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

In 2016, a suicide bombing occurred at the U.S. military base in Bagram Airfield, Afghanistan. The bomber, an Afghan national employed by a subcontractor of Fluor Corporation, detonated an explosive vest, injuring Specialist Winston Tyler Hencely, among others. Hencely sued Fluor, alleging negligence in supervision, entrustment, and retention of the bomber, and breach of contract with the U.S. Government.The U.S. District Court for the District of South Carolina granted judgment to Fluor on all claims. The court found that federal law preempted Hencely’s tort claims and that he was not a third-party beneficiary entitled to enforce the Government’s contract with Fluor. Hencely appealed these decisions.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court’s judgment, holding that the Federal Tort Claims Act’s combatant activities exception preempted Hencely’s state-law tort claims. The court concluded that Fluor was integrated into combatant activities and that the military retained command authority over Fluor’s supervision of Local Nationals at Bagram Airfield. The court also held that Hencely was not an intended third-party beneficiary of the contract between Fluor and the U.S. Government, as the contract did not express an intent to benefit individual soldiers or confer upon them the right to enforce its provisions.Thus, the Fourth Circuit affirmed the district court’s judgment, precluding Hencely’s tort claims and denying his breach of contract claim. View "Hencely v. Fluor Corporation" on Justia Law

The case involves the Republican National Committee (RNC) and the North Carolina Republican Party (NCGOP) filing two state law claims against the North Carolina State Board of Elections (State Board) and its members. The claims, one statutory and one constitutional, allege that the State Board failed to comply with the Help America Vote Act of 2002 (HAVA), which mandates certain voter registration and maintenance procedures. The Democratic National Committee (DNC) intervened as a defendant. The plaintiffs argue that the State Board's noncompliance with HAVA led to improper voter registrations, potentially affecting 225,000 voters.The United States District Court for the Eastern District of North Carolina initially reviewed the case. The district court found it had original jurisdiction over the state statutory claim but not the state constitutional claim. It dismissed the statutory claim, ruling that the relevant statutory provision did not provide a private right of action. Consequently, the district court declined to exercise supplemental jurisdiction over the state constitutional claim and remanded it to state court, also holding that Section 1443 did not provide a valid basis for removal.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the district court's remand order was improper. It found that the district court possessed original jurisdiction over the state constitutional claim under Section 1331 because the claim contained an embedded federal question. The court also determined that removal was permissible under Section 1441. Additionally, the court held that the defendants validly removed the constitutional claim pursuant to Section 1443(2), which allows for removal in cases involving the refusal to perform an act on the grounds that it would be inconsistent with laws providing for equal rights. The court reversed the district court’s remand order and remanded the case for further proceedings consistent with its opinion. View "RNC v. North Carolina State Board of Elections" on Justia Law

Four plaintiffs were injured when a railing collapsed at FedExField during a professional football game. They sued the owner of the football team, the owner of the stadium, the security services provider, and unidentified maintenance persons for negligence. The defendants moved to compel arbitration based on an arbitration clause in the terms and conditions of the tickets, which were purchased online by a friend of the plaintiffs, Brandon Gordon.The United States District Court for the District of Maryland denied the motion to compel arbitration. The court found factual disputes regarding whether Gordon agreed to the arbitration clause. Additionally, the court held that even if Gordon had agreed to the arbitration clause, the defendants did not demonstrate that Gordon was an agent of the plaintiffs who could bind them to the arbitration clause.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court reversed the district court's decision regarding the plaintiffs being bound by any contract Gordon may have entered into, finding that Gordon had apparent authority to bind the plaintiffs to the arbitration clause. The court held that the Washington Football Team's reliance on Gordon's apparent authority was reasonable and traceable to the plaintiffs' actions of using the tickets to enter the stadium. The court vacated the district court's order denying arbitration and remanded the case to resolve the factual disputes about whether Gordon entered into a contract that included the arbitration clause. View "Naimoli v. Pro-Football, Inc." on Justia Law

In 2002, Chadrick Fulks and Brandon Basham engaged in a violent crime spree across several states, including carjacking, kidnapping, and murdering Alice Donovan. They were convicted in the District of South Carolina on multiple counts, including carjacking and kidnapping resulting in death, and were sentenced to death by a jury.Fulks and Basham later filed a successive motion under 28 U.S.C. § 2255, arguing that their firearms convictions under 18 U.S.C. § 924 were invalid. They contended that their carjacking convictions under 18 U.S.C. § 2119 no longer qualified as predicate “crimes of violence” under § 924, citing the Supreme Court’s decision in United States v. Taylor, which held that attempted Hobbs Act robbery was not a crime of violence. They argued that if attempted carjacking was not a crime of violence, then completed carjacking should not be considered a predicate crime of violence either. The district court denied their motion and granted a certificate of appealability.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court’s decision. The court held that the federal carjacking statute is divisible into completed and attempted carjacking. It concluded that completed carjacking is categorically a crime of violence under § 924(c)(3)’s force clause, relying on its previous decisions in United States v. Evans and United States v. Runyon. The court found that the Supreme Court’s decision in Taylor did not undermine these precedents. Additionally, the court determined that Fulks’s and Basham’s § 924 convictions were validly predicated on their carjacking convictions, as the carjacking and kidnapping were inextricably intertwined. Therefore, the Fourth Circuit affirmed the district court’s denial of the § 2255 motion. View "US v. Fulks" on Justia Law

