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

The case involves multiple plaintiffs who sued Khalifa Hifter under the federal Torture Victim Protection Act for his actions as the commander of the Libyan National Army. The plaintiffs sought to hold Hifter liable for alleged torture and extrajudicial killings of their family members in Libya. The lawsuits were filed in the United States District Court for the Eastern District of Virginia over a 15-month period.In the district court, Hifter moved to dismiss the first two cases, and the court granted those motions in part and denied them in part. Hifter later moved to dismiss the third case, and the court again granted the motion in part and denied it in part. The district court eventually consolidated all three cases for discovery and pretrial matters. After cross-motions for summary judgment, the district court dismissed all three suits with prejudice, citing lack of personal jurisdiction over Hifter.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court dismissed Hifter’s cross appeals in Nos. 24-1425, 24-1427, and 24-1429, as they merely sought affirmance of the district court’s judgments on alternative grounds. In Nos. 24-1422 and 24-1426, the court reversed the district court’s judgment, finding that Hifter waived his personal jurisdiction defense by failing to timely assert it in his pre-answer motions. The cases were remanded for further proceedings.In No. 24-1423, the Fourth Circuit concluded that Hifter properly raised a personal jurisdiction defense and that the district court correctly granted summary judgment due to the plaintiffs' failure to make a prima facie showing of personal jurisdiction. However, the court vacated the judgment and remanded with instructions to modify the judgment to state that the dismissal is without prejudice. View "al-Suyid v. Hifter" on Justia Law

Martin Misjuns, a Fire Captain and paramedic with the Lynchburg Fire Department, was terminated after posting offensive social media content targeting transgender individuals. Misjuns alleged that his termination was due to his political and religious views, which he expressed on his Facebook pages. He claimed that the City of Lynchburg and its officials conspired to violate his constitutional rights, leading to his firing.The United States District Court for the Western District of Virginia dismissed all of Misjuns' claims. The court found that the claims against the individual defendants in their official capacities were duplicative and dismissed them. The court also dismissed Misjuns' breach of contract, equal protection, conspiracy, and wrongful termination claims. The court partially dismissed his First Amendment claims but later dismissed them entirely.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court's dismissal of Misjuns' claims. The court held that Misjuns failed to establish Monell liability against the City of Lynchburg, as he did not adequately plead that a policy or custom caused the alleged constitutional violations. The court also found that the City's Employment Policies & Procedures handbook did not constitute a binding contract, thus dismissing the breach of contract claim. Additionally, the court upheld the dismissal of the conspiracy and wrongful termination claims against the individual defendants, as those claims were not asserted against the City and had been dismissed by agreement.The Fourth Circuit concluded that Misjuns did not sufficiently plead facts to state a claim for relief on any of his six claims, affirming the district court's decision. View "Misjuns v. City of Lynchburg" on Justia Law

Two racing teams, 2311 Racing LLC and Front Row Motorsports, Inc., filed an antitrust lawsuit against the National Association for Stock Car Auto Racing, LLC (NASCAR) and its CEO, James France. The plaintiffs alleged that NASCAR, as a monopolist, required them to sign a release for past conduct as a condition of participating in the NASCAR Cup Series, which they claimed was anticompetitive. The plaintiffs sought declaratory and injunctive relief, as well as treble damages.The United States District Court for the Western District of North Carolina granted the plaintiffs' motion for a preliminary injunction. The court ordered NASCAR to allow the plaintiffs to participate in the Cup Series under the 2025 Charter Agreement terms, excluding the release provision. The district court found that the plaintiffs were likely to succeed on their Section 2 Sherman Act claim, concluding that a monopolist could not require a release from antitrust claims as a condition of doing business.The United States Court of Appeals for the Fourth Circuit reviewed the case and vacated the preliminary injunction. The appellate court held that the district court's theory of antitrust law was unsupported by any case law. The court found that the release provision did not constitute anticompetitive conduct and that the plaintiffs failed to show a likelihood of success on the merits. The Fourth Circuit emphasized that a preliminary injunction is an extraordinary remedy requiring a clear showing of entitlement, which the plaintiffs did not meet. The court concluded that the district court abused its discretion in granting the preliminary injunction. View "2311 Racing LLC v. National Association for Stock Car Auto Racing" on Justia Law

