States on a J-1 exchange visa for a postdoctoral fellowship at Georgetown University. He and his wife, a U.S. citizen of Palestinian descent, lived in Virginia and publicly opposed the war in Gaza. Following their social media activity and associations, the Department of Homeland Security (DHS) detained him under a new program targeting foreign nationals thought to support designated terror groups based on online speech. After his arrest, he was quickly transferred between several detention facilities in Virginia, Louisiana, and Texas, often without notice to his family or counsel, and was held under allegedly punitive and harmful conditions. He filed a habeas petition in the United States District Court for the Eastern District of Virginia, which was where he lived, was first detained, and initially held. The government moved to dismiss, arguing that the court lacked habeas jurisdiction because he was no longer detained in Virginia. The district court denied the motion, finding it had jurisdiction under the “unknown custodian” exception and the exception articulated in Justice Kennedy’s concurrence in *Rumsfeld v. Padilla*, since the petitioner’s location and custodian were unknown due to government actions. The district court also declined to transfer venue and enjoined the government from removing the petitioner while his habeas case was pending, later ordering his release on bail. The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court’s orders. The Fourth Circuit held that the district court had habeas jurisdiction under both the unknown custodian exception and the exception for government conduct thwarting access to the courts. The court further held that no provision of the Immigration and Nationality Act, including 8 U.S.C. §§ 1252(g), 1252(b)(9), or 1252(a)(5), stripped the district court of jurisdiction over the habeas petition. The court also concluded that the district court did not abuse its discretion by denying transfer or by invoking the All Writs Act to preserve its jurisdiction. View "Suri v. Trump" on Justia Law

US v. Jones

2026-07-21T11:01:16-08:00

Federal authorities investigated a large gun trafficking operation spanning West Virginia and Pennsylvania, involving straw purchasers who bought firearms in West Virginia to resell them in Pennsylvania. Bisheem Jones was identified as a leader, directing participants, organizing purchases, compensating straw purchasers, and facilitating resale. The scheme involved at least nineteen people and more than one hundred thirty firearms, with many later recovered by law enforcement in Pennsylvania. A federal grand jury in the Southern District of West Virginia indicted Jones for conspiracy to travel interstate to deal firearms without a license, conspiracy to commit promotional money laundering, aiding and abetting interstate travel to deal firearms, and being a felon in possession of a firearm. After a five-day jury trial, Jones was convicted on all counts except the felon-in-possession charge. He moved for acquittal, arguing insufficient evidence for the promotional money laundering conspiracy, but the District Court denied the motion. At sentencing, several enhancements were applied under the Sentencing Guidelines, including for obliterated serial numbers, number of firearms, and gun trafficking. Jones was sentenced to twenty-five years imprisonment. The United States Court of Appeals for the Fourth Circuit reviewed Jones’s appeal. The court found insufficient evidence for the promotional money laundering conspiracy conviction, concluding the government had not shown an agreement between Jones and another participant to funnel illicit proceeds back into the gun trafficking business. The court vacated that conviction, ordered entry of acquittal on that count, and remanded for resentencing. The court affirmed the District Court’s application of sentencing enhancements relating to obliterated serial numbers, gun trafficking, and the number of firearms, finding no clear error. The remaining convictions for firearm-related conspiracies and aiding and abetting were affirmed. View "US v. Jones" on Justia Law

US v. Ellis

2026-07-20T10:31:40-08:00

The case involves Tamarcus Ellis, who was tried and convicted for conspiracy to traffic methamphetamine and actual drug trafficking in Greensboro, North Carolina. During his four-day trial in federal court, a government witness, Malcolm Russell, appeared intimidated while testifying. The U.S. Marshals Service reported that individuals in the gallery were making audible noises and gestures perceived as signaling disagreement with Russell’s testimony. Based on this, the district court partially closed the courtroom for approximately one hour during Russell’s testimony, excluding most members of the public but allowing Ellis’ family and defense counsel’s family to remain. After Ellis was convicted and sentenced to 480 months’ imprisonment by the United States District Court for the Eastern District of North Carolina, he appealed. Ellis argued that the partial closure violated his Sixth Amendment right to a public trial, asserting this was structural error requiring automatic reversal and a new trial. The United States Court of Appeals for the Fourth Circuit reviewed the appeal. The court acknowledged that the closure was not trivial and implicated the Sixth Amendment’s Public Trial Clause. It applied the modified Waller test for partial courtroom closures, which requires a “substantial reason” for the closure, that the closure be no broader than necessary, consideration of reasonable alternatives, and adequate findings by the trial court. The Fourth Circuit found that the district court had a substantial reason to partially close the courtroom to prevent witness intimidation, tailored the closure appropriately, considered alternatives, and made sufficient findings on the record. Therefore, the Fourth Circuit held that the partial closure did not violate Ellis’ Sixth Amendment right to a public trial and affirmed the district court’s judgment. View "US v. Ellis" on Justia Law

