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

A West Virginia law, known as the "Save Women's Sports Act," stipulates that athletic teams or sports designated for females, women, or girls shall not be open to students of the male sex, with "male" defined as an individual whose biological sex determined at birth is male. The law was challenged by a 13-year-old transgender girl, B.P.J., who has been taking puberty-blocking medication and has publicly identified as a girl since the third grade. B.P.J. argued that the law violated the Equal Protection Clause and Title IX by preventing her from participating in her school's cross country and track teams.The United States District Court for the Southern District of West Virginia initially granted a preliminary injunction, allowing B.P.J. to participate in her school's sports teams. However, upon review of cross-motions for summary judgment, the court reversed its decision, rejecting B.P.J.'s claims and ruling that the law was constitutional and did not violate Title IX.On appeal, the United States Court of Appeals for the Fourth Circuit disagreed with the lower court's decision. The appellate court held that the law could not lawfully be applied to prevent B.P.J. from participating in her school's sports teams. The court found that the law's sole purpose and effect were to prevent transgender girls from playing on girls' teams, which was not substantially related to an important government interest. The court also found that the law violated Title IX by treating B.P.J. worse than people to whom she was similarly situated, depriving her of any meaningful athletic opportunities, and doing so on the basis of sex. The court dismissed the cross-appeal, vacated in part, reversed in part, and remanded the case with instructions to enter summary judgment for B.P.J. on her Title IX claims. View "B.P.J. v. West Virginia State Board of Education" on Justia Law

The case involves Darryl Colton Frazer, who was convicted and sentenced on drug and firearm offenses in 2023 in the District of Maryland. The charges stemmed from an incident in 2019 when Frazer was stopped by police officers who had reasonable suspicion to conduct an investigatory stop. Frazer had thrown away a black bag just before he was apprehended, which was later found to contain a firearm and approximately 100 grams of marijuana. Frazer unsuccessfully moved to suppress this evidence, arguing that the officers lacked reasonable suspicion to stop him and that they needed a warrant to search the bag.The District Court rejected Frazer's suppression effort, ruling that the police officers had reasonable suspicion to conduct an investigatory stop and could constitutionally search the bag that Frazer had discarded. Frazer was subsequently convicted for three offenses and sentenced to 72 months in prison. He appealed, challenging the denial of his suppression motion and the court’s failure to give a reasonable doubt instruction.The United States Court of Appeals for the Fourth Circuit affirmed the lower court's decision. The court found that the officers had reasonable suspicion to stop Frazer, based on his headlong flight and noncompliance with the officers' commands. The court also ruled that Frazer had voluntarily abandoned his bag, and thus lacked Fourth Amendment standing to challenge the search. Regarding the reasonable doubt instruction, the court held that the district court was not required to define reasonable doubt to the jury, and thus did not abuse its discretion by declining to give the instruction. View "United States v. Frazer" on Justia Law

The case involves six non-citizens who were indicted for illegally reentering the U.S. following their prior removal, a violation of 8 U.S.C. § 1326. They moved to dismiss their indictments on the ground that § 1326 is unconstitutional because it was enacted with a racially discriminatory purpose. The district court rejected their argument, finding that they had not shown racial discrimination was a motive for enacting § 1326.The defendants argued that the 1929 Act, which was one of § 1326’s predecessor offenses, was enacted with racial animus against Mexican and Central American immigrants, and this animus carried forward to the Immigration and Nationality Act (“INA” or “1952 Act”) which enacted § 1326. The district court disagreed, stating that even if the 1929 Act had racist motivations, the case for racial bias with respect to the 1952 Act and § 1326 was much weaker, as they were focused on economic factors, labor market factors, and national security factors.Upon appeal, the United States Court of Appeals for the Fourth Circuit affirmed the judgment of the district court, holding that the defendants had not shown that § 1326 violates the equal protection guarantee of the Fifth Amendment because it was enacted with a racially discriminatory purpose. The court found that the defendants had not carried their burden of showing that racial bias against Mexican and Central American immigrants was “a motivating factor” for Congress when it enacted § 1326 in 1952. View "United States v. Sanchez-Garcia" on Justia Law

The plaintiff, Peter Massaro, a police officer with the Fairfax County Police Department, alleged that his employer retaliated against him by transferring him to an inferior position after he filed a complaint about discrimination in promotion practices within the department. He sought relief under Title VII of the Civil Rights Act, the Age Discrimination in Employment Act, and 42 U.S.C. § 1983. The district court granted summary judgment to Fairfax County, dismissing all of Massaro's claims. The court held that Massaro failed to establish a causal connection between his initial discrimination complaint and his subsequent job transfer.Upon appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court ruled that the time gap between Massaro's complaint and his transfer was too long to support a causal inference. It found no evidence that the transfer was a result of a scheme to punish Massaro for his complaint. Instead, the court concluded that Massaro's transfer was a result of his own subsequent behavior that led to a violation of departmental policy.The court also dismissed Massaro's First Amendment claim, ruling that his promotion complaint made via an internal grievance process did not reflect a matter of public concern, and thus did not meet the threshold for First Amendment protection. View "Massaro v. Fairfax County" on Justia Law

In this case, the United States Court of Appeals for the Fourth Circuit was asked to determine the constitutionality of a process for selecting a student member of a county school board in Howard County, Maryland. Two parents sued the board, arguing that allowing public-school students to elect the student member diminishes adults’ voting power, violating the Equal Protection Clause, and that the selection process violates the Free Exercise Clause as it excludes students who opt not to attend public schools, including those who do so for religious reasons.The court affirmed the dismissal of both claims. It held that the selection process was "basically appointive rather than elective," therefore, the one-person, one-vote principle derived from the Equal Protection Clause was not applicable. The court also found that the selection process was neutral and generally applicable, thus it did not violate the Free Exercise Clause. The process excluded students who chose not to attend public school for any reason, not just those who did so for religious reasons. View "Kim v. Board of Education of Howard County" on Justia Law

