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

In July 2023, law enforcement responded to an incident in which James Jacobs allegedly discharged a firearm during a dispute with his girlfriend at his home. During a subsequent search, officers discovered two firearms. Jacobs, who has a prior felony conviction and a previous misdemeanor conviction for domestic battery in West Virginia, admitted to knowing he was prohibited from possessing firearms. As a result, a grand jury in the Northern District of West Virginia indicted him for possessing firearms after a felony conviction under 18 U.S.C. § 922(g)(1) and after a misdemeanor crime of domestic violence under § 922(g)(9).The United States District Court for the Northern District of West Virginia granted Jacobs’ motion to dismiss both counts of the indictment. The district court, employing the framework from New York State Rifle & Pistol Association v. Bruen, found that the government failed to demonstrate a historical tradition of disarming individuals like Jacobs—nonviolent felons and domestic violence offenders. The court concluded that both statutes were unconstitutional as applied to Jacobs and dismissed the charges without reaching the facial challenges.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s rulings de novo. The Fourth Circuit held that recent decisions—including United States v. Rahimi, United States v. Canada, United States v. Hunt, and United States v. Nutter—foreclose Jacobs’ facial and as-applied challenges to § 922(g)(1) and his facial challenge to § 922(g)(9). Accordingly, the court reversed the district court’s dismissal of the § 922(g)(1) charge and barred Jacobs from reviving those challenges. However, the Fourth Circuit determined that further proceedings were necessary regarding Jacobs’ as-applied challenge to § 922(g)(9), vacated the district court’s ruling on that count, and remanded for additional factfinding and analysis. View "United States v. Jacobs" on Justia Law

The case concerns a defendant who, in May 2023, sold crack cocaine to a confidential informant on three occasions, totaling nearly 66 grams. When law enforcement later executed an arrest warrant for his failure to register as a sex offender, they discovered additional quantities of cocaine, marijuana, and crack cocaine in his possession. The defendant was indicted on three counts of distributing cocaine base and one count of possessing cocaine with intent to distribute. He pled guilty to all four counts without a plea agreement.A probation officer preparing a Presentence Investigation Report determined that the defendant should be classified as a career offender under the Sentencing Guidelines, based on two prior state convictions for drug offenses. This classification significantly increased his sentencing range. The defendant objected, arguing that one of the predicate offenses—under Florida law—criminalized conduct not covered by the federal definition of a “controlled substance offense,” such as simple possession and purchase. The United States District Court for the Eastern District of North Carolina accepted the career-offender enhancement but, anticipating a possible error, stated it would impose the same 120-month sentence regardless, based on the defendant’s criminal history and other factors.On appeal, the United States Court of Appeals for the Fourth Circuit held that the district court erred in applying the career-offender enhancement, because the underlying Florida statute was not a categorical match to the federal definition. However, the Fourth Circuit found this error harmless. The district court made clear it would have imposed the same sentence even without the enhancement, and the sentence was substantively reasonable in light of the court’s thorough consideration of statutory sentencing factors. The Fourth Circuit therefore affirmed the judgment. View "United States v. Cox" on Justia Law

Several nonprofit organizations and local governments received federal grants from agencies including the Department of Energy, Environmental Protection Agency, Department of Agriculture, and Department of Transportation. These grants were funded under statutes such as the Inflation Reduction Act, the Infrastructure Investment and Jobs Act, and the American Rescue Plan Act. In early 2025, President Donald Trump issued executive orders directing federal agencies to pause, review, and terminate certain grant programs—including those related to environmental justice, equity, and efficiency—based on new administration priorities. Agencies subsequently suspended or terminated various grants, prompting the plaintiffs to file suit.The U.S. District Court for the District of South Carolina reviewed the case. It held that it had jurisdiction over the plaintiffs’ claims under the Administrative Procedure Act (APA) and issued a permanent injunction requiring the government to restore funding for 32 of the grants. The court also granted a preliminary injunction on the plaintiffs’ separation of powers and ultra vires claims, enjoining the government from further freezing or terminating those grants. The government appealed, and the Fourth Circuit stayed the injunctions pending appeal.The United States Court of Appeals for the Fourth Circuit found that the district court abused its discretion in issuing both injunctions. The Fourth Circuit held that the district court lacked jurisdiction over the APA claims because they were essentially contractual, and thus subject to the exclusive jurisdiction of the Court of Federal Claims under the Tucker Act. With respect to the nonstatutory review claims, the Fourth Circuit ruled that the plaintiffs’ constitutional arguments were in substance statutory and failed to meet the strict standards for ultra vires review, since no specific statute prohibited the government’s actions. The court vacated the district court’s orders and remanded the case for further proceedings. View "The Sustainability Institute v. Trump" on Justia Law