Adam and Lydia Duffy were severely injured in a motorcycle accident, resulting in damages of nearly $2,000,000. The at-fault motorist's insurance coverage was insufficient, so the Duffys sought compensation through their underinsured motorist (UIM) policies, including one from Selective Insurance Company of South Carolina. Selective paid $300,000, arguing that North Carolina law did not require stacking of the Duffys' multiple insurance policies because the vehicles covered were not "nonfleet private passenger vehicles."The United States District Court for the Western District of North Carolina granted summary judgment in favor of Selective. The court found that the Duffys' policy covered seven vehicles used for their landscaping business, classifying it as fleet coverage under North Carolina law. The court also determined that the vehicles were not "private passenger vehicles" because they were used for commercial purposes. Consequently, the anti-stacking provisions of North Carolina law did not apply.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that the policy was fleet coverage and that the vehicles were not private passenger vehicles. The court also found that the insurance contract clearly limited coverage to $1,000,000 per accident, regardless of the number of insureds. Therefore, Selective's payment of $300,000, after accounting for the contributions from other insurers, was appropriate. The court held that the policy's terms were unambiguous and did not allow for stacking of coverage limits across multiple policies. View "Selective Insurance Company of South Carolina v. Duffy" on Justia Law

Stephen Purks orchestrated a multi-state methamphetamine distribution conspiracy from his Florida state prison cell. The government indicted him on fourteen counts of methamphetamine distribution and one count of conspiracy to distribute and possess with intent to distribute methamphetamine. A jury found him guilty on all counts. Purks appealed his convictions, challenging the district court's denial of his motion to suppress statements made to law enforcement and arguing improper venue for his prosecution.The United States District Court for the Western District of Virginia held an evidentiary hearing on Purks's motion to suppress. Purks claimed that his statements were involuntary due to a beating by Florida Department of Corrections officers before his interview with DEA agents. The court found that Purks was read his Miranda rights and voluntarily waived them, crediting the DEA agent's testimony over Purks's. The court also found that the interview was conducted respectfully and without coercion, and denied the motion to suppress. At trial, the district court denied Purks's Rule 29 motion for acquittal based on improper venue, instructing the jury that venue was proper in the Western District of Virginia.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court's denial of the motion to suppress, holding that Purks's statements were voluntary and that the agents did not coerce him. The court also affirmed the district court's venue instruction, holding that the distribution of methamphetamine is a continuing offense that can be prosecuted in any district where the offense was begun, continued, or completed. The court found that the distribution was completed in the Western District of Virginia, making it a proper venue for prosecution. View "United States v. Purks" on Justia Law

T.M. has a medical condition that causes psychosis when she ingests gluten. After an episode in 2023, she was involuntarily committed to Baltimore Washington Medical Center. Despite her and her father's request for voluntary admission, an administrative hearing led to her involuntary commitment. A clinical review panel approved forcibly injecting T.M. with antipsychotic medication, a decision affirmed by a Maryland administrative law judge. T.M. and the medical center later reached an oral agreement for her release, which was formalized in a consent order by a state court. The consent order required T.M. to follow certain conditions, including taking prescribed medications and dismissing other lawsuits.The United States District Court for the District of Maryland dismissed T.M.'s claims, citing the Rooker-Feldman doctrine, which prevents federal courts from reviewing state court judgments. The court found it lacked subject matter jurisdiction over T.M.'s claims and dismissed the parents' claims for failure to state a claim. T.M.'s claims were dismissed with prejudice, while the parents' claims were dismissed without prejudice.The United States Court of Appeals for the Fourth Circuit affirmed the district court's dismissal of T.M.'s claims for lack of subject matter jurisdiction under the Rooker-Feldman doctrine. The court held that T.M. was a state court loser seeking to overturn a state court judgment, which is barred by the doctrine. The court vacated the dismissal with prejudice and remanded with instructions to modify the judgment to dismiss T.M.'s claims without prejudice. The court also affirmed the dismissal of the parents' claims for failure to state a claim, noting that the complaint did not allege a violation of their First Amendment rights. View "T.M. v. University of Maryland Medical System Corporation" on Justia Law

Lois Ann Brown slipped and fell on ice in the parking lot of a Wal-Mart in Lynchburg, Virginia, on January 28, 2021, following a snowstorm the previous night. The snowstorm ended by 6:15 AM, and Brown fell at approximately 8:30 AM. Brown did not see any salt or deicing chemicals on the ground or on her clothing after the fall. The store manager, Anthony Ware, confirmed that he did not see any salt or chemicals in the parking lot. Surveillance footage showed the contractor's truck driving around the parking lot but not stopping or applying any deicing measures.Brown initially filed a negligence lawsuit against Wal-Mart in state court, seeking $300,000 in damages. Wal-Mart removed the case to the United States District Court for the Western District of Virginia. The district court granted summary judgment in favor of Wal-Mart, holding that Brown failed to show that Wal-Mart had actual or constructive notice of the specific patch of ice and that Brown did not provide sufficient evidence to prove that Wal-Mart breached its duty of care.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the snowstorm itself provided Wal-Mart with notice of the ice and snow in the parking lot, creating a duty to use reasonable care to remove the hazards. The court found that there was a genuine dispute of material fact regarding whether Wal-Mart breached its duty of care. The evidence, including conflicting testimonies and surveillance footage, suggested that a reasonable jury could find for either party. Therefore, the Fourth Circuit vacated the district court's grant of summary judgment and remanded the case for further proceedings. View "Brown v. Wal-Mart Stores East, LP" on Justia Law

