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

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

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

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

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

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

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

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

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

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

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