Covington Specialty Insurance Company v. Omega Restaurant & Bar, LLC

2026-07-20T10:31:39-08:00

Omega Restaurant & Bar, LLC operated a nightclub in Virginia Beach and used images of professional models in its online advertising without their consent. The models sued Omega in Virginia state court, alleging misappropriation of their likenesses and damage to their professional reputations. After the models amended their complaint, Omega removed the lawsuit to federal court and sought defense and indemnification from its commercial insurer, Covington Specialty Insurance Company, pursuant to its policy. Covington initially agreed to defend Omega under a reservation of rights, but then filed a lawsuit in federal court seeking a declaration that it had no duty to defend or indemnify Omega for the models’ claims. The United States District Court for the Eastern District of Virginia heard Covington’s declaratory relief action. In March 2022, Omega and the models settled the underlying lawsuit, entering a consent judgment, which included dismissal of the models’ claims with prejudice and assignment of Omega’s rights under the insurance policy to the models. The district court, apparently unaware of this settlement, proceeded to grant summary judgment in favor of Covington in March 2023, holding that the insurance policy did not cover the models’ claims and Covington owed no duty to defend or indemnify Omega. Omega’s subsequent motion to alter or amend the judgment was denied, and Omega appealed. The United States Court of Appeals for the Fourth Circuit reviewed the case. On appeal, Covington argued for the first time that the declaratory relief action was moot due to the settlement and consent judgment in the underlying lawsuit. Because the mootness issue had not been addressed by the district court, the Fourth Circuit remanded the case to the district court to determine whether a live case or controversy remains under Article III. The Fourth Circuit did not reach the merits of Omega’s appeal. View "Covington Specialty Insurance Company v. Omega Restaurant & Bar, LLC" on Justia Law

In re: The Boeing Company

2026-07-20T10:31:39-08:00

A group of shareholders alleged that a major aerospace manufacturer and several of its former executives made repeated misrepresentations regarding the company’s commitment to safety following two fatal airplane crashes involving one of its aircraft models. The shareholders claimed that these false and misleading statements artificially inflated or maintained the company’s stock price. When a subsequent in-flight safety incident and other disclosures revealed ongoing safety and quality issues, the company’s stock price declined, causing significant losses for the shareholders. The lead plaintiffs, representing a proposed class, sought to recover these losses through a class action lawsuit. The United States District Court for the Eastern District of Virginia oversaw the initial proceedings. It denied the defendants’ motion to dismiss, finding the allegations sufficiently detailed, and subsequently certified a class. The district court concluded that the plaintiffs’ proposed damages methodology, which was based on an “out-of-pocket” measure, satisfied the requirements established by Rule 23 of the Federal Rules of Civil Procedure and the Supreme Court’s decision in Comcast Corp. v. Behrend. The court found that this methodology fit the plaintiffs’ theory of liability and that class-wide issues predominated over individual questions. On appeal, the United States Court of Appeals for the Fourth Circuit reviewed whether class certification was proper. The Fourth Circuit found that the plaintiffs did not provide a sufficiently specific damages methodology at the class certification stage, as required by Comcast. The court held that simply describing a general measure of damages was inadequate, and that the plaintiffs needed to commit to a particular methodology and demonstrate its consistency with their liability theory. Because the district court did not conduct the rigorous analysis required and relied on inadequate proof, the Fourth Circuit reversed the class certification order and remanded the case for further proceedings. View "In re: The Boeing Company" on Justia Law

Near v. Enerco Group, Inc.

2026-07-17T11:00:41-08:00

A man died from burn injuries after his clothing ignited while he was working near a portable propane tank top heater manufactured by Enerco Group, Inc. The decedent’s estate, represented by Jesse Near, filed a wrongful death suit alleging that the heater was defectively designed because it lacked an adequate guard or feasible alternative design to prevent clothing ignition when someone came close to the heater. The plaintiff did not assert a separate failure-to-warn claim. However, the sufficiency of the product warnings was central to the dispute, as Enerco maintained that adequate warnings rendered the product nondefective under South Carolina law. The United States District Court for the District of South Carolina addressed three key issues: it denied the plaintiff’s motion to certify to the Supreme Court of South Carolina the question of whether adequate warnings preclude a design defect claim; it excluded the plaintiff’s expert witness on the adequacy of warnings, finding her methodology unreliable; and, after treating the warnings as adequate as a matter of law (because there was no admissible evidence to the contrary), it granted summary judgment to Enerco, holding that under South Carolina law, adequate warnings preclude a design defect claim. The district court relied on the Fourth Circuit’s prior decision in Hickerson v. Yamaha Motor Corp., which interpreted South Carolina law to that effect. On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the exclusion of the plaintiff’s expert witness, holding that the district court did not abuse its discretion in finding the expert’s opinions unreliable. However, the Fourth Circuit found that South Carolina law was unsettled on whether adequate warnings categorically preclude a design defect claim, especially in light of subsequent developments in South Carolina case law. Accordingly, the Fourth Circuit certified this specific legal question to the Supreme Court of South Carolina and deferred ruling on the summary judgment issue until the Supreme Court responds. View "Near v. Enerco Group, Inc." on Justia Law

