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

Matthew Ryan Hunt was charged with violating 18 U.S.C. § 922(g)(1), which prohibits individuals convicted of a crime punishable by imprisonment for a term exceeding one year from possessing firearms. Hunt's 2017 conviction for breaking and entering in West Virginia served as the predicate offense. In May 2022, Hunt pleaded guilty without raising a Second Amendment challenge. On appeal, Hunt argued that § 922(g)(1) violated the Second Amendment both facially and as applied to him. He also contended that the district court erred in applying a four-point enhancement to his offense level under the federal sentencing guidelines.The United States District Court for the Southern District of West Virginia accepted Hunt's guilty plea and applied the four-point enhancement, finding that Hunt had fired a gun inside an apartment building during a domestic violence incident, which constituted wanton endangerment under West Virginia law. Hunt appealed the decision, arguing that the statute was unconstitutional and that the district court's factual findings were erroneous.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court reaffirmed that § 922(g)(1) is facially constitutional, consistent with its prior decision in United States v. Canada. The court also rejected Hunt's as-applied challenge, holding that neither the Supreme Court's decisions in New York State Rifle & Pistol Association, Inc. v. Bruen nor United States v. Rahimi abrogated the Fourth Circuit's precedent foreclosing as-applied challenges to § 922(g)(1). Additionally, the court concluded that § 922(g)(1) would survive Second Amendment scrutiny even if decided anew.The Fourth Circuit also upheld the district court's application of the four-point enhancement, finding no clear error in the factual determination that Hunt fired a gun in the apartment. Consequently, the court affirmed the district court's judgment. View "US v. Hunt" on Justia Law

The American Civil Liberties Union Foundation of South Carolina (ACLU-SC) challenged the South Carolina Department of Corrections (SCDC) policy that prohibits personal contact interviews with inmates. ACLU-SC sought to record and publish interviews with death row inmate Marion Bowman, Jr., and another inmate, Sofia Cano, for a series of audio podcasts and written pieces. The SCDC policy, however, forbids such interviews. ACLU-SC filed a lawsuit alleging that the policy violates the First Amendment both facially and as applied to its planned interviews.The United States District Court for the District of South Carolina dismissed ACLU-SC’s complaint for failure to state a claim and denied its request for a preliminary injunction. The district court found that ACLU-SC has no First Amendment right to access prison inmates to conduct interviews for publication. The court relied on Supreme Court precedents that reject a claimed right to access and interview inmates, concluding that the Constitution does not mandate a right of access to government information or sources of information within the government’s control.The United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The Fourth Circuit held that ACLU-SC has no First Amendment right to interview and record SCDC inmates, as the policy does not place the press in any less advantageous position than the public generally. The court also rejected ACLU-SC’s facial challenge to the policy, finding that the policy does not prohibit a substantial amount of protected speech relative to its plainly legitimate sweep. The court concluded that the district court correctly dismissed ACLU-SC’s complaint and did not abuse its discretion in denying the preliminary injunction. View "American Civil Liberties Union Foundation of South Carolina v. Stirling" on Justia Law

The plaintiffs in this case are retail pet stores, a dog broker, and a dog breeder who want to sell dogs through physical retail stores in Maryland. However, a Maryland law restricts their ability to do so. The plaintiffs sued, alleging that the Maryland statute is preempted by the federal Animal Welfare Act (AWA) and violates the Commerce Clause of the United States Constitution.The United States District Court for the District of Maryland dismissed the plaintiffs' complaint, concluding that they failed to state plausible claims. The plaintiffs then appealed to the United States Court of Appeals for the Fourth Circuit.The Fourth Circuit reviewed the case de novo and affirmed the district court's decision. The court held that the AWA does not preempt the Maryland statute because the AWA expressly contemplates state and local regulation on the same subject. The court also found that the Maryland statute does not pose an impermissible obstacle to achieving the purposes and objectives of the AWA.Regarding the Commerce Clause claims, the court held that the Maryland statute does not discriminate against interstate commerce in purpose or effect. The statute applies equally to in-state and out-of-state breeders and brokers, and it does not prohibit the flow of interstate goods or place added costs upon them. The court also found that the statute does not violate the Pike balancing test because the plaintiffs failed to plausibly allege that the statute imposes a substantial burden on interstate commerce that is clearly excessive in relation to its putative local benefits.In conclusion, the Fourth Circuit affirmed the district court's dismissal of the plaintiffs' complaint, holding that the Maryland statute is not preempted by the AWA and does not violate the Commerce Clause. View "Just Puppies, Inc. v. Brown" on Justia Law

