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

Defendant appealed the district court's decision allowing him to represent himself at trial in light of the Supreme Court's decision in Indiana v. Edwards. The heightened standard discussed in Edwards, which applied when the district court considered whether to force counsel on a severely mentally ill defendant competent to stand trial who wished to represent himself, did not control. The court held that this case was more akin to Godinez v. Moran because the district court granted defendant's request to represent himself. Because the court rejected defendant's interpretation of Edwards and was satisfied that the district court applied the correct legal standard, the court affirmed the judgment. View "United States v. Bernard" on Justia Law

Defendant was convicted of crimes stemming from a scheme where he faked his death with the assistance of his girlfriend in order to avoid a state probation violation hearing. Defendant appealed his conviction and sentence. Although the government did not prove that defendant's girlfriend was aware and therefore intended that the U.S. Coast Guard would respond to the false distress call, it proved that she knew of and participated in the plan and that, under the plan, a false distress call would be made. With this proof and proof that the U.S. Coast Guard received the call, the government established a conspiracy to violate 14 U.S.C. 88(c), regardless of whether the conspirators knew or intended that the Coast Guard would receive the call. The court also concluded that defendant's sentence was not "plainly unreasonable," the standard applicable when, as here, no Guidelines existed for the offenses committed. View "United States v. Deffenbaugh" on Justia Law

Plaintiff, seeking to offer services as a psychic and spiritual counsel in the County of Chesterfield, challenged the application of regulations enacted by the County affecting fortune tellers. The County regulated fortune tellers in four ways, one of which was applicable to all those operating a business in the County, with the others more specific to fortune tellers. The district court considered and rejected plaintiff's claims and plaintiff subsequently appealed. The court held that the First Amendment Free Speech Clause afforded some degree of protection to plaintiff's activities where the County could not establish either premise of its argument that fortune telling was inherently deceptive speech outside the scope of the First Amendment. However, the County's regulations did not abridge plaintiff's First Amendment freedom of speech where the County's regulation of plaintiff's activities fell squarely within the scope of the professional speech doctrine. The court agreed with the district court's conclusion that granting summary judgment to the County on plaintiff's constitutional and statutory religion claims was proper where plaintiff's beliefs comprised a way of life, and not a religious exercise. Finally, plaintiff's Equal Protection argument failed where the court, applying rational basis review, held that the County's regulatory scheme was rationally related to a legitimate government interest. Accordingly, the court affirmed the judgment. View "Moore-King v. County of Chesterfield, VA" on Justia Law

Defendant, a juvenile, appealed from the judgment of the district court which imposed, as a condition of his juvenile delinquent supervision, that he register under the Sex Offender Registration and Notification Act (SORNA), 42 U.S.C. 16901 et seq. The court held that the district court did not err by imposing the sex offender registration condition because the court concluded that Congress, in enacting SORNA, intentionally carved out a class of juveniles from the Federal Juvenile Delinquency Act's, 18 U.S.C. 5031 et seq., confidentiality provisions, and that SORNA's registration requirements were not punitive as applied to defendant. View "United States v. Under Seal" on Justia Law

Plaintiffs, prospective luxury home buyers, alleged that Toll Brothers, a real estate development company, unlawfully refused to return deposits when plaintiffs could not obtain mortgage financing. The district court denied Toll Brothers' motion to dismiss or stay the suit pending arbitration, finding that the Agreement of Sale's arbitration provision lacked mutuality of consideration under Maryland law because it required only the buyer - but not the seller - to submit disputes to arbitration. The court held that the appeal was properly before it under 9 U.S.C. 16(a), and that the Agreement of Sale's arbitration provision was unenforceable for lack of mutual consideration under Maryland law. Accordingly, the court affirmed the judgment. View "Noohi v. Toll Bros., Inc." on Justia Law

Plaintiff, an architecture firm that specialized in designing single family homes, alleged that Lennar's architectural plans infringed on its copyrights. The court held that plaintiff did not have sufficient evidence to support a finding that there existed a reasonable possibility that Lennar had access to its copyrighted plans. Accordingly, the district court correctly concluded that as a matter of law, plaintiff lacked the evidence necessary to sustain its claims of copyright infringement. View "Building Graphics, Inc. v. Lennar Corp." on Justia Law

Defendant appealed the district court's denial of his motion to suppress a firearm on the basis that it was the fruit of an unlawful seizure of his person. The court concluded that defendant was seized when his ID was retained while his companions were frisked. The totality of the factors outlined by the district court - an individual's presence at a gas station; prior arrest history of another individual; lawful possession and display of a firearm by another; defendant's submission of his ID showing an out-of-district address; all of which occurred in a high crime area at night - failed to support the conclusion that the officer had a reasonable suspicion to detain defendant. Therefore, the court held that there was no reasonable suspicion justifying defendant's seizure and the district court erred in denying his motion to suppress. Accordingly, the court reversed and vacated defendant's conviction and sentence. View "United States v. Black" on Justia Law

Defendant pleaded guilty to distributing five or more grams of crack cocaine. On appeal, defendant argued that the district court incorrectly calculated the applicable Sentencing Guidelines range and imposed an "illegal" and substantively unreasonable sentence. Defendant also contended that the district court's denial of his motion to continue his sentencing hearing was an abuse of discretion. The court granted the government's motion to dismiss with regard to the sentencing issues that fell within the scope of defendant's valid appeal waiver and affirmed as to his contentions regarding the continuance where the district court's denial was neither unreasonable nor arbitrary. View "United States v. Copeland" on Justia Law

Defendant appealed his conviction and capital sentence for conspiracy to commit murder-for-hire, among other charges stemming from the same course of events. The court rejected defendant's assertion that both the federal murder-for-hire statute and the federal carjacking statute were unconstitutional. The court held that there was sufficient evidence to convict defendant under both statutes. The court considered defendant's challenge of the nonstatutory aggravating factors submitted to the jury and the prosecutor's efforts to prove them; defendant's challenge of various statements made by the prosecution during the closing arguments of the penalty selection phase; and defendant's challenges of a number of other aspects of his sentencing proceeding on both constitutional and statutory grounds. The court found defendant's challenges unconvincing and affirmed the judgment. View "United States v. Runyon" on Justia Law

Plaintiffs, three manufacturers of certain pesticides at issue, commenced this action challenging the biological opinion (BiOp) issued by the Service. The BiOp, which the Service provided as part of the EPA's process of reregistering the pesticides at issue, concluded that these pesticides would jeopardize the viability of certain Pacific salmonids and their habitat and that the pesticides could not be reregistered and therefore used without substantial restriction. The court concluded that the BiOp was not the product of reasoned decisionmaking in that the Service failed to explain or support several assumptions critical to its opinion. To enable a renewed agency process, the court vacated the BiOp and remanded for further proceedings. View "Dow AgroSciences LLC v. National Marine Fisheries Serv." on Justia Law