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

This case involves individuals who filed asbestos-related tort claims against DBMP LLC. The claims arise from injuries allegedly caused by asbestos-containing products manufactured by CertainTeed Corporation over several decades. Facing a growing number of lawsuits and significant financial exposure, CertainTeed underwent a "divisional merger" under Texas law, splitting into two entities: New CertainTeed, which received most assets and non-asbestos liabilities, and DBMP, which received all asbestos-related liabilities and certain assets. An uncapped funding agreement obligated New CertainTeed to cover DBMP’s asbestos liabilities. DBMP then filed for Chapter 11 bankruptcy, invoking 11 U.S.C. § 524(g) to manage current and future asbestos claims through a trust. As a result, pending tort actions were automatically stayed.The United States Bankruptcy Court for the Western District of North Carolina denied motions from the plaintiffs to lift the automatic stay and to stay a preliminary injunction that extended the stay to CertainTeed affiliates. Applying the standards from In re Robbins, the bankruptcy court found that lifting the stay would prejudice the debtor’s estate, harm judicial economy by returning a large volume of cases to the tort system, and undermine consistent treatment of claimants under a § 524(g) plan. The bankruptcy court also found insufficient evidence of bad faith by DBMP in filing for bankruptcy. The United States District Court for the Western District of North Carolina affirmed, holding that the bankruptcy court’s findings and application of the Robbins factors were not an abuse of discretion.On further appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The Fourth Circuit held that the bankruptcy court did not abuse its discretion in refusing to lift the automatic stay. It found that DBMP sought bankruptcy protection for legitimate purposes under § 524(g), was not shown to have acted in bad faith, and that the statutory framework does not require insolvency. View "Herlihy v. DBMP, LLC" on Justia Law

The case concerns the non-reappointment of a local general registrar of elections in Lynchburg, Virginia. The plaintiff, previously appointed unanimously by a bipartisan electoral board, reapplied for her position after her term expired in 2023. By that time, the board’s partisan makeup had shifted to include two Republicans and one Democrat, reflecting state law. The board interviewed four candidates, including the plaintiff, but ultimately appointed a different candidate who was a registered Republican. The plaintiff, describing herself as an independent, alleged her non-reappointment was due to partisan bias rather than job performance.Following the board’s decision, the plaintiff sued the board and its two Republican members, alleging First Amendment violations tied to political animus. The United States District Court for the Western District of Virginia dismissed the claim against the board itself on sovereign immunity grounds, but allowed the suit against the individual members to proceed. After a jury trial, the verdict favored the defendants. The plaintiff then appealed, raising concerns about jury selection procedures and the exclusion of certain evidence.The United States Court of Appeals for the Fourth Circuit reviewed the appeal. It held that the district court did not abuse its discretion in managing voir dire, including its refusal to allow more pointed questioning about potential jurors’ political affiliations and beliefs. The Fourth Circuit also determined that the plaintiff had not preserved most evidentiary challenges for appellate review, as she failed to make sufficient proffers or obtain definitive rulings on excluded evidence. For the limited evidentiary exclusions properly preserved, the appellate court found no abuse of discretion. Thus, the Fourth Circuit affirmed the judgment in favor of the defendants. View "Gibbons v. Gibbs" on Justia Law

Two individuals were seriously injured during a 2022 mass shooting at the Edmund Burke School in Washington, D.C. The shooter, a 23-year-old man from Virginia, used an AR-15 and various accessories and ammunition manufactured by multiple U.S. and foreign companies. The shooter built his arsenal by purchasing and assembling these products, which were then used in the attack. Both plaintiffs, a parent picking up her child and a school security guard, survived but suffered severe physical and emotional injuries.The plaintiffs filed suit in the United States District Court for the Eastern District of Virginia, asserting claims under Virginia’s False Advertising Statute and Consumer Protection Act, and alleging negligence and negligence per se for violations of the National Firearms Act and Virginia’s Uniform Machine Gun Act. The defendants moved to dismiss, arguing that the plaintiffs lacked Article III standing because their injuries were not “fairly traceable” to the defendants’ conduct. The district court agreed, dismissing the case for lack of subject-matter jurisdiction under Rule 12(b)(1). Despite this, the court also reached the merits and dismissed the claims under Rule 12(b)(6), finding them barred by the Protection of Lawful Commerce in Arms Act (PLCAA).On appeal, the United States Court of Appeals for the Fourth Circuit reversed the district court’s standing ruling, holding that the plaintiffs had alleged sufficient facts to demonstrate that their injuries were “fairly traceable” to the defendants’ alleged misconduct, thus satisfying Article III’s requirements. The Fourth Circuit vacated the district court’s alternative merits ruling under the PLCAA as advisory and beyond its jurisdiction, remanding the case for further proceedings consistent with its opinion. View "Lowy v. Daniel Defense, LLC" on Justia Law

