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

A company developed a specialized vehicle-mounted stairway, with design work primarily performed by the founder’s son, who was promised equity in the business but never received it due to the majority owner’s repeated refusals. The son, with his father’s assistance, eventually obtained a patent for the design, which he used as leverage to seek compensation. Negotiations between the parties failed, leading to the father’s removal as company president and the company filing suit against both the father and son. The company alleged breach of fiduciary duty, misappropriation of trade secrets, business conspiracy, unjust enrichment, fraud, and breach of contract, while the son counterclaimed for patent infringement.The United States District Court for the Eastern District of Virginia granted summary judgment to the father and son on all claims except a breach of contract claim against the father and the son’s patent counterclaim. The court found most claims time-barred or unsupported by evidence, and later, the company voluntarily dismissed its remaining claim. The son’s patent was invalidated by a jury. The district court also awarded attorneys’ fees and costs to the father as the prevailing party under the company’s operating agreement.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo and affirmed the district court’s rulings. The appellate court held that the company’s claims were either time-barred under the applicable statutes of limitations or failed on the merits, as there was no evidence the son benefited from the patent or that he had signed a non-disclosure agreement. The court also affirmed the award of attorneys’ fees and costs to the father, finding no error in the district court’s application of Delaware law or its determination of the prevailing party. View "Mission Integrated Technologies, LLC v. Clemente" on Justia Law

Gregory Bonnie was serving a 144-month federal prison sentence in South Carolina, consisting of 120 months for drug trafficking convictions and a consecutive 24 months for violating supervised release, which included a conviction under 18 U.S.C. § 924(c) for possession of a firearm during a drug trafficking crime. While incarcerated, Bonnie sought to earn time credits under the First Step Act (FSA) for the 120-month portion of his sentence related to drug offenses, acknowledging that the 24-month portion for the § 924(c) conviction was disqualifying under the FSA.The Bureau of Prisons (BOP) denied Bonnie’s request, treating his consecutive sentences as a single, aggregate term of imprisonment pursuant to 18 U.S.C. § 3584(c), and finding him ineligible for FSA time credits because his aggregate sentence included a disqualifying § 924(c) conviction. After exhausting administrative remedies, Bonnie filed a habeas petition under 28 U.S.C. § 2241 in the United States District Court for the District of South Carolina. The district court granted summary judgment for the warden, holding that the plain text and statutory context of the FSA and § 3584(c) required aggregation of sentences, making Bonnie ineligible for FSA time credits for the entire 144-month sentence.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the statutory interpretation de novo. The court held that, under the FSA and § 3584(c), the BOP must treat multiple consecutive or concurrent sentences as a single, aggregate sentence for administrative purposes, including the computation of FSA time credits. Because Bonnie’s aggregate sentence included a conviction under § 924(c), he was ineligible for FSA time credits for any portion of the sentence. The Fourth Circuit affirmed the district court’s judgment denying Bonnie’s habeas petition. View "Bonnie v. Dunbar" on Justia Law

A native and citizen of Mexico was placed in removal proceedings after being charged with a misdemeanor offense in 2014. He conceded removability and applied for cancellation of removal under 8 U.S.C. § 1229b, listing one alias on his application. During his merits hearing, he disclosed additional aliases used for work and border crossing, but did not initially mention another alias, “Juan Sanchez Cabrera,” which the government later introduced through documentary evidence. He explained that he had used a false name during a border crossing but could not recall the specific alias. Throughout his testimony, he stated he did not remember all the aliases he had used.The Immigration Judge of the immigration court denied his application for cancellation of removal, finding him statutorily barred from establishing good moral character under 8 U.S.C. § 1101(f)(6) due to providing false testimony. The judge relied on his failure to disclose the “Juan Sanchez Cabrera” alias on his application and during direct testimony. On appeal, the Board of Immigration Appeals affirmed the denial, finding no clear error in the judge’s determination that he provided false testimony with the intent to deceive for immigration benefits, as evidenced by his incomplete disclosure of aliases until confronted by the Department of Homeland Security.The United States Court of Appeals for the Fourth Circuit reviewed the Board’s decision. The court held that it had jurisdiction over the mixed question of law and fact regarding the application of the false testimony bar, but not over factual determinations of intent. The Fourth Circuit found that the Board applied the incorrect standard of review by reviewing the legal question for clear error rather than de novo. The court granted the petition for review, vacated the Board’s decision, and remanded the case for the Board to apply the correct standard. View "Martinez-Martinez v. Bondi" on Justia Law

