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

The defendant was originally convicted of possession with intent to distribute cocaine and illegal reentry after deportation. He was sentenced to concurrent prison terms and supervised release. After serving his sentence, he was released and removed from the United States. Several years later, he was found in Virginia in possession of over six kilograms of cocaine and charged with a new federal drug offense, to which he pled guilty. The United States Probation Office filed a petition alleging violations of his supervised release: committing a new crime and reentering the country. At his sentencing and revocation hearing, the defendant admitted to both violations and argued that his actions had been influenced by fear of cartel reprisals, seeking a sentence within the advisory guideline range and concurrent with his new sentence.The United States District Court for the Eastern District of Virginia imposed a 36-month sentence for the supervised release violation, the statutory maximum, to run consecutively to the new sentence. The district court cited the defendant’s prior similar conviction and the large quantity of drugs but did not address the defendant’s arguments regarding coercion or mitigating circumstances.The United States Court of Appeals for the Fourth Circuit reviewed the case. It held that the district court’s revocation sentence was procedurally unreasonable because the court failed to sufficiently explain its reasons for imposing the statutory maximum, particularly by not engaging with the defendant’s nonfrivolous argument that his conduct was influenced by coercion. The Fourth Circuit concluded that this error was not harmless and that the sentence was plainly unreasonable under clearly established law. Accordingly, the appellate court vacated the revocation sentence and remanded the case for resentencing. View "US v. Celedon" on Justia Law

Three advocacy organizations filed suit against the South Carolina Department of Juvenile Justice and its executive director, seeking institutional reforms to address alleged unconstitutional and unlawful conditions in the state’s juvenile detention facilities. The plaintiffs alleged that the facilities were overcrowded, understaffed, and dangerous, resulting in violence, isolation, and inadequate services for juveniles. They based their standing on their advocacy and direct representation work with affected youth, and described both the harm to juveniles and the impact on their own organizational missions.The United States District Court for the District of South Carolina dismissed the complaint without prejudice. The district court found that Disability Rights South Carolina (DRSC) had standing to sue on behalf of certain juveniles, but those claims were rendered moot when those juveniles left custody. The court also determined that Justice 360 had standing in its own right but concluded that its claims failed on the merits. The South Carolina State Conference of the NAACP was found to lack standing. The plaintiffs appealed the dismissal.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo and affirmed the district court’s dismissal. The Fourth Circuit held that the advocacy organizations lacked Article III standing to pursue the claims because they failed to demonstrate a sufficient personal stake in the outcome. The court found that DRSC did not meet the requirements for associational standing as its constituents lacked indicia of membership. The court also concluded that none of the organizations suffered a cognizable injury directly caused by the defendants’ actions, but rather incurred self-imposed costs through voluntary advocacy. The court further held that the plaintiffs could not bring claims under 42 U.S.C. § 1983 for the violation of rights belonging to others, as they had not alleged violations of their own federal rights. The dismissal was affirmed. View "South Carolina State Conference of the NAACP v. South Carolina Department of Juvenile Justice" on Justia Law

A substitute teacher in a large Maryland public school system challenged the school board’s policy requiring all staff, including substitutes, to affirm that they would refer to students by their preferred pronouns and not disclose a student’s gender identity to parents without the student’s consent. The teacher, citing her sincerely held religious beliefs, refused to sign the affirmation and requested a religious accommodation, which was ultimately denied. As a result, she was not permitted to substitute teach in the following school years.She brought claims in the United States District Court for the District of Maryland against the school board, asserting violations of Title VII of the Civil Rights Act related to religious accommodation, and First Amendment violations of her rights to free speech and free exercise of religion. She sought damages, declaratory relief, and a preliminary injunction. The district court dismissed her First Amendment claims under Rule 12(b)(6) for failure to state a claim, finding the policy to be neutral and generally applicable, thus subject to rational basis review, and rationally related to legitimate government interests, including compliance with Title IX and student safety. The court concluded that the speech at issue was part of her official duties as a teacher and thus not protected by the First Amendment. The court denied a preliminary injunction, finding no likelihood of success on the merits for the constitutional claims and no irreparable harm for the Title VII claim, which was allowed to proceed.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s dismissal of the First Amendment claims and denial of a preliminary injunction. The Fourth Circuit held that the policy was neutral and generally applicable, survived rational basis review, and the compelled speech fell within the teacher’s official duties. Therefore, the plaintiff was not entitled to injunctive relief on her constitutional claims. View "Polk v. Montgomery County Public Schools" on Justia Law

