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

A married couple, acting on behalf of their minor child, challenged West Virginia’s compulsory vaccination law after their daughter was disenrolled from a public virtual school because she was not fully vaccinated. The parents sought a religious exemption from the vaccination requirement, but were informed that only medical exemptions—based on specific medical contraindications or precautions certified by a physician—are permitted under state law. After being denied a religious exemption, the parents filed suit, claiming that the absence of a religious exemption violated their First Amendment right to freely exercise their Christian faith. They requested a preliminary injunction to allow their daughter’s re-enrollment in the virtual academy during the litigation.The United States District Court for the Northern District of West Virginia granted the preliminary injunction, finding that the parents were likely to succeed on their free exercise claim. The district court applied the test from Employment Division, Department of Human Resources of Oregon v. Smith, concluding that the vaccination law was not generally applicable, and thus subject to strict scrutiny, which it found the law did not survive.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s grant of preliminary relief. The Fourth Circuit held that West Virginia’s compulsory vaccination law is a neutral and generally applicable measure enacted under the state’s police power to protect public health, as recognized in longstanding Supreme Court precedent including Jacobson v. Massachusetts and Prince v. Massachusetts. The court found that the medical exemption process does not constitute a “mechanism for individualized exemptions” that would undermine general applicability under cases such as Fulton v. City of Philadelphia. The Fourth Circuit concluded that the law is subject to rational basis review, which it easily satisfies, and that the Free Exercise Clause does not require religious exemptions simply because medical exemptions exist. The court reversed the district court’s preliminary injunction and remanded the case. View "Perry v. Marteney" on Justia Law

A miner filed a claim for benefits under the Black Lung Benefits Act, asserting total disability due to lung disease following over two decades of coal mine employment. The miner had a significant history of cigarette smoking, but no evidence of clinical pneumoconiosis was present. The dispute centered on whether his disabling pulmonary impairment—despite his smoking history—was legally attributable to his coal mine dust exposure.An Administrative Law Judge (ALJ) first reviewed the claim and found that the miner had worked in coal mines for 27 years and suffered from a totally disabling pulmonary impairment. These facts entitled the miner to a statutory presumption that his disability was caused by pneumoconiosis. The ALJ determined that the mining company, as the responsible employer, failed to rebut this presumption. The ALJ discredited the employer’s medical experts, who attributed the impairment solely to smoking, because their opinions did not properly consider the additive effects of smoking and coal dust, as recognized by the Department of Labor’s Preamble to its Black Lung regulations. The Benefits Review Board affirmed the ALJ’s decision.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the ALJ correctly applied the law by requiring the employer to rebut the presumption, and properly evaluated the medical evidence in light of the regulatory guidance. The court found that the ALJ’s decision was supported by substantial evidence and that there was no legal error in the treatment of expert opinions or the regulatory preamble. The Fourth Circuit denied the mining company’s petition for review, leaving the award of benefits to the miner in place. View "Wolf Run Mining Company v. DOWCP" on Justia Law

The defendant pleaded guilty to transporting child sexual abuse material and was sentenced to 144 months in prison. Upon release, he was placed on lifetime supervised release with a special condition prohibiting access to any pornographic material, including legal pornography. The defendant repeatedly violated conditions of his supervised release, resulting in multiple revocations and returns to prison. Each time he was released, similar conditions were imposed. The defendant later consented to a special condition that barred him from viewing or possessing any visual depiction of sexually explicit conduct on electronic devices, but later contested the imposition of a broader ban.After the defendant’s initial appeal, the United States Court of Appeals for the Fourth Circuit (in Castellano I) vacated the district court’s imposition of the pornography ban, finding it was not supported by individualized evidence, and remanded with instructions to strike the special condition. The district court complied. However, after subsequent violations and revocations, the government requested a new special condition banning all pornography, this time presenting testimony and a written evaluation from the defendant’s treatment provider, who offered individualized clinical reasons for the restriction based on years of treating the defendant.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed whether the district court abused its discretion in imposing the pornography ban. The court held that the special condition was supported by individualized evidence specific to the defendant and his treatment needs. The court further held that neither the mandate rule from Castellano I nor other legal doctrines barred the district court from imposing the new condition in light of changed circumstances and new evidence. The judgment of the district court was affirmed. View "US v. Castellano" on Justia Law

