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

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

While incarcerated at a North Carolina women’s correctional facility, the plaintiff learned she was pregnant and, due to her history of opioid use disorder, was prescribed medication for opioid withdrawal (MOUD) under a prison policy that restricted such treatment to pregnant inmates. When she went into labor, she was transported to the hospital and was shackled at various stages during labor, delivery, and her return to prison. After giving birth, the facility denied her further MOUD because she was no longer pregnant, instead providing a short course of alternative pain medication. She experienced significant withdrawal symptoms as a result. The plaintiff brought claims against various prison officials, alleging violations of the Eighth Amendment for the shackling and for denial of MOUD, as well as disability discrimination under the Americans with Disabilities Act and the Rehabilitation Act.The United States District Court for the Eastern District of North Carolina granted summary judgment to all defendants, finding no constitutional violations and that qualified immunity protected the officials. It also concluded that the plaintiff was not discriminated against under federal disability law because the MOUD program was limited to pregnant inmates.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed in part, vacated in part, and remanded. The Fourth Circuit held that, as to certain officials, there was a genuine dispute of fact regarding whether shackling the plaintiff during labor and postpartum, without evidence of a security or flight risk, violated the Eighth Amendment. The court also held that the denial of MOUD following pregnancy, pursuant to a categorical policy, could constitute deliberate indifference to serious medical needs under the Eighth Amendment, and that summary judgment was inappropriate for the medical officials involved. The court further vacated the lower court’s disposition of the plaintiff’s ADA and Rehabilitation Act claims, remanding for further proceedings. Summary judgment for other defendants was affirmed. View "Edwards v. Witherspoon" on Justia Law

Two individuals who had lived in the United States for many years after entering without inspection were detained by Immigration and Customs Enforcement in October 2025. Both were apprehended while living and working in the Washington, D.C. area, and had established significant ties to the community. Removal proceedings were initiated against them on the basis that they had entered the country without authorization. Following their detention, neither was given an opportunity for a bond hearing, a process that, prior to July 2025, would have typically been available to noncitizens in their circumstances unless they posed certain risks or had committed specific crimes—none of which applied to these individuals.After the Department of Justice adopted a new interpretation of the relevant immigration statute in July 2025, mandating detention for all noncitizens who entered without inspection under 8 U.S.C. § 1225(b)(2)(A), the individuals filed habeas petitions in the United States District Court for the Eastern District of Virginia. They argued that they were entitled to bond hearings under 8 U.S.C. § 1226(a) and that their continued detention violated due process. The district court agreed, granting habeas relief and ordering bond hearings under § 1226(a). During these hearings, immigration judges found neither individual posed a danger or flight risk, and both were released on bond. The government appealed, and the cases were consolidated.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s grant of habeas relief de novo. The Fourth Circuit held that § 1226, not § 1225, governs the detention of noncitizens who have been present in the United States for years, regardless of their manner of entry. The court concluded that the statutory text, structure, history, and longstanding interpretation all supported this reading, and that detaining such individuals without bond hearings raised significant constitutional concerns. The court affirmed the district court’s grant of habeas relief, requiring bond hearings for the petitioners. View "Lopez Garcia v. Guadian" on Justia Law

On New Year’s Day 2024, a Franklin County sheriff’s lieutenant attempted to stop a speeding Kia driven by Isaac Martinez-Chavez, who was a convicted felon. The vehicle accelerated, turned off its lights, and stopped in a yard. Upon approaching the car, the officer saw Martinez-Chavez reaching into the passenger area. After detaining him, officers found a sawed-off .22 rifle, a .22 revolver, and .22 caliber ammunition inside the vehicle. Martinez-Chavez claimed he was unaware of the firearms, presenting testimony from Olman Vallejos, who said he hid the guns without Martinez-Chavez’s knowledge. However, Vallejos’s credibility was severely undermined at trial.The United States District Court for the Western District of Virginia presided over the trial. Before trial, Martinez-Chavez requested an adverse-inference jury instruction because dispatch recordings of the arrest had been deleted in accordance with a routine records-retention policy. The district court denied this motion, finding no evidence of bad faith or willful conduct by the government and noting comparable evidence remained. During closing arguments, the prosecutor made two improper remarks, one referring to a witness as a “liar” and another appealing to the jury to convict for the sake of law enforcement. The court overruled defense objections but instructed the jury that statements by lawyers were not evidence and that law enforcement testimony was not to be given extra weight.The United States Court of Appeals for the Fourth Circuit reviewed the case. It held that although the prosecutor’s remarks were improper, they did not prejudice Martinez-Chavez’s right to a fair trial, given the overwhelming evidence against him and the curative jury instructions. The appellate court also found the district court did not abuse its discretion in denying the adverse-inference instruction, as there was no showing of willful destruction or governmental knowledge of the recordings’ relevance before their deletion. The conviction was affirmed. View "US v. Martinez-Chavez" on Justia Law

Richard Rund, a U.S. citizen and businessman, failed to report his interest in multiple foreign bank accounts over several years, specifically from 2003 to 2008, 2013, and 2014. He maintained accounts in his own name and in the names of various businesses and entities, including FOB Instruments Ltd., York Luen, and Far East Ventures Ltd. Despite knowing about his obligation to file annual FBARs (Reports of Foreign Bank and Financial Accounts), Rund omitted many accounts from his filings or failed to file altogether. He later participated in the IRS’s Offshore Voluntary Disclosure Program but was removed from it. Throughout the period, Rund experienced personal and health challenges, but continued to work with tax professionals.The United States District Court for the Eastern District of Virginia reviewed the government’s civil suit to reduce IRS-assessed penalties to judgment after Rund did not pay the $2,915,633 assessed for his willful FBAR violations. After discovery, the district court granted summary judgment for the government, finding that Rund had a financial interest in the accounts, knew of his reporting requirements, and intentionally or recklessly disregarded them. The court also held that the Excessive Fines Clause of the Eighth Amendment did not apply to civil FBAR penalties and, even if it did, the penalties were not excessive. Judgment was entered against Rund for the full penalty plus interest.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The court affirmed summary judgment, holding that Rund’s FBAR violations were willful as a matter of law under the civil recklessness standard set out in United States v. Horowitz, 978 F.3d 80 (4th Cir. 2020). The court further held that the $2.9 million penalty did not violate the Excessive Fines Clause, as it was not grossly disproportional to the gravity of Rund’s willful, repeated violations. The judgment was affirmed. View "US v. Rund" on Justia Law