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

A decorated Army sergeant was convicted in Virginia after pleading guilty to two counts of malicious wounding and other charges stemming from separate incidents occurring on a single day in March 2011. At the time, he had recently returned home from combat in Afghanistan, where he had suffered multiple serious injuries, including two traumatic brain injuries. His crimes included shooting a woman during an altercation and, later that day, assaulting a man in a bar. He received a sentence of 46 years, well above the state’s discretionary sentencing guidelines.On direct appeal, the Court of Appeals of Virginia and the Supreme Court of Virginia both affirmed his convictions and sentence, finding no error in the sentencing court’s weighing of mitigating evidence. The defendant then pursued state habeas relief in the Circuit Courts for the City and County of Roanoke, arguing ineffective assistance of counsel under the Sixth Amendment. He contended his lawyer failed to present readily available mitigating evidence, including details of his military service, combat injuries, mental health struggles (especially PTSD), and failed to object to the use of his expunged juvenile criminal record. The state court denied relief, concluding there was no prejudice, and the Supreme Court of Virginia summarily refused further appeal.In subsequent federal habeas proceedings under 28 U.S.C. § 2254, the United States District Court for the Western District of Virginia denied relief, holding that the state decision was not contrary to or an unreasonable application of federal law.The United States Court of Appeals for the Fourth Circuit reversed. The court held that the state court applied the wrong legal standard for prejudice under Strickland v. Washington, failed to consider the totality of available mitigating evidence, and that there was a reasonable probability of a different sentence had counsel performed adequately. The case was remanded with instructions to grant a writ of habeas corpus unless the Commonwealth provides plenary resentencing within a reasonable time. View "Coleman v. Dotson" on Justia Law

During the COVID-19 pandemic, an employer instituted a company-wide vaccine mandate that applied to all employees, including those working remotely. Two remote employees requested religious exemptions from the vaccine requirement. One objected on the basis of her Christian beliefs regarding the use of fetal cell lines in vaccine development, while the other cited her conscience and faith, referencing Catholic teachings. Both exemption requests were denied, and the employees were subsequently terminated.After their terminations, the two employees initiated a lawsuit in the United States District Court for the District of Maryland. Their claims included religious discrimination under Title VII of the Civil Rights Act and two disability discrimination claims under the Americans with Disabilities Act (ADA): one for unlawful medical inquiry and one for being “regarded as” disabled due to their unvaccinated status. The district court dismissed all claims, concluding that the plaintiffs had not sufficiently pleaded that their objections were based on religious beliefs and finding that neither ADA theory was viable because vaccination status is not equivalent to a disability.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s decision de novo. The Fourth Circuit held that the plaintiffs’ complaints plausibly alleged that their opposition to the vaccine mandate was an essential part of their religious faith and that their refusal to be vaccinated was connected to those beliefs. Therefore, the court found that the district court erred in dismissing the Title VII religious discrimination claims at the pleading stage. However, the Fourth Circuit affirmed the dismissal of both ADA claims, holding that an inquiry into vaccination status is not a disability-related inquiry and that being unvaccinated does not constitute a physical or mental impairment under the ADA. The case was affirmed in part, vacated in part, and remanded for further proceedings on the Title VII claims. View "Finn v. Humane Society of the United States" on Justia Law

The defendant was convicted by a jury in 2002 on multiple federal drug and firearm charges, receiving a lengthy sentence. He unsuccessfully challenged his convictions and sentence through direct appeals and several motions for habeas relief under 28 U.S.C. § 2255, including claims of ineffective assistance, vindictive prosecution, and arguments based on later Supreme Court rulings. After a First Step Act sentence reduction in 2019, which resulted in an amended judgment and a reduced sentence, the defendant filed another pro se § 2255 motion in 2022, arguing that he was actually innocent of one of his firearm convictions because both firearm offenses occurred as part of the same drug conspiracy.The United States District Court for the District of South Carolina dismissed the defendant’s 2022 habeas motion on two alternative grounds: first, that it was an unauthorized “second or successive” motion because a First Step Act sentence reduction does not create a “new judgment” for purposes of AEDPA; and second, that it was untimely under the one-year limitations period, with no basis for equitable tolling. The district court found that even if the motion was not successive, it was still time-barred, and the merits of his claim did not justify tolling.The United States Court of Appeals for the Fourth Circuit reviewed only the question of whether a First Step Act sentence reduction results in a “new judgment” under AEDPA, having denied the defendant’s request to expand the appeal to include the timeliness issue. The Fourth Circuit held that, because the district court’s alternative ruling of untimeliness was not appealable and would remain unaffected regardless of the outcome on the “new judgment” issue, the court had no ability to redress the defendant’s injury. As a result, the appeal was dismissed as moot. View "United States v. Robinson" on Justia Law

