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

Six small businesses entered into two contracts with Bank of America: one for deposit accounts, which included an arbitration provision, and another for Paycheck Protection Program (PPP) loans, which did not include an arbitration clause. When disputes arose regarding the bank's handling of the PPP loans, the businesses sued the bank in federal court. The bank moved to compel arbitration based on the deposit agreements.The United States District Court for the District of Maryland granted the bank's motion to compel arbitration and dismissed the complaint. The court concluded that the deposit agreements contained a valid and enforceable delegation clause, which required that any disputes about the arbitrability of the claims be decided by an arbitrator, not the court.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The Fourth Circuit agreed that the deposit agreements clearly and unmistakably delegated the question of arbitrability to the arbitrator. The court noted that the businesses failed to properly raise any fourth-order disputes, which would involve determining which of the two contracts governed the arbitrability of the disputes. The court also found that the businesses did not specifically challenge the validity of the delegation clause itself, which is necessary to avoid its application.The Fourth Circuit held that the district court correctly compelled arbitration and dismissed the complaint, as the businesses did not request a stay of the proceedings pending arbitration. The court emphasized that the businesses' arguments about the scope of the arbitration provision were matters for the arbitrator to decide, given the valid delegation clause in the deposit agreements. View "Modern Perfection, LLC v. Bank of America, N.A." on Justia Law

Carmen Wannamaker-Amos, a Black woman, worked in quality management at Purem Novi, Inc. for over thirty years. Despite receiving positive reviews from her supervisors, she faced negative treatment from Javad Hosseini, Purem’s chief quality executive. Hosseini repeatedly urged her supervisors to fire her, and in January 2020, after a problem with an automobile part, he requested her termination. Purem terminated her two days later. Wannamaker-Amos sued Purem, alleging racial and sex discrimination under Title VII of the Civil Rights Act of 1964 and the Civil Rights Act of 1866.The United States District Court for the District of South Carolina granted summary judgment to Purem, ruling that Wannamaker-Amos failed to produce sufficient evidence that the nondiscriminatory reason given for her firing was pretextual. The court found that she did not meet her employer’s legitimate expectations at the time of her termination.The United States Court of Appeals for the Fourth Circuit reviewed the case and concluded that numerous issues of material fact were in dispute. The court found that Wannamaker-Amos provided ample evidence to dispute Purem’s claims about her performance and that Hosseini’s criticisms were baseless. The court also noted that Purem’s shifting reasons for her termination and failure to follow its own disciplinary policies could indicate pretext for discrimination. The court emphasized that it is the role of the jury to decide which party’s evidence is more persuasive.The Fourth Circuit vacated the district court’s grant of summary judgment and remanded the case for further proceedings, allowing a jury to determine whether Wannamaker-Amos was subjected to intentional discrimination. View "Wannamaker-Amos v. Purem Novi, Inc." on Justia Law

Johnnie Franklin Wills, a state prisoner, filed a habeas petition challenging his life sentence under West Virginia’s recidivist statute. He argued that the judicially crafted test for determining whether a recidivist life sentence is proportional to the crime is unconstitutionally vague. Wills was convicted of grand larceny and conspiracy to commit grand larceny in 2016, and due to his prior eight felony convictions, he was sentenced to life imprisonment with parole eligibility after fifteen years under the recidivist statute.The West Virginia courts denied Wills relief, stating that the void-for-vagueness doctrine does not apply to their proportionality test. The Supreme Court of Appeals of West Virginia affirmed this decision, distinguishing Wills’s case from the U.S. Supreme Court’s decisions in Johnson v. United States and Sessions v. Dimaya, which invalidated certain statutory provisions as unconstitutionally vague. The state court maintained that the proportionality test was clear and did not fall under the same scrutiny as the statutes in Johnson and Dimaya.Wills then filed a federal habeas petition under 28 U.S.C. § 2254, which the United States District Court for the Northern District of West Virginia also denied. The district court found that the state court’s decision was not contrary to or an unreasonable application of clearly established federal law. The court noted that the proportionality test serves as a judicial limitation on the recidivist statute, unlike the statutory mandates in Johnson and Dimaya.The United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The court held that the state court’s ruling was not an unreasonable application of clearly established federal law, as the U.S. Supreme Court has not extended the void-for-vagueness doctrine to judicially crafted proportionality tests. Therefore, Wills’s habeas petition was denied. View "Wills v. Pszczolkowski" on Justia Law

