Justia U.S. 4th Circuit Court of Appeals Opinion Summaries

A tenant and her adult son rented a house in Arlington, Virginia, for a year. Several months into the lease, they noticed water leaking through a skylight and informed the landlord. The landlord and a contractor inspected the skylight and confirmed it was leaking, but no repairs were made. After a period of snow and rain, the tenant slipped on water that had accumulated from the leak, suffering significant injuries. She then sued the landlord, alleging breach of contract for failing to complete repairs as required by the lease and state law, and common-law negligence in failing to take steps to prevent injury from the leak.The landlord removed the case to the United States District Court for the Eastern District of Virginia, which treated the landlord’s demurrer as a motion to dismiss. The district court dismissed the negligence claim, finding the complaint did not allege that the landlord or contractor undertook repairs or performed any negligent acts—only that they inspected and confirmed the leak. The court concluded Virginia law does not impose a tort duty on landlords for failing to repair, but only for negligent acts in the course of repair. The breach of contract claim survived the motion to dismiss, but the parties later stipulated to voluntarily dismiss it to allow an immediate appeal.The United States Court of Appeals for the Fourth Circuit first determined it had appellate jurisdiction, accepting the tenant's binding representation that she was abandoning the contract claim with prejudice. The court then affirmed the district court’s dismissal of the negligence claim. It held that, under Virginia law, a landlord is not liable in tort for failing to make repairs unless the landlord undertakes repairs and does so negligently. Because the complaint did not allege any negligent repair or positive act, only nonfeasance, the negligence claim failed as a matter of law. View "Metz v. McCarthy" on Justia Law

Augustine Perez was on federal supervised release in North Carolina, subject to conditions that allowed warrantless searches of his “person and property” by probation officers. Perez moved from a residence at Teal Drive to Lawndale Drive, reporting the change as required, but retained ownership of Teal Drive and leased it to Deanna Coleman, who moved in with her daughter. About a year later, probation officers received a tip from a confidential informant that Perez was living at Teal Drive and involved in drug trafficking. Without a warrant, officers searched both Lawndale Drive and Teal Drive on the same day. At Teal Drive, Coleman objected to the search, but officers proceeded, finding cash and items they alleged were connected to drug trafficking.In the United States District Court for the Middle District of North Carolina, Perez and Coleman moved to suppress the evidence from the Teal Drive search, claiming it was unconstitutional. The district court denied the motion to suppress and granted summary judgment to the government, ruling that the currency found was subject to forfeiture as drug proceeds, largely relying on the evidence seized during the search.On appeal, the United States Court of Appeals for the Fourth Circuit reversed, vacated, and remanded. The court held that a supervised release condition permitting warrantless searches of a supervisee’s “property” does not authorize the search of real property owned by the supervisee but leased and occupied by a third party. The court further held that, to lawfully search Coleman’s residence under Perez’s supervision conditions, officers needed probable cause to believe Perez resided there. The government failed to meet this standard, rendering the search of Teal Drive unconstitutional. The Fourth Circuit ordered suppression of the evidence and dismissal of the forfeiture complaint. View "US v. Perez" on Justia Law

A married couple who lived in West Virginia refinanced their home loan in 2004. Over the years, they regularly sent their mortgage servicer payments that included both the scheduled monthly amount and additional principal prepayments, combining the two in single checks and clearly indicating when a prepayment was included. The loan servicers, including LoanCare, LLC (which began servicing the loan in 2019), allegedly failed to apply the prepayments before the monthly payments, resulting in the couple being charged excess interest. Despite several requests for correction, LoanCare did not adjust its practices. The couple eventually paid off the loan and sought a refund for the excess interest.The couple filed a putative class action in the United States District Court for the Eastern District of Virginia, alleging that LoanCare violated two provisions of the West Virginia Consumer Credit and Protection Act (the Act): section 46A-2-127(d) and section 46A-2-128. They also asserted claims for unjust enrichment and conversion. The district court dismissed the unjust enrichment and conversion claims, but allowed the statutory claims to proceed. After discovery, LoanCare moved for summary judgment, arguing that the Act required proof of intentional misconduct, and that there was no evidence it acted intentionally.The United States District Court for the Eastern District of Virginia granted summary judgment for LoanCare, holding that the Act’s provisions at issue required proof of intentional violation, which the couple could not show. On appeal, the United States Court of Appeals for the Fourth Circuit concluded that the district court erred in requiring intent, holding that the statutory provisions impose strict liability and do not require proof of intent to violate. The appellate court vacated the judgment and remanded the case for further proceedings. View "Tederick v. Loancare, LLC" on Justia Law

