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

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

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