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

The defendant, after pleading guilty to being a felon in possession of a firearm, received a below-Guidelines prison sentence followed by supervised release. Upon commencing supervision, he repeatedly violated its conditions, including using illegal drugs, failing to report for drug testing, skipping required addiction recovery meetings, and not paying a special assessment. After admitting these violations at a revocation hearing, he requested a return to supervision, while the government urged a significant term of imprisonment. The district court ultimately imposed a nine-month prison term followed by additional supervised release.Previously, the United States District Court for the Eastern District of Virginia considered the parties’ arguments, with the defense contending that the court could not consider the need to sanction the defendant’s breach of trust when imposing a revocation sentence. The court rejected this argument, relying on circuit precedent from United States v. Lewis, and imposed the revocation sentence. The defendant then appealed, arguing that the Supreme Court’s subsequent decision in Esteras v. United States abrogated the Fourth Circuit’s approach in Lewis.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court reaffirmed that its prior decision in Lewis remains valid, holding that a district court may lawfully impose a revocation sentence to sanction a defendant’s breach of the court’s trust. The Fourth Circuit explained that Esteras did not abrogate Lewis, as Esteras only barred consideration of retribution for the original offense, not the need to sanction a breach of supervised release conditions. The court concluded that the district court had not procedurally erred and that the revocation sentence was reasonable. Accordingly, the Fourth Circuit affirmed the judgment of the district court. View "US v. Chafin" on Justia Law

The petitioner, a native of Jordan, lawfully entered the United States in 2014 as the unmarried child of a U.S. citizen. In 2019, after being convicted in Virginia for a crime involving moral turpitude, he was charged with removability by the Department of Homeland Security. He sought relief from removal by applying for asylum, humanitarian asylum, withholding of removal, and protection under the Convention Against Torture (CAT), asserting that he feared persecution or torture if returned to Jordan due to past sexual assaults by two men, Abdul and Anas. The petitioner alleged that Abdul, a government employee, targeted him because of his vulnerability, and that Anas joined Abdul in the assaults. He reported these incidents to the police in Jordan, resulting in Anas’s conviction, but claimed Abdul was never charged. The petitioner returned to Jordan multiple times after the assaults but avoided further harm.The Immigration Judge (IJ) found the petitioner’s testimony about the assaults credible but denied all forms of relief, concluding there was no nexus between the alleged persecution and his proposed social group of “imputed homosexuals.” The IJ also determined he had not shown it was more likely than not that he would be tortured if returned to Jordan. The Board of Immigration Appeals affirmed the IJ’s decision, finding substantial evidence that the abuse was motivated by vulnerability rather than perceived homosexuality and that claims of future persecution on this basis were speculative. The Board also concluded that the petitioner had not established a sufficient probability of future torture.The United States Court of Appeals for the Fourth Circuit reviewed both the IJ’s and Board’s findings. Applying a highly deferential substantial evidence standard to factual findings and reviewing legal conclusions de novo, the court held that the agency did not err in denying relief. The court denied the petition for review, affirming the Board’s determinations that the petitioner did not qualify for asylum, withholding of removal, or CAT protection. View "Qaiymah v. Blanche" on Justia Law

Marshall Austin, a former federal prosecutor, joined the board of trustees of a private school attended by his children. During his tenure, the school had received and transferred federal COVID relief funds, and Austin became concerned about potential misuse or fraud related to these funds. He and his wife also vocally opposed the school's mask mandate policies, resulting in ongoing disputes with school administration. Austin’s access to board resources was revoked after he investigated financial documents, and the board ultimately voted to remove him, citing disruptive conduct and threats of legal action.After his removal, Austin filed suit under the False Claims Act’s anti-retaliation provision in the United States District Court for the District of South Carolina, naming the school, its Chair, and its Head of School as defendants. The district court granted summary judgment for the defendants, dismissing individual liability claims against the Chair and Head of School, and holding that Austin, as a trustee, was not an “employee, contractor, or agent” under 31 U.S.C. § 3730(h). Additionally, the court found no evidence that the school knew of Austin’s protected activities or acted against him because of them.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s summary judgment de novo. The Fourth Circuit affirmed the judgment, holding that Austin was not an “employee, contractor, or agent” of the school as defined by the False Claims Act and common-law agency principles. The court concluded that individual trustees lack authority to bind the institution and do not create agency relationships merely by engaging in fundraising or recruitment. Therefore, Austin could not maintain a retaliation claim under the False Claims Act, and the district court’s decision was affirmed. View "Austin v. Charleston Day School" on Justia Law

