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

In the case before the United States Court of Appeals for the Fourth Circuit, Yagoub Mohamed, a self-employed mechanic, sued Bank of America, alleging that the bank's conduct and error-claim procedures violated the federal Electronic Fund Transfer Act (EFTA) and various state laws. Mohamed had applied for unemployment benefits during the COVID-19 pandemic and was found eligible to receive $14,644, which he elected to receive via a Bank of America-issued debit card. However, by the time he received and activated his card, the entire benefit amount had been spent on transactions he did not recognize. The bank opened an error claim and later froze his account due to possible fraud.The district court granted Bank of America's motion to dismiss Mohamed's federal claim, stating that the unemployment benefits he was to receive via a prepaid debit card were not protected by the EFTA. The court did not exercise jurisdiction over the state-law claims.On appeal, the Fourth Circuit vacated the judgment and remanded the case for further proceedings. The court held that the account in which Mohamed's benefits were held qualified as a "government benefit account" under the EFTA and its implementing regulations. As such, the court concluded that Mohamed had stated a claim under the Act. The court rejected the bank's arguments that it had established the account in question, asserting that the account was established by the state of Maryland, and the bank acted solely under its contract with the state.The court's holding is significant because it clarifies the scope of protection offered by the EFTA for government benefits distributed via prepaid debit cards, and it underlines the responsibilities of banks in managing such accounts. View "Mohamed v. Bank of America, N.A." on Justia Law

Kenneth Hart was convicted of drug dealing, sex trafficking, and witness tampering. He appealed his convictions, arguing that the government violated the Speedy Trial Act by failing to indict him for the witness tampering charge within thirty days of his arrest. The United States Court of Appeals for the Fourth Circuit agreed that the government violated the Speedy Trial Act on the witness tampering conviction, but rejected his evidentiary challenges.The court held that the government failed to indict Hart for witness tampering within the Speedy Trial Act’s thirty-day window. So it vacated only Hart’s witness-tampering conviction and remanded the case for resentencing on the four counts added by the superseding indictment. Hart also contended that the district court erred by allowing certain prejudicial evidence at trial, but the court disagreed and affirmed the district court’s rulings on these evidentiary challenges. View "US v. Hart" on Justia Law

The case revolves around two developers, SAS Associates 1, LLC and Military 1121, LLC, who filed a complaint against the City Council of Chesapeake, Virginia, alleging that their equal protection rights were violated when their rezoning applications were denied by the council. The developers owned several parcels of land in Chesapeake and sought to combine them to create a 90-acre development involving housing units, commercial space, and a conservation district. Their plans required rezoning, which was denied by the Council citing community opposition and the ability to develop under existing zoning classifications. The developers filed a complaint alleging that their application was denied even though similar applications from other developers were approved, and the council's reasons for denial were irrational and arbitrary.The United States Court of Appeals for the Fourth Circuit upheld the district court’s decision to dismiss the developers' claim. The Court of Appeals found that the developers failed to demonstrate that they were treated differently from others who were similarly situated and that the unequal treatment was the result of discriminatory animus. Furthermore, the court highlighted that zoning decisions are primarily the responsibility of local governments and that the Developers did not provide any valid comparators to support their claim of discriminatory treatment. The court noted the lack of any evidence to infer discriminatory intent on the part of the City Council members and ruled that the Developers' disagreement with the Council's decision does not render the Council's judgment call pretextual. The court affirmed the judgment of the district court dismissing the complaint. View "SAS Associates v. City Council of Chesapeake" on Justia Law

