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

Defendant appealed his conviction for possessing a firearm while a convicted felon and the district court's imposition of a sentence of life imprisonment. The court affirmed the conviction but concluded, however, that the district court erred in applying the murder cross-reference provision in U.S.S.G. 2K2.1(c)(1) and in treating as relevant conduct a murder that occurred during the course of an unrelated and uncharged offense, which error substantially increased defendant's advisory Guidelines range. Accordingly, the court vacated the sentence and remanded for resentencing. View "United States v. Horton" on Justia Law

Defendant appealed his convictions and sentence for his role in a bank robbery and mid-escape home intrusion, which ended in the death of an elderly woman who died of a heart attack. The court found that only one of defendant's contentions had merit - that the district court erred in instructing the jury on an offense not charged in the indictment. Therefore, the court vacated the conviction and sentence on the uncharged death results offense and remanded for entry of a judgment of conviction on Count Four regarding the forced accompaniment offense and for appropriate resentencing proceedings. The court affirmed the judgment in all other respects. View "United States v. Whitfield" on Justia Law

This case stemmed from plaintiff's claim for survivor benefits after her husband was awarded total disability benefits in 1993 under the Black Lung Benefits Act, 30 U.S.C. 932, until his death in 2000. The liable employer subsequently filed a modification request seeking reconsideration of the award of benefits. In 2004, the ALJ agreed to modify the 1993 award, retroactively denying plaintiff's living miner's claim and also rejecting her survivor's claim. On plaintiff's petition for review of the ALJ's decision, the court vacated and remanded for further proceedings, holding that the ALJ had failed to exercise the discretion accorded to him with respect to the modification request. On remand, the ALJ again denied plaintiff's claims but the Benefits Review Board (BRB) reversed. The employer petitioned for review and the court denied the petition, affirming the BRB's decision denying modification. View "Westmoreland Coal Co. v. Sharpe" on Justia Law

Defendant was convicted of drug charges in 2004 and almost six years later, he filed a motion under 28 U.S.C. 2255 seeking to vacate his sentence in light of the Supreme Court's decision in Carachuri-Rosendo v. Holder. Because the Supreme Court's decision in Carachuri at most altered the procedural requirements that must be followed in applying recidivist enhancements and did not alter the range of conduct or the class of persons subject to criminal punishment, the court held that Carachuri was a procedural rule. Therefore, Carachuri was not retroactively applicable to cases on collateral review. Thus, defendant's section 2255 motion must be dismissed as untimely pursuant to section 2255(f)(3). View "United States v. Powell" on Justia Law

This matter was previously before the Fourth Circuit on appeal. Petitioner Justin Michael Wolfe, a Virginia prisoner, was convicted of capital murder and sentenced to death by the Commonwealth in 2002. By its decision in 2009, the Court remanded for further proceedings. Specifically, "Wolfe I" instructed the district court to determine whether Petitioner was entitled to an evidentiary hearing and other discovery; to decide in the first instance whether, under "Schlup v. Delo," (513 U.S. 298 (1995)), Petitioner had made a sufficient showing of actual innocence to clear any procedural bars to his constitutional claims; and to assess Petitioner claim, among others, that the prosecution had contravened his Fourteenth Amendment due process rights, as recognized in "Brady v. Maryland," (373 U.S. 83 (1963)), by suppressing favorable and material evidence. On remand, the district court heeded the Fourth Circuit's "Wolfe I" mandate, authorized appropriate discovery and conducted an evidentiary hearing, and ruled in Petitioner's favor on the Schlup issue and his Brady and two additional claims. The court vacated Petitioner's capital murder and other convictions, and ordered the Commonwealth to either retry him within 120 days or release him unconditionally from custody. The judgment was stayed pending this appeal by the Commonwealth, which was initiated on its behalf by Respondent Harold Clarke, Director of the Virginia Department of Corrections. The Commonwealth challenged the remand proceedings from start to finish, contending that the district court erred in its procedural and substantive rulings. Because the Fourth Circuit concluded that the court's award of habeas corpus relief on Petitioner's Brady claim was not made in error, the Fourth Circuit affirmed the judgment. View "Wolfe v. Clarke" on Justia Law

