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

Defendant was convicted of crimes arising from his involvement in the street gang La Mara Salvatrucha (MS-13). On appeal, he raised several challenges to his convictions, focusing on the district court's admission of certain testimony and the sufficiency of the evidence to support his convictions under the Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. 1961-68, and the Violent Crimes in Aid of Racketeering Act (VICAR), 18 U.S.C. 1959. The court held that the district court did not abuse its discretion by admitting expert testimony, evidence of prior bad acts, and testimony of defendant's cellmate. The court further held that there was sufficient evidence to support his convictions. Accordingly, the court affirmed the judgment. View "United States v. Palacios" on Justia Law

Plaintiff sued defendant, a bail bondsman, and others, alleging civil rights violations under 42 U.S.C. 1983, as well as various state law tort claims. The claims stemmed from defendant's efforts to apprehend a fugitive in and around plaintiff's home. A jury found in plaintiff's favor on her section 1983, trespass, and assault claims. Defendant appealed, challenging the jury's verdict and damages award. The court held that defendant was not entitled to qualified immunity where neither history nor policy supported extending the defense to bail bondsmen. The court also held that there was sufficient evidence to support the jury's conclusion that plaintiff's consent was involuntary and the court affirmed the verdict on the 1983 claim. The court further held that there was a sufficient basis to support the jury's conclusion that plaintiff was in reasonable fear of bodily harm. Finally, the court affirmed the district court's denial of defendant's motion regarding the actual damages award and found no abuse of discretion in the district court's decision to leave the punitive damages award undisturbed. Accordingly, the court affirmed the judgment. View "Gregg v. Ham" on Justia Law

Plaintiff filed a complaint against Officer Robert M. Bauer and several other defendants, alleging claims under 42 U.S.C. 1983 for deprivation of her Fourth Amendment right to freedom from seizure without probable cause, and also asserting her state law claim for malicious prosecution. Considering the totality of the circumstances, the court concluded that no prudent person would have believed that plaintiff violated the impersonation statute at issue and therefore, plaintiff's arrest lacked probable cause and was unreasonable. Thus, plaintiff's constitutional right not to be unreasonably seized was violated. The court also held that the district court did not err in ruling that Officer Bauer was not, at this stage of the litigation, entitled to qualified immunity on plaintiff's section 1983 claim. View "Merchant v. Bauer" on Justia Law

Plaintiff, the Chapter 7 trustee for the bankruptcy estate of BioniCare Medical Technologies, contested determinations of the Medicare Appeals Council (MAC) refusing to provide coverage for the BIO-1000, a device to treat osteoarthritis of the knee. Plaintiff alleged that the Secretary improperly used the adjudicative process to create a policy of denying coverage for the BIO-1000, that the MAC's decisions were not supported by substantial evidence, and that the MAC's decisions were arbitrary and capricious on account of a variety of procedural errors. The court rejected those contentions and affirmed the judgment of the district court. View "Almy v. Sebelius" on Justia Law

Defendant was convicted of possession of cocaine with intent to distribute, being a felon in possession of a firearm, and knowingly using and carrying a firearm in furtherance of a drug trafficking crime. The court held that the detention of defendant's vehicle was valid, but that the district court improperly admitted certain prior "bad act" evidence of his statements showing his knowledge of crack cocaine and his willingness to manufacture and distribute it. Accordingly, the court affirmed in part, reversed in part, and remanded the case to the district court. View "United States v. McBride" on Justia Law

Defendants were convicted by a jury of violating and conspiring to violate the animal fighting prohibition of the Animal Welfare Act, 7 U.S.C. 2156(a) (the animal fighting statute), resulting from their participation in "gamefowl derbies," otherwise known as "cockfighting." Defendants raised several challenges on appeal. Upon review of the parties' arguments, the court held that the animal fighting statute was a constitutional exercise of Congress' power under the Commerce Clause; that the provision of different elements of the crime in jurisdictions permitting animal fighting did not violate defendants' equal protection rights; and that the district court did not err in conducting Scott Lawson's trial jointly with the trials of his co-defendants. The court held, however, that the juror's misconduct violated Lawson's right to a fair trial, and therefore vacated the convictions for violating the animal fighting statute. The court also vacated the conspiracy convictions with respect to those defendants for which the conspiracy related solely to the animal fighting activities. Further, the court rejected the challenges made by several defendants to the illegal gambling convictions, and affirmed the convictions relating to those offenses as well as the conspiracy convictions for which illegal gambling was one of the objects of the conspiracy alleged. View "United States v. Lawson; United States v. Hutto; United States v. Hutto; United States v. Peeler; United States v. Dyal; United States v. Collins, Jr." on Justia Law

Defendants were indicted for their roles in organizing, operating, and participating in "gamefowl derbies," otherwise known as "cockfighting." Defendants entered a conditional plea of guilty to the charge of conspiring to violate the Animal Welfare Act, 7 U.S.C. 2156 (the animal fighting statute). At issue was whether Congress exceeded its power under the Commerce Clause in enacting a criminal prohibition against animal fighting. The court held that the animal fighting statute prohibits activities that substantially affected interstate commerce and thus, was a legitimate exercise of Congress' power under the Commerce Clause. The court also held that the statute did not require the government to prove defendants' knowledge regarding the particular venture's nexus to interstate commerce. Accordingly, the court affirmed the convictions. View "United States v. Gibert; United States v. Benfield; United States v. Hoover; United States v. Grooms; United States v. Jeffcoat" on Justia Law

Plaintiff filed suit in state court pursuant to the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., after Aetna terminated his long-term disability benefits under his employer-sponsored plan. Both parties moved for summary judgment, which the district court denied, concluding that relevant evidence had not been adequately addressed, and remanded the case. On appeal, the court held that the collateral order doctrine did not apply in this case and the court dismissed based on lack of subject matter jurisdiction because there was no final decision. View "Dickens v. Aetna Life Ins. Co." on Justia Law

Defendant plead guilty for fraudulently obtaining benefits under the Federal Employment Compensation Act (FECA), 18 U.S.C. 1920. On appeal, defendant contended, inter alia, that the district court failed to follow the mandates of Rule 11 by not advising him that his FECA benefits could be terminated as a result of his guilty plea. The court held that the loss of government benefits was a collateral consequence of defendant's plea and therefore, the district court was not required to advise him of it pursuant to Rule 11. The court also held that the district court conducted a sufficient inquiry into defendant's competence and that the district court, after carefully considering the judicially recognized factors constraining its exercise of discretion, appropriately denied defendant's motion to withdraw his guilty plea. View "United States v. Nicholson" on Justia Law

Defendants were convicted of conspiracy to traffic in counterfeit goods, trafficking in counterfeit goods, and smuggling goods into the United States. The counterfeiting convictions were based on the jury's determination that a mark displayed on goods defendants imported into the United States was a counterfeit of a trademark registered to fashion designer Burberry Ltd, depicting its signature plaid pattern. On appeal, defendants advanced various challenges to their convictions for trafficking in counterfeit goods under 18 U.S.C. 2320(a). Defendants also asserted that certain comments made by prosecutors at trial necessitated a retrial. Because the court found that defendants' arguments lacked merit, the court affirmed the judgment. View "United States v. Lam; United States v. Chan" on Justia Law