A group of defendants operated a drug trafficking ring in Virginia. When a customer failed to pay for drugs, two leaders of the organization sought retribution and offered one defendant $10,000 to murder someone close to the delinquent customer. That defendant recruited his cousin, and together they traveled from North Carolina to Virginia and murdered the customer’s aunt. All four defendants were charged with numerous offenses related to drug distribution, murder, and murder-for-hire. After a jury trial, each defendant was convicted on all counts and sentenced to life imprisonment.Prior to this appeal, the United States District Court for the Eastern District of Virginia reviewed and denied several pretrial motions to suppress evidence, including challenges to GPS tracker warrants, pen register orders, cell-site location data, and wiretap authorizations. The district court also rejected arguments related to double jeopardy, jury instructions, evidentiary rulings, and severance of trials. The defendants raised sufficiency of the evidence challenges and various constitutional and statutory claims in the district court, many of which were preserved for appeal.The United States Court of Appeals for the Fourth Circuit reviewed the convictions and sentences. Applying the relevant legal standards, the Fourth Circuit found that the evidence was sufficient to support the jury’s verdicts on all counts for each defendant. The court held that convictions and sentences for both murder-for-hire and conspiracy to commit murder-for-hire do not violate the Double Jeopardy Clause because each offense requires proof of a fact the other does not. The court affirmed the denial of motions to suppress, finding no reversible error. It also rejected additional challenges related to jury instructions, evidentiary matters, severance, and duplicity. The judgments of the district court were affirmed. View "United States v. Evans" on Justia Law

Under Armour, a publicly traded sports apparel company, faced significant legal claims and government investigations over its financial forecasts and accounting practices following the bankruptcy of a major customer, Sports Authority, in 2016. Shareholders alleged that Under Armour made misleading public statements about its financial prospects and that company insiders sold stock at inflated prices. These allegations led to a federal securities class action, derivative demands, and eventually an SEC investigation into whether Under Armour manipulated its accounting by pulling forward revenue to maintain the appearance of strong growth.In the United States District Court for the District of Maryland, Under Armour’s insurers sought a declaratory judgment, arguing that the securities litigation, derivative actions, and government investigations constituted a single claim under the terms of Under Armour’s directors and officers insurance policies and therefore were subject only to the coverage limit of the earlier policy period. Under Armour countered that the government investigations were a separate claim, entitling it to an additional $100 million in coverage under a subsequent policy. The district court sided with Under Armour, finding that the government investigations and the earlier shareholder claims were not sufficiently related to constitute a single claim under the policy’s language.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s decision de novo. The Fourth Circuit held that, under the plain meaning of the 2017–2018 insurance policy’s “single claims” provision, the claims related to Under Armour’s public financial statements and its accounting practices were “logically or causally related” and thus constituted a single claim. As a result, only the coverage limits from the earlier, 2016–2017 policy period applied. The Fourth Circuit reversed the district court’s judgment in favor of Under Armour. View "Navigators Insurance Co. v. Under Armour, Inc." on Justia Law