In this case before the United States Court of Appeals for the Fourth Circuit, the defendant, Trezith Rashad Smart, appealed his drug-trafficking convictions. He argued that his prosecution violated the Speedy Trial Act and that the district court erred in not granting his motion to suppress evidence from two traffic stops.Smart was initially stopped for speeding in Louisiana in 2017. During this stop, a drug-sniffing dog was deployed and alerted officers to the presence of cocaine in Smart's car. Smart was later linked to a drug dealing operation in Virginia and further evidence of drug trafficking was gathered during a second stop in 2018. He was subsequently arrested and charged with one count of conspiracy to possess and distribute cocaine.On appeal, the court rejected Smart's arguments. It held that there was no violation of the Speedy Trial Act, noting that delays in the proceedings, including changes of counsel and the complexity of the case, were justified and fell within the exceptions provided in the Act. It also held that both traffic stops were constitutional. Specifically, the court found that the officer had reasonable suspicion to extend the first traffic stop and deploy a drug-sniffing dog based on Smart's extreme nervousness, inconsistent answers about his travel plans, and the presence of a gas can in his car, which the officer, based on experience, associated with drug trafficking. Consequently, the court affirmed Smart's conviction. View "United States v. Smart" on Justia Law

The United States Court of Appeals for the Fourth Circuit denied a motion filed by the United States Environmental Protection Agency (EPA) to transfer a case brought by the state of West Virginia to the Court of Appeals for the District of Columbia or to dismiss it due to improper venue. The case pertains to the EPA's disapproval of West Virginia's State Implementation Plan (SIP), which the state had submitted as part of its obligation under the Clean Air Act to address the emission of gases contributing to the formation of ground-level ozone. The EPA had disapproved West Virginia's SIP because it found that the plan did not sufficiently reduce ozone-forming emissions that were adversely affecting air quality in downwind states. The Fourth Circuit court also granted the state of West Virginia's motion to stay the EPA's final action pending the outcome of its petition for review. The court's decision on venue was based on its interpretation of the Clean Air Act, which stipulates that the venue for review of EPA actions depends on whether the action is nationally applicable or locally or regionally applicable. The court concluded that the EPA's disapproval of West Virginia's SIP was based on circumstances particular to West Virginia and therefore was locally or regionally applicable. View "State of West Virginia v. EPA" on Justia Law

In this case, plaintiffs Kewon English and Earl Powell were arrested for sexual assault and burglary and detained for over a year before their cases were nolle prossed and they were released. They sued Senior Investigator Joseph Clarke of the Richland County Sheriff’s Department, alleging that he had coerced them into signing false confessions. They also sued Sheriff Leon Lott and the Richland County Sheriff's Department for damages under § 1983, claiming their constitutional rights under the First, Fourth, Fifth, Sixth, and Fourteenth Amendments were violated. The United States Court of Appeals for the Fourth Circuit affirmed the grant of summary judgment on English’s claims and dismissed Clarke’s cross-appeal. The court determined that there was probable cause to arrest English based on the victim’s identifications. Regarding English's malicious prosecution claim, the court held that even assuming probable cause was negated, Clarke cannot be held responsible for English’s continued detention. The court found no evidence that the Richland County Sheriff's Department had any unconstitutional policy or custom, and that Clarke could not be held liable for the continued detention of English. Furthermore, the court dismissed Clarke's cross-appeal, ruling that the appeal turned on a question of fact and was therefore not suitable for interlocutory treatment. View "English v. Clarke" on Justia Law

In this case, Jordan Jones, a prisoner at North Carolina’s Avery-Mitchell Correctional Institution, sued multiple prison officials under § 1983. The suit challenged the conditions of his confinement and a transfer to another prison that he alleged was retaliatory. The United States Court of Appeals for the Fourth Circuit affirmed in part and reversed in part the district court's grant of summary judgment to the defendants.Jones had been placed in a “dry” cell, with the water turned off, for about 17 hours after he was suspected of having ingested contraband. He was allowed to clean himself only with toilet paper, despite having to defecate three times in a portable toilet. He also had to eat a meal with his hands, which he was unable to wash. The court concluded that while the conditions of Jones's confinement were deplorable, the officials were entitled to qualified immunity on this claim because it was not clearly established in April 2015 that these conditions posed a substantial risk of serious harm in violation of the Eighth Amendment.However, the court reversed the district court's grant of summary judgment to defendant Gregory Taylor on Jones's claim that his transfer to another prison was in retaliation for his filing of grievances. The court concluded that a reasonable jury could find that Taylor ordered the transfer in retaliation for Jones's grievances, and that Taylor was not entitled to qualified immunity on this claim because it was clearly established at the time of the transfer that such retaliation violated the First Amendment. The court remanded for further proceedings on this claim. View "Jones v. Solomon" on Justia Law