Charles Pittman pleaded guilty to violating a federal law that criminalizes burning or attempting to burn buildings owned by institutions that receive federal funding. He was charged with aiding and abetting others in maliciously damaging and destroying the Market House, a building owned by the City of Fayetteville, which receives federal financial assistance. During his plea hearing, Pittman confirmed his understanding of the charges and admitted to committing acts constituting the elements of the crime.The United States District Court for the Eastern District of North Carolina accepted Pittman's guilty plea and later sentenced him to 60 months of imprisonment. Before sentencing, Pittman moved to dismiss Count 1, arguing that the statute required a nexus between the federal financial assistance and the damaged property, and that the criminal information failed to allege such a nexus. He also argued that the City of Fayetteville is not an "institution or organization" under the statute. The district court denied the motion to dismiss.The United States Court of Appeals for the Fourth Circuit reviewed the case. Pittman argued that his conduct did not violate the statute and that the statute was unconstitutional as applied to him. The court held that Pittman waived his statutory construction arguments by pleading guilty, as a guilty plea admits that the conduct violated the statute. The court also found that Pittman's as-applied constitutional challenge was forfeited because he did not timely raise it before the district court, and he failed to show plain error.The Fourth Circuit affirmed the district court's judgment, holding that Pittman's guilty plea waived his statutory arguments and that his constitutional challenge was both forfeited and failed to meet the plain-error standard. View "United States v. Pittman" on Justia Law

The defendant, Thuy Tien Luong, was convicted of forced labor in violation of 18 U.S.C. § 1589. Luong used threats and coercion to force the victim, a nail technician, to continue working against her will. The victim, who had a limited education and poor English skills, was subjected to physical abuse and threats of reputational harm and legal consequences by Luong. The victim was coerced into writing checks for alleged mistakes and a fabricated debt of $180,000. The abuse included physical violence, such as beatings and threats, which led to visible injuries and scars on the victim.The case was initially reviewed by the United States District Court for the Western District of North Carolina. After a five-day trial, the jury found Luong guilty of forced labor. At sentencing, the district court applied several enhancements, including a two-level vulnerable victim enhancement and a four-level permanent scarring enhancement, resulting in a final offense level of 37. Luong was sentenced to 180 months in prison. She appealed her conviction and sentence, arguing insufficient evidence for her conviction and errors in the application of sentencing enhancements.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed Luong's conviction, finding substantial evidence that she knowingly coerced the victim into forced labor through threats and physical abuse. However, the court vacated and remanded her sentence for resentencing. The court found that the district court did not provide sufficient findings to support the application of the two-level vulnerable victim enhancement under U.S.S.G. § 3A1.1(b)(1). The court upheld the four-level permanent scarring enhancement under U.S.S.G. § 2H4.1(b)(1)(A), finding sufficient evidence that the victim's scars were permanent. View "U.S. v. Luong" on Justia Law

Kristen M. Barnett, a former registered nurse at INOVA Health Care Services, refused to receive the COVID-19 vaccine due to her religious beliefs. INOVA had a policy requiring vaccination unless an exemption was granted. Barnett initially received a medical exemption but later requested a religious exemption, which was denied. She was subsequently placed on administrative leave and then discharged for noncompliance. Barnett filed a lawsuit against INOVA, alleging religious discrimination under Title VII and the Virginia Human Rights Act (VHRA).The United States District Court for the Eastern District of Virginia granted INOVA's motion to dismiss Barnett's complaint in its entirety. The court found that Barnett failed to state a claim for reasonable accommodation under Title VII because her objection did not raise issues related to abortion or fetal cells. The court also dismissed her disparate treatment claims under Title VII and the VHRA, finding them duplicative and lacking a comparator.The United States Court of Appeals for the Fourth Circuit reviewed the case and reversed the district court's decision. The appellate court held that Barnett had sufficiently alleged religious discrimination for all three claims at the motion to dismiss stage. The court found that Barnett's allegations demonstrated her sincere religious beliefs and that her refusal to receive the vaccine was religious in nature. The court also found that Barnett's allegations supported a reasonable inference of discriminatory intent by INOVA.The Fourth Circuit reversed the district court's dismissal and remanded the case for further proceedings, allowing Barnett's claims to proceed. View "Barnett v. INOVA Health Care Services" on Justia Law

Cornelius Mayberry was involved in a narcotics sting operation where he was arrested at a Red Roof Inn in Gaffney, South Carolina. Mayberry was found with a backpack containing over four pounds of methamphetamine. He entered a conditional guilty plea to charges including possession with intent to distribute methamphetamine and fentanyl, possession of a firearm in furtherance of a drug trafficking offense, and assault and resistance to official search or seizure. Mayberry reserved the right to appeal the district court’s denial of his motions to suppress evidence obtained from his backpack and his post-arrest statements, as well as the court’s denial of his motion to withdraw his guilty plea before sentencing.The United States District Court for the District of South Carolina denied Mayberry’s motions to suppress, finding that the officers had probable cause to arrest him and that he had abandoned his backpack. The court also denied his motion to withdraw his guilty plea, concluding that Mayberry had not provided a fair and just reason for the withdrawal. Mayberry was sentenced to 414 months in prison.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court’s decisions. The appellate court held that the district court did not abuse its discretion in denying Mayberry’s motion to withdraw his guilty plea, as the plea was entered knowingly and voluntarily. The court also found that the officers had probable cause to arrest Mayberry based on the information provided by a cooperating individual and the real-time observations of Mayberry’s actions. Additionally, the court upheld the district court’s finding that Mayberry had abandoned his backpack, thus relinquishing any reasonable expectation of privacy in it. Consequently, the search of the backpack was deemed lawful. View "US v. Mayberry" on Justia Law

