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

Plaintiff, through her next friends and guardians, filed a complaint in state court against Matt Blair and Res-Care. Res-Care removed to federal court, asserting subject matter jurisdiction based on diversity of citizenship. The district court sua sponte remanded the case back to state court, determining that federal diversity jurisdiction has not been established because Res-Care did not allege the state in which it had its principal place of business. The court concluded that it had jurisdiction to review the district court's remand order because the district court based its remand order on a procedural defect in the removal notice. The court held that a district court exceeds its statutory authority when it remands a case sua sponte based on a procedural defect absent a motion from a party. In this case, the district court exceeded its statutory authority by remanding this case sua sponte. Accordingly, the court reversed and remanded. View "Jane Doe #1 v. Blair" on Justia Law

PHA filed suit against Wells Fargo, alleging that Wells Fargo falsely represented that it would forbear collection of the principal balance of a line of credit, ultimately causing PHA to default and enter bankruptcy. PHA subsequently filed suit in Virginia state court, which Wells Fargo removed to federal court. Along with repeating the claims made in the bankruptcy adversary complaint, PHA alleged new theories of lender liability. The district court dismissed the suit. The court rejected PHA's contention that the district court erroneously gave res judicata effect to various sale orders issued during PHA’s Chapter 11 bankruptcy, concluding that the elements of res judicata are satisfied. Accordingly, the court affirmed the judgment. View "Providence Hall Assoc. v. Wells Fargo Bank, N.A." on Justia Law

Victims of a massive ponzi scheme centered in South Carolina obtained a judgment of over $150 million against Derivium and others. Plaintiffs are now pursuing others whom they claim also participated in the scheme. The district court granted Vision International's motion to dismiss for lack of personal jurisdiction under FRCP 12(b)(2). The district court also granted Randolph Anderson, Patrick Kelley, and Total Eclipse's motion for judgment as a matter of law on plaintiffs' claim for aiding and abetting common law fraud. Plaintiffs filed separate appeals on the two rulings. The court consolidated the appeals. The court concluded that, because the parties engaged in full discovery on the jurisdictional issue and fully presented the relevant evidence to the district court, that court properly addressed Vision International’s Rule 12(b)(2) motion by weighing the evidence, finding facts by a preponderance of the evidence, and determining as a matter of law whether plaintiffs carried their burden of demonstrating personal jurisdiction over Vision International. Further, the court agreed with the district court’s conclusion that South Carolina has not recognized a cause of action for aiding and abetting common law fraud and that it is not the court's role as a federal court to so expand state law. Accordingly, the court affirmed the judgment as to both appeals. View "Grayson v. Anderson" on Justia Law

Perdue appealed the district court's dismissal of its breach of contract action against BRF for lack of personal jurisdiction. The court concluded that Perdue has alleged few facts to satisfy its prima facie burden in support of personal jurisdiction. In this case, the only fact that it alleges that indisputably weighs in favor of jurisdiction is that the agreement at issue includes a Maryland choice-of-law clause. On the contrary, many undisputed facts indicate that a Maryland court does not have personal jurisdiction over BRF: the company employs no Maryland officers or agents and owns no property in the state; BRF did not initiate the negotiations that led to the agreement; no BRF employee traveled to Maryland in connection with the agreement; and BRF conducts no business in Maryland. In this case, BRF’s alleged breach of the agreement occurred not in Maryland, but in foreign countries. Accordingly, the court affirmed the judgment. View "Perdue Foods LLC v. BRF S.A." on Justia Law

Plaintiff, a Senior Managing Attorney for CVLAS, filed suit alleging discrimination on the basis of race, sex, and age. The district court granted CVLAS's motion to dismiss without prejudice. The court concluded that the order of dismissal was not a final and appealable order, and therefore, the court dismissed the appeal for lack of jurisdiction and remanded the case to the district court with instructions. The court held that the grounds for dismissal in this case did not clearly preclude amendment. View "Goode v. Central Virginia Legal Aid Society" on Justia Law