Wood v. Straughn

2026-07-17T11:00:41-08:00

A West Virginia defendant was indicted in 2018 on multiple sexual offense charges involving a seven-year-old girl. Prior to trial, the court granted the defendant’s motions to exclude a video interview of the victim and records from her therapy sessions, limiting both the State and the defense from introducing certain hearsay evidence. During opening statements at the first trial, defense counsel referenced specific statements made by the victim in the excluded materials, suggesting an alternative perpetrator. The State objected after the opening statements, arguing that the defense had violated pretrial evidentiary rulings. The trial court found that the defense’s actions had gone “far afield” of its orders and, over the defendant’s objection, granted the State’s motion for a mistrial. The defendant moved to dismiss the indictment on double jeopardy grounds, arguing that the mistrial was not required by “manifest necessity.” The trial court denied the motion, finding that the defense had created the necessity for a mistrial. The Supreme Court of Appeals of West Virginia later affirmed, holding that the defendant’s right against double jeopardy was not violated because defense counsel’s conduct in opening statement created a manifest necessity for the mistrial. The defendant subsequently filed a federal habeas petition in the United States District Court for the Northern District of West Virginia, which granted relief, concluding that the defense had not violated any pretrial orders and that manifest necessity was lacking. On appeal, the United States Court of Appeals for the Fourth Circuit reversed the district court’s judgment. The Fourth Circuit held that, under the highly deferential standard of review required by AEDPA, the state court’s conclusion that manifest necessity justified the mistrial was neither contrary to nor an unreasonable application of clearly established Supreme Court precedent. The case was remanded with instructions to deny the habeas petition. View "Wood v. Straughn" on Justia Law

Cisneros v. Blanche

2026-07-17T11:00:40-08:00

A Salvadoran national first entered the United States without inspection in 1985 and later received Temporary Protected Status (TPS). When TPS for El Salvador ended in 1992, the individual became a beneficiary of Deferred Enforced Departure (DED), a form of discretionary executive relief that defers removal but is not rooted in statute. In 1994, with DED-based travel authorization, the individual left and reentered the country; upon return, a passport was stamped “Admitted,” with a notation referencing DED. After several similar trips and ultimately adjusting to lawful permanent resident status in 2006, the individual was later convicted of offenses that rendered her removable. Removal proceedings began in 2016 in Arlington, Virginia. At a hearing before an Immigration Judge, the individual conceded removability but sought cancellation of removal under 8 U.S.C. § 1229b(a), which requires seven years of continuous residence after being “admitted in any status.” The Immigration Judge found that entry under DED in 1994 did not qualify as admission “in any status,” concluding that DED is not an immigration status under the statute. The Board of Immigration Appeals affirmed this decision. On review, the United States Court of Appeals for the Fourth Circuit considered whether entry under DED constituted admission “in any status” for purposes of cancellation of removal under § 1229b(a). The court held that “status” under the Immigration and Nationality Act means membership in a class defined by statute, and that DED, as an exercise of executive forbearance, is not a statutory status. Thus, the court concluded that the individual was not “admitted in any status” upon her return under DED, making her ineligible for cancellation of removal. The Fourth Circuit denied the petition for review. View "Cisneros v. Blanche" on Justia Law

Flores-Turcios v. Blanche

2026-07-16T10:30:26-08:00

The petitioner, a native and citizen of Guatemala, entered the United States without inspection in 2016 and was detained. He conceded removability but applied for asylum, withholding of removal, and protection under the Convention Against Torture (CAT), seeking voluntary departure in the alternative. He asserted that he feared persecution due to his membership in two social groups: Guatemalan adolescents and/or youths, and Guatemalan adolescents and/or youths who resist gang recruitment based on personal belief. He testified that MS-13 gang members assaulted and threatened him, demanding recurring payments, and attempted to recruit him when he could not pay. He claimed he did not report these incidents to the police because he believed they were corrupt or powerless. An Immigration Judge credited his testimony but found that the proposed social groups were not legally cognizable and that his membership in those groups was not a central reason for his targeting. The judge also determined there was no past torture, insufficient likelihood of torture upon return, and no official acquiescence, denying all requested relief but remanding for voluntary departure. The Board of Immigration Appeals adopted the Immigration Judge’s decision and wrote separately, finding the gang targeted the petitioner for economic reasons, not due to his membership in the proposed social groups, and found no clear error in denying CAT protection. The United States Court of Appeals for the Fourth Circuit reviewed the Board’s and Immigration Judge’s decisions, applying substantial evidence review to factual findings and de novo review to legal conclusions. The court held that substantial evidence supported the Board’s finding that the gang’s motive was economic and not based on the petitioner’s youth or resistance to recruitment. The court also found no evidence compelling a contrary conclusion regarding CAT protection. The petition for review was denied. View "Flores-Turcios v. Blanche" on Justia Law

Golden Corral Corp. v. Illinois Union Insurance Co.