Raymond Richardson was indicted for first-degree robbery under West Virginia law, specifically charged with using the threat of deadly force against Denise Cool to steal money. However, at trial, the prosecution presented evidence that Richardson accomplished the robbery by physically assaulting Cool rather than by threatening her with a deadly weapon. Richardson admitted to hitting Cool but denied taking her money. The jury found him guilty of first-degree robbery, assault during the commission of a felony, and possession with intent to deliver cocaine. The central issue on appeal concerned the alleged variance between the indictment and the State’s theory at trial.Following his conviction, Richardson sought post-conviction relief in state court, arguing that his trial counsel was ineffective for failing to object to the variance between the indictment and the evidence presented at trial. At an evidentiary hearing, Richardson and his trial counsel testified. Counsel acknowledged missing the indictment’s specific language but stated that the variance did not affect the defense strategy, which was focused on denying any theft rather than disputing the manner in which the robbery was committed. The state court denied habeas relief, finding Richardson had sufficient notice of the charges and was not prejudiced by the variance. The West Virginia Supreme Court of Appeals affirmed, concluding the difference between the indictment and trial evidence did not mislead Richardson or prejudice his defense.On federal habeas review, the United States District Court for the Southern District of West Virginia denied Richardson’s petition, finding he received adequate notice under the Fourteenth Amendment. The United States Court of Appeals for the Fourth Circuit affirmed, holding that the variance did not violate due process because Richardson was convicted of the offense charged, had actual notice of the evidence to be presented, and failed to show that the variance hindered his defense. The court found no ineffective assistance of counsel or prejudice and affirmed the district court’s denial of habeas relief. View "Richardson v. Frame" on Justia Law

Plaintiffs, consisting of individuals and gun rights organizations, challenged multiple Maryland statutes and regulations that prohibit the carrying of firearms in a range of locations, including government buildings, mass transit, school grounds, public demonstrations, state parks and forests, healthcare facilities, places of amusement, locations selling alcohol, and private property. The plaintiffs claimed these laws violated their Second Amendment rights, arguing that the restrictions could not be justified under the Supreme Court’s “sensitive places” exception to the right to bear arms.The United States District Court for the District of Maryland consolidated the cases and ruled on cross-motions for preliminary injunction and summary judgment. It denied injunctive relief for most challenges, including those relating to museums, healthcare facilities, mass transit, state parks and forests, places of amusement, school grounds, and government buildings. However, it granted injunctive relief to plaintiffs for the restrictions on carrying guns on private property held open to the public, at public demonstrations, and at locations selling alcohol for on-site consumption. All summary judgment motions were initially denied without prejudice; on renewal, the district court granted summary judgment in part and denied it in part. Both sides appealed.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo and issued a comprehensive decision applying Supreme Court precedent, particularly District of Columbia v. Heller and New York State Rifle & Pistol Association, Inc. v. Bruen. The Fourth Circuit affirmed the constitutionality of Maryland’s restrictions on carrying firearms in government buildings, mass transit, school grounds, state parks and forests, museums, healthcare facilities, stadiums, racetracks, amusement parks, and casinos. It also reversed the district court and upheld Maryland’s restrictions at public demonstrations and locations selling alcohol. However, the Fourth Circuit affirmed the district court’s ruling that Maryland’s ban on carrying firearms on private property held open to the public without express permission is unconstitutional, and found plaintiffs lacked standing to challenge the restriction on property not held open to the public. The judgment was affirmed in part and reversed in part. View "Kipke v. Moore" on Justia Law

A nonprofit organization based in Virginia, which advocates for election integrity, requested access to South Carolina’s statewide voter registration list from the state’s Election Commission. The request was made under the National Voter Registration Act of 1993 (NVRA), which generally requires states to make certain records about voter list maintenance available for public inspection and copying. South Carolina’s Election Commission denied the request, citing a state law that restricts disclosure of the voter list to individuals registered to vote within the state. The nonprofit responded by notifying the Election Commission that this refusal violated the NVRA and, after receiving a reiteration of the Commission’s position, filed a federal lawsuit seeking disclosure of the list.The United States District Court for the District of South Carolina reviewed the case. Both parties filed motions for summary judgment. The district court granted summary judgment to the nonprofit, concluding that the NVRA requires disclosure of the voter list and preempts the conflicting state law. The district court ordered the Election Commission to disclose the list. The Election Commission then moved for reconsideration, but the district court denied this motion. The Election Commission appealed both the grant of summary judgment and the denial of reconsideration.The United States Court of Appeals for the Fourth Circuit reviewed the case. On appeal, the Election Commission argued for the first time that the nonprofit lacked Article III standing to sue under the NVRA. The Fourth Circuit held that standing is a threshold jurisdictional issue and that the record lacked sufficient factual findings on standing, as the issue was not previously addressed in the district court. The Fourth Circuit remanded the case to the district court to determine whether the nonprofit has standing to bring the suit. The merits of the case were not addressed on appeal. View "Public Interest Legal Foundation, Inc. v. Wooten" on Justia Law