Four football players who had previously attended junior colleges (JUCOs) and then transferred to a Division I university challenged the NCAA’s “JUCO Rule.” This rule treats time spent and games played at JUCOs as counting toward limits on athletes’ eligibility to play NCAA sports—specifically, a five-year window to play four seasons. The NCAA had recently issued a temporary waiver (the “Pavia waiver”) that relaxed the rule regarding the number of seasons, but not the five-year limit. The plaintiffs, having enrolled in college over five years earlier, were rendered ineligible for the 2025–26 season under the rule, even with the waiver. After their requests for an NCAA waiver were denied, the players sued, alleging the rule violated the Sherman Act and state law.The United States District Court for the Northern District of West Virginia granted a preliminary injunction, allowing the players to participate for the 2025–26 season. The NCAA appealed, and the Fourth Circuit requested additional briefing on mootness since the 2025–26 season had ended. The circuit court found the case was not moot because the dispute was capable of repetition yet evading review, especially as one player had already sought a waiver for the following season.The United States Court of Appeals for the Fourth Circuit vacated the preliminary injunction and remanded the case. The court held that the district court erred by applying an abbreviated “quick look” analysis instead of the full “rule of reason” required under the Sherman Act for this type of eligibility rule. The circuit court further found that the district court failed to make adequate factual findings regarding the relevant market, as required for antitrust analysis. The court concluded that the players had not met their burden for a preliminary injunction, and the district court’s order was therefore vacated and remanded for further proceedings. View "Robinson v. National Collegiate Athletic Association" on Justia Law

A company that designs and manufactures interactive technology products entered into reseller agreements with another company, granting the latter exclusive rights to sell its products in certain territories. Several years later, the manufacturer revoked the exclusivity, after which the reseller’s owner and his son developed a competing product. The manufacturer then terminated the reseller relationship. Subsequently, the reseller sued the manufacturer in South Carolina state court for various business torts and contract claims. The parties settled and executed a written agreement that broadly released and dismissed any and all claims and counterclaims that could have been brought in the litigation, including through a specific handwritten provision. Nevertheless, shortly after, the manufacturer initiated a federal lawsuit, alleging intellectual property violations related to the competing product.The state court dismissed the original action with prejudice, including all possible claims and counterclaims. In the federal action, the defendants argued that the settlement agreement and res judicata barred the new claims. The United States District Court for the District of South Carolina initially allowed certain claims to proceed, but after further evidence and reconsideration, it granted summary judgment for the defendants, finding the claims precluded by the settlement and the state court’s dismissal. A jury was then impaneled for trial on the defendants’ counterclaims.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s rulings. The Court of Appeals held that the manufacturer’s claims were barred by res judicata based on the settlement and state court order, as the language of the agreement and the parties’ intent encompassed the intellectual property claims. The appellate court also found no abuse of discretion in the district court’s evidentiary rulings, its reconsideration of summary judgment, or the conduct of the trial, and affirmed the judgment in full. View "Clear Touch Interactive, Inc. v. The Ockers Company" on Justia Law

A group of pharmaceutical manufacturers that participate in the federal 340B drug pricing program challenged a new West Virginia law, S.B. 325, which imposed restrictions and penalties on manufacturers regarding the delivery of discounted drugs to contract pharmacies. The 340B program is a federal scheme where drug manufacturers provide discounts to designated health care providers (“covered entities”) in exchange for access to the Medicaid market. Dissatisfied with the federal program’s scope, West Virginia enacted S.B. 325, which specifically barred manufacturers from restricting delivery of 340B drugs to any location authorized by a covered entity (including contract pharmacies), and from requiring data submission as a condition for delivery, with significant penalties for violations.The manufacturers sued in the United States District Court for the Southern District of West Virginia seeking to enjoin enforcement of S.B. 325, arguing that it was preempted by federal law. The district court found that the manufacturers were likely to succeed on the merits of their preemption claim, that they faced irreparable harm, and that the balance of equities and public interest favored injunctive relief. The court granted a preliminary injunction against enforcement of the statute.On appeal, the United States Court of Appeals for the Fourth Circuit addressed whether S.B. 325 was preempted by federal law. The Fourth Circuit held that S.B. 325 likely interferes with the federal 340B program by imposing additional conditions on manufacturers solely because of their participation in a federal program, thereby intruding into a domain reserved for federal regulation. The court found that Congress had struck a careful bargain in the 340B program and that West Virginia’s law sought to alter that bargain in a way that conflicted with federal objectives and the enforcement scheme administered by the Department of Health and Human Services. The Fourth Circuit affirmed the district court’s preliminary injunction, barring enforcement of S.B. 325. View "Pharmaceutical Research & Manufacturers of America v. McCuskey" on Justia Law

The case concerns a defendant who pleaded guilty to two drug offenses and was sentenced in the United States District Court for the Eastern District of North Carolina. During the sentencing hearing, the court orally pronounced certain discretionary conditions for supervised release, including a condition regarding warrantless searches. The court stated that such searches would be allowed only upon reasonable suspicion of a violation or, without suspicion, for safety issues. Later that day, the court entered a written judgment that imposed broader conditions, permitting warrantless searches by probation officers as part of their general supervision functions, without limiting such searches to the occasions described orally.After sentencing, the defendant appealed, arguing that the written judgment contained conditions of supervised release that materially differed from those announced in open court. The government raised several arguments in response, including claims about waiver and harmlessness, and noted that the written condition matched the presentence report’s recommendation, which the defendant had not objected to. The United States Court of Appeals for the Fourth Circuit reviewed these arguments de novo, consistent with its precedent.The Fourth Circuit held that there was a material discrepancy between the oral pronouncement and the written judgment regarding the scope of warrantless searches, which constituted error under its Rogers–Singletary line of cases. The court rejected the government’s arguments that the error was harmless or waived by the plea agreement, emphasizing that the oral pronouncement controls and that a defendant has standing to challenge such discrepancies. Accordingly, the Fourth Circuit vacated the judgment and remanded the case for resentencing. View "United States v. Tostado" on Justia Law

