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

Edward Joseph Walsh, III was riding his lawn mower when he was struck and killed by an underinsured motorist. Walsh had underinsured motorist (UIM) coverage on two personal automobiles insured by Owners Insurance Company. After Owners paid benefits equal to the UIM coverage limits for a single covered automobile, Walsh’s estate sought to stack the UIM coverage from the other. Owners asserted that stacking was unavailable and, in the declaratory judgment action that followed, the district court agreed. The court found that neither South Carolina law nor the terms of the policy entitled the insured to stack coverage under these circumstances.The United States District Court for the District of South Carolina evaluated the parties’ cross-motions for summary judgment. The district court determined that the policy terms disallowed stacking and that this limitation was consistent with South Carolina law. Consequently, the court granted summary judgment to Owners Insurance Company and dismissed the case.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s grant of summary judgment de novo. The appellate court considered whether Walsh’s estate was entitled to stack UIM benefits from both scheduled automobiles under South Carolina law and the terms of the policy. The court concluded that the policy provisions clearly limited stacking to specific circumstances not applicable in this case. Additionally, the court found that the lawn mower involved in the accident was not an insured vehicle, and thus, the estate was not entitled to stack UIM coverage. The Fourth Circuit affirmed the district court’s judgment, holding that the estate was not entitled to collect additional UIM benefits beyond what had already been paid by Owners Insurance Company. View "Owners Insurance Co. v. Walsh" on Justia Law

AdvanFort Company, a maritime security firm based in Virginia, deployed a vessel, the Seaman Guard Virginia, for anti-piracy services in the Red Sea. In October 2013, the vessel docked at the Jeddah Shipyard in Saudi Arabia for repairs by Zamil Offshore Services Company. During the repairs, a fire broke out, which AdvanFort attributed to Zamil's personnel. AdvanFort sued Zamil and the Saudi Ports Authority in a Saudi court in 2014, but the court dismissed AdvanFort's claims and awarded partial damages to Zamil on its countersuit. In 2022, Zamil moved the vessel to a storage yard, claiming it was at risk of sinking, and later informed AdvanFort that it would dispose of the vessel if not retrieved.AdvanFort filed a complaint in the Eastern District of Virginia in July 2023, alleging conversion, breach of bailment, negligence, and gross negligence against Zamil and the Ports Authority. Zamil moved to dismiss the complaint on the grounds of forum non conveniens and lack of personal jurisdiction, arguing that Saudi courts were a more appropriate forum. The Ports Authority did not appear, leading to a default entry against it.The United States District Court for the Eastern District of Virginia dismissed AdvanFort's complaint on the basis of forum non conveniens, finding that Saudi courts were available, adequate, and more convenient for the litigation. The court noted that the relevant events and evidence were located in Saudi Arabia and that the Saudi courts had jurisdiction over both defendants.The United States Court of Appeals for the Fourth Circuit affirmed the district court's dismissal. The appellate court held that the district court did not abuse its discretion in determining that Saudi Arabia was a more convenient forum and that the Saudi courts were both available and adequate for adjudicating AdvanFort's claims. The court also found no error in the district court's denial of limited discovery on forum non conveniens issues. View "AdvanFort Co. v. Zamil Offshore Services Co." on Justia Law

Ansar Hassen Hussen, an Ethiopian citizen, entered the U.S. on a B-2 visitor visa in January 2014 and overstayed. He applied for asylum, withholding of removal, and relief under the Convention Against Torture (CAT), claiming persecution in Ethiopia due to his political opinion and ethnicity. An immigration judge (IJ) found his account implausible and denied his application. The Board of Immigration Appeals (BIA) affirmed, agreeing that material aspects of Hussen's story did not add up. Hussen filed a petition for review, No. 23-1047.While the first petition was pending, Hussen married a U.S. citizen, who filed an I-130 application for an immigrant visa on his behalf. Hussen then filed a motion with the BIA to reopen his proceedings to seek an adjustment of status based on his marriage. The BIA denied the motion, concluding that Hussen's evidence was insufficient to prove the bona fides of his marriage. Hussen filed a second petition for review, No. 23-2197.While the second petition was pending, Hussen filed another motion with the BIA to reopen the proceedings and reconsider its denial of his earlier motion. He provided additional evidence, but the BIA denied the motion, and Hussen filed a third petition for review, No. 24-1257.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court denied Hussen's first petition, No. 23-1047, upholding the BIA's adverse credibility determination. The court granted Hussen's second petition, No. 23-2197, vacated the BIA's order denying the motion to reopen, and remanded for further proceedings, finding that the BIA applied the wrong legal standard. The court denied Hussen's third petition, No. 24-1257, as moot in light of the relief granted on the second petition. View "Hussen v. Bondi" on Justia Law

