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

Augustine Perez was on federal supervised release in North Carolina, subject to conditions that allowed warrantless searches of his “person and property” by probation officers. Perez moved from a residence at Teal Drive to Lawndale Drive, reporting the change as required, but retained ownership of Teal Drive and leased it to Deanna Coleman, who moved in with her daughter. About a year later, probation officers received a tip from a confidential informant that Perez was living at Teal Drive and involved in drug trafficking. Without a warrant, officers searched both Lawndale Drive and Teal Drive on the same day. At Teal Drive, Coleman objected to the search, but officers proceeded, finding cash and items they alleged were connected to drug trafficking.In the United States District Court for the Middle District of North Carolina, Perez and Coleman moved to suppress the evidence from the Teal Drive search, claiming it was unconstitutional. The district court denied the motion to suppress and granted summary judgment to the government, ruling that the currency found was subject to forfeiture as drug proceeds, largely relying on the evidence seized during the search.On appeal, the United States Court of Appeals for the Fourth Circuit reversed, vacated, and remanded. The court held that a supervised release condition permitting warrantless searches of a supervisee’s “property” does not authorize the search of real property owned by the supervisee but leased and occupied by a third party. The court further held that, to lawfully search Coleman’s residence under Perez’s supervision conditions, officers needed probable cause to believe Perez resided there. The government failed to meet this standard, rendering the search of Teal Drive unconstitutional. The Fourth Circuit ordered suppression of the evidence and dismissal of the forfeiture complaint. View "US v. Perez" on Justia Law

Three individuals living with well-managed HIV, whose infections are controlled by daily medication and who have undetectable viral loads, sought to join or rejoin the U.S. Army. They were denied enlistment based on Department of Defense and Army policies that list HIV infection as a disqualifying medical condition, alongside numerous other chronic or communicable diseases. A nonprofit organization, Minority Veterans of America, also supported their challenge. The plaintiffs argued that these policies violate their equal protection rights under the Fifth Amendment and are arbitrary and capricious in violation of the Administrative Procedure Act.The United States District Court for the Eastern District of Virginia granted summary judgment to the plaintiffs. The court issued a permanent injunction barring the Military from denying accession to asymptomatic HIV-positive individuals with undetectable viral loads, prohibiting enforcement of HIV-specific policy provisions, and ordering reevaluation of prior decisions made under these policies. The district court concluded that the Military’s justifications—based on medical, cost, and diplomatic concerns—were irrational, arbitrary, and capricious.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the judgment. Applying rational basis review with heightened deference to military judgments, the Fourth Circuit found that the Military’s policies were rationally related to legitimate military purposes, including maintaining deployable, medically fit servicemembers, minimizing complications from chronic conditions, controlling costs, and addressing diplomatic issues with foreign host nations. The court distinguished this case from Roe v. Department of Defense, which concerned policies for current servicemembers rather than initial entry. The Fourth Circuit held that the Military’s HIV accession policy did not violate the Fifth Amendment or the APA and reversed the district court’s judgment, remanding with instructions to enter judgment for the Military. View "Wilkins v. Hegseth" on Justia Law

The case concerns the non-reappointment of a local general registrar of elections in Lynchburg, Virginia. The plaintiff, previously appointed unanimously by a bipartisan electoral board, reapplied for her position after her term expired in 2023. By that time, the board’s partisan makeup had shifted to include two Republicans and one Democrat, reflecting state law. The board interviewed four candidates, including the plaintiff, but ultimately appointed a different candidate who was a registered Republican. The plaintiff, describing herself as an independent, alleged her non-reappointment was due to partisan bias rather than job performance.Following the board’s decision, the plaintiff sued the board and its two Republican members, alleging First Amendment violations tied to political animus. The United States District Court for the Western District of Virginia dismissed the claim against the board itself on sovereign immunity grounds, but allowed the suit against the individual members to proceed. After a jury trial, the verdict favored the defendants. The plaintiff then appealed, raising concerns about jury selection procedures and the exclusion of certain evidence.The United States Court of Appeals for the Fourth Circuit reviewed the appeal. It held that the district court did not abuse its discretion in managing voir dire, including its refusal to allow more pointed questioning about potential jurors’ political affiliations and beliefs. The Fourth Circuit also determined that the plaintiff had not preserved most evidentiary challenges for appellate review, as she failed to make sufficient proffers or obtain definitive rulings on excluded evidence. For the limited evidentiary exclusions properly preserved, the appellate court found no abuse of discretion. Thus, the Fourth Circuit affirmed the judgment in favor of the defendants. View "Gibbons v. Gibbs" on Justia Law

