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

Brad Acy Holley, who was serving a 127-month federal sentence after pleading guilty to methamphetamine conspiracy, suffered from significant health issues, including polycystic kidney disease and end-stage renal disease requiring dialysis. Following his declining health and ongoing treatments in a federal medical facility, Holley sought compassionate release, arguing that his condition constituted an extraordinary and compelling reason for a sentence reduction. He also asserted that he was not receiving necessary specialized medical care in prison, particularly a kidney transplant, and requested appointment of counsel and an expert witness to assist with his motion.The United States District Court for the Southern District of West Virginia denied Holley’s requests, finding that his medical condition, while serious, was being adequately managed in prison and did not qualify as a terminal illness or otherwise meet the threshold for extraordinary and compelling reasons for compassionate release. The court also declined to appoint counsel or an expert, determining that neither was warranted under the circumstances. Holley appealed these decisions.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s decisions for abuse of discretion. The appellate court held that the district court did not abuse its discretion in denying compassionate release, finding the court properly relied on Holley’s individualized medical records rather than generalized statistics, and reasonably concluded Holley was not suffering from a terminal illness with an end-of-life trajectory. The Fourth Circuit also held that Holley was not legally entitled to appointed counsel or an expert witness for his compassionate release motion, as there were no exceptional circumstances justifying such appointments. Accordingly, the Fourth Circuit affirmed the district court’s judgment in all respects. View "US v. Holley" on Justia Law

Bobby Morgan, who suffers from bipolar and schizoaffective disorders, was involved in an altercation with his neighbors, during which he threatened to shoot them and displayed what appeared to be a functional pistol. After retreating to his home, Bobby fired his gun multiple times, prompting a police standoff. Despite attempts to deescalate, Bobby continued firing—later revealed to be with a prop gun that could only shoot blanks but appeared real. Officers responded with gunfire, striking Bobby three times. Bobby survived after receiving medical care. Felicia Morgan, his mother and legal guardian, sued the City of Charlotte and several officers, alleging excessive force under the Fourth Amendment and failure to reasonably accommodate Bobby’s disabilities in violation of the Americans with Disabilities Act (ADA).The United States District Court for the Western District of North Carolina granted summary judgment to the defendants. The court found that from the perspective of a reasonable officer, Bobby posed an imminent threat of serious physical harm due to his erratic and repeated firing of a realistic-looking gun in a residential area. The court also determined that the officers acted reasonably in attempting to accommodate Bobby’s mental conditions, given the exigent circumstances and the risks posed to officers and civilians.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the claims de novo, applying the objective reasonableness standard for excessive force and the requirement of reasonable accommodation under the ADA. The Fourth Circuit affirmed the district court’s decision, holding that the officers’ use of force was justified given the threat Bobby posed and that the City and its officers acted reasonably under the circumstances. The Court concluded that unfortunate events do not automatically create legal liability when officers reasonably perceive an imminent threat and take appropriate action. View "Morgan v. City of Charlotte" on Justia Law

A middle-school teacher at an all-boys preparatory school in Baltimore developed a close relationship with a minor student, serving as his advisor, coach, and frequent driver. Over time, this relationship escalated into grooming and sexual exploitation, including coercing the student into running naked, engaging in sexually explicit acts that were filmed, and threats to expose the student through social media. The teacher continued the abusive conduct over several years, leveraging explicit images to maintain control and compliance, even after the student graduated. The case came to light after other students reported suspicious behavior, leading to a police investigation and a search of the teacher’s home and electronic devices.The United States District Court for the District of Maryland oversaw pretrial proceedings and the trial itself. The defendant moved to suppress evidence from his iPhone, arguing that law enforcement had unlawfully obtained his passcode, and requested a competency evaluation due to reported suicidal ideation. The district court denied both requests, finding the passcode was entered voluntarily and that the defendant was competent to stand trial. After a six-day trial, the jury convicted the defendant on all counts, including child exploitation, possession of child sexual abuse material, and cyberstalking. The court sentenced him to 35 years’ imprisonment and lifetime supervised release, rejecting arguments regarding the admissibility of victim-impact statements at sentencing.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the district court did not abuse its discretion in denying a competency evaluation, properly found the defendant’s entry of the iPhone passcode voluntary and not the result of interrogation, and correctly handled the Jencks Act material issue. It also found no error in allowing the victim’s parents to present impact statements at sentencing. Accordingly, the Fourth Circuit affirmed the convictions and sentence. View "US v. Bendann" on Justia Law