Brock Beeman was convicted by a federal jury of mailing three threatening letters to a prosecutor and an investigator involved in a previous criminal case against him, violating 18 U.S.C. § 876(c). Beeman appealed his conviction, challenging the district court's decisions on three grounds: the admission of an uncharged threatening letter, the empaneling of an anonymous jury, and the denial of his motion for a mistrial due to the prosecutor's improper statement during closing arguments.The United States District Court for the Eastern District of Virginia admitted the uncharged letter as res gestae evidence and under Federal Rule of Evidence 404(b), finding it provided necessary context for Beeman's animus and intent. The court also empaneled an anonymous jury due to Beeman's history of threatening behavior and potential for lengthy incarceration, while ensuring Beeman's rights were protected by providing his counsel with an unredacted juror list. During closing arguments, the prosecutor improperly suggested jurors consider their personal feelings about the threats, but the court immediately corrected this with a curative instruction.The United States Court of Appeals for the Fourth Circuit reviewed Beeman's challenges for abuse of discretion. The court found no abuse of discretion in admitting the uncharged letter, as it was relevant to proving elements of the crime and not unfairly prejudicial. The court also upheld the empaneling of an anonymous jury, noting the district court's careful consideration of the factors and safeguards to protect Beeman's rights. Finally, the court determined that the prosecutor's improper statement during closing arguments did not prejudice Beeman, given the immediate correction and overwhelming evidence of his guilt.The Fourth Circuit affirmed the district court's judgment, upholding Beeman's conviction. View "US v. Beeman" on Justia Law

Justin Longworth, a federal inmate, alleged that he faced repeated sexual harassment and abuse by Sherry M. Beck, a correctional officer at the Federal Correctional Institution in Butner, North Carolina. Longworth claimed Beck engaged in daily aggressive sexual harassment and abuse, including forced oral sex, fondling, and groping. He did not immediately report Beck's conduct due to fear of retaliation. Other officials at the institution initially did nothing to stop or report Beck's abuse. Eventually, Beck was reported, fired, and Longworth was transferred to another facility, but Beck continued to harass him through letters.Longworth filed two separate lawsuits in the Eastern District of North Carolina. The first lawsuit was a Bivens action against the officials directly involved, alleging violations of his civil rights under the Fourth and Eighth Amendments. The district court dismissed the Bivens claims, finding that they presented new contexts and that special factors counseled hesitation in extending Bivens to this context. Longworth appealed the dismissal of his Bivens claims. The second lawsuit was an FTCA claim against the United States, alleging negligence by the officials. The district court dismissed the FTCA claim for lack of subject matter jurisdiction, finding that Beck was not acting within the scope of her employment during the alleged misconduct. Longworth did not appeal the FTCA judgment.The United States Court of Appeals for the Fourth Circuit reviewed the case and concluded that the district court's FTCA judgment precluded Longworth's Bivens appeal. The FTCA judgment bar provides that an FTCA judgment is a complete bar to any action by the claimant against the employee of the government whose act or omission gave rise to the claim. Since a judgment on the FTCA claim had been entered, Longworth could no longer pursue his Bivens action based on the same conduct. Consequently, the Fourth Circuit dismissed the appeal. View "Longworth v. Mansukhani" on Justia Law

Two former employees sued Zen Nails Studio LLC and its owners for violating the Fair Labor Standards Act (FLSA) and a similar Maryland state law. After a five-day bench trial, the plaintiffs won and were awarded approximately 60% of their requested damages. The plaintiffs then sought $343,189.85 in attorney’s fees, but the district court awarded them $167,115.49, which was less than half of what they requested. The plaintiffs appealed the district court’s decision regarding the hourly rates used to calculate the attorney’s fees.The United States District Court for the District of Maryland, at Greenbelt, initially reviewed the case. The district court set the hourly rates for the plaintiffs’ attorneys, paralegals, and paraprofessionals based on the local rules' guidelines, which it treated as presumptively reasonable. The court then calculated the hours reasonably worked and reduced the total by 35% due to the plaintiffs achieving a moderately successful outcome. The plaintiffs challenged the district court’s reliance on the local rules' guidelines for setting the hourly rates.The United States Court of Appeals for the Fourth Circuit reviewed the case. The appellate court held that the district court erred by treating the hourly rates in the local rules as presumptively correct and requiring special justification for higher rates. The Fourth Circuit emphasized that while fee matrices can be a useful starting point, they should not be treated as setting a baseline that requires special justification to deviate from. The appellate court vacated the fee award and remanded the case for further proceedings, instructing the district court to consider all relevant evidence to determine the prevailing market rates without giving undue weight to the local rules' guidelines. View "De Paredes v. Zen Nails Studio LLC" on Justia Law