Several individuals whose livelihoods depended on interacting with spinner dolphins challenged a federal regulation that restricted human proximity to these dolphins. The regulation, known as the Approach Rule, was issued by the National Marine Fisheries Service under the authority of the Marine Mammal Protection Act. The plaintiffs included a psychotherapist who used dolphin encounters in therapy, a boat captain who operated dolphin swim tours, and a dolphin guide and photographer. They argued that the regulation was unconstitutional because it was signed and promulgated by an official who, they claimed, was not properly appointed under the Appointments Clause of the U.S. Constitution.The United States District Court for the District of Maryland reviewed the case after the plaintiffs filed suit seeking to invalidate the regulation and enjoin its enforcement. During the litigation, Dr. Richard Spinrad, the Senate-confirmed NOAA Administrator and a principal officer, ratified the regulation, affirming that he independently evaluated and approved it. The district court found that this ratification cured any potential Appointments Clause defect and granted summary judgment in favor of the government. The plaintiffs appealed this decision.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The court held that, under established principles of agency law, a principal officer’s ratification of a regulation can cure any constitutional defect arising from its initial promulgation by a non-principal officer. The court found that Dr. Spinrad’s ratification was valid and not impermissibly retroactive, as it did not impose new liabilities for past conduct but merely confirmed the regulation’s validity from the time of its original publication. Accordingly, the Fourth Circuit affirmed the district court’s dismissal of the suit. View "Wille v. Lutnik" on Justia Law

A woman from Honduras, along with her daughter, sought asylum, withholding of removal, and protection under the Convention Against Torture (CAT) in the United States. She described a history of abuse by male relatives and partners in Honduras, culminating in severe stalking and threats from a man named Matute, who attempted to abduct her and threatened her and her daughter’s lives. After repeated failures by local police to respond to her pleas for help, she fled Honduras with her daughter, leaving her son with her grandparents. She later learned that Matute continued to harass her family after her departure.After entering the United States, an asylum officer found she had a credible fear of persecution or torture. The Department of Homeland Security charged her and her daughter with inadmissibility. At her merits hearing before an immigration judge, she presented testimony and country-conditions evidence about violence against women in Honduras. The immigration judge found her not credible, gave little weight to her expert evidence, and denied all relief, concluding that her proposed social groups were not cognizable and that there was no nexus between her persecution and a protected ground. The judge also found she had not established a likelihood of torture with government acquiescence and could have relocated within Honduras.The Board of Immigration Appeals (BIA) affirmed the immigration judge’s decision, focusing on the lack of nexus between her harm and a protected ground, and finding no clear error in the denial of CAT relief. The BIA concluded that the harm she suffered was due to a private dispute rather than persecution on account of a protected ground.The United States Court of Appeals for the Fourth Circuit granted the petition for review, vacated the BIA’s order, and remanded the case. The court held that the BIA abused its discretion by failing to meaningfully consider the country-conditions evidence relevant to her claims, as required by precedent. View "Alfaro-Zelaya v. Bondi" on Justia Law

The defendant was indicted on three charges related to the production and possession of child pornography. He pleaded guilty to one count—production of child pornography—and was sentenced to 256 months in prison, followed by a lifetime of supervised release. The terms of his supervised release included both mandatory and special conditions. Of particular relevance was a special condition requiring him to submit to substance abuse testing and contribute to the cost of such testing, as determined by a sliding scale approved by the Probation Office.The United States District Court for the District of South Carolina imposed these conditions at sentencing. The defendant did not object to the special condition regarding substance abuse testing during the sentencing proceedings. On appeal, he argued that this special condition unconstitutionally delegated a core judicial function—specifically, the authority to determine the number of drug tests—to the Probation Office.The United States Court of Appeals for the Fourth Circuit reviewed the case for plain error, given the lack of objection below. The court found that the plain language of the special condition did not delegate authority to determine the number of drug tests to the Probation Office; rather, it addressed only the payment for drug testing ordered by the court. The court concluded that the discretion over the number of drug tests remained with the district court, and the special condition merely facilitated payment. As a result, the Fourth Circuit held that there was no error, let alone plain error, in imposing the special condition and affirmed the defendant’s sentence. The government’s motion to dismiss the appeal based on an appeal waiver was denied as moot. View "US v. Jones" on Justia Law

The plaintiff worked as an Admissions Coordinator at a Maryland hospital’s Center for Eating Disorders, where her duties required frequent in-person contact with medically vulnerable patients and other staff. During the COVID-19 pandemic, the hospital implemented a vaccine mandate for all employees, following state health directives and public health guidance. The hospital allowed employees to request religious or medical exemptions, evaluating each on a case-by-case basis. The plaintiff requested a religious exemption, which was denied after the hospital determined her role could not be performed remotely and that accommodating her would pose risks to patient safety. She was terminated after refusing vaccination.After her termination, the plaintiff filed a discrimination charge with the EEOC and then sued the hospital in the United States District Court for the District of Maryland, alleging a violation of Title VII for failure to accommodate her religious beliefs. The district court granted summary judgment to the hospital, finding that exempting the plaintiff from the vaccine requirement would have created an undue hardship by jeopardizing patient safety and increasing the risk of COVID-19 outbreaks in a sensitive healthcare environment.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s summary judgment ruling de novo. The Fourth Circuit held that, under the standard clarified by the Supreme Court in Groff v. DeJoy, the hospital met its burden to show that granting the requested religious accommodation would have resulted in substantial increased costs and significant health and safety risks, both to patients and staff. The court also found that the hospital properly considered alternative accommodations and the aggregate impact of granting similar exemptions. The Fourth Circuit affirmed the district court’s judgment in favor of the hospital. View "Hall v. Sheppard Pratt Health System" on Justia Law

