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

The case concerns Robert Boyd, who had a history of sexual offenses involving minors. After serving prison time for downloading child sexual abuse material, post-incarceration civil commitment proceedings were initiated against him under the Adam Walsh Child Protection and Safety Act. Boyd was designated a “sexually dangerous person” and committed to the custody of the Attorney General. Eight years later, Boyd was conditionally discharged after the district court concluded he no longer posed a threat if released under a strict treatment regimen. Conditions included supervision, participation in treatment, restrictions on internet usage, and prohibitions on possessing pornography.About a year after his conditional discharge, the Government sought to revoke Boyd’s release, alleging he violated his treatment regimen by possessing an SD card with images deemed pornographic and engaging in risk-related behaviors, such as interactions with underage individuals and unauthorized internet use. The United States District Court for the Eastern District of North Carolina found Boyd in violation, determined he remained sexually dangerous, and revoked his conditional discharge, returning him to federal custody.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s factual findings for clear error and legal conclusions de novo. The court held that revocation of conditional discharge under the Adam Walsh Act requires the Government to prove by a preponderance of the evidence that the individual failed to comply with their prescribed regimen, suffers from a serious mental disorder, and would have serious difficulty refraining from sexually violent conduct if released. The Fourth Circuit affirmed the district court’s findings, concluding there was sufficient evidence Boyd violated his regimen and posed a risk if allowed to remain in the community. The judgment revoking Boyd’s conditional discharge was affirmed. View "US v. Boyd" on Justia Law

A transmission development company sought to build a high-voltage transmission line across three Maryland counties to address a regional electricity shortage. After receiving federal approval, the company was required to obtain a Certificate of Public Convenience and Necessity (CPCN) from Maryland's Public Service Commission (PSC) before construction. As part of the CPCN application, environmental and socioeconomic field studies needed to be conducted on properties along the proposed route. The property owners refused access for these surveys, prompting the developer to submit desktop studies instead, which the PSC's Power Plant Research Program (PPRP) found inadequate, deeming the application incomplete. The developer then sought an injunction to enter the properties for the necessary field studies.The United States District Court for the District of Maryland granted the developer's motion for a preliminary injunction, finding that the developer was likely to succeed on the merits under Maryland law, particularly Section 12-111(a) of the Real Property Article, which allows entities with eminent domain powers to access private land for surveys. The court determined that the developer had a viable claim to such power for the purposes of conducting the surveys, even though it could not condemn property until it obtained a CPCN. The court also found irreparable harm due to lost revenues from project delays, that the balance of equities favored the developer, and the public interest supported the injunction.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s decision under an abuse of discretion standard. The Fourth Circuit affirmed, holding that the district court did not abuse its discretion in granting the preliminary injunction. The court concluded that the developer likely possessed the statutory right of access to conduct surveys prior to obtaining a CPCN, and that all four Winter factors for injunctive relief were satisfied. View "PSEG Renewable Transmission LLC v. Arentz Family, LP" on Justia Law

A South Carolina lender originates loans only within South Carolina but has extended credit to individuals with Pennsylvania addresses. Although the lender does not operate in Pennsylvania, it has engaged in activities connected to Pennsylvania, such as perfecting liens, collecting payments, and repossessing vehicles located in Pennsylvania. The Pennsylvania Department of Banking and Securities investigated the lender’s practices involving Pennsylvania residents, issuing subpoenas and ultimately initiating a formal administrative enforcement proceeding for alleged violations of Pennsylvania’s usury laws.Previously, the United States District Court for the District of Delaware granted summary judgment for the lender, finding Pennsylvania’s subpoena violated the Dormant Commerce Clause. The United States Court of Appeals for the Third Circuit reversed, holding that Pennsylvania could investigate and apply its usury laws to conduct connected to Pennsylvania. Afterward, Pennsylvania enforced its subpoena and initiated the administrative enforcement proceeding. The lender responded by filing suit in the United States District Court for the District of South Carolina, seeking to enjoin both the enforcement proceeding and a new subpoena, raising constitutional claims including those under the Dormant Commerce Clause.The United States District Court for the District of South Carolina dismissed the lender’s complaint, holding that claims related to the enforcement proceeding were barred by issue preclusion or, alternatively, by Younger abstention. Claims challenging the second subpoena were dismissed as unripe due to lack of present injury.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s dismissal of claims challenging the administrative enforcement proceeding under Younger abstention, finding it was a quasi-criminal civil enforcement proceeding and that state interests and procedures were sufficient. The court also affirmed dismissal of claims challenging the second subpoena on ripeness grounds, but vacated the judgment insofar as those claims were dismissed with prejudice, remanding with instructions to dismiss them without prejudice. View "TitleMax of South Carolina, Inc. v. Spicher" on Justia Law