NCO Financial Systems, Inc. (NCO) entered into a lease agreement with Montgomery Park, LLC (Montgomery Park) for over 100,000 square feet of office space in Baltimore, Maryland. The lease allowed NCO to terminate early after eight years if certain conditions were met. NCO attempted to terminate early, but Montgomery Park claimed the conditions were not satisfied. NCO vacated the premises and stopped paying rent, leading Montgomery Park to send a default notice. NCO then filed a lawsuit seeking a declaratory judgment that it had properly terminated the lease and that the rent was based on misrepresented square footage.The United States District Court for the District of Maryland found in favor of Montgomery Park after a bench trial, awarding it $9,854,566.95 plus ongoing interest. The court also set a schedule for determining Montgomery Park’s claim for costs, fees, and expenses. Montgomery Park filed a motion seeking approximately $3.8 million for these costs, which NCO opposed on several grounds, including the lack of a proper demand for payment and the inclusion of fees for defending against NCO’s initial suit.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court concluded that Montgomery Park made a valid demand for payment when it filed its motion for costs, fees, and expenses on August 24, 2022. The court held that default interest should run only from the date of this demand, not from when the costs were incurred, and remanded the case to recalculate the interest. The court affirmed the district court’s award of costs, fees, and expenses, including those incurred in defending against NCO’s claims and expert witness fees, finding no abuse of discretion or error in the district court’s decisions.The Fourth Circuit affirmed in part, vacated in part, and remanded with instructions to recalculate the default interest. View "NCO Financial Systems, Inc. v. Montgomery Park, LLC" on Justia Law

Luis Avila pleaded guilty to three counts of violating 18 U.S.C. § 2252A(a)(2) and (b)(1) for possessing material involving the sexual exploitation of a minor. The probation officer calculated Avila’s advisory guideline range using Section 2G2.2 of the Federal Sentencing Guidelines, which starts with a base offense level of 22 and includes several enhancements that increased Avila’s offense level to 35. The probation officer then applied a cross-reference under Section 2G2.2(c)(1), which increased the offense level to 38, resulting in a guidelines range of 168 to 210 months after a three-level decrease for acceptance of responsibility.Avila challenged the application of the cross-reference, arguing that his actions did not cause the creation of the sexually explicit material because the victims were already sending the same videos to other people. The government argued that Avila’s actions, including offering and paying money for specific videos, caused the victims to create and send the videos. The United States District Court for the Western District of North Carolina overruled Avila’s objection and applied the cross-reference, sentencing him to 132 months of imprisonment followed by 30 years of supervised release.The United States Court of Appeals for the Fourth Circuit reviewed the case and found that the district court committed procedural error in sentencing Avila. The appellate court held that the district court’s factual findings were legally insufficient to support the application of the cross-reference under Section 2G2.2(c)(1). The court concluded that offering money for specific conduct and causing that conduct to happen are different, and proving the former does not prove the latter. Therefore, the Fourth Circuit vacated the district court’s judgment and remanded the case for resentencing. View "US v. Avila" on Justia Law

In May 2021, the appellant, along with a co-defendant, robbed a gas station in New Bern, North Carolina. The appellant entered the store armed with a revolver, pointed it at the cashier, struck the cashier on the head, and took money and cartons of cigarettes. The robbery was captured on surveillance video, and a witness provided a photo of the getaway vehicle. The next day, law enforcement located the vehicle and arrested the appellant and his co-defendant, recovering stolen items and the revolver used in the robbery.The appellant was indicted for robbery, using/brandishing a firearm during a crime of violence, and possession of a firearm by a convicted felon. He agreed to plead guilty to the first two counts and waived his right to appeal his conviction and sentence, except on grounds of ineffective assistance of counsel or prosecutorial misconduct. The district court conducted a brief plea hearing and sentenced the appellant to 144 months of imprisonment. The appellant argued that his appeal waiver was invalid because the district court failed to properly conduct the plea hearing and did not acknowledge his mitigation arguments or provide an explanation for the sentence.The United States Court of Appeals for the Fourth Circuit reviewed the case and held that the appellant’s appeal waiver was not knowingly and intelligently made. The court found that the district court failed to properly inform the appellant of the terms of the appeal waiver and did not ensure that he understood it. The court also noted that enforcing the appeal waiver would result in a miscarriage of justice due to the district court’s repeated disregard for proper procedure. Consequently, the Fourth Circuit vacated the sentence as procedurally unreasonable and remanded the case for reassignment to a different district court judge for further proceedings. View "US v. Smith" on Justia Law

A nurse at a medical clinic where Dr. George P. Naum, III worked prescribed controlled substances without a doctor's supervision. The government prosecuted Naum for conspiracy and aiding and abetting the distribution of controlled substances outside the usual course of his professional practice, alleging he knew about the nurse’s conduct but did not stop it. A federal jury convicted Naum on these counts.The United States District Court for the Northern District of West Virginia handled the initial trial. Naum was found guilty of one count of conspiracy to distribute controlled substances outside the bounds of professional medical practice and four counts of aiding and abetting in the distribution of controlled substances outside the bounds of professional medical practice. Naum's motion for a new trial was denied, and he appealed. The Fourth Circuit initially affirmed the district court's decision.The United States Supreme Court later clarified in Ruan v. United States that to convict a defendant under 21 U.S.C. § 841(a), the government must prove the defendant knew or intended that their conduct was unauthorized. Naum argued that the district court failed to instruct the jury on this requirement. The Fourth Circuit agreed that the jury instructions misstated the law post-Ruan but applied plain error review. The court concluded that Naum did not meet his burden of showing that the outcome of his trial would have been different with proper instructions. Therefore, the Fourth Circuit affirmed Naum's conviction. View "United States v. Naum" on Justia Law