The defendant purchased fifty-nine firearms over sixteen months, completing federal transaction records for each purchase and listing two Virginia addresses as his residence. However, he did not live at either address—one did not even exist. A grand jury indicted him on twenty-four counts of making false statements to a federal firearms licensee. The government had substantial evidence, including testimony from residents of the listed addresses and GPS data showing the defendant’s actual residence in Maryland. On the eve of trial, the defendant entered into a plea agreement, pleading guilty to one count in exchange for dismissal of the remaining counts and a sentencing recommendation for acceptance of responsibility.The United States District Court for the Eastern District of Virginia accepted the guilty plea after a colloquy that omitted several requirements of Federal Rule of Criminal Procedure 11, such as explicit discussion of the appeal waiver and the nonbinding nature of the Sentencing Guidelines. The defendant did not object at the time. Months later, after replacing his original counsel due to alleged ineffectiveness and disciplinary issues, the defendant moved to withdraw his plea, arguing it was not knowing and voluntary. The district court denied the motion and sentenced him to fourteen months’ imprisonment and two years of supervised release.The United States Court of Appeals for the Fourth Circuit reviewed the case, applying plain error review to the Rule 11 colloquy and abuse of discretion review to the denial of the motion to withdraw. The court held that, despite the procedural deficiencies, the defendant failed to show a reasonable probability that he would not have pleaded guilty absent the errors. The court also found no fair and just reason to permit withdrawal of the plea, given the evidence, the delay in seeking withdrawal, and the lack of prejudice to the defendant. The judgment of the district court was affirmed. View "United States v. Smith" on Justia Law

Two inmates in Virginia, each serving sentences for attempted aggravated murder, were initially informed by the Department of Corrections that they would be released in July 2022 due to a new state law expanding sentence credits for good behavior. This law, H.B. 5148, allowed certain inmates to earn more credits and thus reduce their incarceration time. However, after a change in the Attorney General’s office, the new Attorney General issued an advisory opinion stating that inmates convicted of inchoate offenses related to aggravated murder were not eligible for the enhanced credits. As a result, the Department reversed its earlier decision and kept the inmates incarcerated for an additional year, until the Supreme Court of Virginia later clarified that such inmates were indeed eligible for the credits and ordered their release.The inmates then filed a lawsuit in the United States District Court for the Eastern District of Virginia, seeking damages under 42 U.S.C. § 1983. They alleged that the Attorney General and the Director of Corrections violated their Eighth and Fourteenth Amendment rights by acting with deliberate indifference to their over-incarceration. The district court dismissed the complaint, finding that both officials had acted reasonably in interpreting an unsettled question of state law and that their conduct did not rise to the level of deliberate indifference or conscience-shocking behavior.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The Fourth Circuit held that the officials’ actions did not constitute deliberate indifference under the Eighth Amendment, nor did they shock the conscience under the Fourteenth Amendment. The court emphasized that federal courts should not hold state officials personally liable for reasonable legal interpretations of unsettled state law, especially when those interpretations are made in good faith and with conventional legal reasoning. View "Swart v. Miyares" on Justia Law

A man was accused of sexually abusing a minor, referred to as Jane Doe, based on allegations that surfaced in 2018 and 2019. Initially, the police received a referral from Child Protective Services after Doe made statements to a suicide hotline about being abused by her “father’s friend.” The case was closed when Doe refused to discuss the allegations. In 2019, after another suicide attempt, Doe identified the man by name during therapy, and this information was relayed to the police. Detective Thorsdottir conducted a forensic interview with Doe, who provided detailed accounts of abuse and identified the accused. The investigation included interviews with Doe’s parents and therapists, surveillance, and searches of the accused’s home, which yielded a handgun but no evidence of child pornography. The accused was arrested and indicted, but the charges were later dropped after new evidence suggested Doe had previously identified a different individual as her abuser.The accused filed a civil suit in Virginia state court, later removed to the United States District Court for the Eastern District of Virginia, alleging malicious prosecution under both state law and the Fourth Amendment. The district court dismissed the complaint under Rule 12(b)(6), finding that the plaintiff failed to plausibly allege a lack of probable cause for his arrest and prosecution, and that the detective was entitled to qualified immunity on the federal claim.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the dismissal de novo. The court held that the complaint and its exhibits did not plausibly allege that the detective acted with deliberate or reckless disregard for the truth, nor that she omitted material facts necessary to negate probable cause. The court concluded that probable cause existed based on Doe’s identification and corroborating evidence, and affirmed the district court’s dismissal of both the federal and state malicious prosecution claims. View "Moretti v. Thorsdottir" on Justia Law