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

Demmerick Brown, an inmate at Red Onion State Prison in Virginia, violated the prison’s COVID-19 policy by removing his face mask to get a shave at the barber shop. As a result, the prison fined him fifteen dollars, which was deducted from his prison trust account. Brown claimed that he was not provided the necessary forms to present evidence and call witnesses at his disciplinary hearing, and his request to postpone the hearing was denied. He was found guilty and fined.Brown sued three prison officials under 42 U.S.C. § 1983, alleging a violation of his Fourteenth Amendment due process rights. The United States District Court for the Western District of Virginia dismissed his case, concluding that Brown lacked a property interest in the money in his prison trust account, and thus, the fine did not trigger due process protections.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court vacated the district court’s dismissal, holding that inmates do have a property interest in the money in their prison trust accounts, as established in Henderson v. Harmon. The court found that the fifteen-dollar fine deprived Brown of this property interest, and thus, the Due Process Clause was applicable. The court rejected the argument that the fine was de minimis, noting its significance within the prison context.The Fourth Circuit vacated the district court’s decision and remanded the case for further proceedings to determine what process was due and whether any errors in Brown’s disciplinary proceedings were harmless. View "Brown v. Stapleton" on Justia Law

Joel Aaron Burrell, a prisoner, filed a lawsuit against several correctional officers under 42 U.S.C. § 1983. Burrell sought to proceed in forma pauperis, which allows indigent prisoners to file lawsuits without prepaying filing fees. The district court denied his request, citing the three-strike rule under the Prison Litigation Reform Act, which prevents prisoners from proceeding in forma pauperis if they have had three prior lawsuits dismissed for being frivolous, malicious, or failing to state a claim. The district court identified three such dismissals in Burrell's case history and dismissed his current action when he did not pay the filing fee.Burrell appealed, arguing that two of the prior dismissals should not count as strikes. The first case was dismissed under the Younger abstention doctrine, which prevents federal courts from interfering with ongoing state proceedings. The second case was dismissed after Burrell failed to amend his complaint following a court order that found his initial complaint failed to state a claim.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court concluded that a dismissal under Younger abstention does not count as a strike because it does not assess the merits of the complaint. Regarding the second case, the court determined that while a failure to amend following a finding of failure to state a claim can count as a strike, it should not be counted if the dismissal occurred after the current lawsuit was filed.The Fourth Circuit held that the district court erred in applying the three-strike rule to Burrell's case. Since Burrell had only one valid strike at the time he filed the current lawsuit, the district court's dismissal was vacated and the case was remanded for further proceedings. View "Burrell v. Shirley" on Justia Law

Dan G. Martin prevailed against Deborah Faye Parker in a Virginia state court for breach of contract. Instead of paying the judgment, Deborah filed for Chapter 7 bankruptcy. Dan then initiated an adversary action, claiming his judgment was nondischargeable under 11 U.S.C. § 523(a)(4) for embezzlement. The bankruptcy court ruled in Dan's favor, finding the judgment nondischargeable. Deborah appealed to the district court, which reversed the bankruptcy court's decision, ruling that Dan had not proven Deborah's fraudulent intent.The bankruptcy court found that Deborah embezzled funds by liquidating accounts she held jointly with her father, Morton, despite knowing the terms of Morton's will and a post-marital agreement. The court concluded that Deborah's actions met the definition of embezzlement. However, the district court found that Deborah had disclosed the will and agreement to the bank, which advised her that she was entitled to the funds. This led the district court to conclude that Deborah had a good-faith belief that the funds were hers, precluding a finding of fraudulent intent.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 bankruptcy court's finding of fraudulent intent was clearly erroneous because Deborah had disclosed the relevant documents to the bank and acted on the bank's advice. The court concluded that Deborah's good-faith belief that the funds were hers negated the fraudulent intent required for embezzlement under § 523(a)(4). Therefore, the district court correctly reversed the bankruptcy court's judgment for Dan, and the judgment for Deborah was affirmed. View "Parker v. Martin" on Justia Law