During the onset of the COVID-19 pandemic, a limited liability company (LLC), FS Medical Supplies, entered into a contract to supply personal protective equipment and related products to TannerGAP, Inc. and Tanner Pharma UK Limited for distribution. FS Medical later discovered that the Tanner entities had contracted directly with one of its suppliers, prompting FS Medical to sue for breach of contract.Initially, FS Medical brought suit in California state court, but the defendants removed the case to federal court, where it was dismissed for lack of personal jurisdiction. FS Medical then filed two actions in the United States District Court for the Western District of North Carolina, asserting diversity jurisdiction under 28 U.S.C. § 1332(a)(3). FS Medical alleged that its members were citizens of Texas and California, and later acknowledged that one member was a citizen of China. The defendants included both U.S. citizens domiciled in North Carolina and a United Kingdom corporation. After limited discovery and amendment of the complaint, the district court, following a magistrate judge’s recommendation, dismissed the actions for lack of subject matter jurisdiction, concluding that the presence of both domestic and foreign members in the plaintiff LLC destroyed diversity jurisdiction.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the dismissal de novo. The court held that, under § 1332(a)(3), complete diversity requires at least one U.S. citizen on each side of the action. Because FS Medical, as an LLC, had both domestic and foreign members at the time the complaints were filed, and because there were foreign defendants as well, the suit was not between “citizens of different States.” The Fourth Circuit affirmed the district court’s dismissal and declined to grant relief under North Carolina’s savings statute, finding it lacked jurisdiction to do so. View "FS Medical Supplies, LLC v. Tanner Pharma UK Limited" on Justia Law

South Carolina has administered its own workplace safety program under federal law for decades. In July 2016, the Occupational Safety and Health Administration (OSHA) issued an interim final rule requiring states with their own plans to increase monetary penalties in line with federal levels. South Carolina did not adjust its penalties, and OSHA’s annual monitoring reports repeatedly noted this issue without finding formal noncompliance until 2022. That year, OSHA formally found South Carolina noncompliant and recommended legislative changes to bring the state into alignment with federal standards.Previously, in 2022, South Carolina officials challenged only OSHA’s 2022 inflation adjustment in the United States District Court for the District of South Carolina. The district court held that the 2022 adjustment was not a final agency action and dismissed the claim. In 2023, South Carolina brought a new suit in the same court, this time challenging the 2016 interim final rule under the Administrative Procedure Act (APA). The Department of Labor moved to dismiss, arguing the claims were untimely under the APA’s six-year statute of limitations. The district court agreed, finding that any injury occurred when the 2016 rule was promulgated and dismissed the APA claims as time-barred.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed whether the APA claims were timely. The court held that a claim accrues when the plaintiff is injured by a final agency action, which, in this case, was when the 2016 rule was published. The court determined that South Carolina could have filed suit as early as 2016 and was therefore outside the six-year limitations period. The court also noted that South Carolina may still raise its substantive arguments if an enforcement action is initiated. The Fourth Circuit affirmed the district court’s dismissal. View "McMaster v. Department of Labor" on Justia Law

