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

Andrew Fields, while incarcerated at U.S. Penitentiary Lee, alleged that he was subjected to excessive force by several prison officials, violating his Eighth Amendment rights. Fields claimed that after failing to carry his inmate movement pass, he was berated, placed in administrative segregation, and had his legal documents and prescription eyeglasses seized. He further alleged that during his transfer to the Special Housing Unit (SHU), he was physically abused, including being hit and having his head rammed into a wall, despite posing no threat. Fields also claimed that prison staff denied him access to the Bureau of Prisons' administrative grievance procedure, preventing him from pursuing alternative remedies.The United States District Court for the Western District of Virginia dismissed Fields's complaint under the Prison Litigation Reform Act’s prescreening procedure, concluding that his allegations either did not state a constitutional violation or were not cognizable under Bivens v. Six Unknown Named Agents of Federal Narcotics Bureau. Fields appealed the dismissal, focusing solely on his Eighth Amendment excessive force claim.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo and concluded that Fields's allegations, if true, could overcome the limitations on Bivens claims. The court found that Fields's claim did not implicate systemic prison policies but rather concerned individual officers' conduct in violation of prison policy. The court also noted that Fields was denied access to alternative remedies due to the officers' actions. Consequently, the Fourth Circuit affirmed the dismissal of claims against the Bureau of Prisons and supervisory officials but reversed and remanded the excessive force claim against the individual officers who allegedly subjected Fields to abuse. View "Fields v. Federal Bureau of Prisons" on Justia Law

In January 2021, Julius Lamart Hodges, an inmate at the Prince William-Manassas Adult Detention Center, volunteered to work in the kitchen during a COVID-19 outbreak while most inmates quarantined. Hodges did not contract COVID-19 but claimed that his exposure to the virus constituted cruel and unusual punishment under the Eighth Amendment. He also alleged that his working conditions were harsh and that he was retaliated against for filing grievances about these conditions.The United States District Court for the Eastern District of Virginia dismissed Hodges’s complaint. The court found that Hodges failed to state a claim under the Eighth Amendment because he voluntarily chose to work and could have opted to quarantine. The court also dismissed his First Amendment retaliation claim, concluding that Hodges did not plausibly allege a causal connection between his grievances and any adverse action taken by the prison officials.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court’s dismissal. The Fourth Circuit held that Hodges’s Eighth Amendment claim failed because he voluntarily exposed himself to the conditions he complained about, and thus, the prison officials did not inflict those conditions upon him. The court also found that Hodges’s First Amendment retaliation claim was insufficient because he did not adequately allege a causal relationship between his grievances and the denial of his Work Release application. The court noted that the temporal gap between his grievance and the adverse action was too long to support an inference of causation.The Fourth Circuit modified the district court’s dismissal to be without prejudice, allowing Hodges the opportunity to amend his complaint if he could address the deficiencies identified by the court. View "Hodges v. Meletis" on Justia Law

Kenneth Ray Jenkins, a pretrial detainee at Wilson County Detention Center (WCDC) in 2018, alleged that he was subjected to unsanitary living conditions, including confinement in cells infested with feces, which led to a bacterial illness. Jenkins, who suffers from mental health disorders, claimed that he was denied his medication, placed in solitary confinement, and later moved to an unsanitary "Rubber Room." He further alleged that he was denied medical attention for severe rectal bleeding for several months, which resulted in a diagnosis of multiple medical conditions.Jenkins filed a pro se complaint under 42 U.S.C. § 1983, asserting violations of his Fourteenth Amendment rights. The United States District Court for the Eastern District of North Carolina dismissed most of his claims but allowed his conditions-of-confinement and deliberate-indifference claims against Sheriff Calvin Woodard to proceed. Jenkins requested additional time for discovery and appointment of counsel, both of which were denied by the district court. The court granted summary judgment in favor of Sheriff Woodard, finding that Jenkins failed to demonstrate a material factual dispute.The United States Court of Appeals for the Fourth Circuit reviewed the case and found that the district court abused its discretion in denying Jenkins’s requests for counsel and additional time for discovery. The appellate court noted that Jenkins’s severe mental illness, lack of legal knowledge, and inability to access legal materials and evidence while incarcerated demonstrated that he lacked the capacity to present his claims. The Fourth Circuit reversed the district court’s denials of Jenkins’s requests for discovery and counsel, vacated the summary judgment decision, and remanded the case for further proceedings, directing the district court to appoint counsel for Jenkins. View "Jenkins v. Woodard" on Justia Law

