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

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

The case involves defendants Aghee William Smith II and David Alcorn, who were convicted in the Eastern District of Virginia for their roles in fraudulent schemes that defrauded investors of millions of dollars. The schemes included marketing and selling phony investments in a dental services marketing program and fraudulent spectrum investments. The fraudulent activities primarily targeted elderly victims, resulting in significant financial losses.In the district court, Smith and Alcorn were tried together before a jury in February 2022. They raised three main issues on appeal: a joint constitutional challenge to the district court’s COVID-19 trial protocol under the Public Trial Clause of the Sixth Amendment, Smith’s separate challenge to the admission of videotaped depositions under the Confrontation Clause, and Alcorn’s challenge to the imposition of supervised release conditions.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court rejected Smith and Alcorn’s joint contention that the COVID-19 trial protocol violated their rights under the Public Trial Clause, finding that the protocol did not constitute a partial courtroom closure and was justified by substantial public health reasons. The court also rejected Smith’s Confrontation Clause challenge, concluding that the government had made a good faith effort to secure the witnesses’ presence at trial and that the witnesses were unavailable due to health concerns.However, the court found merit in Alcorn’s challenge regarding the imposition of supervised release conditions. The district court had failed to properly incorporate the standard conditions of supervised release during the oral pronouncement of Alcorn’s sentence, leading to a Rogers error. As a result, the Fourth Circuit vacated Alcorn’s sentences and remanded for resentencing.In summary, the Fourth Circuit affirmed Smith’s convictions and sentences, affirmed Alcorn’s convictions, but vacated Alcorn’s sentences and remanded for resentencing. View "United States v. Smith" on Justia Law

Jonathan Eugene Brunson, an inmate in North Carolina, filed a § 1983 action against the North Carolina Attorney General and other state officials, seeking various forms of relief. Brunson acknowledged that he had previously filed four § 1983 suits that were dismissed under Heck v. Humphrey, which bars federal courts from entertaining § 1983 suits for damages that would undermine the legality of a conviction unless the conviction has been invalidated. Despite these dismissals, Brunson moved to proceed in forma pauperis.The United States District Court for the Eastern District of North Carolina initially granted Brunson’s request to proceed in forma pauperis but later vacated that order, citing the Prison Litigation Reform Act’s (PLRA) three-strikes rule. The district court determined that Brunson’s prior dismissals under Heck counted as strikes for failure to state a claim. Consequently, Brunson prepaid the filing fee, but his § 1983 complaint was eventually dismissed for reasons not relevant to the current appeal. Brunson then appealed and applied to proceed on appeal without prepaying fees, arguing that Heck dismissals should not count as PLRA strikes.The United States Court of Appeals for the Fourth Circuit reviewed the case to determine whether a dismissal under Heck constitutes a strike under the PLRA. The court held that a Heck dismissal is necessarily for failure to state a claim because it denies the existence of a cause of action unless the plaintiff can prove that the conviction or sentence has been invalidated. Therefore, such dismissals count as strikes under the PLRA. As Brunson had at least three prior Heck dismissals, the court denied his motion to proceed in forma pauperis on appeal. View "Brunson v. Stein" on Justia Law

In April 2024, Russell Richardson Vane, IV, was arrested and charged with attempting to produce a biological agent or toxin, specifically ricin, in violation of 18 U.S.C. § 175(a). The FBI found castor beans and equipment for producing ricin in his home. Vane had previously been involved with a militia group, the Virginia Kekoas, and had shared information on making explosives. The group expelled him, suspecting entrapment, and reported him to the FBI. Vane was detained pending trial based on the government's evidence, including proffered information.A magistrate judge granted the government's motion for pretrial detention, and the district court affirmed this decision. Vane argued that 18 U.S.C. § 3142(f) only allows the defendant, not the government, to introduce information by proffer. The district court disagreed, noting that other circuit courts have allowed the government to use proffers in detention hearings. The court found that the totality of the circumstances, including the proffered evidence, justified Vane's detention.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that 18 U.S.C. § 3142 does not prohibit the government from making evidentiary proffers during detention hearings. The court emphasized that the statute's text and context support allowing both parties to present information by proffer, promoting efficiency in detention proceedings. The court affirmed the district court's order, concluding that the government met its burden to justify Vane's pretrial detention. View "US v. Vane" on Justia Law