A group of nine individuals, representing a putative class, alleged that a credit union systematically discriminated against racial minorities in its residential mortgage lending practices. The plaintiffs varied in racial background (eight Black, one Latino), state of residence, type of loan product sought, and financial circumstances. Despite these differences, they claimed the credit union used a single, semi-automated underwriting process for all applicants, which, through its proprietary algorithm, resulted in discriminatory outcomes against minority applicants. The complaint sought both damages and injunctive relief, and proposed a class consisting of all minority applicants for mortgage-related products from 2018 to the present who faced adverse actions compared to similarly situated non-minority applicants.The United States District Court for the Eastern District of Virginia partially granted the defendant’s motion to dismiss and struck the class allegations, relying on Federal Rules of Civil Procedure 12(f) and 23(d)(1)(D). The district court focused on the diversity of the plaintiffs’ circumstances, suggesting that the variations in loan types and applicant characteristics defeated the possibility of class certification, particularly under Rule 23(b)(3).On interlocutory appeal, the United States Court of Appeals for the Fourth Circuit addressed the standards governing class certification denials at the pleading stage before discovery. The Fourth Circuit held that district courts should only deny class certification at this stage if, on the face of the complaint, the Rule 23 requirements are not met as a matter of law. The appellate court affirmed the district court’s denial of class certification under Rule 23(b)(3), finding the lack of predominance and superiority apparent from the complaint due to the differences among the plaintiffs. However, the Fourth Circuit vacated the district court’s order as to Rule 23(b)(2), concluding that the complaint sufficiently alleged commonality for classwide declaratory and injunctive relief, and that the district court acted prematurely in denying certification under that provision. View "Oliver v. Navy Federal Credit Union" on Justia Law

After President Donald J. Trump began his second term, he issued two executive orders requiring federal agencies to end “diversity, equity, and inclusion” (DEI) programs in their grant and contracting processes. These directives included provisions for agencies to terminate DEI-related offices, positions, and funding (“Termination Provision”); to require federal grantees and contractors to certify compliance with anti-discrimination laws and the absence of DEI programs that violate those laws (“Certification Provision”); and to prepare a report on steps to deter illegal DEI programs (“Enforcement Threat Provision”). The plaintiffs—a city government and two organizations involved in higher education and academic advocacy—alleged that these provisions violated their constitutional rights and sought a preliminary injunction to halt their enforcement.The United States District Court for the District of Maryland found the plaintiffs likely to succeed on their constitutional claims and issued a nationwide preliminary injunction against most of the challenged provisions, except for the preparation of the enforcement report. The defendants appealed and the United States Court of Appeals for the Fourth Circuit granted a stay of the injunction pending appeal. The plaintiffs later sought to have the injunction vacated so they could amend their complaint, but the district court denied this request.Reviewing the case, the United States Court of Appeals for the Fourth Circuit held that the plaintiffs lacked standing to challenge the Enforcement Threat Provision because their alleged injuries were too speculative and intertwined with intra-governmental processes. However, the court found the plaintiffs had standing to challenge the Termination and Certification Provisions because these provisions resulted in concrete and imminent injuries, such as loss of funding or compelled changes in organizational activities.On the merits, the Fourth Circuit concluded the plaintiffs were unlikely to succeed on their facial constitutional challenges. The court ruled that the Termination Provision was not unconstitutionally vague under the Fifth Amendment, and that the Certification Provision did not violate the First Amendment on its face. The court vacated the preliminary injunction and remanded the case for further proceedings. View "Natl. Assoc. of Diversity Officers in Higher Edu. v. Trump" on Justia Law