2026-07-15T10:30:39-08:00

Golden Corral, a buffet restaurant chain, held a commercial property insurance policy issued by Illinois Union Insurance Company, covering losses from physical damage to its property. When state and local governments, including North Carolina, mandated closure of indoor dining facilities in response to the COVID-19 pandemic, Golden Corral suspended its restaurant operations, resulting in significant lost revenue and reduced income from franchisees. Golden Corral submitted a claim to Illinois Union for coverage of these losses, which Illinois Union denied. After the denial, Golden Corral filed suit in North Carolina state court, seeking a declaration that its pandemic-related losses were covered under the policy. The case was removed to the United States District Court for the Eastern District of North Carolina, where Golden Corral amended its complaint to add claims for breach of contract and breach of the implied covenant of good faith and fair dealing. Illinois Union moved for judgment on the pleadings, arguing that COVID-19 did not cause physical loss or damage as required for coverage. The district court granted the motion and dismissed the case with prejudice, a decision affirmed by the United States Court of Appeals for the Fourth Circuit. Over three years later, Golden Corral sought relief from final judgment under Federal Rule of Civil Procedure 60(b)(6), citing a subsequent North Carolina Supreme Court decision in North State Deli v. Cincinnati Insurance Co. that found similar losses covered. The United States Court of Appeals for the Fourth Circuit reviewed the district court’s denial of the Rule 60(b)(6) motion for abuse of discretion. The court held that a change in state decisional law alone does not constitute "extraordinary circumstances" warranting relief under Rule 60(b)(6), especially when the later case involved different parties, policies, and injuries. The Fourth Circuit affirmed the district court’s decision to deny relief. View "Golden Corral Corp. v. Illinois Union Insurance Co." on Justia Law

Burey v. Blanche

2026-07-14T11:00:38-08:00

A Jamaican citizen who entered the United States on a work visa married a U.S. citizen and later experienced domestic violence from his spouse, who was eventually arrested. After his visa expired, removal proceedings were initiated, and an immigration judge ordered his removal. Under the Violence Against Women Act (VAWA), survivors of domestic violence have a one-year deadline to file a motion to reopen removal proceedings. On the last day of this period, the petitioner’s counsel attempted to file the motion electronically, but the system rejected it. When he tried to file in person, a court clerk refused to accept the paper copy, insisting it be filed electronically. After continued unsuccessful attempts, the motion was finally mailed and accepted, but after the deadline. The Immigration Judge denied the motion to reopen, finding it untimely and concluding that the petitioner did not provide sufficient proof he was prevented from timely filing. The Board of Immigration Appeals (BIA) affirmed, with the majority agreeing that the record did not support the claim of impeded filing and that no exception to the deadline applied. One BIA member dissented, noting clear evidence of repeated filing attempts thwarted by the court. The United States Court of Appeals for the Fourth Circuit reviewed both the Immigration Judge and BIA decisions. Applying de novo review to legal and constitutional questions and substantial evidence review to factual findings, the Fourth Circuit held that the record compelled the conclusion that the petitioner was prevented from timely filing. The court found this defect rendered the proceedings fundamentally unfair and prejudiced the petitioner’s case, thus violating his Fifth Amendment due process rights. The court granted the petition for review, reversed the BIA’s denial, and remanded for further proceedings. View "Burey v. Blanche" on Justia Law

US v. Snyder

2026-07-14T11:00:38-08:00

Stephen Snyder, a veteran Maryland attorney, was charged with attempted extortion and Travel Act violations after threatening to launch a damaging media campaign against a hospital unless it paid him $25 million in a personal consultancy deal. Snyder had represented patients in medical malpractice cases against the hospital and, during negotiations, repeatedly demanded the payment, suggesting it would "bury" incriminating findings about the hospital’s transplant program. Despite declining health and cognitive concerns, Snyder insisted on representing himself at trial, supported by standby counsel. The United States District Court for the District of Maryland held two Faretta hearings, where Snyder’s competency and voluntary waiver of counsel were confirmed. Throughout pretrial and trial, Snyder’s health issues became evident, and the court repeatedly advised against self-representation, but Snyder persisted. During the nine-day trial, the court addressed issues including limiting testimony from a witness bound by a nondisclosure agreement, denying Snyder’s request for a reliance-on-counsel jury instruction, and refusing to voir dire the jury after Snyder’s contempt arrest. The jury convicted Snyder on all counts. The United States Court of Appeals for the Fourth Circuit reviewed the district court’s rulings. It held that Snyder’s concession of competence to stand trial precluded his argument for reversal based on self-representation, reaffirming that a defendant competent to stand trial is competent to waive counsel. The court found no abuse of discretion in the denial of the reliance-on-counsel instruction, the limitation of testimony due to the nondisclosure agreement, or the refusal to voir dire the jury regarding publicity about Snyder’s contempt. The Fourth Circuit affirmed the district court’s judgment in full. View "US v. Snyder" on Justia Law