After President Donald J. Trump began his second term, he issued two executive orders requiring federal agencies to end “diversity, equity, and inclusion” (DEI) programs in their grant and contracting processes. These directives included provisions for agencies to terminate DEI-related offices, positions, and funding (“Termination Provision”); to require federal grantees and contractors to certify compliance with anti-discrimination laws and the absence of DEI programs that violate those laws (“Certification Provision”); and to prepare a report on steps to deter illegal DEI programs (“Enforcement Threat Provision”). The plaintiffs—a city government and two organizations involved in higher education and academic advocacy—alleged that these provisions violated their constitutional rights and sought a preliminary injunction to halt their enforcement.The United States District Court for the District of Maryland found the plaintiffs likely to succeed on their constitutional claims and issued a nationwide preliminary injunction against most of the challenged provisions, except for the preparation of the enforcement report. The defendants appealed and the United States Court of Appeals for the Fourth Circuit granted a stay of the injunction pending appeal. The plaintiffs later sought to have the injunction vacated so they could amend their complaint, but the district court denied this request.Reviewing the case, the United States Court of Appeals for the Fourth Circuit held that the plaintiffs lacked standing to challenge the Enforcement Threat Provision because their alleged injuries were too speculative and intertwined with intra-governmental processes. However, the court found the plaintiffs had standing to challenge the Termination and Certification Provisions because these provisions resulted in concrete and imminent injuries, such as loss of funding or compelled changes in organizational activities.On the merits, the Fourth Circuit concluded the plaintiffs were unlikely to succeed on their facial constitutional challenges. The court ruled that the Termination Provision was not unconstitutionally vague under the Fifth Amendment, and that the Certification Provision did not violate the First Amendment on its face. The court vacated the preliminary injunction and remanded the case for further proceedings. View "Natl. Assoc. of Diversity Officers in Higher Edu. v. Trump" on Justia Law

A substitute teacher in a large Maryland public school system challenged the school board’s policy requiring all staff, including substitutes, to affirm that they would refer to students by their preferred pronouns and not disclose a student’s gender identity to parents without the student’s consent. The teacher, citing her sincerely held religious beliefs, refused to sign the affirmation and requested a religious accommodation, which was ultimately denied. As a result, she was not permitted to substitute teach in the following school years.She brought claims in the United States District Court for the District of Maryland against the school board, asserting violations of Title VII of the Civil Rights Act related to religious accommodation, and First Amendment violations of her rights to free speech and free exercise of religion. She sought damages, declaratory relief, and a preliminary injunction. The district court dismissed her First Amendment claims under Rule 12(b)(6) for failure to state a claim, finding the policy to be neutral and generally applicable, thus subject to rational basis review, and rationally related to legitimate government interests, including compliance with Title IX and student safety. The court concluded that the speech at issue was part of her official duties as a teacher and thus not protected by the First Amendment. The court denied a preliminary injunction, finding no likelihood of success on the merits for the constitutional claims and no irreparable harm for the Title VII claim, which was allowed to proceed.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s dismissal of the First Amendment claims and denial of a preliminary injunction. The Fourth Circuit held that the policy was neutral and generally applicable, survived rational basis review, and the compelled speech fell within the teacher’s official duties. Therefore, the plaintiff was not entitled to injunctive relief on her constitutional claims. View "Polk v. Montgomery County Public Schools" on Justia Law

