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

After a jury trial, Appellants, Abukar Osman Beyle and Shani Nurani Shiekh Abrar, were convicted on twenty-six criminal counts arising from the armed abduction and murder of four U.S. citizens off the coast of Somalia. The Fourth Circuit affirmed, holding (1) the district court had jurisdiction over the charges of murder and concomitant use of a firearm because the site of the murders, thirty to forty nautical miles from the Somali coast, lay on the “high seas,” and thus, Appellants were within the reach of the U.S. criminal statutes under which they were convicted; and (2) Abrar was not denied his Fifth Amendment right to due process or his Sixth Amendment right to present witnesses material to his duress defense, and therefore, the district court did not err in denying Abrar’s motion to dismiss the indictment. View "United States v. Beyle" on Justia Law

After a jury trial, Defendant was convicted of three counts relating to marijuana trafficking and was sentenced to 121 months of incarceration. Defendant filed a motion to vacate his conviction and sentence, alleging that his trial and appellate counsel had provided ineffective assistance. The district court denied the motion. The Fourth Circuit affirmed, holding (1) Defendant was not prejudiced by his trial counsel’s failure to request an instruction that the jury find a drug weight based on the amount attributable to or reasonably foreseeable by Defendant; (2) Defendant was not prejudiced by his appellate counsel’s failure to raise the failure to request that instruction as an issue on direct appeal; and (3) Defendant’s trial counsel was not ineffective for failing to challenge the drug weight and advisory guidelines range at sentencing. View "United States v. Rangel" on Justia Law

The Professional Massage Training Center (PMTC) filed suit against the Accreditation Alliance of Career Schools and Colleges (ACCSC) after ACCSC denied PMTC’s application for re-accreditation. The district court entered judgment in favor of PMTC, finding that ACCSC had violated the school’s due process rights. The court awarded the school more than $400,000 in damages and ordered ACCSC to fully reinstate its accreditation. The Supreme Court reversed in part and affirmed in part, holding (1) the district court erred in conducting a de novo approach to the accreditation process; (2) judged by the correct standard of review, the accreditation decision was well supported and not arbitrary or capricious; and (3) the district court correctly dismissed PMTC’s state law claims for breach of contract, negligence, and tortious interference. Remanded. View "Prof’l Massage Training v. Accreditation Alliance of Career Schs." on Justia Law

After a jury trial, Appellant was convicted of first degree murder. The conviction was upheld on direct appeal. After unsuccessfully seeking habeas corpus relief in state court, Appellant filed a federal habeas petition alleging that he received ineffective assistance of counsel due to his trial counsel’s failure to request a jury instruction defining heat of passion. The district court denied the petition. The Fourth Circuit reversed, holding (1) the state habeas court’s denial of Appellant’s ineffective assistance claim was based on an unreasonable application of clearly established federal law set forth in Strickland v. Washington; and (2) Appellant’s counsel erred in failing to request the heat of passion jury instruction, and Appellant suffered prejudice as a result of this error. Remanded. View "Lee v. Clarke" on Justia Law

Plaintiff filed suit against Officer R.R. Ray, alleging a violation of 42 U.S.C. 1983 claim for excessive force and a state-law claim for assault and battery. Ray filed a motion for summary judgment on the basis of qualified immunity. The district court denied the motion, concluding that a reasonable jury could find that Ray employed excessive force in detaining Plaintiff. Plaintiff appealed, arguing that the district court erred in denying his motion for summary judgment concerning the excessive-force claim. The Fourth Circuit affirmed, holding that the district court properly denied Ray’s summary judgment motion because Ray was not entitled to qualified immunity at this stage in the litigation. View "Smith v. Ray" on Justia Law