After a workplace injury, an employee developed a disability that prevented him from performing his previous physically demanding job as a pest control technician. He repeatedly requested reassignment to a less demanding “light-duty” position, providing medical documentation and engaging with his employer about his limitations and desire to return to work. Despite these requests, the employer neither responded substantively nor engaged in discussions about available light-duty positions. Over sixteen months, the employee remained on unpaid leave and ultimately resigned after the employer filled several suitable positions without contacting him.The United States District Court for the District of Maryland granted summary judgment in favor of the employer on both claims brought under the Americans with Disabilities Act (ADA). The court found that the employee could not perform the essential functions of his original position with a reasonable accommodation and concluded that placing him on indefinite unpaid leave constituted a reasonable accommodation. It also determined that the unlawful termination claim failed because the employee had voluntarily resigned.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. It held that genuine issues of material fact remained regarding whether the employer was obligated to reassign the employee to a light-duty position and whether it failed to provide a reasonable accommodation. The court clarified that the ADA requires consideration of whether an employee can perform the essential functions of the desired position, not just the original one, and that indefinite unpaid leave is not a reasonable accommodation when reassignment is possible. However, the court affirmed dismissal of the unlawful termination claim because the employee failed to exhaust administrative remedies on that claim. The Fourth Circuit vacated and remanded the summary judgment on the failure to accommodate claim, but affirmed summary judgment on the unlawful termination claim. View "Dieng v. Orkin, LLC" on Justia Law

The case concerns two individuals who owned a car loan business in Virginia. Their business, Total Auto Financing, LLC, borrowed significant sums from American Credit Acceptance, LLC, with the loans personally guaranteed by the owners. After a series of renewals and a final short-term extension with restrictive terms, Total Auto defaulted on its debt. Following the default, American Credit replaced Total Auto as the servicer of its loan portfolio with Peritus Portfolio Services II, LLC. The new servicer’s management coincided with a sharp decline in the value and performance of the loan portfolio. The business was eventually forced into bankruptcy, and its main asset was sold at auction for much less than its previous value, leaving the owners personally liable for a large deficiency due to their guarantees.After the bankruptcy filing, the owners, acting in their personal capacities, filed complaints against American Credit and the new servicer (and related parties), alleging a range of claims including breach of fiduciary duty, negligence, unjust enrichment, conspiracy, and others. The United States Bankruptcy Court for the Eastern District of Virginia dismissed both complaints, finding that the claims belonged to the LLC, not the individual owners. The United States District Court for the Eastern District of Virginia affirmed the dismissals.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. It held that the principle determining who owns a claim—whether the business or its equity holders—means that owners cannot personally sue for injuries suffered by the business, even if they are financially harmed as a result. The court concluded that all claims asserted were either direct claims belonging to the LLC or failed to allege a personal injury distinct from the LLC’s injury. The Fourth Circuit affirmed the district court’s judgment, holding that the individual owners could not bring these claims in their own names. View "Bayramov v. American Credit Acceptance" on Justia Law