Ten nonprofit organizations that received federal grants through the U.S. Citizenship and Immigration Services’ “Citizenship and Integration Grant Program” filed suit after the Department of Homeland Security (DHS) froze and subsequently terminated their grant funding. The freeze and termination followed an executive order issued by the incoming President in January 2025 directing DHS to pause and review grants that funded services to undocumented immigrants, with the aim of ensuring compliance with law and preventing waste, fraud, or abuse. DHS notified grantees of the freeze in February 2025 and terminated the grants in March 2025, prompting the plaintiffs to seek a preliminary injunction to restore the program and funding.The United States District Court for the District of Maryland denied the plaintiffs’ motion for a preliminary injunction. The court determined that the plaintiffs’ claims were essentially contractual—seeking disbursement of funds based on grant agreements—and thus fell under the exclusive jurisdiction of the United States Court of Federal Claims pursuant to the Tucker Act. The court also found that the plaintiffs had not identified a reviewable “final agency action” under the Administrative Procedure Act (APA). Additionally, it concluded that the plaintiffs had failed to provide adequate legal authority for their ultra vires and separation-of-powers claims.Reviewing the appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The Fourth Circuit held that the relief sought by the plaintiffs was materially indistinguishable from relief denied in recent Supreme Court cases, Department of Education v. California and National Institutes of Health v. Public Health Association. It concluded that claims seeking to enforce contractual obligations to pay money must be brought in the Court of Federal Claims and that the plaintiffs had not shown a likelihood of success on their alternative constitutional or statutory claims. The district court’s denial of the preliminary injunction was therefore affirmed. View "Solutions in Hometown Connections v. Noem" on Justia Law

In July 2023, law enforcement responded to an incident in which James Jacobs allegedly discharged a firearm during a dispute with his girlfriend at his home. During a subsequent search, officers discovered two firearms. Jacobs, who has a prior felony conviction and a previous misdemeanor conviction for domestic battery in West Virginia, admitted to knowing he was prohibited from possessing firearms. As a result, a grand jury in the Northern District of West Virginia indicted him for possessing firearms after a felony conviction under 18 U.S.C. § 922(g)(1) and after a misdemeanor crime of domestic violence under § 922(g)(9).The United States District Court for the Northern District of West Virginia granted Jacobs’ motion to dismiss both counts of the indictment. The district court, employing the framework from New York State Rifle & Pistol Association v. Bruen, found that the government failed to demonstrate a historical tradition of disarming individuals like Jacobs—nonviolent felons and domestic violence offenders. The court concluded that both statutes were unconstitutional as applied to Jacobs and dismissed the charges without reaching the facial challenges.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s rulings de novo. The Fourth Circuit held that recent decisions—including United States v. Rahimi, United States v. Canada, United States v. Hunt, and United States v. Nutter—foreclose Jacobs’ facial and as-applied challenges to § 922(g)(1) and his facial challenge to § 922(g)(9). Accordingly, the court reversed the district court’s dismissal of the § 922(g)(1) charge and barred Jacobs from reviving those challenges. However, the Fourth Circuit determined that further proceedings were necessary regarding Jacobs’ as-applied challenge to § 922(g)(9), vacated the district court’s ruling on that count, and remanded for additional factfinding and analysis. View "United States v. Jacobs" on Justia Law