The case involves Warren Balogh, who participated in the "Unite the Right" rally in Charlottesville, Virginia. The rally, organized to protest the removal of a Robert E. Lee statue, quickly turned violent between protesters and counterprotesters. Balogh alleged that the Charlottesville Police, under Chief Al Thomas, and the Virginia State Police, under Lieutenant Becky Crannis-Curl, failed to protect his First and Fourteenth Amendment rights by not intervening in the violence and declaring an unlawful assembly, which he claimed amounted to a heckler's veto.The United States District Court for the Western District of Virginia dismissed Balogh's complaint under Federal Rule of Civil Procedure 12(b)(6). The court found that the defendants were entitled to qualified immunity because there was no clearly established right to police intervention to protect First Amendment rights from third-party violence. The court also held that Balogh failed to state a plausible claim for relief under the First and Fourteenth Amendments, noting that the police did not selectively enforce the unlawful assembly order and that Balogh's allegations of intentional discrimination were conclusory.The United States Court of Appeals for the Fourth Circuit affirmed the district court's dismissal. The Fourth Circuit held that the First Amendment does not obligate police to protect protesters' constitutional rights amid violence, explicitly stating that the First Amendment is a shield against invasive speech regulations, not a sword to wield against violent disruptions. The court also found that Balogh's equal protection claim under the Fourteenth Amendment failed because he did not provide sufficient facts to show intentional or purposeful discrimination. Additionally, the court rejected Balogh's Monell claim against the City of Charlottesville, as he did not demonstrate that the City Manager, the final policymaker, had ratified or delegated authority to Chief Thomas. View "Balogh v. Virginia" on Justia Law

In 2000, Antonio Lamont Lightfoot was convicted by a jury in the District of Maryland for bank robbery and using a firearm during a crime of violence. The government identified two prior convictions for serious violent felonies: a 1985 armed bank robbery in Virginia and a 1990 armed bank robbery in Michigan. Consequently, Lightfoot was sentenced to mandatory life imprisonment under the federal "three-strikes" law, 18 U.S.C. § 3559(c), and an additional seven years for the firearm charge. His convictions and sentence were affirmed on appeal, and subsequent collateral challenges were unsuccessful.Following the Supreme Court's 2015 decision in Johnson v. United States, which invalidated the residual clause of the Armed Career Criminal Act (ACCA) as unconstitutionally vague, Lightfoot sought to vacate his sentence under 28 U.S.C. § 2255. He argued that the residual clause of the "serious violent felony" definition in 18 U.S.C. § 3559(c) was similarly void for vagueness. The district court denied his motion, holding that Michigan bank robbery is a divisible offense and that Lightfoot was convicted of the assaultive version, which qualifies as a serious violent felony under the enumerated offenses clause.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The court affirmed the district court's decision, concluding that Michigan's bank robbery statute is divisible into assaultive and non-assaultive offenses. Lightfoot was convicted of the assaultive version, which involves taking from another by force or intimidation. The court held that this offense qualifies as a serious violent felony under the enumerated offenses clause of the federal three-strikes law, 18 U.S.C. § 3559(c)(2)(F)(i). Therefore, Lightfoot's life sentence was upheld. View "United States v. Lightfoot" on Justia Law

Alvin Johnson pled guilty to possession with intent to distribute cocaine under a plea agreement. The agreement included a stipulation regarding the drug quantity and its base offense level but allowed the Government to make a sentencing recommendation. Johnson was initially sentenced to 128 months in prison, classified as a career offender based on prior convictions. He later successfully challenged one of these convictions, leading to a recalculated Guidelines range of 57-71 months.The United States District Court for the Eastern District of North Carolina initially sentenced Johnson to 128 months. Upon remand, after Johnson's successful challenge to his career offender status, the Probation Office recalculated his Guidelines range to 57-71 months. The Government then moved for an upward departure or variance, arguing that Johnson's criminal history warranted a higher sentence. The district court agreed and sentenced Johnson to 120 months.The United States Court of Appeals for the Fourth Circuit reviewed the case. Johnson argued that the Government breached the plea agreement by seeking a sentence above the recalculated Guidelines range. The court found that the plea agreement did not restrict the Government from recommending a higher sentence and that the Government had reserved the right to make a sentencing recommendation. The court held that the Government did not breach the plea agreement and affirmed the 120-month sentence. View "United States v. Johnson" on Justia Law