Three men—Clifton Mosley, Davon Carter, and Matthew Hightower—were involved in marijuana trafficking together. Hightower, who worked at a medical supply company, was indicted for healthcare fraud based on information provided by his coworker, Lisa Edmonds. After Hightower’s indictment, he, Carter, and Mosley allegedly conspired to retaliate against Edmonds, who was expected to testify against Hightower. On the morning Edmonds was scheduled for a court appearance, Carter fatally shot Edmonds’ neighbor, Latrina Ashburne, having apparently mistaken her for Edmonds. Surveillance footage, phone records, and witness testimony connected Mosley and Carter to the murder and to each other in the hours before the shooting.The United States District Court for the District of Maryland presided over the criminal proceedings. Carter and Mosley were jointly tried and convicted by a jury of witness-murder and marijuana trafficking. Mosley had moved to sever the murder and marijuana charges and to suppress evidence found on Carter, but the district court denied these motions, finding the offenses were properly joined under the Federal Rules, and that Mosley lacked standing to challenge the search of Carter’s property. A jury returned guilty verdicts on all counts, and Mosley received life imprisonment for the witness-murder counts and a concurrent sentence for marijuana distribution.The United States Court of Appeals for the Fourth Circuit reviewed Mosley’s appeal. The court held that joinder of the charges was proper, and the district court did not abuse its discretion in denying severance. The appellate court also held that Mosley lacked standing to challenge the suppression of evidence from Carter’s property. Finally, the Fourth Circuit concluded that substantial evidence supported the jury’s verdict. Accordingly, the court affirmed the district court’s judgment and upheld Mosley’s convictions. View "US v. Mosley" on Justia Law

A woman of Syrian descent, who worked as a computer-assisted design drafter at an architecture and engineering firm, was terminated from her job and subsequently sued her former employer. She alleged discrimination based on race and national origin, hostile work environment, retaliation, breach of contract, and a Fair Labor Standards Act violation. The core of her complaint was that she was denied promotions and demoted due to her race, harassed by another employee due to her Arab background, and retaliated against after reporting discrimination, culminating in her termination.The United States District Court for the Eastern District of Virginia initially dismissed all of her claims. On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the dismissal of most claims but allowed a retaliatory termination claim to proceed. After discovery, the district court granted summary judgment to the employer on that claim, finding insufficient evidence of pretext for retaliation. The Fourth Circuit affirmed. Following this, the district court imposed sanctions on the plaintiff’s counsel under 28 U.S.C. § 1927, reasoning that counsel should have known after discovery that the claim lacked a basis and unreasonably multiplied proceedings by opposing summary judgment and appealing.The United States Court of Appeals for the Fourth Circuit reviewed the imposition of sanctions. It held that the district court abused its discretion in finding that the opposition to summary judgment was so baseless as to warrant sanctions. The appellate court concluded that counsel had at least two non-frivolous arguments for opposing summary judgment, including shifting reasons for termination and deviations from policy, making sanctions inappropriate under § 1927. The Fourth Circuit therefore reversed the district court’s judgment imposing sanctions. View "Ali v. BC Architects Engineers, PLC" on Justia Law

The defendant was charged with several offenses arising from a scheme in which he and others conspired to commit wire fraud by deceiving businesses into transferring funds to accounts they controlled. The conspirators, operating from Nigeria and Saudi Arabia, used phishing emails containing malware to access business computers and steal money. The government linked the defendant to the conspiracy using evidence including overlapping social media handles, email accounts, IP addresses, and testimony connecting his online activity to fraud-related accounts. The government also introduced evidence that one company suffered financial losses and response costs due to the crimes.A grand jury indicted the defendant and his co-conspirators, but only the defendant proceeded to trial in the United States District Court for the Eastern District of Virginia. During jury selection, a prospective juror mentioned familiarity with the defendant and the case due to his work in cybersecurity. The court struck this juror for cause and repeatedly instructed the panel on impartiality. The jury convicted the defendant on all counts, including sentencing enhancements. The defendant moved for acquittal and a new trial, arguing that the prospective juror’s comments affected jury impartiality and that the evidence was insufficient to connect him to the scheme or to establish the necessary $5,000 loss for an enhanced sentence. The district court denied these motions and sentenced the defendant to 120 months’ imprisonment.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s denial of a new trial, finding no prejudicial error in the jury selection process and holding that there was sufficient evidence linking the defendant to the fraud. However, the appellate court reversed the sentencing enhancement for intentional damage to a protected computer, concluding that the government failed to prove $5,000 in qualifying losses as required by statute. The case was remanded for resentencing consistent with this opinion. View "United States v. Umeti" on Justia Law

A resident of a retirement community, who has celiac disease and relies on a gluten free diet, experienced multiple episodes of illness after consuming meals labeled as gluten free at the facility. She signed a residential contract based on assurances that her dietary needs would be accommodated. Over several years, she reported incidents of illness to staff, including a crab cake in 2018, a stuffed tomato in 2020, and chicken marsala in 2021, all purportedly gluten free. The facility made various adjustments in response to her complaints, including menu changes, staff training, and kitchen modifications. She continued to use her meal plan but gave away the food. In 2023, she filed suit alleging violations of federal disability rights statutes and several state-law claims.The United States District Court for the District of Maryland granted summary judgment to the retirement community on all claims. The court found her federal claims untimely and denied her request for injunctive relief, concluding she lacked standing. It also rejected her state-law breach of contract and negligence claims, holding they were barred by the statute of limitations and unsupported by evidence.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court’s judgment as to the federal claims, holding that the plaintiff lacked standing for injunctive relief under the Americans with Disabilities Act and that her Fair Housing Act and Rehabilitation Act claims were barred by the applicable statutes of limitations. It also affirmed dismissal of state-law claims related to the 2018 incident. However, the court vacated summary judgment as to her breach of contract and negligence claims arising from the January 2021 chicken marsala incident, finding genuine issues of material fact that should be resolved by a jury. The case was remanded for further proceedings on those claims. View "McGinn v. Broadmead, Inc." on Justia Law