David Ray Gunter, who had a mechanical heart valve and required daily anticoagulant medication (Coumadin), was arrested and detained at two North Carolina county jails. During his detention, Gunter did not consistently receive his prescribed medication, missing doses over several days due to failures by the contracted medical provider and jail staff. After his release, he suffered serious medical complications, including blood clots and subsequent surgeries. Gunter alleged these injuries were the result of inadequate medical care during his incarceration.The United States District Court for the Middle District of North Carolina granted summary judgment for defendants on Gunter’s constitutional claims under 42 U.S.C. § 1983, including deliberate indifference and Monell claims, finding insufficient evidence that jail officials or contracted medical providers acted with deliberate indifference or that county policies caused the deprivation. The district court also granted summary judgment to Southern Health Partners, Inc. (SHP) on the medical malpractice claim, finding that Gunter’s expert testimony did not establish a breach of the standard of care by SHP, and excluded expert evidence it found speculative. However, the district court found genuine disputes of fact regarding medical malpractice claims against two individual medical providers, but ultimately found no proximate cause. The district court denied Gunter’s motion to compel deposition of the defendants’ expert as untimely and granted a motion to strike a post-deposition declaration from Gunter’s expert.The United States Court of Appeals for the Fourth Circuit reversed the district court’s dismissal of Gunter’s deliberate indifference claim against the medical provider defendants, the Monell claim against the counties, and the medical malpractice claims against SHP and two medical providers, holding that genuine disputes of material fact remained. The appellate court also reversed the exclusion of certain expert testimony and the grant of the motion to strike, but affirmed the denial of the motion to compel. The case was remanded for further proceedings. View "Swink v. Southern Health Partners Inc." on Justia Law

A native and citizen of Honduras entered the United States without authorization in 2019, seeking protection from removal based on claims of past persecution and a likelihood of future harm by the MS-13 gang. He described a series of violent incidents involving MS-13, including the murders of two brothers, threats, extortion attempts, and physical assaults. The petitioner asserted that reporting these incidents to Honduran authorities would have been futile or dangerous due to widespread corruption and gang infiltration of law enforcement. He also provided evidence that MS-13 continued to search for him and his family after he fled Honduras.Removal proceedings were initiated in 2023. The Immigration Judge (IJ) found the petitioner credible but denied his applications for withholding of removal and protection under the Convention Against Torture (CAT). The IJ concluded that the petitioner had not shown the Honduran government was unable or unwilling to control MS-13, partly because he had not reported the incidents to police and because police responded to his brothers’ murders. The IJ also determined that the petitioner had not demonstrated he could not reasonably relocate within Honduras to avoid harm, and that he had not established a likelihood of torture with government acquiescence. The Board of Immigration Appeals (BIA) affirmed the IJ’s decision, finding no clear error in the IJ’s analysis and dismissing the appeal.The United States Court of Appeals for the Fourth Circuit reviewed both the IJ’s and BIA’s decisions. The court held that the IJ and BIA abused their discretion by disregarding credible, unrebutted, and legally significant evidence that reporting to authorities would have been futile or dangerous, and by failing to meaningfully engage with country condition evidence of government corruption and gang control. The court vacated the BIA’s decision and remanded for further proceedings, holding that the record compelled the conclusion that the Honduran government was unable or unwilling to control MS-13 and that the petitioner could not reasonably relocate to avoid persecution. The court also found that the agency failed to properly consider evidence relevant to CAT relief. View "Marquez v. Bondi" on Justia Law