The case involves eight multiemployer benefit plans (the "Funds") seeking to recover delinquent contributions from Stromberg Metal Works, Inc. for health, pension, and other benefits for sheet metal workers. The Funds allege that Stromberg underpaid contributions owed under a collective bargaining agreement (CBA) with the Sheet Metal, Air, Rail and Transportation Union (SMART Union) by hiring temporary workers through staffing agencies without making the required contributions.Initially filed in the Middle District of Tennessee, the case was transferred to the Eastern District of North Carolina. The district court denied Stromberg’s motion for summary judgment, granted the Funds’ cross-motion for summary judgment, and awarded the Funds over $823,000 in delinquent contributions and more than $430,000 in liquidated damages and interest. Stromberg appealed, challenging both the liability and damages rulings.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court’s liability ruling, agreeing that the 2019 Settlement between Stromberg and Local 5 did not preclude the Funds from seeking delinquent contributions. The court emphasized that multiemployer benefit plans have distinct interests from local unions and are not bound by settlements to which they are not parties.However, the Fourth Circuit vacated the district court’s damages ruling. The appellate court concluded that while the Funds could rely on the CBA’s default staffing ratio to approximate damages due to Stromberg’s failure to maintain adequate records, Stromberg had presented sufficient evidence to cast doubt on the accuracy of the Funds’ damages calculation. The case was remanded for further proceedings to address the disputed damages issue. View "Sheet Metal Workers' Health & Welfare Fund of North Carolina v. Stromberg Metal Works, Inc." on Justia Law

Tijuana Decoster, an African American, served as the Chief Grants Management Officer for the National Institute of Neurological Disorders & Stroke at the U.S. Department of Health and Human Services (HHS). Her working relationship with her supervisor, Robert Finkelstein, deteriorated in 2019, leading to allegations of racial discrimination. Decoster claimed Finkelstein singled her out, treated her with contempt, and threatened to fire her. She was issued a Letter of Expectation and placed on an Opportunity to Demonstrate Acceptable Performance plan. Despite her complaints to Human Resources and Finkelstein, the alleged harassment continued, leading Decoster to retire in February 2020.Decoster filed a formal discrimination complaint with the National Institutes of Health (NIH) in December 2019, alleging harassment, discrimination based on race, and retaliation. NIH's Final Agency Decision in November 2020 found that Decoster was subjected to retaliation but denied her other claims. Decoster then filed a complaint in the District of Maryland, raising three claims under Title VII: hostile work environment, constructive discharge, and retaliation. The district court dismissed her complaint for failure to state a claim under Fed. R. Civ. P. 12(b)(6).The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the dismissal of Decoster’s hostile work environment and constructive discharge claims, finding that her allegations did not establish severe or pervasive conduct or intolerable working conditions. However, the court reversed the dismissal of her retaliation claim, holding that Decoster had sufficiently stated a plausible claim of retaliation under Title VII. The case was remanded for further proceedings on the retaliation claim. View "Decoster v. Becerra" on Justia Law

Two plaintiffs, Smith-Phifer and Patterson, served with the Charlotte Fire Department for over twenty years and alleged racial discrimination by the department. They filed a lawsuit against the City of Charlotte, claiming violations of Title VII, 42 U.S.C. §§ 1981 & 1983, and the North Carolina Constitution. The case was initially brought in state court but was removed to federal court. Smith-Phifer and the City reached a settlement during her trial, while Patterson's case was delayed due to illness and later went to mediation.The United States District Court for the Western District of North Carolina granted Smith-Phifer and Patterson’s motions to enforce their settlement agreements. The court found that the City breached the agreements by not treating the settlement payments as pension-eligible wages under the Charlotte Firefighters Retirement Systems Act. The City appealed, arguing that the district court erred in its decision, particularly in not holding an evidentiary hearing for Patterson’s case and in its interpretation of the settlement terms regarding pension eligibility.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court vacated the district court’s order regarding Patterson, stating that an evidentiary hearing was necessary to determine whether a complete settlement agreement was reached. The court found that there were unresolved factual disputes about the terms of the agreement, particularly regarding sick leave and pension eligibility.However, the court affirmed the district court’s decision regarding Smith-Phifer. It held that the City breached the settlement agreement by failing to make the required retirement deduction from the payment to Smith-Phifer. The court concluded that the payment was “Compensation” under the Charlotte Firefighters Retirement Systems Act, which mandated the deduction. The case was remanded for further proceedings consistent with these findings. View "Smith-Phifer v. City of Charlotte" on Justia Law