While serving a 180-month sentence at a federal prison, an inmate was implicated in the 2009 killing of another inmate during a prison altercation. Based on a prison official’s review, the inmate was charged administratively but, given the seriousness of the allegation, the prison deferred its process pending FBI and U.S. Attorney review. While no criminal charges were filed, the inmate remained in restrictive confinement for nearly three years. After the federal investigation concluded without prosecution, the prison resumed its disciplinary process, leading first to a finding against the inmate, then an administrative remand, and ultimately, in January 2017, to a complete expungement of the incident from his record.In 2016, the inmate filed two administrative tort claims under the Federal Tort Claims Act (FTCA), one alleging abuse of process related to the administrative remand, and a broader one alleging wrongful confinement, emotional distress, and other injuries. Both claims were denied by the Bureau of Prisons, the latter with explicit notice of a six-month period in which to file suit. The inmate filed his complaint in April or May 2017 in the United States District Court for the Northern District of West Virginia, which ultimately dismissed his claims as either time-barred under 28 U.S.C. § 2401(b) or unexhausted under 28 U.S.C. § 2675, concluding that the relevant limitations period began before his record was expunged and that his timely administrative claim did not encompass all pleaded causes of action.The United States Court of Appeals for the Fourth Circuit held that the inmate’s tort claims did not accrue until his disciplinary record was expunged on January 25, 2017, under the principles articulated in Heck v. Humphrey, 512 U.S. 477 (1994). Since the complaint was filed within six months of that date, the action was timely. The appellate court vacated the district court’s judgment and remanded for further proceedings, including an exhaustion analysis in light of its holding. View "Parrish v. US" on Justia Law

An IT analyst who is openly gay was hired by a large, Catholic-affiliated nonprofit based in Maryland. At the time of hiring, he was told his husband would be covered under the organization’s dependent health benefits. However, several months after his employment began, the organization informed him that providing benefits to his same-sex spouse was contrary to its religious beliefs and terminated those benefits. The employee declined alternative compensation and ultimately resigned from the organization after several years.The employee sued in the United States District Court for the District of Maryland, bringing claims under federal and state employment discrimination laws, including Title VII, the Equal Pay Act, and the Maryland Fair Employment Practices Act (MFEPA). The district court granted summary judgment for the employee on the Title VII and Equal Pay Act claims and, after certifying questions to the Maryland Supreme Court regarding the scope of the MFEPA’s religious exemption, held a bench trial and entered judgment for the employee on the remaining MFEPA claim. The parties stipulated to damages, but the employer reserved the right to appeal on liability.The United States Court of Appeals for the Fourth Circuit reviewed the employer’s statutory and constitutional defenses. The court held that Title VII’s religious employer exemption does not shield religious organizations from liability for discrimination based on sex, even if the employment decision is rooted in religious belief. Similarly, under MFEPA, the court found the exemption applies only to employees whose duties directly further the core mission of the organization; the employee’s roles did not meet this test. The court also held that the Religious Freedom Restoration Act does not apply to suits between private parties. Constitutional arguments based on the First Amendment’s Religion Clauses and church autonomy doctrine were rejected as grounds for immunity. The Fourth Circuit affirmed the district court’s judgment on Title VII and MFEPA claims and dismissed the Equal Pay Act appeal as moot. View "Doe v. Catholic Relief Services" on Justia Law

Two public school boards in Virginia adopted policies permitting transgender and gender-expansive students to use bathrooms, locker rooms, and overnight accommodations consistent with their gender identity, rather than their sex assigned at birth. These policies also ensured that such students would not be required to use separate or single-occupancy facilities unless all other students were similarly required. After a complaint was filed, the Department of Education’s Office for Civil Rights investigated and determined that these policies violated Title IX. The Department attempted to negotiate a resolution, but when the school boards refused to make changes, the Department designated them as “high-risk” federal grant recipients and required them to use a reimbursement payment method for federal funds until compliance was achieved.The school boards filed suit in the United States District Court for the Eastern District of Virginia under the Administrative Procedure Act, seeking declarations that their policies were lawful under Title IX, an order vacating the high-risk designations, and injunctions against further enforcement actions. The district court sua sponte dismissed the consolidated complaints for lack of subject matter jurisdiction, holding that the Tucker Act granted exclusive jurisdiction to the Court of Federal Claims because the complaints, in its view, sought to enforce contractual obligations regarding federal funding.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the dismissal de novo. The court held that the district court erred in concluding that all claims were essentially contractual and thus exclusively within the jurisdiction of the Court of Federal Claims. The Fourth Circuit determined that the school boards’ claims were based on statutory rights under Title IX, not contract rights, and that at least some of the relief sought, including declaratory and injunctive relief, was not contractual in nature. The court vacated the district court’s dismissal and remanded the case for further proceedings. View "Fairfax County School Board v. McMahon" on Justia Law

Jesse Owens, while serving a term of supervised release following a federal conviction for possessing a firearm and ammunition while under a domestic violence restraining order, was accused of several violations, including new criminal conduct. Specifically, he was charged in South Carolina state court with first-degree assault and battery after an incident where the victim testified that Owens bit, choked, and punched her over an eight-hour period, causing significant injuries. Photographic evidence of her injuries was presented at the revocation hearing.The United States District Court for the District of South Carolina found Owens had violated his supervised release by committing first-degree assault and battery under South Carolina law. The court classified the conduct as a Grade A violation, calculated the advisory Sentencing Guidelines range as 12 to 18 months, but imposed an upward variance, sentencing Owens to 24 months in prison and an additional 12 months of supervised release. The court justified the sentence based on Owens’s history of violence and his disregard for imposed conditions. Owens did not object to the characterization of his conduct or the severity of the violation at the time.Owens appealed to the United States Court of Appeals for the Fourth Circuit, arguing that the district court erred by categorizing South Carolina first-degree assault and battery as a “crime of violence,” affecting the guidelines calculation. The Fourth Circuit applied the categorical and modified categorical approaches, referencing its own precedent in United States v. Mack, and rejected Owens’s reliance on United States v. Clemons from the Supreme Court of South Carolina, noting Clemons did not directly address first-degree assault and battery. The Fourth Circuit held that the district court did not commit plain error and affirmed the district court’s judgment. View "US v. Owens" on Justia Law