A maximum security prison in Virginia faced a surge in near-fatal drug overdoses among inmates in May and June 2023. In response, prison officials implemented a policy requiring every inmate who accessed the no-contact video visitation rooms to undergo a strip search both before and after each visit. Marcus Ingram, an inmate who used these rooms to call his wife, was subjected to 26 strip searches in a single month as a result. The policy was based on uncorroborated tips from inmates suggesting that contraband was being circulated through these rooms, despite no evidence of any actual contraband being found in connection with the video visitation rooms.Ingram filed a pro se lawsuit under 42 U.S.C. § 1983 in the United States District Court for the Western District of Virginia against the prison warden and the officer who conducted most of the searches. He alleged violations of his Fourth and Eighth Amendment rights, along with a claim of supervisory liability against the warden. The district court granted summary judgment to the defendants on the basis of qualified immunity, holding that the searches were reasonable due to the drug problem and that there was no evidence of harassment or intimidation. The court also dismissed the supervisory liability claim as there was no underlying constitutional violation.On appeal, the United States Court of Appeals for the Fourth Circuit assumed without deciding that some of the strip searches may have violated the Fourth Amendment. However, it held that the right at issue was not clearly established at the time, as neither controlling precedent nor a consensus of persuasive authority made the unconstitutionality of the policy beyond debate. Therefore, the Fourth Circuit affirmed the district court’s grant of qualified immunity to the defendants. View "Ingram v. Hamilton" on Justia Law

Two Black officers, Don Gordon and Terrell Jones, were assigned to a Maryland State Police multi-agency drug task force. They allege they were consistently excluded from meetings and communications where overtime and desirable assignments were distributed to white officers. This exclusion resulted in lost work opportunities and compensation. The situation escalated when a supervisor, Corporal Oros, sent a racially and sexually offensive image involving George Floyd to the group shortly after Floyd’s death, and Sergeant Heath, a co-leader of the unit, took no corrective action. The officers assert that these actions and inactions created a racially hostile work environment, leading to feelings of mistrust and concern for their safety on the job.After filing charges with the U.S. Equal Employment Opportunity Commission and receiving right-to-sue letters, Gordon and Jones brought suit in the United States District Court for the District of Maryland. The district court dismissed their race discrimination claims but permitted the Title VII hostile work environment claim against the Maryland State Police and the § 1981 hostile work environment claims against Sergeant Heath and Corporal Oros (in their individual capacities) to proceed. The district court denied qualified immunity to Sergeant Heath at the pleading stage.The United States Court of Appeals for the Fourth Circuit reviewed Sergeant Heath’s interlocutory appeal concerning qualified immunity. The court held that the plaintiffs’ complaint plausibly alleged Sergeant Heath’s participation in and tacit authorization of a racially hostile work environment. The court further ruled that the right to be free from such a racially hostile work environment was clearly established at the time of the events described. Therefore, the Fourth Circuit affirmed the district court’s denial of qualified immunity to Sergeant Heath. View "Gordon v. Heath" on Justia Law

The defendant engaged in a series of shootings at military-related sites in Northern Virginia in late 2010, and was apprehended in June 2011 at Arlington National Cemetery, carrying materials linked to his offenses. He later pleaded guilty to three charges: injuring government property, using a firearm during a crime of violence, and attempting to injure a veteran’s memorial. As part of a Rule 11(c)(1)(C) plea agreement, he accepted a twenty-five year sentence and waived his right to appeal within statutory limits. After being found competent despite a schizophrenia diagnosis, he was sentenced accordingly and did not initially appeal.Years later, the defendant sought relief under 28 U.S.C. § 2255. The United States Court of Appeals for the Fourth Circuit previously vacated his firearm conviction under 18 U.S.C. § 924(c) and remanded for resentencing on the remaining counts. On remand, the United States District Court for the Eastern District of Virginia held a new competency hearing and discussed whether to postpone sentencing to monitor medical compliance. Ultimately, the court declined a lengthy postponement due to statutory and constitutional concerns, resentenced the defendant to consecutive maximum terms totaling 240 months, and ordered a pre-release hearing to plan for his transition.The United States Court of Appeals for the Fourth Circuit reviewed four challenges to the resentencing. Two claims were deemed forfeited for not being raised at sentencing, and the remaining two failed under the abuse-of-discretion standard. The court held that the defendant did not demonstrate a plain error under Tapia v. United States regarding the imposition of a sentence to promote rehabilitation or medical compliance. The court further found the sentence to be both procedurally and substantively reasonable, and rejected arguments regarding the district court’s authority to order a pre-release hearing. The judgment of the district court was affirmed. View "US v. Melaku" on Justia Law