The plaintiff, a former Assistant Commonwealth’s Attorney for the City of Martinsville, Virginia, sought leave under the Family and Medical Leave Act (FMLA) in November 2021 to care for his mother. He submitted an FMLA certification form, personally completing the section meant for a medical provider and subsequently obtaining a nurse’s signature. After submitting the form to his employer, concerns arose regarding the authenticity of the certification, specifically whether the medical provider was aware of signing a FMLA-related document. The plaintiff was questioned by his supervisor about the circumstances and ultimately terminated after declining to resign.The United States District Court for the Western District of Virginia reviewed the plaintiff’s claim that his FMLA rights had been interfered with when his employer contacted his mother’s medical provider for authentication before giving him an opportunity to cure any alleged deficiency. The district court assumed qualified immunity was a defense to FMLA interference claims, but denied the defendant’s summary judgment motion, ruling that federal regulations clearly established the right to a cure period before such contact.The United States Court of Appeals for the Fourth Circuit reviewed the interlocutory appeal, focusing on whether it was clearly established in November 2021 that an employer was prohibited from contacting a certifying medical provider for authentication without first offering the employee an opportunity to cure any inauthenticity. The Fourth Circuit found that the relevant FMLA regulations were not sufficiently clear to place this right “beyond debate” and concluded that a reasonable official could interpret the regulations as not requiring a cure period for authenticity concerns. The Fourth Circuit vacated the district court’s judgment and remanded the case for further proceedings on whether qualified immunity is available as a defense to FMLA interference claims. View "Mook v. Hall" on Justia Law

A group of plaintiffs submitted a request under the Freedom of Information Act (FOIA) to the Central Intelligence Agency (CIA), seeking documents related to American prisoners of war and government recovery efforts. Among other records, they sought access to a report jointly authored by the CIA and Department of Defense in response to a U.S. Senator’s criticism of a National Intelligence Estimate. The CIA responded by releasing some documents in full, some in part—including a redacted version of the requested report—and withholding others entirely. The plaintiffs challenged the CIA’s refusal to search its operational files and the adequacy of the agency’s redactions to the report.After receiving the FOIA request, the plaintiffs sued the CIA in the United States District Court for the Eastern District of Virginia. The district court treated the plaintiffs’ argument about the CIA’s obligation to search operational files as a motion to compel such a search and denied it, finding the plaintiffs had not met the statutory burden to show improper withholding or misplacement of documents. The court also determined that the CIA’s affidavits adequately justified the redactions under FOIA exemptions and granted summary judgment in favor of the CIA.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the denial of the motion to compel and the grant of summary judgment de novo. The court held that the CIA was not required to search its operational files because the plaintiffs failed to provide sufficient evidence of improper withholding or misplacement of records. Additionally, the court held that the CIA’s affidavits provided adequate, specific justifications for the redactions under the national security and statutory exemptions to FOIA. The Fourth Circuit affirmed the district court’s judgment in full. View "Driggs v. CIA" on Justia Law

A woman born in Guinea, who entered the United States on a student visa and later overstayed, faced removal proceedings initiated by the Department of Homeland Security. She is a single mother raising two U.S. citizen daughters. Her primary concern was that, if removed to Guinea, her daughters would face the risk of female genital mutilation, as she herself did as a child. She sought relief through two applications: one for asylum, withholding of removal, and protection under the Convention Against Torture, and another for cancellation of removal. Both applications focused on the potential harm to her daughters if they accompanied her to Guinea.An Immigration Judge (IJ) held a hearing and granted her withholding of removal to Guinea, meaning she could not be sent there as long as the threat persisted, but could potentially be removed to another country. The judge asked the parties to brief whether this grant of withholding made her ineligible for cancellation of removal, and never held the promised follow-up hearing. In a written decision, the IJ denied cancellation on factual grounds, finding no qualifying hardship to her daughters since removal to Guinea was off the table. The Board of Immigration Appeals (BIA) affirmed, reasoning that the only hardship identified was tied to Guinea, and that the woman had been given a sufficient opportunity to present her claim through briefing.The United States Court of Appeals for the Fourth Circuit reviewed the case, applying de novo review to legal questions and substantial evidence review to factual determinations. The court held that the BIA erred in finding the woman had a sufficient opportunity to present evidence and argument regarding hardship from removal to a third country. The court vacated the BIA’s order and remanded for further proceedings. The petition for review related to reconsideration was dismissed as moot. View "Keita v. Blanche" on Justia Law

