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

Appellant appealed the district court's award of summary judgment in favor of appellees. The district court held that appellant failed to submit sufficient evidence to meet his burden with regard to various Americans with Disabilities Act (ADA), 42 U.S.C. 12112, claims. Appellees cross-appealed on the ancillary issue of whether the number of employees of the National Red Cross and the Greenbrier Valley Chapter could be aggregated for purposes of determining "employer" status. The court held that appellant did not meet the ADA's definitions of disability and affirmed the district court with regard to appellant's primary ADA claim; appellant's retaliation claim based on appellant's lifting restriction and on his workers' compensation request both failed; and appellant did not have sufficient evidence to support his confidentiality claim. The court also held that Arbaugh v. Y&H Corp. dictated that the ADA's employee threshold was not a limit on jurisdiction but, rather, an element of the claim itself; the cross-appeal was not properly taken; and the court vacated the district court's ruling on the employee aggregation issue. View "Reynolds v. American National Red Cross" on Justia Law

Respondent finished serving his prison sentence for child molestation in 2008, but has remained incarcerated while the government sought to have him declared a "sexually dangerous person" pursuant to the Adam Walsh Child Protection and Safety Act of 2006, 18 U.S.C. 4248. The government appealed the judgment of the district court that respondent be freed from the custody of the Bureau of Prisons and granted supervised release. The court concluded that, contrary to the district court's legal determination and as established by the evidence, respondent indeed suffered from a qualifying mental impairment. The court nevertheless affirmed the judgment, discerning no clear error in the district court's alternative rationale that the government fell short of carrying its burden to demonstrate a relative likelihood that respondent would reoffend. View "United States v. Caporale" on Justia Law

Defendant appealed his conviction and sentence for a child pornography offense. The court held that law enforcement officers had probable cause to enter into the property at issue and their subsequent inquiries regarding laptop computers were also lawful and proper. Therefore, the court rejected defendant's contention of a Fourth Amendment violation. The court also held that the district court did not abuse its discretion by denying defendant's motion to dismiss and striking the lesser-included offense of possession of child pornography. Accordingly, the court affirmed the judgment. View "United States v. Brown" on Justia Law

After counsel for defendant filed a motion in limine seeking to exclude evidence as a sanction for the government's alleged discovery violation, the district court denied the motion at a hearing that defendant did not attend and in which he did not otherwise participate. Defendant argued on appeal that he should have been present. Because the plain text of Federal Rule of Criminal Procedure 43 did not require a defendant to be present at a hearing on such a motion, the court affirmed defendant's conviction and sentence. View "United States v. Gonzales-Flores" on Justia Law

This dispute related to Employee Retirement Security Act (ERISA), 29 U.S.C. 1001 et seq., contributions made pursuant to a collective bargaining agreement. The district court ordered return of certain allegedly mistaken employer contributions even though the plan administrator determined that the contributions were not made by mistake. Because the court found that the administrator's decision was not an abuse of discretion, the court reversed and remanded for further proceedings. View "U.S. Foodservice, Inc. v. Truck Drivers & Helpers Union" on Justia Law

Plaintiffs appealed from the district court's dismissal of their complaint for declaratory and injunctive relief. Plaintiffs initiated this proceeding against defendants, challenging the use of advanced imaging technology (AIT) scanners and invasive pat-downs at airport screening checkpoints in the United States. On appeal, plaintiffs maintained that the district court erred in dismissing the complaint for lack of subject matter jurisdiction because the TSA's standard operating procedures for checkpoint screenings did not constitute an "order" under 49 U.S.C. 46110. Alternatively, plaintiffs argued, that section 46110's conferral of exclusive jurisdiction in a court of appeals deprived them of due process and contravened the separation of powers rooted in the Constitution. The court held that it had jurisdiction under 28 U.S.C. 1291; on the merits, the district court did not err in ruling that the Checkpoint Screen SOP constituted an order of the TSA Administrator under section 46110; and plaintiffs' remaining contentions lacked merit. Accordingly, the court affirmed the judgment. View "Blitz v. Napolitano" on Justia Law

Defendant filed a motion to suppress evidence of cocaine and subsequently pled guilty to drug charges. Defendant was driving a rental car with a passenger in Virginia when police pulled him over for speeding. Based on the passenger's apparent nervousness and the presence of four cellular phones in the center console, and on defendant's and the passenger's conflicting explanations of their travels, the officer called a drug-detection dog. The dog arrived 13 minutes after the initiation of the traffic stop and a resulting search revealed 830.6 grams of cocaine. The court held that the officer had reasonable suspicion and the delay and search of the vehicle were reasonable. Accordingly, the court affirmed the judgment. View "United States v. Vaughan" on Justia Law

Defendant was convicted of wire fraud, conspiracy to commit wire fraud, conspiracy to commit money laundering, and conspiracy to commit smuggling for his role as the mastermind of a multi-million dollar scheme to defraud the Department of Defense (DOD). The crux of defendant's scheme involved the knowing supply of defective and nonconforming spare parts for use in U.S. military aircraft, vehicles, and weapons systems. Defendant appealed his convictions and sentence on a variety of grounds. The court found his arguments without merit and affirmed the judgment of the district court. View "United States v. Day, Jr." on Justia Law

This case arose when plaintiff filed a putative class action in state court against Santander alleging violations of various Maryland consumer protection laws for undisclosed finance charges and other unfair business practices. Santander subsequently appealed from the district court's order denying its motion to compel arbitration and stay court proceedings of plaintiff's claims against it. While finding that an enforceable arbitration agreement encompassing plaintiff's claims existed, the district court nevertheless concluded that Santander had waived its rights to enforce arbitration by its delay. The court concluded that the record did not support the district court's finding of waiver. Therefore, the court reversed and remanded with directions to defer the claims to arbitration. View "Rota-McLarty v. Santander Consumer USA, Inc." on Justia Law

The MTA applied to the Board to abandon freight transportation use of a right-of-way and to convert it to a recreational trail, as authorized by the National Trails System Act, 16 U.S.C. 1247. The Board rejected the MTA's application, concluding that instead of assuming full responsibility for legal liability or indemnifying the MTA for any potential liability, the proposed sponsors conditioned their undertakings by subjecting them to sovereign immunity and to future state legislative appropriations. The Board explained that instead of assuming full responsibility, the proposed sponsors offered the possibility of no responsibility. The MTA subsequently filed a petition for review. The court found that the MTA's arguments were unpersuasive, especially in light of its burden to demonstrate that the Board acted arbitrarily and capriciously. Accordingly, the court affirmed the decision of the Board and denied the petition for review. View "Maryland Transit v. Surface Transportation Board" on Justia Law