Amanda Watts received two vaccines, Pneumovax 23 and Boostrix, at a CVS Pharmacy in 2017. She claimed that both vaccines were negligently administered in the same improper location on her arm, leading to a chronic pain condition. However, CVS is immune from suit for the administration of Boostrix under the National Childhood Vaccine Injury Act of 1986. Consequently, Watts's complaint focused solely on the alleged negligence in administering Pneumovax.The United States District Court for the District of Maryland granted summary judgment to CVS, finding that Watts presented no evidence from which a jury could determine that her injury was caused by the Pneumovax vaccine rather than the Boostrix vaccine. The court also struck an errata sheet submitted by Watts's expert, Dr. Akhil Chhatre, which attempted to amend his deposition testimony to suggest that both vaccines contributed to Watts's injury.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The Fourth Circuit agreed that Watts failed to provide evidence to establish that her injury was caused by the Pneumovax shot, as required to overcome CVS's immunity for the Boostrix shot. The court noted that both of Watts's experts could not definitively attribute her injury to the Pneumovax vaccine alone. The court also upheld the district court's decision to strike Dr. Chhatre's errata sheet, which materially altered his original testimony.The Fourth Circuit concluded that without evidence to separate the effects of the two vaccines, a jury could only speculate on the cause of Watts's injury. Therefore, Watts could not satisfy the causation element of her negligence claim, and the summary judgment in favor of CVS was affirmed. View "Watts v. Maryland CVS Pharmacy, LLC" on Justia Law

Cristian Cabrera-Rivas was convicted by a jury of two drug offenses related to a methamphetamine deal. Cabrera-Rivas, who grew up in Honduras and has limited education and English proficiency, was involved in negotiating a meth deal with a confidential informant named Hector, who was working with the Department of Homeland Security. During the deal, Cabrera-Rivas vouched for the meth supplier, Marco Ramos-Garcia, and was present when the meth was delivered. The police arrested Cabrera-Rivas at the scene and found cash and nearly pure methamphetamine.The United States District Court for the Western District of North Carolina found Cabrera-Rivas competent to stand trial based on a government psychologist's evaluation. The court denied his motion for a judgment of acquittal and precluded him from presenting certain affirmative defenses but allowed him to argue entrapment. The jury convicted him on both counts. Post-trial, the district court denied his motions for a new trial and a retrospective competency hearing, finding sufficient evidence for the convictions and no bad faith in the destruction of a recorded interview.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decisions. The appellate court found no clear error in the magistrate judge's competency ruling and held that the district court did not abuse its discretion in denying a second competency hearing. The court also found sufficient evidence to support the convictions, noting that a reasonable jury could infer that Cabrera-Rivas had constructive possession of the meth. The court rejected Cabrera-Rivas's due process claim regarding the destroyed interview recording, as there was no evidence of bad faith. Finally, the court upheld the district court's refusal to instruct the jury on the public authority, innocent intent, outrageous conduct, and entrapment by estoppel defenses. View "US v. Cabrera-Rivas" on Justia Law

Law enforcement agents were surveilling a motel room in Charles Town, West Virginia, to arrest a woman. They saw Dehaven Craig leave the room and drive off. Craig had a significant criminal history, including prior felony convictions. After Craig left, agents entered the motel room, arrested the woman, and found a loaded .380 caliber pistol. The woman claimed the gun belonged to Craig. When Craig returned, officers stopped him and found 0.8 grams of cocaine base in his SUV. Craig was indicted on two drug charges and one charge for unlawful possession of a firearm as a felon.Craig and the government reached a plea agreement where Craig would plead guilty to the firearm charge, and the government would drop the drug charges and recommend a sentence within the Guidelines range. The plea agreement included a stipulation of facts relevant to sentencing. At the plea hearing, the government stated that the stipulation contained Craig’s total relevant conduct. The court accepted the plea, and the probation officer calculated Craig’s Guidelines range. The government sought two enhancements based on facts not included in the stipulation, which Craig objected to, but the probation officer and the district court overruled his objections, resulting in a higher Guidelines range and a 100-month sentence.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that the plea agreement stipulated to Craig’s total relevant conduct for sentencing purposes and that the government breached the agreement by seeking enhancements based on facts outside the stipulation. The court held that the government’s duty of candor did not excuse it from its commitments under the plea agreement. The court vacated Craig’s sentence and remanded for resentencing before a different district court judge. View "US v. Craig" on Justia Law

Victor Manuel Castro-Aleman, originally from El Salvador, was brought to the United States illegally in 1973 as a child. Over the years, he had multiple encounters with law enforcement, including four DUI convictions in Virginia between 2009 and 2014. In 2016, while serving a sentence for his fourth DUI, he was visited by ICE agents and subsequently issued a Notice to Appear in removal proceedings. He was ordered removed by an Immigration Judge (IJ) after failing to submit an asylum application and not appealing the removal order. Castro-Aleman reentered the United States illegally and was discovered in Virginia in 2023, leading to his indictment for illegal reentry.The United States District Court for the Eastern District of Virginia denied Castro-Aleman's motion to dismiss the indictment, which argued that his 2016 removal order was invalid due to due process violations. The district court found that he had knowingly and voluntarily waived his right to appeal the removal order.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The court held that Castro-Aleman failed to demonstrate that his removal order was "fundamentally unfair" under 8 U.S.C. § 1326(d)(3). The court found that even if there were due process violations, such as the IJ's failure to inform him adequately of his right to appeal, Castro-Aleman could not show actual prejudice. His extensive criminal history and admissions during the removal hearing established multiple independent grounds for his removability, making any appeal futile. Consequently, the court affirmed the denial of his motion to dismiss and upheld his conviction for illegal reentry. View "United States v. Castro-Aleman" on Justia Law