Lusk v. Merchant

2026-07-14T11:00:37-08:00

The plaintiff, a resident of Salem, South Carolina, frequently visited her local post office. During one visit, after experiencing poor service, she was confronted and physically attacked by a postal employee, resulting in significant injuries. The Postmaster, rather than assisting her or calling for help, allegedly exacerbated the situation by physically handling her and preventing her from seeking help. The plaintiff claimed the employee had a history of aggressive behavior known to postal management. The plaintiff initially filed suit in South Carolina state court against the individual employees and the United States. The case was removed to the United States District Court for the District of South Carolina, which, after the government substituted itself for the individual defendants under the Westfall Act and moved to dismiss, dismissed all claims. The district court determined the Federal Tort Claims Act (FTCA) did not waive sovereign immunity for most claims, including those arising from assault and battery, and that the claims for negligent hiring, supervision, and retention were barred by the discretionary function exception. The court also dismissed the Bivens constitutional claims and the FOIA claim for failure to exhaust administrative remedies. On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s dismissal of most claims, holding that the FTCA’s intentional tort exception precludes claims against the government for injuries arising from assault and battery by a postal employee, even if pleaded as negligence. However, the Fourth Circuit reversed and remanded as to a narrow aspect of the negligence claim against the Postmaster, holding that under the Supreme Court’s decision in Sheridan v. United States, a claim may proceed if the government employee negligently created the risk of harm, independent of the tortfeasor’s employment status. The Fourth Circuit otherwise affirmed the district court’s judgment. View "Lusk v. Merchant" on Justia Law

van Faassen v. Lindberg

2026-07-14T11:00:37-08:00

A Dutch life insurance company, through its trustees, sought to enforce an arbitral award against its former owners after they failed to maintain the company’s required solvency capital ratio, as agreed. When the capital ratio fell below the stipulated threshold, the company initiated urgent arbitration proceedings in the Netherlands, resulting in an award ordering the owners to restore the ratio and imposing a substantial penalty for noncompliance. Despite confirmations of the award by Dutch courts—including the Court of Rotterdam, the Court of Appeal of the Hague, and the Supreme Court of the Netherlands—the owners did not comply, leading to the company's liquidation. The trustees filed a petition in the United States District Court for the Middle District of North Carolina, seeking to confirm the arbitration award under the Federal Arbitration Act (FAA) and the New York Convention, as well as to recognize the Dutch court’s judgment under the North Carolina Uniform Foreign-Country Money Judgments Recognition Act. The district court found the arbitration award enforceable, holding the FAA’s three-year statute of limitations was “permissive,” not “mandatory,” and also concluded the Dutch judgment was recognizable as a foreign-country judgment under North Carolina law. The court entered judgment, confirming the award under federal law and did not rule on the alternative state-law claim. On appeal, the United States Court of Appeals for the Fourth Circuit held that the three-year statute of limitations in 9 U.S.C. § 207 is mandatory, not permissive, and reversed the district court’s order confirming the foreign arbitral award under the FAA due to untimeliness. However, the appellate court agreed that the Dutch court judgment qualifies for recognition under the North Carolina Act and remanded the case for further proceedings on the petitioners’ motion to enforce that judgment under state law. View "van Faassen v. Lindberg" on Justia Law

US v. Ball

2026-07-14T11:00:37-08:00

Kirsten Ball, a licensed physician, was indicted in April 2023 for conspiracy to distribute oxycodone and twenty counts of distribution of oxycodone, based on her practice of prescribing unusually large quantities of the drug from her home office between 2005 and 2022. The government presented evidence that her prescribing practices deviated from accepted medical standards, which Ball did not dispute. Her appeal focused on whether the jury instructions at trial properly conveyed the correct mens rea standard required for conviction under 21 U.S.C. § 841(a)(1), particularly in light of the Supreme Court’s decision in Ruan v. United States. The United States District Court for the Eastern District of Virginia conducted a five-day jury trial, after which Ball was convicted of conspiracy and all but one distribution count. The parties had jointly proposed jury instructions that required proof Ball knew she was acting outside the “course of her professional practice.” The district court revised these instructions, removing the possessive pronoun “her” to avoid confusion about idiosyncratic medical practice. Ball’s counsel objected to the change, arguing it was inconsistent with the Ruan decision, which clarified the subjective mental state required for conviction. Reviewing the case, the United States Court of Appeals for the Fourth Circuit applied a de novo standard to the jury instructions. The court held that the instructions, read as a whole, accurately reflected the law: the government must prove both that Ball’s prescriptions were objectively unauthorized under professional standards and that she subjectively knew or intended her conduct to be unauthorized. The court determined that the charge sufficiently required the jury to find this subjective knowledge, distinguishing the instructions from those found insufficient in prior Fourth Circuit cases. Accordingly, the Fourth Circuit affirmed Ball’s convictions. View "US v. Ball" on Justia Law