In this appeal to the United States Court of Appeals for the Fourth Circuit, James Dow Vandivere challenged a district court decision denying his motion for release from civil commitment under the Adam Walsh Act. Vandivere, who had been convicted of multiple crimes involving the sexual exploitation of minors and sentenced to almost twenty years in prison, was nearing the end of his sentence when the government moved to civilly commit him. The government argued, and the district court agreed, that Vandivere remained sexually dangerous. Vandivere filed a motion for discharge and, following a hearing, the district court found he remained sexually dangerous and denied his motion. Vandivere appealed, arguing that he was wrongly forced to bear the burden of proof at the hearing and that the district court erred in determining that he remained sexually dangerous.The Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The appellate court found that under the Adam Walsh Act, the burden of proof at an Adam Walsh Act discharge hearing is on the detainee to show his recovery by a preponderance of the evidence. The court also found this allocation of burden does not violate the detainee’s due process rights. Further, the appellate court found no error in the district court's conclusion that Vandivere remained sexually dangerous, stating that the district court had appropriately considered Vandivere's behavior while in custody, his persistent cognitive distortions about sexual abuse, his refusal to participate in sex offender therapy, and his proposed release plan. View "US v. Vandivere" on Justia Law

In this case heard before the United States Court of Appeals for the Fourth Circuit, the plaintiff, Daniella Easterbrook, appealed the denial of her application for disability benefits by the Social Security Administration. Easterbrook, who has suffered from persistent back pain since 2011, argued that the Administrative Law Judge (ALJ) failed to provide a "good reason," supported by substantial evidence, for not giving adequate weight to the opinions of her treating physician, Dr. John Kim.The court agreed with Easterbrook, stating that the ALJ erred in not applying the "treating source rule" to Dr. Kim's opinions and not providing a sufficient justification for giving his opinions less weight. The court noted that Dr. Kim's opinions were well-supported by medically acceptable clinical and laboratory diagnostic techniques and were consistent with the substantial evidence in the record.The court also found that the ALJ's reasons for discounting Dr. Kim's opinions, such as Easterbrook's decision not to undergo certain treatments, were inappropriate and did not constitute "good reasons." The court stated that a patient's refusal to pursue a specific type of medical treatment does not automatically call into question the severity of her pain.As a result, the court reversed the Commissioner's decision and remanded the case for a determination consistent with its opinion. View "Easterbrook v. Kijakazi" on Justia Law

Plaintiffs sought to enjoin the state from enforcing only this additional, preliminary handgun-licensure requirement. The district court originally dismissed that challenge for lack of Article III standing, but we reversed and remanded for a decision on the merits. On remand, the district court again rejected Plaintiffs’ claims, this time holding that Maryland’s handgun licensure law did not violate the Second Amendment. So Plaintiffs appealed once more.   The Fourth Circuit reversed the district court’s decision. The court explained that the challenged law restricts the ability of law-abiding adult citizens to possess handguns, and the state has not presented a historical analogue that justifies its restriction; indeed, it has seemingly admitted that it couldn’t find one. The court enjoined the enforcement explaining that under the Supreme Court’s new burden-shifting test for these claims, Maryland’s law fails. The court wrote that Maryland has not shown that this regime is consistent with the Nation’s historical tradition of firearm regulation. There might well be a tradition of prohibiting dangerous people from owning firearms. But, under the Second Amendment, mechanism matters. And Maryland has not pointed to any historical laws that operated by preemptively depriving all citizens of firearms to keep them out of dangerous hands. View "Maryland Shall Issue, Inc. v. Wes Moore" on Justia Law