Plaintiffs, consisting of individuals and gun rights organizations, challenged multiple Maryland statutes and regulations that prohibit the carrying of firearms in a range of locations, including government buildings, mass transit, school grounds, public demonstrations, state parks and forests, healthcare facilities, places of amusement, locations selling alcohol, and private property. The plaintiffs claimed these laws violated their Second Amendment rights, arguing that the restrictions could not be justified under the Supreme Court’s “sensitive places” exception to the right to bear arms.The United States District Court for the District of Maryland consolidated the cases and ruled on cross-motions for preliminary injunction and summary judgment. It denied injunctive relief for most challenges, including those relating to museums, healthcare facilities, mass transit, state parks and forests, places of amusement, school grounds, and government buildings. However, it granted injunctive relief to plaintiffs for the restrictions on carrying guns on private property held open to the public, at public demonstrations, and at locations selling alcohol for on-site consumption. All summary judgment motions were initially denied without prejudice; on renewal, the district court granted summary judgment in part and denied it in part. Both sides appealed.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo and issued a comprehensive decision applying Supreme Court precedent, particularly District of Columbia v. Heller and New York State Rifle & Pistol Association, Inc. v. Bruen. The Fourth Circuit affirmed the constitutionality of Maryland’s restrictions on carrying firearms in government buildings, mass transit, school grounds, state parks and forests, museums, healthcare facilities, stadiums, racetracks, amusement parks, and casinos. It also reversed the district court and upheld Maryland’s restrictions at public demonstrations and locations selling alcohol. However, the Fourth Circuit affirmed the district court’s ruling that Maryland’s ban on carrying firearms on private property held open to the public without express permission is unconstitutional, and found plaintiffs lacked standing to challenge the restriction on property not held open to the public. The judgment was affirmed in part and reversed in part. View "Kipke v. Moore" on Justia Law

Raymond Richardson was indicted for first-degree robbery under West Virginia law, specifically charged with using the threat of deadly force against Denise Cool to steal money. However, at trial, the prosecution presented evidence that Richardson accomplished the robbery by physically assaulting Cool rather than by threatening her with a deadly weapon. Richardson admitted to hitting Cool but denied taking her money. The jury found him guilty of first-degree robbery, assault during the commission of a felony, and possession with intent to deliver cocaine. The central issue on appeal concerned the alleged variance between the indictment and the State’s theory at trial.Following his conviction, Richardson sought post-conviction relief in state court, arguing that his trial counsel was ineffective for failing to object to the variance between the indictment and the evidence presented at trial. At an evidentiary hearing, Richardson and his trial counsel testified. Counsel acknowledged missing the indictment’s specific language but stated that the variance did not affect the defense strategy, which was focused on denying any theft rather than disputing the manner in which the robbery was committed. The state court denied habeas relief, finding Richardson had sufficient notice of the charges and was not prejudiced by the variance. The West Virginia Supreme Court of Appeals affirmed, concluding the difference between the indictment and trial evidence did not mislead Richardson or prejudice his defense.On federal habeas review, the United States District Court for the Southern District of West Virginia denied Richardson’s petition, finding he received adequate notice under the Fourteenth Amendment. The United States Court of Appeals for the Fourth Circuit affirmed, holding that the variance did not violate due process because Richardson was convicted of the offense charged, had actual notice of the evidence to be presented, and failed to show that the variance hindered his defense. The court found no ineffective assistance of counsel or prejudice and affirmed the district court’s denial of habeas relief. View "Richardson v. Frame" on Justia Law

William White, a federal prisoner serving a lengthy sentence, was transferred from one federal correctional institution to another, spending three days at a federal transfer center in Oklahoma City, where he was held in a Special Housing Unit for security reasons. During this brief transit period, he was not offered, nor did he participate in, any evidence-based recidivism reduction programming required under the First Step Act of 2018 (FSA). White later sought to have his time at the transfer center count toward FSA time credits, which could reduce his period of incarceration.The United States District Court for the District of Maryland denied White’s habeas corpus petition under 28 U.S.C. § 2241. The court found that the Bureau of Prisons’ (BOP) refusal to award FSA time credits for the three-day transfer period was consistent with BOP regulations and policy statements, which generally do not consider prisoners in transit or in certain housing statuses to be “successfully participating” in qualifying programs. The court also rejected White’s claim that his due process rights were violated, holding that the FSA does not create a protected liberty interest in earning time credits during every day of incarceration.Reviewing the case, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The Fourth Circuit held that, under the plain text of the FSA, a prisoner is entitled to time credits only for days in which he actually participates in qualifying programming or productive activities. Because White did not participate in any such programming during his three days in transit, he was not statutorily entitled to those time credits. The court further held that the FSA does not create a constitutionally protected liberty interest in earning time credits, so the BOP’s actions did not violate due process. View "White v. Warden of Fed Correctional Ins - Cumberland" on Justia Law