Two journalists, both of Iraqi national origin, worked for a Virginia-based media company operating Arabic-language broadcasts targeting the Middle East and North Africa. The company maintained a mandatory Code of Ethics and social media policy requiring its journalists to remain neutral both in their reporting and in personal social media posts. Both journalists violated these policies by posting political content on social media, and after refusing direct orders to remove the posts, each was terminated. They alleged that the company enforced its policies more harshly against Iraqi journalists than non-Iraqi journalists and that their terminations were discriminatory under Title VII of the Civil Rights Act of 1964.Each journalist filed a separate lawsuit in the United States District Court for the Eastern District of Virginia, asserting claims of national origin discrimination. Both district courts granted the employer’s motions to dismiss, finding that the complaints failed to allege sufficient facts to plausibly support a claim of discrimination. Specifically, the courts found that neither plaintiff identified non-Iraqi employees who engaged in similarly insubordinate conduct—such as violating the same policies after direct warnings—yet were treated more favorably.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed both cases de novo. The court affirmed the district courts’ decisions, holding that the plaintiffs’ complaints did not state plausible claims for relief under Title VII. The court found that the facts alleged showed the plaintiffs were terminated for insubordination and repeated policy violations, not because of their national origin, and that the comparator allegations were too generalized to support an inference of discrimination. The court also held that the district court did not abuse its discretion in denying one plaintiff leave to amend, as no request for leave was made and amendment would have been futile. The judgments of dismissal were affirmed. View "Aljizzani v. Middle East Broadcasting Networks, Inc." on Justia Law

The dispute centers on the HAVANA CLUB trademark, originally registered in the United States in 1976 by a Cuban state-owned company, Cubaexport. Due to changes in U.S. law, renewal of the trademark registration required a specific license from the Treasury’s Office of Foreign Assets Control (OFAC) after 1998. In December 2005, Cubaexport submitted its renewal application and payment to the United States Patent and Trademark Office (PTO) without the required OFAC license. OFAC later notified the PTO that the payment was unauthorized, leading to the PTO’s refund of the fee and refusal to renew the registration. Cubaexport unsuccessfully litigated against OFAC and, in 2015, reapplied for the license, which OFAC granted retroactively in 2016, authorizing the 2005 payment.After the PTO Director accepted Cubaexport’s renewal filing based on the retroactive OFAC license, Bacardi sued the PTO and its Director in the United States District Court for the Eastern District of Virginia. Bacardi argued the PTO lacked statutory authority to renew the expired registration and acted arbitrarily and capriciously. The district court initially dismissed the case, finding judicial review precluded by the Lanham Act, but the United States Court of Appeals for the Fourth Circuit reversed and remanded. On remand, Cubaexport intervened, and after cross-motions for summary judgment, the district court granted judgment for the defendants, finding the OFAC license validated the payment and that any deficiency was cured during the petition process.Reviewing the district court’s summary judgment de novo, the United States Court of Appeals for the Fourth Circuit held that the PTO Director acted within statutory authority, as the retroactive OFAC license validated the 2005 payment, satisfying the renewal requirements. The court also held the Director’s explanation for the renewal was reasonable and not arbitrary or capricious. The Fourth Circuit affirmed the district court’s judgment. View "Bacardi and Company Limited v. Squires" on Justia Law