US v. Cardozo

2026-07-13T10:30:28-08:00

A traveler arriving in the United States from Bolivia was subject to inspection by U.S. Customs and Border Protection at Washington Dulles International Airport. The officer requested that the traveler unlock his two iPhones, which he did. Within approximately two minutes, the officer accessed the photo galleries, including hidden folders, and discovered sexually explicit images of prepubescent girls. The traveler was subsequently arrested and indicted by a federal grand jury in the United States District Court for the Eastern District of Virginia on multiple counts relating to child pornography. The defendant moved to suppress the evidence obtained from the search of his phones, arguing that the search violated the Fourth Amendment. The district court held an evidentiary hearing, during which the officer explained her suspicions. The court denied the motion to suppress, finding that either individualized suspicion was present or, alternatively, that the officer acted in good faith. The defendant entered a conditional guilty plea to all counts, preserving his right to appeal the suppression ruling. He was sentenced to 18 years in prison and 25 years of supervised release. On appeal, the United States Court of Appeals for the Fourth Circuit reviewed whether manual searches of cell phones at the border are “routine” and thus exempt from the requirement of individualized suspicion under the Fourth Amendment. The Fourth Circuit held that manual searches of cell phones at the border are routine border searches and do not require individualized suspicion, distinguishing such searches from forensic searches, which are nonroutine and require some level of individualized suspicion. The court affirmed the district court’s denial of the motion to suppress. View "US v. Cardozo" on Justia Law

Lee v. West Virginia University Medical Corp.

2026-07-10T10:30:54-08:00

Dr. Mark Lee, age 59 at hiring, was appointed Chair of the Department of Neurosurgery at West Virginia University’s School of Medicine and also employed as a pediatric neurosurgeon by University Health Associates. By spring 2020, senior administrators raised concerns about Lee’s performance, including absenteeism and lack of engagement. In March 2021, Lee was offered a new position requiring him to step down as Chair, which he ultimately declined. Discussions about his removal continued, during which Lee was allegedly told the university sought a younger Chair. After Lee’s attorney raised age discrimination concerns in July and August 2021, Lee was informed he would be removed as Chair effective September 1, 2021, rather than the previously discussed later date. Lee subsequently resigned in January 2022 and pursued claims for age discrimination, retaliation, and breach of contract. The United States District Court for the Northern District of West Virginia dismissed claims against WVU defendants on sovereign immunity grounds and granted summary judgment to University Health Associates on all remaining claims. The district court found Lee’s age discrimination claim lacked direct and circumstantial evidence, noting Lee’s replacement and the decisionmaker were of similar age. Lee’s retaliation claims failed because the removal process began before his complaints, and the decision to accelerate his removal was attributed to his conduct at a July meeting rather than his protected activity. The breach-of-contract claims were rejected based on the employment agreement’s terms and integration clause. The United States Court of Appeals for the Fourth Circuit reviewed the district court’s summary judgment de novo. The Fourth Circuit affirmed summary judgment for University Health Associates on Lee’s age discrimination, retaliation (removal and constructive discharge), and breach-of-contract claims. However, it vacated the judgment on Lee’s claim that the acceleration of his removal constituted unlawful retaliation, finding genuine disputes of material fact precluded summary judgment. The case was remanded for further proceedings on that claim. View "Lee v. West Virginia University Medical Corp." on Justia Law

Dmarcian, Inc. v. DMARC Advisor BV

2026-07-10T10:30:53-08:00

An American software company based in North Carolina and a Dutch company entered into a business relationship that later soured. The American company alleged that the Dutch company stole its brand name, software code, and customer base. The Dutch company operated a website nearly identical to the American company’s, using its name, logo, and marketing materials, and targeted American customers, even convincing at least one U.S. company to switch providers. Disputes between the parties also led to reciprocal lawsuits in both the United States and the Netherlands, with overlapping subject matter. The United States District Court for the Western District of North Carolina initially issued a preliminary injunction against the Dutch company, finding the American company was likely to succeed on its copyright, trademark, trade secret, and tortious interference claims. After the Supreme Court’s decision in Abitron Austria GmbH v. Hetronic International, Inc. altered the standard for the extraterritorial application of the Lanham Act, the district court modified its injunction to comply with the new “conduct-focused” approach and dismissed the copyright claim. The district court also ordered the Dutch company to correct statements made to the Dutch court and later held the company in civil contempt for failing to comply fully, imposing a monetary sanction. The United States Court of Appeals for the Fourth Circuit reviewed the case. Applying the Supreme Court’s new guidance from Abitron, the Fourth Circuit affirmed the second amended preliminary injunction, holding that the Dutch company’s conduct constituted infringing use in U.S. commerce under the Lanham Act, and that the Defend Trade Secrets Act’s express extraterritorial provision was satisfied by acts in furtherance of misappropriation occurring in the United States. The court dismissed the appeals from the correction and contempt orders for lack of appellate jurisdiction. View "Dmarcian, Inc. v. DMARC Advisor BV" on Justia Law