Plaintiff, who was African American and female, applied for two open positions with the Maryland Department of Transportation’s State Highway Administration (Highway Administration). Plaintiff was not selected for either position. Plaintiff filed this lawsuit, alleging that the Highway Administration refused to her hire her because of her race and her sex in violation of Title VII of the Civil Rights Act. The district court dismissed the complaint for failure to state a claim, concluding that Plaintiff failed to plead adequate facts to give rise to a reasonable inference of discrimination. The Fourth Circuit affirmed, holding (1) the district court improperly applied the evidentiary standard set forth in McDonnell Douglas Corp. v. Green in analyzing the sufficiency of Plaintiff’s complaint; but (2) the court nevertheless reached the correct conclusion because Plaintiff failed to include adequate factual allegations to support a claim that the Highway Administration discriminated against her because she was African American or female. View "McCleary-Evans v. Md. Dep’t of Transp." on Justia Law

Plaintiff, a former inmate in the Virginia Department of Corrections facilities, filed numerous complaints about repeated physical and sexual abuse he suffered while imprisoned in the facilities. Plaintiff brought suit against various prison officials alleging violations of his right under the Eighth Amendment to be free from cruel and unusual punishment. The magistrate judge found that Defendants should have been more diligent in handling Plaintiff’s complaints but recommended that because Defendants did not actually know of the substantial risk of harm Plaintiff faced, his claims failed. The district court adopted in its entirety the findings and recommendation of the magistrate judge. The Fourth Circuit vacated the dismissal of Plaintiff’s claims against certain defendants, holding that the magistrate judge and district court failed to appreciate that the subjective “actual knowledge” standard required to find prison officials deliberately indifferent to a substantial risk of serious injury may be proven by circumstantial evidence that a risk was so obvious that it had to have been known. Remanded. View "Makdessi v. Fields" on Justia Law

Plaintiff, a deputy clerk at a courthouse in New Hanover County, North Carolina, was assigned to provide customer service at the courthouse front counter. Plaintiff requested to be assigned to a role with less direct interpersonal interaction, believing that her alleged social anxiety disorder hindered her ability to perform her job. Three weeks later, Plaintiff’s employer terminated her. Plaintiff sued her employer, alleging violations of the Americans with Disabilities Act. The district court granted summary judgment in favor of the employer. The Fourth Circuit reversed, holding that the district court erred by resolving disputed facts in favor of the movant and improperly resolved factual issues at the summary judgment stage in contravention of well-settled law. Remanded for trial. View "Jacobs v. N.C. Admin. Office of the Courts" on Justia Law

After a jury trial, Appellants, four individuals, were convicted of multiple offenses arising from a string of robberies they committed in December 2012. The Fourth Circuit affirmed the convictions, holding (1) the trial judge did not abuse his discretion or violate the Federal Rules of Evidence by admitting certain evidence; (2) assuming the admission of evidence recovered from one appellant’s cell phone violated the Sixth Amendment where not everyone in the phone’s chain of custody testified at trial, the error was harmless beyond a reasonable doubt; and (3) there was sufficient evidence to convict Appellants on every charged offense. View "United States v. Reed" on Justia Law

A written state policy mandates that all persons sentenced to death in Virginia be confined on “death row” while awaiting execution. Inmates on death row live in separate single cells, with minimal visitation and recreational opportunities. After incarceration on Virginia’s death row for almost six years, Plaintiff brought this 42 U.S.C. 1983 action alleging that his confinement on death row violated his procedural Due Process rights and seeking injunctive relief. The district court granted summary judgment for Plaintiff and issued an injunction ordering Virginia prison officials to either alter the policy or to improve the conditions. The Fourth Circuit reversed, holding (1) contrary to Plaintiff’s contention, harsh and atypical confinement conditions in and of themselves do not give rise to a liberty interest in their avoidance; and (2) Plaintiff failed to point to a Virginia law or policy providing him with an expectation of avoiding the conditions of his confinement and failed to establish that those conditions imposed an atypical and significant hardship in relation to the ordinary incidents of prison life. View "Prieto v. Clarke" on Justia Law