A corporation, formed as a captive insurance company in North Carolina, was owned by three shareholders who also served as its directors. The majority shareholder, who was not involved in daily operations, alleged that the two minority shareholders, who managed the company, and a Chief Technology Officer (CTO) hired to develop proprietary software, conspired to create a competing insurance entity. The proprietary software in question was designed to analyze medical records and price insurance contracts more effectively, and was claimed to be confidential and of significant economic value. All employees, including the CTO and the minority shareholders, were required to sign employment contracts containing confidentiality and invention provisions, which specified that inventions and confidential information developed during employment would be the exclusive property of the company.The plaintiffs filed suit in the United States District Court for the Eastern District of North Carolina, alleging, among other claims, that the defendants misappropriated trade secrets in violation of the Defend Trade Secrets Act (DTSA). The defendants moved for judgment on the pleadings. The district court granted the motion as to the DTSA claim, finding that the plaintiffs had not sufficiently alleged that they took reasonable measures to protect the secrecy of the proprietary software. The court declined to exercise supplemental jurisdiction over the remaining state law claims. The plaintiffs appealed the dismissal of the DTSA claim.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s decision de novo. The Fourth Circuit held that the plaintiffs had plausibly alleged ownership of a trade secret, reasonable measures to protect its secrecy through confidentiality agreements, and misappropriation by the defendants. The court concluded that, at the pleading stage, the existence of confidentiality and invention provisions was sufficient to allege reasonable efforts to maintain secrecy. The Fourth Circuit reversed the district court’s dismissal of the DTSA claim and remanded for further proceedings. View "Samuel Sherbrooke Corporate, Ltd v. Mayer" on Justia Law

In this case, the defendant applied for U.S. citizenship in 2011 and, on his application and during an interview, denied ever having committed a crime for which he was not arrested. However, in 2013, he pleaded guilty in North Carolina state court to attempted statutory rape for conduct that occurred in 2008, admitting to engaging in a sexual act with a minor. He did not disclose this conduct on his naturalization application. Years later, a federal grand jury indicted him for naturalization fraud, alleging he knowingly concealed his criminal history to obtain citizenship.The United States District Court for the Western District of North Carolina denied the defendant’s motion to dismiss the indictment for unconstitutional preindictment delay, finding he had not shown actual prejudice from the delay. The court also denied his motion to suppress evidence of his state guilty plea, ruling that he could not collaterally attack the validity of his state conviction in federal court except for a deprivation of counsel, which did not apply here. At trial, the court limited the testimony of the defendant’s expert witness regarding his cognitive abilities, excluding certain opinions about his capacity to understand the application question. The jury convicted the defendant, finding he knowingly made a false statement, and the court sentenced him to six months in prison and revoked his citizenship.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The Fourth Circuit held that the defendant failed to demonstrate substantial actual prejudice from the preindictment delay, that the district court properly refused to suppress the state guilty plea, and that while the limitation of the expert’s testimony was error under recent Supreme Court guidance, the error was harmless given the other evidence presented. The conviction and sentence were therefore affirmed. View "US v. Palmer" on Justia Law