Plaintiffs Tati Abu King and Toni Heath Johnson were unable to register to vote in Virginia due to felony convictions. King was convicted of felony drug possession in 2018, and Johnson was convicted of multiple felonies, including drug possession, in 2021. Virginia's constitution disenfranchises individuals convicted of felonies unless their civil rights are restored by the Governor or other appropriate authority. King and Johnson argued that this disenfranchisement violated the Virginia Readmission Act, a federal statute from 1870, which they claimed restricted Virginia from amending its constitution to disenfranchise individuals for crimes that were not felonies at common law in 1870.The United States District Court for the Eastern District of Virginia dismissed three of the four counts in the plaintiffs' complaint for failure to state a claim but allowed one count based on the Virginia Readmission Act to proceed. The defendants, including various state election officials and the Governor of Virginia, moved to dismiss the complaint on sovereign immunity grounds, which the district court rejected.The United States Court of Appeals for the Fourth Circuit reviewed the case and held that the plaintiffs' claim met the requirements of the Ex parte Young doctrine, which allows suits for prospective relief against state officials to prevent ongoing violations of federal law. The court affirmed the district court's decision to allow the claim to proceed against most defendants but reversed the decision regarding the Governor of Virginia and the Secretary of the Commonwealth, finding that they lacked enforcement responsibility for the challenged state action. The court concluded that the Governor and Secretary must be dismissed from the case on sovereign immunity grounds. The district court's order was thus affirmed in part and reversed in part. View "King v. Youngkin" on Justia Law

Stephen Bullis was convicted of six federal crimes, including two counts of using a firearm during and in relation to other crimes, in violation of 18 U.S.C. § 924(c). After serving twenty-three years in prison, the United States Supreme Court struck down the “residual clause” of 18 U.S.C. § 924(c) as unconstitutional. This led the district court to set aside Bullis’s two Section 924(c) convictions and resentence him on the remaining four counts. Bullis argued that the resentencing violated his rights under the Double Jeopardy Clause because he had fully served his sentence on these counts at the time of the resentencing.The United States District Court for the Eastern District of North Carolina initially sentenced Bullis to 235 months of imprisonment on each of Counts 1, 2, 4, and 5, all to run concurrently. On Count 3, Bullis was sentenced to 360 months, and on Count 6, he received a lifetime sentence, both to run consecutively to the 235-month concurrent sentences. After the Supreme Court’s ruling, the district court vacated Counts 3 and 6 and resentenced Bullis to 450 months on Count 2 and 240 months on Counts 1, 3, and 5, all to run concurrently.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that Bullis’s resentencing did not violate the Double Jeopardy Clause because his sentences for Counts 1, 2, 4, and 5 were part of a consecutive sentence package that had not been fully served. However, the court found that the district court committed reversible errors by imposing a special condition of supervised release that differed materially from the court’s oral pronouncement and by failing to incorporate clearly the Standard Conditions of Supervision as adopted in the Eastern District of North Carolina. Consequently, the Fourth Circuit vacated and remanded the case for resentencing. View "US v. Bullis" on Justia Law

The case involves Russell Lucius Laffitte, who was convicted of bank and wire fraud in the United States District Court for the District of South Carolina. The government alleged that between 2006 and 2021, Laffitte, as CEO of Palmetto State Bank, conspired with Alex Murdaugh, a disbarred attorney, to defraud Murdaugh’s clients. Laffitte was accused of using his position to access settlement accounts, collecting fees, and extending unsecured loans to Murdaugh, resulting in nearly two million dollars being stolen from the accounts. Laffitte was charged with conspiracy to commit wire and bank fraud, bank fraud, wire fraud, and misapplication of bank funds.During the trial, the government presented fifteen witnesses, and Laffitte called eight witnesses and testified in his own defense. After the jury began deliberations, the court received notes from jurors indicating issues, including one juror needing medication and another feeling pressured. The district court decided to remove two jurors, Juror No. 88 and Juror No. 93, and replaced them with alternates. The jury then returned a guilty verdict on all counts.Laffitte appealed, arguing that the removal of the jurors violated his Fifth Amendment right to be present and his Sixth Amendment right to an impartial jury. The Fourth Circuit Court of Appeals reviewed the case and found that the removal of Juror No. 88 violated Laffitte’s Sixth Amendment right because there was a reasonable and substantial possibility that her removal was related to her views on the case. The court also found that the removal violated Laffitte’s Fifth Amendment right to be present, as he was not present during the in camera interview when the decision to remove Juror No. 88 was made. The court concluded that these errors were not harmless and vacated Laffitte’s convictions and sentence, remanding the case for a new trial. View "US v. Russell Laffitte" on Justia Law

The plaintiff, Siddhanth Sharma, a convicted felon, challenged North Carolina's felony-disclosure requirement for candidates running for federal office. This state law mandates that candidates disclose any felony convictions and provide additional information about the convictions and the restoration of citizenship rights. Sharma, who announced his candidacy for North Carolina’s Thirteenth Congressional District seat, argued that this requirement violated the Qualifications Clause and the First Amendment.The United States District Court for the Eastern District of North Carolina dismissed Sharma's claims. The court found that Sharma had standing to challenge the felony-disclosure requirement but concluded that it did not constitute an additional qualification for office. The court also held that the requirement did not violate the First Amendment, as it served a substantial interest in promoting an informed electorate and posed only a modest burden. Sharma's challenge to the address-disclosure requirement was dismissed for lack of standing, as the court found his injury insufficiently particularized.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court's decision, holding that the felony-disclosure requirement is constitutional. The court reasoned that the requirement does not exclude candidates from the ballot or disadvantage political viewpoints, and it falls within the state's authority to regulate elections. The court also found that the requirement imposes only a light burden on First Amendment rights and serves the state's interest in fostering an informed electorate. However, the court vacated the judgment on the address-disclosure challenge and remanded it to the district court with instructions to dismiss it as moot, as Sharma's address was already publicly available in the voter-search database. View "Siddhanth Sharma v. Alan Hirsch" on Justia Law