Marco Fernandez applied to rent an apartment, and RentGrow, Inc. provided a tenant screening report to the property owner. The report inaccurately indicated that Fernandez had a "possible match" with a name on the OFAC list, which includes individuals involved in serious crimes. However, the property manager did not understand or consider this information when deciding on Fernandez's application. Fernandez sued RentGrow, alleging that the company violated the Fair Credit Reporting Act (FCRA) by not ensuring the accuracy of the OFAC information.The United States District Court for the District of Maryland certified a class of individuals who had similar misleading OFAC information in their reports. The court rejected RentGrow's argument that Fernandez and the class lacked standing because they did not demonstrate a concrete injury. The district court held that the dissemination of the misleading report itself was sufficient to establish a concrete injury.The United States Court of Appeals for the Fourth Circuit reviewed the case and disagreed with the district court's conclusion. The appellate court held that reputational harm can be a concrete injury, but only if the misleading information was read and understood by a third party. In this case, there was no evidence that anyone at the property management company read or understood the OFAC information in Fernandez's report. Therefore, Fernandez failed to demonstrate a concrete injury sufficient for Article III standing. The Fourth Circuit vacated the district court's class certification order and remanded the case for further proceedings. View "Fernandez v. RentGrow, Inc." on Justia Law

The case involves Makel Elboghdady, who was convicted of traveling in interstate commerce with the intent to engage in illicit sexual conduct, violating 18 U.S.C. § 2423(b) and (e). The conviction stemmed from an undercover operation where a West Virginia State Police officer posted an ad on Craigslist to attract child predators. Elboghdady responded to the ad and engaged in a series of communications with the undercover officer, which led to his travel from Ohio to West Virginia for a face-to-face meeting. Upon arrival, he was arrested and charged.In the United States District Court for the Southern District of West Virginia, Elboghdady was denied an entrapment defense and subsequently convicted by a jury. The district court sentenced him to 120 months’ imprisonment, applying an enhancement and cross-reference for crimes involving a victim under the age of 12. Elboghdady appealed, arguing that he was entitled to an entrapment defense and that his sentence was unreasonable.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court’s decision to deny the entrapment defense, finding no evidence of government overreach or inducement. However, the appellate court vacated Elboghdady’s sentence, determining that the district court improperly applied sentencing enhancements that required evidence of intent to engage with a minor under 12 years old. The appellate court found that the district court’s factual findings did not support the application of these enhancements. Consequently, the case was remanded for resentencing without the improper enhancements. View "United States v. Elboghdady" on Justia Law

In 1999, a Virginia state court jury convicted Askari Lumumba of second-degree murder and other related charges, sentencing him to fifty-eight years in prison. While serving his sentence, Lumumba engaged in communications that led to disciplinary action. He spoke on the phone about organizing inmates and sent emails discussing potential group actions within the prison. As a result, he was charged with attempting to garner support for a group demonstration, violating Disciplinary Offense Code 128, which prohibits participating in or encouraging work stoppages or group demonstrations.Lumumba's disciplinary hearing concluded with a finding of guilt, resulting in 30 days of disciplinary segregation and a loss of 180 days of good-conduct sentence credits. His appeals to the Warden and Regional Director were denied. He then petitioned for a writ of habeas corpus in the Supreme Court of Virginia, which was denied on jurisdictional grounds. Subsequently, Lumumba filed a federal habeas corpus petition under 28 U.S.C. § 2254, arguing that Offense Code 128 was void for vagueness and violated the First Amendment. The district court dismissed his petition, finding the regulation clear and reasonably related to legitimate penological interests.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that Offense Code 128 is not facially unconstitutional under the First Amendment, as it reasonably relates to maintaining order and security in prisons. The court also found that the regulation is not void for vagueness, as it provides sufficient notice of prohibited conduct and does not invite arbitrary enforcement. Consequently, the Fourth Circuit affirmed the district court's dismissal of Lumumba's petition. View "Lumumba v. Kiser" on Justia Law