United States v. Wable

2026-07-10T10:30:53-08:00

While serving a term of supervised release for prior, unrelated convictions, an individual was found by probation officers to have acquired several weapons, including a loaded assault-style rifle. During subsequent proceedings, the individual attempted to persuade a young man to falsely claim ownership of the rifle at a revocation hearing, offering payment and making threats against the young man’s mother. The young man later recanted and disclosed the threats and payment. As a result, a jury convicted the individual of unlawful possession of a firearm and of witness tampering. The United States District Court for the Northern District of West Virginia received a presentence investigation report that set the base offense level at twenty-six under the Sentencing Guidelines, citing the type of firearm and the defendant’s two prior controlled substance felony convictions—one federal and one under West Virginia law. The defendant objected pro se to considering the state conviction as a qualifying offense, and also argued for a downward departure based on alleged mistreatment while in pretrial detention. At sentencing, the district court adopted the presentence report in full, imposed enhancements for obstruction, and, after weighing the 18 U.S.C. § 3553(a) factors and considering arguments from both sides, denied a downward departure. The court imposed concurrent sentences of 120 months for the firearm offense and 180 months for witness tampering, citing the seriousness of the conduct and the defendant’s lengthy, violent criminal history. The United States Court of Appeals for the Fourth Circuit reviewed the sentence. It held that the district court did not plainly err in treating the West Virginia conviction as a qualifying controlled substance offense for Guidelines purposes and that the district court did not abuse its discretion in addressing the defendant’s sentencing arguments. The Fourth Circuit affirmed the sentence. View "United States v. Wable" on Justia Law

Dmarcian, Inc. v. Millen

2026-07-10T10:30:53-08:00

A North Carolina software company initiated a lawsuit in the United States District Court for the Western District of North Carolina against its former business partner, a Dutch entity, after their business relationship dissolved. The plaintiff alleged copyright and trademark infringement, misappropriation of trade secrets, and various state law violations. Shortly after the complaint, the plaintiff obtained a preliminary injunction limiting the defendant’s business activities. Meanwhile, the defendant commenced related litigation in the Netherlands. During those Dutch proceedings, the defendant’s American attorney, Pressly Millen, submitted an affidavit that the plaintiff claimed misrepresented the scope and timing of the U.S. litigation. The Dutch court initially denied the plaintiff’s request to stay the Dutch proceedings, partly relying on representations from the defendant’s counsel. The plaintiff returned to the North Carolina court, seeking an order requiring the defendant to correct these alleged misrepresentations in the Dutch court. The district court ordered the defendant to submit both its order and a corrective statement to the Dutch court. The defendant submitted the order but did not file the separate corrective statement. Later, the Dutch court stayed its proceedings. The plaintiff then moved for contempt sanctions in the North Carolina court against the defendant and its attorneys for failing to comply fully with the correction order. Following a show cause hearing, the district court held the defendant and Millen in civil contempt, sanctioning Millen by suspending his ability to practice in the district, though not holding him jointly liable for monetary sanctions. On appeal, the United States Court of Appeals for the Fourth Circuit found that it had jurisdiction to review the contempt order against Millen, a nonparty. The appellate court held that the district court abused its discretion by imposing civil contempt sanctions on Millen without clear and convincing evidence that the plaintiff was harmed by Millen’s failure to submit the separate statement. The court vacated the civil contempt adjudication and sanction against Millen. View "Dmarcian, Inc. v. Millen" on Justia Law

Ramos v. Blanche

2026-07-09T11:00:38-08:00

A Honduran citizen, who was a lawful permanent resident in the United States, was convicted in Virginia of embezzling over $46,000 in scrap metal from his employer. After serving his sentence, the Department of Homeland Security detained him and charged him as removable, alleging that his conviction was for an aggravated felony involving fraud or deceit under federal immigration law. His wife and daughter, also lawful residents, sought to help him avoid removal by filing a family visa petition, but the immigration process was delayed. An immigration judge denied further continuances for the visa process and concluded that the embezzlement conviction involved fraud or deceit, ordering removal to Honduras. The Board of Immigration Appeals affirmed both the denial of the continuance and the finding that the conviction was for an aggravated felony. Although the government mistakenly deported the petitioner during his appeal, they brought him back and assured the court of procedural safeguards. The Board's decision resulted in the petitioner’s removal, and he sought review by the United States Court of Appeals for the Fourth Circuit. The United States Court of Appeals for the Fourth Circuit reviewed the case de novo, applying the categorical approach to determine whether Virginia’s embezzlement statute necessarily involves fraud or deceit. The court concluded that the statute does not categorically require fraudulent or deceitful conduct, as its elements criminalize wrongful taking but do not always require misrepresentation, trickery, or intentional concealment. Therefore, the conviction did not qualify as an aggravated felony under the charged theory. The Fourth Circuit granted the petition, vacated the final order of removal, and remanded the case for further proceedings. View "Ramos v. Blanche" on Justia Law