Benjamin Carter, a Virginia state prisoner housed in the Restrictive Housing Unit at Sussex State Prison, alleged that prison officials subjected him to unconstitutional conditions of confinement, particularly harmful due to his serious mental illnesses. He also claimed that after he submitted an informal complaint seeking reclassification and transfer out of restrictive housing, officials retaliated against him by denying his requests and making threatening statements. Carter attempted to address these issues through the Virginia Department of Corrections' grievance process, submitting informal complaints and regular grievances about both the conditions and the alleged retaliation. His grievances were rejected and appeals denied. Carter initially filed a federal complaint about his conditions of confinement before the administrative process was completed, then filed an amended complaint after exhausting the grievance process, raising both Eighth and First Amendment claims.The United States District Court for the Eastern District of Virginia screened Carter’s complaints and dismissed his Eighth Amendment claim against the VDOC Director for failure to state a claim, finding no plausible supervisory liability. The court then granted summary judgment to the remaining defendants, holding that Carter had not exhausted administrative remedies as required by the Prison Litigation Reform Act (PLRA) when he filed his original complaint, and concluded he could not cure this by exhausting before filing an amended complaint. The court also held, in the alternative, that Carter failed to state retaliation claims against two defendants.The United States Court of Appeals for the Fourth Circuit reviewed the case. It held that Carter properly exhausted his First Amendment retaliation claims because he completed the administrative process before filing the amended complaint in which those claims were first raised, and the PLRA does not bar claims first pleaded in an amended complaint after exhaustion. The court vacated the district court’s dismissal of Carter’s Eighth Amendment claims, remanding for the district court to determine whether administrative remedies were truly “available” to Carter. The court also vacated the district court’s dismissal of retaliation claims against two defendants, finding Carter’s complaint stated plausible claims. The judgment was vacated and remanded for further proceedings. View "Carter v. Cabell" on Justia Law

A man named Sylvester Demetrius Selby was shot and killed by Deputy Edward Glaser III of the Dare County Sheriff’s Office in North Carolina, after Selby, who was wounded and holding a knife and an apple, failed to comply with repeated commands to drop the knife. After initially exiting his home, Selby did not surrender but instead jumped down the porch steps toward the deputies while still holding the knife. Following the first shot, Selby dropped the knife and apple, flailed on the ground, and then attempted to stand up and flee, at which point he lunged in the direction of Deputy Glaser, who fired two additional shots, resulting in Selby’s death.Legacy Spencer, administrator of Selby’s estate, filed suit in the United States District Court for the Eastern District of North Carolina against Deputy Glaser (individually) and the Dare County Sheriff (officially), alleging violations of the Fourth Amendment (excessive force) and North Carolina state law (assault, battery, and wrongful death). The defendants moved to dismiss. The district court, referencing body camera footage that contradicted certain key factual allegations in the complaint, determined the use of force was objectively reasonable under the circumstances and dismissed all claims for failure to state a claim. It also found qualified immunity barred the federal claims and public official immunity barred the state claims against Deputy Glaser. The claims against the sheriff failed because they were premised on Glaser's reasonable actions.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the dismissal de novo. The court held that it was proper to consider the body camera videos at the dismissal stage where they blatantly contradicted the complaint’s allegations. The court concluded that Deputy Glaser’s use of force was reasonable and did not violate the Fourth Amendment or state law, affirming the district court’s judgment and dismissing all claims. View "Spencer v. Glaser" on Justia Law