Appellants sought to intervene as plaintiffs in a civil RICO action brought by CVLR Performance Horses against John Wynne and his businesses. The district court denied the motions and appellants appealed. The underlying suit between CVLR and Wynne settled and was dismissed by the district court approximately ten weeks later, while this appeal was pending. Wynne then moved to dismiss this appeal, arguing that the settlement of the underlying action rendered the appeal moot. The court rejected claims of mootness and concluded that it had jurisdiction over the appeal because a ruling in appellants’ favor on the merits of their appeal would provide them effective relief. The court concluded that the district court’s refusal to apply equitable tolling was not an abuse of discretion because appellants did not demonstrate diligent pursuit of their rights or extraordinary circumstances sufficient to excuse their delay. Accordingly, the court affirmed the judgment. View "Foster v. Wynne" on Justia Law

The South Carolina Coastal Conservation League filed suit against various parties under federal law to stop what it fears will be significant degradation to 485 acres of freshwater wetlands and its conversion to saltwater wetlands. The court affirmed the district court's dismissal of the action as moot where the record on appeal does not support the proposition that granting the League the relief it seeks on any of its claims will likely prevent the water within the Embanked Tract from becoming more saline. Because the district court’s mootness ruling is sound and the League has offered no additional basis for standing, the district court did not abuse its discretion in denying, on the ground of futility, the League’s motion seeking leave to amend its First Amended Complaint. View "South Carolina Coastal v. U.S. Army Corps" on Justia Law

A multiemployer pension plan (the “Pension Fund”) commenced this action under 29 U.S.C. 1401(b)(2) by filing a complaint seeking to vacate or modify an arbitration order entered pursuant to section 1401(a)(1). The Pension Fund later filed an amended complaint that it argued related back to the filing date of the original complaint. The district court concluded that the Pension Fund could challenge the arbitration award only by filing a motion to vacate or modify, as provided in the Federal Arbitration Act. The court then treated the amended complaint as a motion and dismissed it, concluding that it was untimely under section 1401(a)(2) because a motion cannot “relate back” under Fed. R. Civ. P. 15. The Fourth Circuit reversed the district court’s order of dismissal and remanded for further proceedings as a civil action, holding (1) a party seeking to vacate or modify an arbitrator’s award under section 1401(b)(2) must commence an action in a district court by filing a complaint; and (2) the amended complaint in this case related back to the filing date of the original complaint, thus rendering it timely. View "Local Union 557 Pension Fund v. Penske Logistics LLC" on Justia Law

Five individuals (collectively, “Plaintiffs”) each filed a petition for individual bankruptcy under Chapter 13 in the Bankruptcy Court for the District of Maryland. LVNV Funding, LLC and its affiliated companies (collectively, “Defendants”) filed a proof of unsecured claim based on defaulted debts it had acquired against each plaintiff. Each Chapter 13 plan was approved. Defendants’ claims were allowed, and they received payments from the Chapter 13 trustees on these claims. Plaintiffs subsequently filed this putative class action lawsuit in the District of Maryland alleging that Defendants violated the federal Fair Debt Collection Practices Act (FDCPA) and various Maryland laws by filing proofs of claim without a Maryland debt collection license. The district court dismissed the action, concluding (1) the state common law claims were barred by res judicata, and (2) the federal and state statutory claims failed to state a claim. The Fourth Circuit affirmed but on res judicata grounds, holding (1) Plaintiffs’ claims were based on the same cause of action as Defendants’ claims in the confirmed bankruptcy plans and were thus barred by res judicata; and (2) Plaintiffs’ statutory claims were subject to the normal principles of res judicata and were thus precluded by the confirmation of the Chapter 13 plans. View "Covert v. LVNV Funding, LLC" on Justia Law

Beyond Systems, an internet service provider, filed suit against Kraft and Connexus seeking damages under California's and Maryland's anti-spam statutes based upon several hundred e-mails which it alleges were unlawful spam. As a preliminary matter, the court concluded that Beyond Systems had Article III standing by claiming a harm: receiving spam e-mail. On the merits, the court agreed with the district court that Beyond Systems is barred from recovery because it consented to the harm underpinning its anti-spam claims. In this case, Beyond Systems created fake e-mail addresses, solely for the purpose of gathering spam; it embedded these addresses in websites so that they were undiscoverable except to computer programs that serve no other function than to find e-mail accounts to spam; it increased its e-mail storage capacity to retain a huge volume of spam; and it intentionally participated in routing spam e-mail between California and Maryland to increase its exposure to spam and thereby allow it to sue under both states' laws. Accordingly, the court affirmed the judgment of the district court. View "Beyond Systems v. Kraft Foods" on Justia Law