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

Plaintiff brought this declaratory judgment action, asserting that the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., preempted a state court order requiring him to turn over benefits received under ERISA retirement and life insurance plans owned by his deceased ex-wife. At issue was whether ERISA prohibited a state court from ordering plaintiff, who had previously waived his right to those benefits, to relinquish them to the administrators of the ex-wife's estate. The court held that ERISA did not preempt post-distribution suits against ERISA beneficiaries because the court detected no conflict with either ERISA's objectives or relevant Supreme Court precedent. Accordingly, the court affirmed the judgment. View "Andochick v. Byrd" on Justia Law

Defendant was convicted of carjacking, using a firearm in furtherance of carjacking, and conspiracy. Defendant appealed the district court's denial of his motion for a new trial, arguing that the discovery of the actual dates of the Short Hair Picture - a photo of a second suspect with short hair - and the Dreadlocks Picture - a photo of the second suspect with dreadlocks - constituted newly discovered evidence and, alternatively, that the government's failure to disclose this fact violated Brady v. Maryland. The court concluded that defendant was entitled to a new trial because the court found that the district court erred in rejecting defendant's newly-discovered-evidence argument. View "United States v. Moore" on Justia Law

MASC filed an action in the district court seeking a declaration that South Carolina municipalities were entitled to assess municipal business license taxes based on, or measured by, the total flood insurance premiums collected in the particular municipality by insurance companies under an arrangement with FEMA. The district court denied the insurance companies' motion for summary judgment on grounds of preemption and sovereign immunity. The flood insurance premiums were federal property that could not be taxed and the participating private insurance companies, in their operation of and participation with the National Flood Insurance Program, were federal instrumentalities so closely connected with the federal government that they were immune from taxation. The federal government did not consent to this tax, and it was therefore invalid. Accordingly, the court reversed the district court's grant of partial summary judgment to MASC and denial of summary judgment to the insurance companies. View "Municipal Assoc. of SC v. USAA General Indemnity Co." on Justia Law

The Trustee in bankruptcy of ESA appealed from the affirmance by the district court of the award of summary judgment by the bankruptcy court to Hanover. The bankruptcy court concluded that ESA's transfer of $1.375 million to Hanover within 90 days of ESA's filing a petition for bankruptcy was not an avoidable preference under 11 U.S.C. 547(b). The court held that, although the bankruptcy court erred in finding that the earmarking defense applied in this case, the court found no error in its determination that Hanover was entitled to the new value defense under section 547(c) to the Trustee's claim of a preferential transfer. Therefore, the court affirmed the judgment of the bankruptcy court awarding summary judgment to Hanover. View "ESA Environmental Specialists, Inc. v. The Hanover Ins. Co." on Justia Law