Darrell Meade worked as a coal miner for 37 years and applied for benefits under the Black Lung Benefits Act, which provides compensation to miners totally disabled by pneumoconiosis. A Labor Department claims examiner initially found that Meade qualified for benefits and that Dominion Coal Corporation was responsible for payment. However, the administrative law judge reviewing the case denied the claim, concluding that Meade’s medical evidence—including x-rays, biopsies, and CT scans—did not establish the irrebuttable presumption of complicated pneumoconiosis required for benefits.Meade appealed to the Benefits Review Board. The Board agreed with the judge’s findings regarding the x-ray and biopsy evidence but determined that the judge had not sufficiently evaluated or explained his analysis of the conflicting expert opinions on the CT scans. The Board vacated the denial in part and remanded the case, instructing the judge to address the competing expert rationales and to provide a clear explanation for his findings. On remand, the judge found Dr. DePonte’s interpretation of the scans more persuasive than Dr. Adcock’s and concluded that the evidence supported a diagnosis of complicated pneumoconiosis, awarding benefits to Meade. Dominion Coal Corporation appealed, challenging both the Board’s standard of review and the judge’s authority based on alleged unconstitutional removal protections.The United States Court of Appeals for the Fourth Circuit reviewed the Board’s interlocutory and final orders. The court held that it had jurisdiction to review interlocutory Board orders after a final order was issued. It found that the Board properly remanded the case when the administrative law judge failed to adequately explain his reasoning and that substantial evidence supported the final award of benefits. The court also rejected Dominion’s constitutional challenge, holding that Dominion had not shown harm from the removal protections. The Fourth Circuit denied Dominion’s petition for review. View "Dominion Coal Corporation v. DOWCP" on Justia Law

Vernon Vanderpool worked underground for over twenty years in coal mines, primarily as a roof bolter and section foreman. After retiring due to a back injury, he developed progressively worsening respiratory symptoms and was eventually diagnosed with pneumoconiosis, commonly known as black lung disease. In 2014, Vanderpool filed a claim for benefits under the Black Lung Benefits Act, asserting that his respiratory ailments rendered him totally disabled.Following his claim, the District Director of the U.S. Department of Labor’s Office of Workers’ Compensation Programs issued a decision awarding benefits. Clinchfield Coal Company, Vanderpool’s former employer, contested this decision. An Administrative Law Judge (ALJ) held a hearing and upheld the award, finding total disability based on pulmonary function tests and medical opinion evidence. Clinchfield then appealed to the Benefits Review Board, arguing that the ALJ erred in crediting certain pulmonary function tests and in weighing medical opinions. The Board rejected these arguments and affirmed the ALJ’s decision.The United States Court of Appeals for the Fourth Circuit reviewed Clinchfield’s petition, applying a highly deferential standard to the ALJ’s findings. The court held that the ALJ properly applied regulatory standards regarding pulmonary function tests, treating deviations from quality standards as affecting the weight rather than admissibility of the evidence. The ALJ’s assessment of medical opinions, including his rationale for crediting one expert over others, was sufficiently explained and satisfied the requirements of the Administrative Procedure Act. Substantial evidence supported the finding of total disability, permitting invocation of the statutory presumption of disability under the Act. As a result, the Fourth Circuit affirmed the Board’s decision and denied Clinchfield’s petition for review. View "Clinchfield Coal Company v. DOWCP" on Justia Law