The case centers around an accrediting agency’s decision to withdraw accreditation from an online university operated by a nonprofit educational organization. After years of below-benchmark graduation and employment rates, probation, and repeated warnings, the accrediting agency concluded the university was not compliant with its accreditation standards. The university responded by investing in improvement initiatives and shifting enrollment to a single online institution, but continued to struggle with student achievement. When accreditation was finally withdrawn, the university appealed internally and subsequently sought binding arbitration, arguing that the agency’s process was unfair, especially in its refusal to consider evidence about probationary treatment of other schools.Following arbitration, the arbitrator affirmed the agency’s decision, finding substantial evidence to support the withdrawal and concluding that the excluded evidence regarding other schools was irrelevant. The university then filed a motion to vacate the arbitration award and a complaint in the United States District Court for the Eastern District of Virginia, asserting due process violations and tortious interference. The district court denied the motion to vacate and granted judgment on the pleadings for the accrediting agency, holding that the university’s claims amounted to an impermissible collateral attack on the arbitration award, barred by the exclusivity provisions of the Federal Arbitration Act.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s rulings de novo. It affirmed both the denial of the motion to vacate and the grant of judgment on the pleadings. The Fourth Circuit held that the arbitration process did not deprive the university of a fair hearing and that the university’s complaint constituted an impermissible collateral attack on the arbitration award. The court formally adopted the impermissible-collateral-attack rule, concluding that such claims must be dismissed and the district court’s judgment was affirmed. View "Center for Excellence v. Accreditation Alliance" on Justia Law

An individual who served as Executive Director of a local economic development authority in Virginia was indicted on thirty-four counts stemming from multiple fraudulent schemes. These included wire fraud, bank fraud, money laundering, and aggravated identity theft. The prosecution presented evidence that the defendant used forged documents and misrepresentations to divert public funds for personal gain. One scheme involved a $2 million wire transfer, where the defendant lied to both her employer and others, using another person’s identity to facilitate the movement of funds. The trial was repeatedly delayed due to health issues experienced by the defendant and her counsel, resulting in significant breaks and several motions for mistrial by the defense.The United States District Court for the Western District of Virginia presided over the trial, ultimately entering judgments of acquittal on four counts of bank fraud but allowing the remaining convictions to stand. The court denied the defendant’s motions for mistrial, a new trial, and to introduce certain grand jury testimony. After the jury returned guilty verdicts on the remaining counts, the defendant was sentenced accordingly. The defendant appealed, challenging the aggravated identity theft conviction, the handling of trial delays, evidentiary rulings, and a supplemental jury instruction given after closing arguments.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that, under Dubin v. United States, the aggravated identity theft conviction could not stand because the use of another’s identity was not at the “crux” of the predicate wire fraud offense. The court vacated the conviction and sentence on that count and remanded for resentencing. However, the Fourth Circuit affirmed the district court’s rulings on all other issues, including denial of a mistrial, exclusion of grand jury testimony, and the propriety of the additional jury instruction. View "United States v. McDonald" on Justia Law

Lawrence Levon Jones was investigated by Raleigh police as a suspected drug supplier during a larger drug-trafficking operation in 2020. Officers monitored a suspected stash house and wiretapped Jones’s phone, observing frequent visits by Jones and connections with other individuals involved in drug distribution. Jones financed marijuana purchases via Wesley Kelly, who transported drugs between California and North Carolina. Coordinated arrests and searches in July 2020 resulted in the seizure of large quantities of drugs, cash, and firearms from the stash house and related locations. Jones was arrested at the stash house and later made jail calls directing associates to move large sums of money.The United States District Court for the Eastern District of North Carolina charged Jones and others with several drug and firearms offenses. Jones was specifically indicted on four counts, including drug conspiracy and firearms possession. At trial, the government presented testimony from investigators and Kelly, a cooperating witness. The district court excluded evidence of Kelly’s decades-old federal drug convictions under Federal Rule of Evidence 609(b). After the government’s case, Jones moved for acquittal on the firearms charges, arguing lack of evidence of possession; the court denied the motion. The jury found Jones guilty on all counts. During sentencing, Jones objected to enhancements for obstruction and leadership, but the district court overruled these objections and imposed a sentence of 480 months.On appeal to the United States Court of Appeals for the Fourth Circuit, Jones challenged the exclusion of Kelly’s convictions, the denial of his motion for acquittal, and the sentencing enhancements. The Fourth Circuit held that the district court did not abuse its discretion in excluding impeachment evidence, that sufficient evidence supported the firearms convictions under constructive possession principles, and that the sentencing enhancements were not clearly erroneous. The Court also found that any error would have been harmless given Jones’s guidelines range. The judgment of the district court was affirmed. View "United States v. Jones" on Justia Law

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