The case involves the Republican National Committee (RNC) and the North Carolina Republican Party (NCGOP) filing two state law claims against the North Carolina State Board of Elections (State Board) and its members. The claims, one statutory and one constitutional, allege that the State Board failed to comply with the Help America Vote Act of 2002 (HAVA), which mandates certain voter registration and maintenance procedures. The Democratic National Committee (DNC) intervened as a defendant. The plaintiffs argue that the State Board's noncompliance with HAVA led to improper voter registrations, potentially affecting 225,000 voters.The United States District Court for the Eastern District of North Carolina initially reviewed the case. The district court found it had original jurisdiction over the state statutory claim but not the state constitutional claim. It dismissed the statutory claim, ruling that the relevant statutory provision did not provide a private right of action. Consequently, the district court declined to exercise supplemental jurisdiction over the state constitutional claim and remanded it to state court, also holding that Section 1443 did not provide a valid basis for removal.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the district court's remand order was improper. It found that the district court possessed original jurisdiction over the state constitutional claim under Section 1331 because the claim contained an embedded federal question. The court also determined that removal was permissible under Section 1441. Additionally, the court held that the defendants validly removed the constitutional claim pursuant to Section 1443(2), which allows for removal in cases involving the refusal to perform an act on the grounds that it would be inconsistent with laws providing for equal rights. The court reversed the district court’s remand order and remanded the case for further proceedings consistent with its opinion. View "RNC v. North Carolina State Board of Elections" on Justia Law

The case involves Warren Balogh, who participated in the "Unite the Right" rally in Charlottesville, Virginia. The rally, organized to protest the removal of a Robert E. Lee statue, quickly turned violent between protesters and counterprotesters. Balogh alleged that the Charlottesville Police, under Chief Al Thomas, and the Virginia State Police, under Lieutenant Becky Crannis-Curl, failed to protect his First and Fourteenth Amendment rights by not intervening in the violence and declaring an unlawful assembly, which he claimed amounted to a heckler's veto.The United States District Court for the Western District of Virginia dismissed Balogh's complaint under Federal Rule of Civil Procedure 12(b)(6). The court found that the defendants were entitled to qualified immunity because there was no clearly established right to police intervention to protect First Amendment rights from third-party violence. The court also held that Balogh failed to state a plausible claim for relief under the First and Fourteenth Amendments, noting that the police did not selectively enforce the unlawful assembly order and that Balogh's allegations of intentional discrimination were conclusory.The United States Court of Appeals for the Fourth Circuit affirmed the district court's dismissal. The Fourth Circuit held that the First Amendment does not obligate police to protect protesters' constitutional rights amid violence, explicitly stating that the First Amendment is a shield against invasive speech regulations, not a sword to wield against violent disruptions. The court also found that Balogh's equal protection claim under the Fourteenth Amendment failed because he did not provide sufficient facts to show intentional or purposeful discrimination. Additionally, the court rejected Balogh's Monell claim against the City of Charlottesville, as he did not demonstrate that the City Manager, the final policymaker, had ratified or delegated authority to Chief Thomas. View "Balogh v. Virginia" on Justia Law

The case involves defendants Aghee William Smith II and David Alcorn, who were convicted in the Eastern District of Virginia for their roles in fraudulent schemes that defrauded investors of millions of dollars. The schemes included marketing and selling phony investments in a dental services marketing program and fraudulent spectrum investments. The fraudulent activities primarily targeted elderly victims, resulting in significant financial losses.In the district court, Smith and Alcorn were tried together before a jury in February 2022. They raised three main issues on appeal: a joint constitutional challenge to the district court’s COVID-19 trial protocol under the Public Trial Clause of the Sixth Amendment, Smith’s separate challenge to the admission of videotaped depositions under the Confrontation Clause, and Alcorn’s challenge to the imposition of supervised release conditions.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court rejected Smith and Alcorn’s joint contention that the COVID-19 trial protocol violated their rights under the Public Trial Clause, finding that the protocol did not constitute a partial courtroom closure and was justified by substantial public health reasons. The court also rejected Smith’s Confrontation Clause challenge, concluding that the government had made a good faith effort to secure the witnesses’ presence at trial and that the witnesses were unavailable due to health concerns.However, the court found merit in Alcorn’s challenge regarding the imposition of supervised release conditions. The district court had failed to properly incorporate the standard conditions of supervised release during the oral pronouncement of Alcorn’s sentence, leading to a Rogers error. As a result, the Fourth Circuit vacated Alcorn’s sentences and remanded for resentencing.In summary, the Fourth Circuit affirmed Smith’s convictions and sentences, affirmed Alcorn’s convictions, but vacated Alcorn’s sentences and remanded for resentencing. View "United States v. Smith" on Justia Law