Three individuals, all Cameroonian Americans, participated in a secretive group dedicated to sending firearms and ammunition from Maryland to Anglophone fighters in Cameroon. The group, known as the “Peanut Project,” operated out of a basement in Baltimore County, where they assembled, modified, and packaged weapons and ammunition for overseas shipment. Their concealment methods included obliterating serial numbers from firearms and hiding the items within compressor tanks and other cargo. In 2019, law enforcement intercepted a shipping container en route to Nigeria containing over 35,000 rounds of ammunition and 39 firearms, many with defaced serial numbers. A subsequent search of the group’s base revealed a full-scale operation for manufacturing and preparing firearms for export.A federal grand jury in the United States District Court for the District of Maryland indicted the defendants on five counts, including conspiracy, illegal exportation, transportation of firearms with obliterated serial numbers, and smuggling. After a ten-day jury trial, the defendants were convicted of conspiracy, transporting firearms with obliterated serial numbers, and smuggling, but acquitted on the exportation counts. The district court denied post-trial motions challenging the sufficiency of the evidence and various trial rulings. At sentencing, the court applied enhancements for the number of firearms involved and for trafficking, sentencing each defendant to 63 months’ imprisonment and two years of supervised release.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the convictions and sentences. The court held that the evidence was sufficient to support the jury’s findings, the district court did not abuse its discretion in evidentiary or instructional rulings, and the sentencing enhancements were properly applied. The court also found no error in the oral and written pronouncement of supervised release conditions. The judgments of the district court were affirmed. View "US v. Nji" on Justia Law

Several individuals associated with the Reccless Tigers, a Northern Virginia-based drug gang, were charged with a range of offenses, including drug trafficking, racketeering, kidnapping, and murder. The gang was involved in distributing marijuana and cocaine, and members targeted those who failed to pay drug debts or cooperated with law enforcement. The case centered on the murder of Brandon White, who owed a drug debt and had testified against a gang member. Evidence showed that gang members, including the defendants, orchestrated White’s abduction and murder, with some directly participating in the killing.The United States District Court for the Eastern District of Virginia presided over a joint trial. The court denied several pretrial motions, including requests for continuances, motions to substitute counsel, and a motion to dismiss based on alleged violations of the Speedy Trial Act and the Sixth Amendment. The jury convicted three defendants—Lamborn, Yoo, and Peter—of racketeering conspiracy, murder in aid of racketeering, kidnapping conspiracy, kidnapping resulting in death, drug conspiracy, and killing while engaged in drug trafficking, with Lamborn also convicted of using a firearm resulting in death. Tony was convicted of racketeering and drug conspiracy but acquitted of destructive device charges. The court sentenced Lamborn, Yoo, and Peter to life imprisonment and Tony to 312 months.The United States Court of Appeals for the Fourth Circuit reviewed the case. It affirmed the convictions and most sentences, finding no abuse of discretion in the denial of continuances or substitution of counsel, and sufficient evidence supported the convictions. The court also upheld the district court’s application of sentencing enhancements and rejected the Speedy Trial Act and Sixth Amendment claims. However, it vacated the sentences of Lamborn, Yoo, and Peter due to inconsistencies between the oral pronouncement and written judgments regarding supervised release conditions, remanding for resentencing on that issue. View "US v. Lamborn" on Justia Law

Law enforcement stopped a vehicle in which Michael Henderson was a passenger. During a search, a K-9 alerted to drugs in Henderson’s bag, which contained approximately 1,921.2 grams of pure methamphetamine. Henderson was arrested, and while in jail, he made phone calls instructing associates on drug distribution using coded language. One associate, Bonnie Cagle, revealed to police that Henderson’s references to “puppies” were code for firearms, and “sockets” and “tools” referred to drugs. Police recovered two firearms linked to Henderson from Cagle and her mother’s home.Henderson pleaded guilty in the United States District Court for the Southern District of West Virginia to possessing 500 grams or more of methamphetamine with intent to distribute. The presentence investigation report initially recommended a two-level enhancement for possession of a firearm, but after Henderson’s timely objection and the government’s lack of response, the probation officer removed the enhancement. The revised report also recommended a reduction for acceptance of responsibility. The district court later requested supplemental briefing on Henderson’s eligibility for “safety valve” relief under 18 U.S.C. § 3553(f). The government then argued for sentencing enhancements and against the reduction for acceptance of responsibility, which Henderson claimed were untimely.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the district court acted within its discretion in considering the government’s late arguments for sentencing enhancements, finding that the request for supplemental briefing constituted good cause. The court also found sufficient evidence to support the firearm enhancement, concluding that Henderson constructively possessed firearms in connection with drug trafficking. The court affirmed the district court’s judgment, upholding Henderson’s sentence. View "US v. Henderson" on Justia Law