Three plaintiffs, including a Virginia citizen, a Virginia entity, and an out-of-state entity, challenged Virginia Senate Bill 903, which regulates the retail sale of hemp products based on their total tetrahydrocannabinol (THC) concentration. The plaintiffs argued that the 2018 Farm Bill, which legalized hemp with a delta-9 THC concentration of no more than 0.3%, preempts the more restrictive Virginia law. They also claimed that the Virginia law violates the Dormant Commerce Clause of the U.S. Constitution.The United States District Court for the Eastern District of Virginia denied the plaintiffs' motion for a preliminary injunction. The court found that the plaintiffs were unlikely to succeed on their preemption arguments, as the 2018 Farm Bill does not expressly preempt state laws regulating hemp more stringently. The court also concluded that the plaintiffs did not sufficiently allege that they were licensed processors under Virginia law, thus lacking standing to challenge the provision preventing Virginia processors from selling hemp products to others who would use them in violation of the total THC standard. Additionally, the court rejected the plaintiffs' Dormant Commerce Clause claims, finding no evidence that the Virginia law discriminates against or unduly burdens interstate commerce.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court agreed with the district court that the plaintiffs lacked standing to challenge the sales restriction provision, as they did not allege sufficient facts showing they were licensed processors. The court vacated the district court's order regarding this claim and remanded with instructions to dismiss it without prejudice. However, the court affirmed the district court's denial of injunctive relief concerning the total THC standard, finding that the plaintiffs failed to show a likelihood of success on their preemption and Dormant Commerce Clause claims. View "Northern Virginia Hemp and Agriculture, LLC v. Commonwealth of Virginia" on Justia Law

John Doe 2, a student athlete at North Carolina State University, alleged that he was sexually abused by Robert Murphy, the university’s Director of Sports Medicine, under the guise of medical treatment. Doe claimed that the university was deliberately indifferent to prior complaints of Murphy’s sexual misconduct. The district court dismissed Doe’s complaint, finding that he failed to plead facts supporting an inference that the university had actual notice of Murphy’s sexual harassment.The United States District Court for the Eastern District of North Carolina dismissed the complaint under Federal Rule of Civil Procedure 12(b)(6). The court concluded that a report of “sexual grooming” could not provide actual notice to the university of sexual harassment. The district court assumed without deciding that the report was made to an official with the requisite authority for Title IX purposes but found that the report did not describe an incident of sexual harassment and thus could not support a plausible inference of actual notice.The United States Court of Appeals for the Fourth Circuit reviewed the case and vacated the district court’s judgment. The Fourth Circuit held that a report of “sexual grooming” can objectively be construed as alleging sexual harassment, thus providing actual notice to the university. The court found that the district court erred in its conclusion and remanded the case for further proceedings to determine whether the report was made to an appropriate official with the authority to address complaints of sexual harassment and to institute corrective measures on behalf of the university. View "John Doe 2 v. North Carolina State University" on Justia Law

Davina Ricketts, a sophomore at a high school in North Carolina, decided to run for student council to address its lack of diversity. She faced racial harassment and cyberbullying from peers, and the school district allegedly failed to intervene. Ricketts filed a lawsuit claiming the school district was deliberately indifferent to her harassment. The district court dismissed her complaint and denied her motion to amend, stating her proposed amended complaint also failed to state a claim. Ricketts appealed the denial of her motion for leave to amend.The United States District Court for the Eastern District of North Carolina initially dismissed Ricketts' complaint and denied her motion to amend on futility grounds. The court reasoned that her proposed amended complaint did not sufficiently state claims for deliberate indifference, retaliation, or equal protection violations.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that Ricketts sufficiently alleged deliberate indifference, retaliation, and equal protection claims. The court held that Ricketts' allegations of racial harassment, the school administrators' authority and actual knowledge of the harassment, and their deliberate indifference were sufficient to state a Title VI claim. The court also found that Ricketts sufficiently alleged retaliation by showing she engaged in protected activity, faced materially adverse actions, and established a causal connection between the two. Additionally, the court held that Ricketts sufficiently alleged an equal protection claim against individual defendants and the Board of Education by showing discriminatory intent and a municipal custom or policy of indifference.The Fourth Circuit reversed the district court's judgment, directed the district court to allow Ricketts to amend her complaint, and remanded the case for further proceedings. View "Ricketts v. Wake County Public School System" on Justia Law