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

Defendant pleaded guilty to being a felon in possession of a firearm and ammunition and was sentenced under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e). On appeal, defendant argued that the district court erred in relying on his 2002 South Carolina conviction for the common law crime of assault and battery of a high and aggravated nature (ABHAN) to impose a mandatory fifteen-year minimum. The court concluded that ABHAN was not categorically a violent felony and that the modified categorical approach played no part in this matter. Accordingly, the court vacated and remanded for resentencing. View "United States v. Hemingway" on Justia Law

Defendant appealed his sentence after pleading guilty to one count of Possession of Child Pornography. The court concluded that the district court improperly applied the five-level sentencing enhancement under U.S.S.G. 2G2.(b)(3)(B), which resulted in improper calculation of defendant's sentencing range. The court declined to adopt the Government's proposed reciprocity rule by applying the enhancement to every Gigatribe distribution offense absent any evidence of the particular defendant's state of mind. The district court's reliance on an improperly calculated sentencing range constituted significant procedural error and the error was not harmless. Accordingly, the court vacated and remanded for resentencing. View "United States v. McManus" on Justia Law

Plaintiff filed suit against the Bank, alleging that the Bank violated the Equal Credit Opportunity Act (ECOA), 15 U.S.C. 1691, by requiring her to serve as her husband's guarantor. Plaintiff sought equitable and injunctive relief, asserting a claim for unjust enrichment and seeking a declaratory judgment. The district court dismissed the complaint with prejudice because plaintiff failed to state a claim upon which relief could be granted and, in any event, waiver and limitation barred her claims. The court concluded that the Bank may have violated ECOA by requiring plaintiff to sign as an unlimited guarantor. However, the court concluded that plaintiff's claim failed where, in exchange for the Bank's restructuring of the loan at issue, she executed waivers to all claims against the Bank on four separate occasions over a period of more than two years. Accordingly, the court affirmed the district court's dismissal. View "Ballard v. Bank of America, NA" on Justia Law

Motor Carriers filed suit against defendants under 49 U.S.C. 13706(b) of the Interstate Commerce Commission Termination Act. At issue was whether, absent a federal tariff, federal courts have subject matter jurisdiction over a motor carrier's breach of contract claim against a shipper for unpaid freight charges. The court concluded that it lacked jurisdiction over the appeal under the Act, finding that the district court lacked jurisdiction to adjudicate the dispute. Accordingly, the court vacated the judgment of the district court and remanded with instructions to dismiss. View "Gaines Motor Lines, Inc. v. Klaussner Furniture Ind." on Justia Law

Defendant conditionally plead guilty to being a felon in possession of a firearm. On appeal, defendant challenged the district court's denial of his motion to suppress various statements he made to the police and evidence recovered from his home. The court concluded that the district court's finding - that defendant's registration tag was bent - was not clearly erroneous and that the traffic stop was reasonable. The court concluded that Missouri v. Seibert was inapplicable in this case because the court held that no interrogation had occurred before plaintiff was Mirandized. The officers did not conduct an unwarned custodial interrogation on these facts when a detective asked "what do you mean" after plaintiff voluntarily proffered information. Accordingly, the court affirmed the judgment of the district court. View "United States v. Johnson" on Justia Law

After the Appeals Board denied plaintiff's request for review of the denial of social security disability benefits, plaintiff sought judicial review of the ALJ's decision in federal district court. The district court found in favor of plaintiff and the Acting Commissioner appealed. The court held that the district court did not err in its application of Listing 1.04A. Listing 1.04A is the listing identifying disorders of the spine that merit a conclusive presumption of disability and an award of benefits. The court concluded, however, that the district court abused its discretion in directing an award of benefits rather than remanding for further explanation by the ALJ of why plaintiff did not meet Listing 1.04A. Accordingly, the court vacated and remanded for further proceedings. View "Radford v. Colvin" on Justia Law

Petitioner, a native and citizen of India, petitioned for review of the BIA's order affirming the IJ's order of removal. Petitioner, a lawful permanent resident (LPR), was deemed an inadmissible arriving alien upon his return from a 17-day overseas trip. At issue was whether 8 U.S.C. 1101, as amended by the Illegal Immigration Reform and Immigrant Responsibility Act (IIRIRA), still allowed for the case-by-case analysis of an alien's intent under Rosenberg v. Fleuti when determining whether the alien was "seeking an admission" for purposes of removal proceedings. Under Fleuti, LPRs were permitted to take "innocent, casual, and brief" trips abroad without having to seek readmission. The court joined its sister circuits and held that, based on the plain text of the statute, the Fleuti doctrine did not survive IIRIRA's enactment. Accordingly, upon petitioner's entry into the country from India, he was "seeking admission into the United States" and was subject to removal because of his criminal history. The court reached the same result pursuant to principles of administrative deference under Chevron. The court rejected petitioner's remaining claims and denied the petition for review. View "Othi v. Holder, Jr." on Justia Law

Debtors claimed that the bankruptcy court erred by including an inheritance that postdated their Chapter 13 bankruptcy petition by more than 180 days as part of their bankruptcy estate. The court concluded that Bankruptcy Code Section 1306(a) extended the timeline for including "the kind" of property "specified in" Section 541 in Chapter 13 bankruptcy estates. Accordingly, the court affirmed the bankruptcy court's inclusion of the inheritance in debtors' Chapter 13 bankruptcy estate. View "Carroll v. Logan" on Justia Law

Debtor filed a Chapter 13 petition in the bankruptcy court identifying his interest in his primary residence located in Maryland. On appeal, debtor and his spouse argued that the bankruptcy court erred in refusing to strip off a lien on the ground that the spouse's property interest was not part of the bankruptcy estate. The lien was against the property that debtor owned with his non-debtor spouse as tenants by the entireties. The court concluded that the statutory provisions authorizing a strip off, and applicable Maryland property law, did not permit a bankruptcy court to alter a non-debtor's interest in property held in a tenancy by the entirety. The court held that the bankruptcy court correctly determined that it lacked authority to strip off debtor's valueless lien because only debtor's interest in the estate, rather than the complete entireties estate, was before the bankruptcy court. Accordingly, the court affirmed the judgment. View "Alvarez v. HSBC Bank" on Justia Law

Plaintiffs, out-of-state medical providers seeking to open facilities in Virginia, filed suit challenging Virginia's certificate-of-need requirement. In order to launch a medical enterprise in the state of Virginia, a firm was required to obtain a certificate of public need. Plaintiffs alleged, among other things, that Virginia's requirement violated the dormant Commerce Clause by discriminating in both purpose and effect. The district court dismissed the suit for failure to state a claim upon which relief could be granted. The court concluded that plaintiffs' Commerce Clause challenges required closer scrutiny and further proceedings before the district court. The court concluded, however, that plaintiffs' Fourteenth Amendment claims were properly dismissed. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Colon Health Centers v. Hazel" on Justia Law