A jury convicted Defendant Earl Whittley Davis of various federal offenses arising from a course of conduct that included the armed robbery and murder during that robbery of an armored car employee, Jason Schwindler, as well as a subsequent carjacking. On appeal, Defendant challenged the use of DNA evidence against him at trial, and also argued that the district court erred in excluding expert testimony proffered by Defendant in an attempt to undermine an eyewitness identification of him. Upon review of the matter, the Fourth Circuit found no error and affirmed the judgment of the district court. View "United States v. Davis" on Justia Law

Five years after Eric Wilson fully served his sentence for a Virginia state rape conviction, he filed a habeas corpus petition to challenge his conviction. To satisfy the statute's jurisdictional requirement that he be "in custody" at the time he filed his petition, Wilson alleged that the sex offender registration requirements of Virginia and Texas law impose sufficiently substantial restraints on his liberty so as to amount to custody. The district court dismissed Wilson’s petition for lack of jurisdiction, holding that because he had fully served the sentence for his rape conviction, he was no longer "in custody," as required by statute. Upon review of the matter, the Fourth Circuit agreed with the district court and affirmed its decision. View "Wilson v. Flaherty" on Justia Law

On October 6, 2009, Defendant-Appellant Douglas Chappell was stopped for speeding by a U.S. Park Police Officer. In an attempt to avoid a speeding ticket, Defendant falsely told the officer that he was a Fairfax County Deputy Sheriff. In fact, Defendant had not been employed by the Fairfax County Sheriff's Office for approximately one year. The officer asked Defendant for his law enforcement credentials, and Defendant replied that he had left them at home. He then produced his Virginia driver's license, pointing out that the license photo depicted him in uniform. In order to verify Defendant's employment, the officer called the Fairfax County Sheriff's Office, which requested an employee identification number. When asked for his employee identification number, Defendant made one up. He subsequently admitted his lie and was arrested for impersonating a police officer. Defendant appealed his subsequent conviction, and on appeal, asked the Fourth Circuit to hold the statute under which he was charged as facially unconstitutional under the First Amendment. The Fourth Circuit declined the invitation and affirmed the judgment of the district court. View "United States v. Chappell" on Justia Law

In this appeal, the Fourth Circuit reviewed the convictions of three defendants who were tried together on charges relating to the murder of certain government witnesses, the murder of a coconspirator, and numerous other narcotics and firearms-related offenses arising from the defendants' involvement in a drug-trafficking organization in Baltimore. Among the several issues presented, the Court considered: (1) the district court's decision to empanel an "anonymous jury," in which biographical information about prospective jurors was withheld from the parties and their counsel; and (2) the admissibility of hearsay statements of a murdered government witness under the "forfeiture-by-wrongdoing" exception to the hearsay rule and the Confrontation Clause. Upon review of the trial court record, the Fourth Circuit concluded that the district court did not abuse its discretion in maintaining juror anonymity, and that the challenged hearsay statements were admissible based on the defendants' conduct leading to the witness' death. Accordingly, the Court affirmed the trial court on these and all other issues presented. View "United States v. Dinkins" on Justia Law

Following a jury trial in Maryland, Petitioner Charles Lee Smoot was convicted and sentenced to prison for being a felon in possession of a firearm. On appeal, Petitioner contended that his possession of the firearm was legally justified, or, in the alternative, that he was entitled to a new trial on the ground that the jury was misinstructed on an essential element of the offense. Upon review, the Fourth Circuit rejected Petitioner's challenges to his conviction, and another to his sentence, and affirmed. View "United States v. Smoot" on Justia Law