While incarcerated at Augusta Correctional Center in Virginia, Daniel Jackson, proceeding without an attorney, filed a complaint using a standard prisoner form. He named the prison’s medical department and two healthcare providers as defendants, describing his medical condition and alleging a series of events: the confiscation of his prescribed ankle sleeve, the denial of a lower bunk assignment despite his medical needs, and pain caused by required work footwear. Jackson also claimed he was denied proper physical therapy and pain medication, and asserted that one nurse suggested he acquire drugs illicitly. His complaint sought compensation for lost wages, treatment for his pain, and damages for suffering.The United States District Court for the Western District of Virginia screened the complaint under 28 U.S.C. § 1915A. It construed the action as asserting Eighth Amendment deliberate indifference claims against the individual healthcare providers, dismissing the prison medical department as an improper defendant under § 1983. After allowing Jackson to supplement his complaint with additional allegations—such as retaliation by one nurse—the district court recognized both deliberate indifference and First Amendment retaliation claims. The retaliation claim was dismissed for lack of plausible causation. Ultimately, the district court granted summary judgment for the defendants on the deliberate indifference claims, finding no genuine disputes of material fact regarding the adequacy of medical care provided.Jackson, now represented by counsel, appealed to the United States Court of Appeals for the Fourth Circuit. He argued that the district court should have construed his complaint to assert a claim under the Americans with Disabilities Act (ADA). The Fourth Circuit held that the district court did not err in construing Jackson’s complaint as presenting only an Eighth Amendment claim, emphasizing that courts must liberally construe pro se pleadings but are not required to identify every conceivable claim. The judgment in favor of the defendants was affirmed. View "Jackson v. Dameron" on Justia Law

The plaintiff, a long-term employee of a company in Virginia, reported concerns to his supervisor about violations related to overtime compensation. After raising these concerns and authoring a letter outlining managerial failures that affected employee compensation, the plaintiff was terminated by his supervisor and the plant manager. He then brought suit in Virginia state court against both individuals, who he alleged were Virginia citizens, claiming they violated public policy as set forth in Virginia law prohibiting retaliation for discussing wage information.The defendants removed the case to the United States District Court for the Western District of Virginia, asserting diversity jurisdiction. They argued that one defendant was not a Virginia citizen and that the other, the supervisor, was fraudulently joined to defeat diversity jurisdiction. The district court agreed, finding there was no possibility that the plaintiff could state a viable claim against the supervisor under the relevant public policy exception to at-will employment recognized in Bowman v. State Bank of Keysville. On that basis, the district court denied the plaintiff’s motion to remand and dismissed the complaint for failure to state a claim.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s decision de novo. It held that the standard for finding fraudulent joinder was not met because it was not impossible for the plaintiff to establish a claim against the nondiverse defendant under state law; there was uncertainty in Virginia law as to whether a Bowman claim could be brought on these facts. As a result, the Fourth Circuit vacated the district court’s denial of remand and its dismissal of the complaint, and remanded the case for further proceedings. The court’s main holding was that the district court erred in finding fraudulent joinder and retaining jurisdiction. View "Skidmore v. Schinke" on Justia Law

The case concerns a petitioner who was convicted in West Virginia state court in 2004 of sexually abusing his son. After the trial, it was discovered that, during jury deliberations, one juror told others that he knew the petitioner’s family and feared for his own family’s safety if the petitioner was acquitted. Four jurors later confirmed that the comments had been made, though the juror in question denied them. The petitioner argued this introduced an impermissible external influence into the deliberations, violating his right to an impartial jury.The trial court in West Virginia denied the petitioner’s request for a new trial, finding insufficient evidence of juror impartiality and concluding that the statements related only to the jury’s deliberative process, not to any external influence. The Supreme Court of Appeals of West Virginia affirmed this decision, holding that the comments were intrinsic to the deliberations and thus not grounds to set aside the verdict. The petitioner then sought federal habeas relief under 28 U.S.C. § 2254 in the United States District Court for the Southern District of West Virginia, which denied his petition, concluding the state court had not unreasonably applied Supreme Court precedent.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s denial of habeas relief de novo but applied the deferential standard required by § 2254. The Fourth Circuit held that the state court did not unreasonably apply clearly established Supreme Court law in finding that the juror’s comments were intrinsic, not external, to the deliberation process. The court concluded that, under existing Supreme Court precedent, the statements did not rise to the level of external influence necessary to violate the petitioner’s Sixth Amendment rights. Accordingly, the Fourth Circuit affirmed the district court’s judgment denying habeas relief. View "Daugherty v. Dingus" on Justia Law