After her husband was kidnapped and likely murdered in Honduras, and her brother-in-law—who had opposed a local gang—was murdered, a woman and her young daughter fled to the United States. The woman believed the 18th Street Gang was responsible for both crimes and feared retaliation against her family. After arriving in the U.S., she applied for asylum, citing her relationship to her husband’s immediate family as the basis for her claim. She submitted supporting evidence including a death certificate, police report, and affidavits. Later, after receiving direct death threats from individuals identified as gang members, she sought to reopen her asylum proceedings based on this new evidence.The Immigration Judge found her testimony credible but determined the evidence did not sufficiently establish persecution on account of her membership in a protected group—her husband’s family—due to a lack of proof regarding the gang’s involvement in the murders. The Board of Immigration Appeals (BIA) reviewed and affirmed this decision. After the death threats, the woman filed a motion to reopen, providing new evidence; however, the BIA denied the motion, concluding the threats did not demonstrate a nexus between the persecution and her family membership.The United States Court of Appeals for the Fourth Circuit reviewed the BIA’s denial. The Fourth Circuit held that the BIA abused its discretion by failing to adequately consider the new evidence and the context surrounding the threats. The court found that the nexus requirement was satisfied, as the threats and violence were sufficiently connected to the woman’s family membership. The Fourth Circuit granted the petition for review, vacated the BIA’s order, and remanded the case for further proceedings consistent with its opinion. View "Fajardo-Rivas v. Blanche" on Justia Law

While incarcerated on federal charges in North Carolina, the defendant orchestrated a contraband smuggling operation involving bribery of correctional officers and conspiracy to distribute drugs. During a cell search related to the investigation, law enforcement officers discovered drugs and other contraband. As officers attempted to remove the defendant from his cell, he assaulted a correctional officer by lifting him off the ground, throwing him against a wall, and slamming him onto a concrete floor. Although the officer suffered no serious injury, the incident was captured on surveillance video.The United States District Court for the Eastern District of North Carolina accepted the defendant’s guilty plea to bribery of a public official and conspiracy to distribute a controlled substance. At sentencing, the court determined that the six-level “Official Victim” enhancement under U.S.S.G. § 3A1.2(c)(2) applied, finding the assault created a substantial risk of serious bodily injury. The court sentenced the defendant to 102 months’ imprisonment, a sentence within the calculated Guidelines range. The defendant appealed, arguing that the district court applied the wrong legal standard for the enhancement, that the facts did not support its application, and that his sentence was both procedurally and substantively unreasonable.The United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The appellate court held that the district court applied the correct legal standard for the § 3A1.2(c)(2) enhancement and did not clearly err in finding the defendant’s conduct created a substantial risk of serious bodily injury. The court also found that the district court adequately addressed the defendant’s mitigation arguments and properly considered the sentencing factors under 18 U.S.C. § 3553(a). The appellate court concluded that the within-Guidelines sentence was both procedurally and substantively reasonable. View "US v. Vick" on Justia Law

The plaintiff, a convicted inmate at Riverside Regional Jail, was placed in restrictive housing after being found with contraband, and later spent five months in the Restrictive Housing Unit (RHU) due to repeated infractions and misconduct. During this period, he experienced varying levels of confinement and privileges, including periods of isolation, limited access to recreation, and additional restrictions following disciplinary incidents. He was also shackled to a telephone on two occasions for several hours, during which he alleged suffering humiliation and physical discomfort.The United States District Court for the Eastern District of Virginia granted summary judgment to the jail officials, both before and after limited discovery. The court dismissed all but two defendants and ordered production of any surveillance video related to the incidents. After reviewing the available evidence, including video footage, the district court rejected the plaintiff’s claims regarding conditions of confinement and due process violations.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The panel held that the district court did not abuse its discretion in granting summary judgment before discovery, as the plaintiff failed to show that additional evidence would have affected the outcome. Reviewing de novo, the Fourth Circuit concluded that the plaintiff’s placement in restrictive housing did not implicate a protected liberty interest under the Fourteenth Amendment because the conditions, duration, and review process did not constitute atypical and significant hardship. The court also found that the conditions of confinement—including the telephone shackling incidents—did not rise to the level of “extreme deprivation” required for an Eighth Amendment violation, and even if they had, the officials would be entitled to qualified immunity because no clearly established right was violated. The judgment of the district court was affirmed. View "Mason v. Talley" on Justia Law