On June 7, 2019, around 4:20 a.m., two police officers detained Anthry Milla, who was sitting in his car in his driveway. The officers were investigating a nearby stabbing but had no description of a suspect. Milla was cooperative but closed his car door when the officers approached. The officers, suspecting involvement in the stabbing, detained Milla at gunpoint, searched his car, and found no evidence. Milla's parents confirmed his identity, and he was released after about eight minutes.Milla filed a pro se complaint under 42 U.S.C. § 1983, alleging Fourth Amendment violations. The United States District Court for the Eastern District of Virginia granted summary judgment to the officers, finding their actions justified under the totality of the circumstances. The court also held that the officers were entitled to qualified immunity, as they did not violate Milla's constitutional rights.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo and vacated the district court's decision. The appellate court found that the officers lacked reasonable, particularized suspicion to detain Milla. The court emphasized that proximity to a crime scene and Milla's actions, such as closing his car door, did not constitute reasonable suspicion. The court also vacated the district court's award of qualified immunity, as the officers' actions were not justified under established Fourth Amendment standards. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Milla v. Brown" on Justia Law

Petitioners opened brokerage accounts with Stifel, Nicolaus & Company, managed by Coleman Devlin. Dissatisfied with Devlin's performance, they filed for arbitration with the Financial Industry Regulatory Authority (FINRA), alleging negligence, breach of contract, breach of fiduciary duty, negligent supervision, and violations of state and federal securities laws. After nearly two years of hearings, the arbitration panel ruled in favor of Stifel and Devlin without providing a detailed explanation, as the parties did not request an "explained decision."Petitioners moved to vacate the arbitration award in the United States District Court for the District of Maryland, arguing that the arbitration panel manifestly disregarded the law, including federal securities law. The district court denied the motion, stating that the petitioners failed to meet the high standard required to prove manifest disregard of the law. The court noted that the petitioners were essentially rearguing their case from the arbitration.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court noted that the Supreme Court's decision in Badgerow v. Walters requires an independent jurisdictional basis beyond the Federal Arbitration Act (FAA) itself for federal courts to have jurisdiction over petitions to vacate arbitration awards. Since the petitioners did not provide such a basis, the Fourth Circuit vacated the district court's judgment and remanded the case with instructions to dismiss the petition for lack of jurisdiction. The court emphasized that claims of manifest disregard of federal law do not confer federal-question jurisdiction. View "Friedler v. Stifel, Nicolaus, & Company, Inc." on Justia Law

Dolores Ortega-Cordova, a native and citizen of El Salvador, entered the United States without inspection in 2002. In 2012, he was arrested in Norfolk, Virginia, and charged with solicitation of prostitution under Virginia Code § 18.2-346(B). He pleaded guilty and was sentenced to 90 days’ imprisonment, with 86 days suspended, and fined. The Department of Homeland Security initiated removal proceedings against him. Ortega-Cordova conceded removability but applied for cancellation of removal under 8 U.S.C. § 1229b(b)(1).The Immigration Judge (IJ) denied Ortega-Cordova’s application, finding him ineligible for cancellation of removal because his conviction for solicitation of prostitution was deemed a crime involving moral turpitude under 8 U.S.C. § 1227(a)(2)(A)(i). The IJ relied on the Board of Immigration Appeals’ (BIA) long-standing position that prostitution-related offenses are morally turpitudinous. The BIA affirmed the IJ’s decision, noting that Ortega-Cordova failed to prove that solicitation of prostitution is no longer considered morally reprehensible by society.The United States Court of Appeals for the Fourth Circuit reviewed the case and upheld the BIA’s decision. The court concluded that solicitation of prostitution under Virginia law categorically involves moral turpitude because it debases a moral norm against treating sex as a commercial transaction. The court rejected Ortega-Cordova’s arguments that societal views on prostitution are evolving and that the statute criminalizes consensual conduct between adults. The court also dismissed his procedural arguments, including the claim that the BIA abused its discretion by not referring his case to a three-member panel. Consequently, the Fourth Circuit denied Ortega-Cordova’s petition for review. View "Ortega-Cordova v. Garland" on Justia Law

Harris Ford, an inmate in the North Carolina Department of Corrections, filed a lawsuit against six prison officials under 42 U.S.C. § 1983, alleging that they violated his Eighth Amendment rights by failing to protect him from an attack by another inmate. Ford claimed that he had informed the officials of the risk through numerous complaints and grievances, but they were deliberately indifferent, leading to the attack where he was severely injured.The United States District Court for the Middle District of North Carolina granted summary judgment in favor of the prison officials. The court concluded that Ford's complaints were not specific enough to enable the officials to investigate and respond appropriately. Additionally, the court found that Ford failed to demonstrate the necessary mens rea of deliberate indifference required for an Eighth Amendment violation.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's judgment regarding five of the six prison officials. The appellate court agreed that Ford did not provide sufficient evidence to show that these officials were deliberately indifferent to his safety. However, the court vacated the summary judgment concerning Officer Jerry Ingram. The court found that there was a genuine issue of material fact regarding whether Ingram's actions, specifically his public questioning of Ford about the threats, knowingly exacerbated the risk to Ford and contributed to the attack. The case was remanded for further proceedings against Officer Ingram. View "Ford v. Hooks" on Justia Law