A multiemployer pension plan regulated under ERISA and the Multiemployer Pension Plan Amendments Act (MPPAA) sought to recover withdrawal liability from Florida Glass of Tampa Bay and related entities after Florida Glass ceased performing covered work and entered bankruptcy. In 2016, the pension plan filed a contingent proof of claim in Florida Glass’s bankruptcy proceedings, but did not clearly determine or assert withdrawal liability at that time. Several years later, after confirming withdrawal had occurred, the plan issued a formal notice and demand for payment. The defendants did not timely seek arbitration under the statutory process, and, when sued to collect the withdrawal liability, argued that the plan’s earlier bankruptcy filing constituted both a statutory notice and demand and an acceleration of liability, thus triggering the statute of limitations before the suit was filed.The United States District Court for the District of Maryland rejected the defendants’ statute of limitations defense. The court held that the 2016 contingent proof of claim was neither a notice and demand nor an acceleration under the MPPAA, so the limitations period did not begin until the 2022 notice and demand letter. Alternatively, the court reasoned that even if the 2016 filing qualified as a notice and demand, the defendants had waived any related defenses by failing to timely arbitrate. The court granted summary judgment for the pension plan and awarded damages, interest, attorney’s fees, and costs, minus the bankruptcy distribution already received.The United States Court of Appeals for the Fourth Circuit affirmed. The court held that a contingent proof of claim does not constitute a notice and demand, nor an acceleration, unless it clearly satisfies the statutory requirements. Since the 2016 filing was ambiguous and labeled contingent, it did not trigger the statute of limitations, rendering the suit timely. The court affirmed the judgment and associated relief for the pension plan. View "International Painters and Allied Trades Industry v. Florida Glass of Tampa Bay, Inc." on Justia Law

Ten nonprofit organizations that received federal grants through the U.S. Citizenship and Immigration Services’ “Citizenship and Integration Grant Program” filed suit after the Department of Homeland Security (DHS) froze and subsequently terminated their grant funding. The freeze and termination followed an executive order issued by the incoming President in January 2025 directing DHS to pause and review grants that funded services to undocumented immigrants, with the aim of ensuring compliance with law and preventing waste, fraud, or abuse. DHS notified grantees of the freeze in February 2025 and terminated the grants in March 2025, prompting the plaintiffs to seek a preliminary injunction to restore the program and funding.The United States District Court for the District of Maryland denied the plaintiffs’ motion for a preliminary injunction. The court determined that the plaintiffs’ claims were essentially contractual—seeking disbursement of funds based on grant agreements—and thus fell under the exclusive jurisdiction of the United States Court of Federal Claims pursuant to the Tucker Act. The court also found that the plaintiffs had not identified a reviewable “final agency action” under the Administrative Procedure Act (APA). Additionally, it concluded that the plaintiffs had failed to provide adequate legal authority for their ultra vires and separation-of-powers claims.Reviewing the appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The Fourth Circuit held that the relief sought by the plaintiffs was materially indistinguishable from relief denied in recent Supreme Court cases, Department of Education v. California and National Institutes of Health v. Public Health Association. It concluded that claims seeking to enforce contractual obligations to pay money must be brought in the Court of Federal Claims and that the plaintiffs had not shown a likelihood of success on their alternative constitutional or statutory claims. The district court’s denial of the preliminary injunction was therefore affirmed. View "Solutions in Hometown Connections v. Noem" on Justia Law

The case concerns Frederick Allen, a videographer, and his company, Nautilus Productions, who documented the excavation of the Queen Anne’s Revenge, the sunken pirate ship of Blackbeard, off the North Carolina coast. Allen registered copyrights for many years of video footage he recorded during the recovery project. The State of North Carolina and its Department of Natural and Cultural Resources entered into agreements related to the salvage operation. Allen alleged that state officials infringed his copyrights by using his footage online and in state publications without permission, and that the state passed a law, N.C. Gen. Stat. § 121-25(b), which Allen argued authorized this infringement.The United States District Court for the Eastern District of North Carolina initially dismissed some claims but allowed Allen’s claims for declaratory judgment and copyright infringement to proceed, finding Congress had validly abrogated state sovereign immunity under the Copyright Remedy Clarification Act (CRCA). On appeal, the United States Court of Appeals for the Fourth Circuit reversed, holding that the CRCA did not validly abrogate state sovereign immunity, and the Supreme Court affirmed. Allen then voluntarily dismissed his remaining claims against the only non-governmental defendant, closing the case.Despite these rulings, the district court in 2021 allowed Allen to reopen the case, permitting him to amend his complaint based on a new constitutional theory stemming from United States v. Georgia, seeking as-applied, case-by-case abrogation of state sovereign immunity. In 2024, the district court denied sovereign immunity on this new claim, allowing it to proceed. The North Carolina defendants appealed.The United States Court of Appeals for the Fourth Circuit held that the district court abused its discretion in reopening the litigation under Rule 54(b) rather than Rule 60(b), where no extraordinary circumstances justified such relief. The appellate court reversed the order reopening the case, vacated the subsequent 2024 ruling as moot, and remanded with instructions to close the litigation and dismiss all claims against the North Carolina defendants with prejudice. View "Allen v. Stein" on Justia Law

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