Kevin Hsieh, a native and citizen of India, was convicted of inducing a minor to engage in illegal sexual activity under 18 U.S.C. § 2422(b). Following his conviction, an immigration judge (IJ) ordered his removal from the United States, citing his conviction as an aggravated felony of sexual abuse of a minor and a crime of child abuse under the Immigration and Nationality Act (INA). Hsieh appealed the removal order, arguing that the statute of conviction is broader than the generic offenses of sexual abuse of a minor and child abuse.The Board of Immigration Appeals (BIA) dismissed Hsieh's appeal, agreeing with the IJ's determination that Hsieh's conviction under § 2422(b) categorically matched both the aggravated felony of sexual abuse of a minor and the crime of child abuse as defined in the INA. Hsieh then filed a petition for review with the United States Court of Appeals for the Fourth Circuit.The Fourth Circuit reviewed the case and concluded that a conviction under § 2422(b) does indeed categorically constitute a match for both the aggravated felony of sexual abuse of a minor and the crime of child abuse under the INA. The court noted that § 2422(b) targets conduct directed toward minors, involves a mental element focused on sexual gratification, and includes both physical and nonphysical misuse or maltreatment of minors. The court also determined that the statute's mens rea requirement and the harm caused by the offense align with the definitions of sexual abuse of a minor and child abuse.Accordingly, the Fourth Circuit denied Hsieh's petition for review, upholding the BIA's decision that Hsieh's conviction warranted his removal from the United States. View "Hsieh v. Bondi" on Justia Law

In 2018, Marriott announced a data breach affecting the guest reservation database of Starwood Hotels & Resorts Worldwide, which Marriott had acquired in 2016. The breach exposed personal information of approximately 133.7 million guests, including some payment card information. Plaintiffs filed class action lawsuits against Marriott and Accenture, a third-party IT service provider for Starwood and Marriott during the breach. The cases were consolidated for pretrial proceedings in the District of Maryland.The district court initially certified multiple state-specific damages classes against Marriott and issue classes against both Marriott and Accenture. However, the court did not address the effect of a class-action waiver in the Starwood Preferred Guest Program (SPG) contract, which Marriott argued precluded class certification. The Fourth Circuit vacated the class certification, instructing the district court to consider the class-action waiver's impact.On remand, the district court again certified the classes, holding that Marriott had waived its right to enforce the class-action waiver by participating in multidistrict litigation (MDL) and by agreeing to pretrial proceedings in Maryland, contrary to the SPG contract's venue and choice-of-law provisions. The court also suggested that the class-action waiver might be unenforceable under Rule 23 of the Federal Rules of Civil Procedure.The United States Court of Appeals for the Fourth Circuit reviewed the case and reversed the district court's decision. The Fourth Circuit held that Marriott did not waive its right to enforce the class-action waiver and that the waiver was valid and enforceable. The court found that the waiver applied to the plaintiffs' claims, including consumer protection and negligence claims, as they were related to the SPG Program. Consequently, the court reversed the certification of all classes against Marriott and the issue classes against Accenture, as the latter were justified only in combination with the Marriott damages classes. View "Maldini v. Marriott International, Incorporated" on Justia Law

In October 2022, NCIS investigators obtained a military warrant to seize but not search Joshua Lee Ray's cell phone. Despite this, they searched the phone and found evidence of child sexual abuse material. Ray moved to suppress the evidence, arguing the search violated the Fourth Amendment as the warrant did not authorize it. The district court granted the motion.The Government appealed, conceding the warrant did not authorize the search, there was no verbal authorization, and the warrant did not incorporate an affidavit requesting authorization. The Government argued the search was justified under the good faith exception.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the Government could not rely on the good faith exception because the warrant was not deficient; it simply did not authorize the search. The court emphasized that the NCIS exceeded the scope of the valid warrant, and the good faith exception did not apply to such conduct. The court affirmed the district court's decision to suppress the evidence. View "US v. Ray" on Justia Law