In the second year of the COVID-19 pandemic, Johns Hopkins University’s Applied Physics Lab required employees to be vaccinated against the disease. Sally Tarquinio, who suffers from “Lyme-induced immune dysregulation,” requested a medical exemption, fearing adverse effects from the vaccine. The lab found her condition unclear and requested to speak with her doctors, but Tarquinio refused. Consequently, the lab denied her exemption request and terminated her employment for non-compliance. Tarquinio sued under the Americans with Disabilities Act (ADA), and the district court granted summary judgment in favor of the lab.The United States District Court for the District of Maryland reviewed the case and found that Tarquinio had not provided sufficient evidence to support her need for an exemption. The court noted that the lab had made good faith efforts to understand her condition and accommodate her, but Tarquinio’s refusal to allow communication with her doctors prevented the lab from obtaining necessary information. The court concluded that without this information, the lab could not be held liable for failing to provide a reasonable accommodation.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The court affirmed the district court’s decision, holding that Tarquinio’s failure to engage in the interactive process by not providing adequate medical documentation or allowing the lab to speak with her doctors meant that the lab was not on proper notice of her need for accommodation. The court emphasized that the interactive process is essential for determining reasonable accommodations and that an employer cannot be held liable if the employee obstructs this process. Thus, the lab’s actions were deemed appropriate, and the summary judgment in favor of the lab was affirmed. View "Tarquinio v. Johns Hopkins University Applied Physics Lab" on Justia Law

Duane Berry was indicted in 2015 for planting a fake bomb outside a building in Detroit. The district court in Michigan found him mentally incompetent to stand trial and committed him to the custody of the Attorney General under 18 U.S.C. § 4241 for a competency evaluation. After determining that his competency could not be restored, the court dismissed the charges against him in December 2019. Concerned about his potential danger to the public, the court ordered a psychological evaluation under 18 U.S.C. § 4246.The government faced delays due to a backlog at the evaluation facility and the COVID-19 pandemic. Berry was eventually evaluated, and the facility's director certified that his release would pose a substantial risk. The United States District Court for the Eastern District of North Carolina held a hearing and found by clear and convincing evidence that Berry met the criteria for commitment under § 4246, as he was still in custody under § 4241 when the certification was filed.Berry appealed, arguing that he did not fall into any of the categories eligible for commitment under § 4246 and that the delay in filing the certification was unreasonable. The United States Court of Appeals for the Fourth Circuit reviewed the case and concluded that Berry was in lawful custody under § 4241 at the time of the certification. The court found the delay reasonable given the administrative challenges and the pandemic. The Fourth Circuit affirmed the district court's decision to commit Berry under § 4246, holding that the statutory provisions were followed correctly and that Berry's continued custody was lawful. View "United States v. Berry" on Justia Law

A native and citizen of Honduras entered the United States without authorization in 2003. In 2019, an Immigration Judge (IJ) indicated intent to grant his application for cancellation of removal, but due to a legislative cap, the decision was reserved until a visa became available in January 2023. By then, the initial IJ had retired, and a new IJ was assigned. The new IJ scheduled a new merits hearing because the petitioner was charged with a felony during the interim period. The new IJ ultimately denied the application, citing a lack of good moral character.The petitioner appealed to the Board of Immigration Appeals (BIA), arguing that a binding policy required the reserved grant of cancellation to be issued within five days of visa availability, which would have precluded consideration of the new felony charge. The BIA rejected this argument, stating that the policy was not binding and did not create a remedy for exceeding the time frame. The BIA affirmed the new IJ's decision, finding the petitioner lacked good moral character and did not merit a favorable exercise of discretion.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the policy the petitioner relied upon was not binding and, even if it were, it would not have imposed a five-day deadline in this case. The court noted that the policy was an internal guideline not intended to confer individual rights or have the force of law. Additionally, the court found that the petitioner was not substantially prejudiced by the delay, as he was required to maintain good moral character throughout the proceedings. The petition for review was denied. View "Zalaya Orellana v. Bondi" on Justia Law