US v. Gil

2026-07-09T11:00:38-08:00

A noncitizen, originally from El Salvador, unlawfully entered the United States in 2003. In 2018, he was convicted of serious crimes, after which he was placed in removal proceedings while still incarcerated. During those proceedings, he conceded removability but sought deferral of removal under the Convention Against Torture, fearing for his life if returned to El Salvador. The immigration judge denied his application, finding his testimony not credible and ordering his removal. He was informed of his right to appeal by a set deadline. The noncitizen informed his attorney he wished to appeal, but due to delays in receiving and returning a fee waiver form, the notice of appeal was filed after the deadline. The Board of Immigration Appeals dismissed the appeal as untimely, and the noncitizen was removed. After unlawfully reentering the United States and being convicted of new state felonies, he was indicted for illegal reentry under federal law. He moved to dismiss the indictment, arguing that his prior removal order was invalid due to ineffective assistance of counsel, as his attorney failed to timely file the notice of appeal. The United States District Court for the Eastern District of Virginia denied the motion, holding that he had not exhausted available administrative remedies, specifically by failing to properly present his ineffective-assistance claim to the Board in accordance with procedural requirements set forth in Matter of Lozada. On appeal, the United States Court of Appeals for the Fourth Circuit affirmed. The court held that, under 8 U.S.C. § 1326(d), a noncitizen must exhaust administrative remedies before collaterally attacking a removal order. It found that the appellant did not substantially comply with Lozada’s requirements for raising an ineffective-assistance claim before the Board, and thus failed to exhaust his remedies. Accordingly, the denial of the motion to dismiss was affirmed. View "US v. Gil" on Justia Law

US v. Giannone

2026-07-09T11:00:38-08:00

Federal agents investigated an online community involved in trafficking personal information, focusing on an individual who, after arrest, became a confidential informant. The informant communicated with a user known as Pit Boss 2600 (also CIA INTEL), who offered to sell debit card information. Undercover agents deposited money into Pit Boss 2600’s bank account, which was later withdrawn by Jonathan Giannone, the account holder. The government matched statements made by Pit Boss 2600 in online chats to Giannone’s travel records to establish his identity as the perpetrator. Giannone was indicted and, after a jury trial, convicted of three counts of wire fraud and two counts of aggravated identity theft. Following his conviction in the United States District Court for the District of South Carolina, Giannone filed a series of FOIA requests and later pursued a writ of coram nobis, asserting that the government had withheld exculpatory evidence that would have materially affected his trial. The district court denied the petition, finding it untimely because Giannone delayed over eight years after receiving the relevant documents before seeking relief, and also finding no error of a fundamental character justifying the writ. On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s decision. The Fourth Circuit affirmed, holding that Giannone failed to provide a valid reason for his delay in seeking relief and that, even considering his claims cumulatively, the identified withheld evidence was not material enough to undermine confidence in the verdict. The court concluded that Giannone did not meet the stringent requirements for coram nobis relief, as he failed to show either timely pursuit of his claims or an error of the most fundamental character, and thus affirmed the denial of his petition. View "US v. Giannone" on Justia Law

Jackson v. Bush

2026-07-09T11:00:37-08:00

While incarcerated at a maximum-security prison, Dashaun Simmons was fatally stabbed by another inmate, Jonathon Dominick, after a corrections officer, Gerald Bush, released Dominick and another inmate from their cells without proper verification of their authorization to leave. Simmons had a history of being attacked in various facilities and had reported threats and assaults at the current prison, though not specifically to Bush. On the day of the incident, Bush, unfamiliar with the inmates in this particular unit, relied on inmate statements rather than consulting the official list or a supervisor. After the stabbing, officers Cheryl Youngquist and Dontai Parks responded, with Youngquist initially failing to recognize the urgency but then calling for medical help, and Parks transporting Simmons to the medical team. Simmons died from his injuries. In the United States District Court for the District of South Carolina, Simmons’s estate brought suit against several prison officials under 42 U.S.C. § 1983, alleging violations of the Eighth Amendment due to deliberate indifference to Simmons’s safety and medical needs. The district court granted summary judgment in favor of the defendants, concluding that the officials were entitled to qualified immunity because there was no evidence of deliberate indifference or violation of clearly established law. The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The Fourth Circuit affirmed the district court’s judgment, holding that the officers’ conduct did not violate the Eighth Amendment. The court found insufficient evidence that any defendant subjectively knew of and disregarded a substantial risk to Simmons’s safety or medical needs. The court also noted that mere violation of prison policy did not amount to constitutional deliberate indifference, and that, absent evidence of actual or constructive knowledge of a specific risk, qualified immunity applied. The judgment for the officers was therefore affirmed. View "Jackson v. Bush" on Justia Law

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

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

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

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

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

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

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. 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

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

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

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

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

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

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

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

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

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

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

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

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

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