Daqua Ritter was indicted for three federal crimes connected to the murder of Ernest “Dime” Doe, a transgender woman in rural South Carolina. Ritter and Doe had a secretive sexual relationship, and Ritter was sensitive about public knowledge of this relationship, especially since Doe openly referred to Ritter as her boyfriend. Evidence at trial showed Ritter pressured Doe to keep their relationship hidden and reacted angrily when others mentioned it. Doe was found shot dead in a car, and Ritter was last seen with her hours before her death. After the murder, Ritter disposed of his gun and burned his clothes. A federal grand jury indicted Ritter for willfully causing bodily injury based on Doe's gender identity resulting in death, using a gun during a crime of violence, and making false statements to investigators.The United States District Court for the District of South Carolina presided over Ritter’s trial. A jury convicted Ritter on all charges, and the district court sentenced him to life in prison. Ritter moved for a new trial, claiming juror bias and prejudicial hearsay testimony, and challenged the sufficiency of evidence for two counts. The district court held an evidentiary hearing regarding juror bias and denied the motion for a new trial, finding the juror credible and impartial. It also denied the motion for a mistrial based on hearsay, issuing a curative instruction to disregard the testimony.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 finding no juror bias or in denying a mistrial based on hearsay, as the curative instruction was sufficient. The court also found that, viewed in the light most favorable to the government, there was sufficient evidence for the jury to convict Ritter on all counts, including motive based on gender identity and the likelihood that false statements would be communicated to federal law enforcement. The judgment was affirmed. View "United States v. Ritter" on Justia Law

Three individuals living with well-managed HIV, whose infections are controlled by daily medication and who have undetectable viral loads, sought to join or rejoin the U.S. Army. They were denied enlistment based on Department of Defense and Army policies that list HIV infection as a disqualifying medical condition, alongside numerous other chronic or communicable diseases. A nonprofit organization, Minority Veterans of America, also supported their challenge. The plaintiffs argued that these policies violate their equal protection rights under the Fifth Amendment and are arbitrary and capricious in violation of the Administrative Procedure Act.The United States District Court for the Eastern District of Virginia granted summary judgment to the plaintiffs. The court issued a permanent injunction barring the Military from denying accession to asymptomatic HIV-positive individuals with undetectable viral loads, prohibiting enforcement of HIV-specific policy provisions, and ordering reevaluation of prior decisions made under these policies. The district court concluded that the Military’s justifications—based on medical, cost, and diplomatic concerns—were irrational, arbitrary, and capricious.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the judgment. Applying rational basis review with heightened deference to military judgments, the Fourth Circuit found that the Military’s policies were rationally related to legitimate military purposes, including maintaining deployable, medically fit servicemembers, minimizing complications from chronic conditions, controlling costs, and addressing diplomatic issues with foreign host nations. The court distinguished this case from Roe v. Department of Defense, which concerned policies for current servicemembers rather than initial entry. The Fourth Circuit held that the Military’s HIV accession policy did not violate the Fifth Amendment or the APA and reversed the district court’s judgment, remanding with instructions to enter judgment for the Military. View "Wilkins v. Hegseth" on Justia Law

Advance Auto Parts, Inc., a publicly traded company, announced ambitious financial goals for 2023, which increased its stock price. However, the company subsequently lowered its guidance and identified a series of accounting errors, resulting in significant declines in its stock price. The City of Southfield General Employees’ Retirement System, representing investors who purchased stock during the period between November 2022 and November 2023, filed a class action lawsuit against Advance Auto and several former executives. The plaintiffs alleged violations of SEC Rule 10b-5 and Sections 10(b) and 20(a) of the Securities Exchange Act, asserting that the defendants intentionally or recklessly misrepresented the company’s financial results and forecasts.The United States District Court for the Eastern District of North Carolina consolidated several investor suits and designated Southfield as lead plaintiff. The court found that Southfield adequately alleged material misstatements or omissions and satisfied the basic requirements for a securities fraud claim, except for scienter—the requirement that defendants acted with wrongful intent or recklessness. The court concluded that the more plausible inference was that the defendants acted in good faith and corrected errors as they became known, dismissing the complaint for failure to sufficiently plead scienter.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the dismissal de novo. The Fourth Circuit examined the allegations individually and holistically, finding that none supported a strong inference of scienter as required by the Private Securities Litigation Reform Act. The court held that the facts, even when considered collectively, only plausibly suggested wrongful intent but did not meet the heightened standard for a strong inference. Accordingly, the Fourth Circuit affirmed the district court’s dismissal of the securities fraud claims and the related vicarious liability claim. View "City of Southfield General Employees' Retirement v. Advance Auto Parts, Inc." on Justia Law