Kenneth and Anita Wolke Brooks purchased 85 acres of land in Georgia for $1.35 million, subdivided it, and granted a conservation easement on a 41-acre parcel to Liberty County. They claimed a $5.1 million charitable deduction on their tax returns for this easement. The IRS disallowed the deductions for 2010, 2011, and 2012, citing non-compliance with the Internal Revenue Code and regulations, and imposed accuracy-related penalties for gross valuation misstatements.The Brookses challenged the IRS's notice of deficiency in the United States Tax Court. The Tax Court upheld the IRS's disallowance of the deductions and the imposition of penalties. The court found that the Brookses failed to provide a contemporaneous written acknowledgment of the donation, did not submit an adequate baseline report to Liberty County, and misrepresented their basis in the property. The court also found that the valuation of the easement was grossly overstated.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the Tax Court's decision. The court held that the Brookses did not meet the statutory requirements for a charitable deduction due to the lack of a proper contemporaneous written acknowledgment and an inadequate baseline report. The court also agreed with the Tax Court's finding that the Brookses' valuation of the easement was speculative and unsupported, justifying the 40 percent penalty for gross valuation misstatements. The court concluded that the Tax Court did not abuse its discretion in admitting the IRS Civil Penalty Approval Form into evidence despite its late disclosure. View "Brooks v. Commissioner of Internal Revenue" on Justia Law

An elderly couple in Greenville, North Carolina, reported a breaking-and-entering at their residence around 4:00 a.m., hearing glass break and a male voice yelling. Officer David Johnson, who was nearby, responded to the call. Upon arrival, Johnson heard loud yelling and saw Sean Rambert running towards him while yelling. Johnson commanded Rambert to get on the ground eight times, but Rambert did not comply and continued to charge at Johnson. Johnson fired multiple shots at Rambert, who continued to advance even after being shot. Rambert eventually fell and later died from his injuries.The United States District Court for the Eastern District of North Carolina denied Johnson’s motion for summary judgment based on qualified immunity. The court found genuine disputes of material fact regarding the reasonableness of Johnson’s conduct and concluded that a jury could determine that Johnson violated Rambert’s Fourth Amendment rights by using excessive force. The court also denied summary judgment on the remaining federal and state law claims against Johnson and the City of Greenville.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that Johnson was entitled to qualified immunity on the Fourth Amendment claim. The court found that Johnson’s use of deadly force was not objectively unreasonable given the circumstances, including Rambert’s aggressive behavior and failure to comply with commands. The court also determined that the law did not clearly establish that Johnson’s conduct was unconstitutional at the time of the incident. Consequently, the court reversed the district court’s denial of summary judgment on the § 1983 claim against Johnson. However, the court dismissed the appeal regarding the related state and federal claims and claims against the City of Greenville, remanding those issues for further proceedings. View "Rambert v. City of Greenville" on Justia Law

Eunice Nkongho was investigated for her involvement in a munitions export and money laundering conspiracy. Federal agents stopped her at the airport and seized her electronic devices. Nine days later, they obtained a warrant to search her phone, uncovering incriminating text messages. Nkongho was charged with money laundering and conspiracy to launder money. She moved to suppress the evidence from her phone, but the district court denied the motion. At trial, the government used her text messages and call history as key evidence. A jury convicted her, and she was sentenced to twenty-four months’ imprisonment and three years’ supervised release.The United States District Court for the District of Maryland denied Nkongho’s motion to suppress, holding that the seizure of her devices fell within the border search exception, which does not require a warrant. The court found that the scheme involved the theft and international transfer of military equipment, justifying the seizure. The court also rejected her argument that the nine-day delay in obtaining a search warrant was unreasonable, emphasizing the government’s heightened interest in the devices.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that the agents had probable cause to believe Nkongho was part of an international munitions export conspiracy, justifying the seizure of her devices under the border search exception. The court also found that the nine-day delay in seeking a search warrant was not unreasonable, given the agents’ need to consult legal counsel. Additionally, the court upheld the district court’s calculation of Nkongho’s sentence, including the loss amount attributed to her and the denial of a role reduction in the offense level. View "United States v. Nkongho" on Justia Law