In the case before the United States Court of Appeals for the Fourth Circuit, the defendant, a registered sex offender, was convicted for knowingly failing to update his registration as required by the Sex Offender Registration and Notification Act (SORNA). The appellant argued that as he was mobile without a fixed abode, he was not required to register anywhere under SORNA. He also contested the district court's jury instruction on SORNA’s definition of “resides,” claiming it expanded the definition. Furthermore, he argued that SORNA, as applied to him, violated the Tenth Amendment. He also contested two aspects of his sentence: an eight-level enhancement for his third degree sexual abuse of a minor and possession of child pornography, and his lifetime term of supervised release.The court held that the district court correctly instructed the jury on the meaning of “resides” and “habitually lives” under SORNA and that SORNA, as applied to the appellant, did not violate the Tenth Amendment. The court also affirmed the district court’s sentence as procedurally and substantively reasonable. It concluded that the appellant, who was required to register as a sex offender due to a previous conviction, failed to update his registration while residing in West Virginia, thus violating SORNA. The court found that his argument of not having a fixed abode did not exempt him from the registration requirements of SORNA. View "United States v. Kokinda" on Justia Law

The United States Court of Appeals for the Fourth Circuit considered a case involving Gerald Wayne Timms, who was civilly committed as a sexually dangerous person under the Adam Walsh Child Protection and Safety Act of 2006, following his sentence for a child pornography conviction. During his civil commitment, Timms was convicted of and sentenced for two separate federal crimes. After serving the prison terms for these offenses, his civil commitment continued. Timms argued that his civil commitment should have ended when his first criminal sentence started, and he claimed that certain conditions of his criminal confinement violated the requirements of the Act. He also contended that the application of the Act violated his constitutional rights.However, the court held that a person ordered to be civilly detained after a finding of sexual dangerousness remains committed until a court finds that he is no longer sexually dangerous and that an intervening criminal sentence has no impact on the civil commitment. The court also held that the Attorney General did not fail to meet his statutory obligation to detain Timms in a suitable facility and that the Attorney General was not required to seek recommitment following Timms' sentences. Thus, the court affirmed the dismissal of Timms' petition for habeas corpus relief. View "Timms v. U. S. Attorney General" on Justia Law

In a federal case before the United States Court of Appeals for the Fourth Circuit, the petitioner, James Rosemond, appealed a district court's dismissal of his habeas corpus petition. Rosemond, who was serving multiple life sentences for offenses related to drug trafficking and murder, claimed that his continued detention was unconstitutional because then-President Donald Trump had commuted his sentence to time served during a phone conversation with two of Rosemond's supporters, Jim Brown and Monique Brown. The Browns signed declarations stating that during the December 2020 call, they believed President Trump had decided to commute Rosemond's sentence. However, no clemency warrant or official record of clemency for Rosemond exists, and his clemency petition is still listed as "pending" on the Department of Justice’s Office of the Pardon Attorney website.The Court of Appeals affirmed the district court’s dismissal of Rosemond’s petition. The court held that while a written document is not constitutionally required for a presidential commutation, the evidence provided by Rosemond, namely the Browns' declarations, did not establish that President Trump actually commuted his sentence. The court found that President Trump's alleged statements during the phone call were forward-looking and indicative of a desire to commute Rosemond's sentence in the future, rather than a declaration of a completed act of clemency. The court also noted the established practice of documenting acts of presidential clemency, which was consistently followed by President Trump throughout his presidency, and emphasized the constitutional separation of powers, which vests the clemency power exclusively in the President. View "Rosemond v. Hudgins" on Justia Law

In the case before the United States Court of Appeals for the Fourth Circuit, the defendant, Adonis Perry, was arrested in 2017 for possessing a firearm as a felon and for possessing marijuana after he was found with both during a traffic stop. While awaiting trial, Perry repeatedly tried to convince his girlfriend, a key witness for the government, to refuse to cooperate, leading to four witness-tampering and obstruction-of-justice charges. Perry was found guilty on all counts and was sentenced to 210 months and three years of supervised release. Perry appealed his conviction and sentence on several grounds, including that his Fourth, Fifth, and Sixth Amendment rights were violated, and that his sentence was substantively unreasonable.The Court of Appeals affirmed the conviction and sentence. They found that Perry was not unconstitutionally seized during the traffic stop, his girlfriend had authority to consent to the search of his phone, the charges against him should not have been dismissed due to the failure to preserve dashcam footage, the evidence supporting his convictions was sufficient, his convictions did not violate the prohibition against double jeopardy, his counsel was not constitutionally ineffective, and his sentence was not substantively unreasonable. View "US v. Perry" on Justia Law

In the case before the United States Court of Appeals for the Fourth Circuit, plaintiffs Scott Sonda and Brian Corwin, both mineral rights owners in West Virginia, challenged Senate Bill 694, which amended the State's oil and gas conservation law to permit the unitization of interests in horizontal well drilling units, even for nonconsenting mineral rights owners. The plaintiffs claimed that this law constituted a taking of their property and deprived them of property without due process, in violation of the Fifth and Fourteenth Amendments of the U.S. Constitution. The West Virginia Oil and Gas Conservation Commission filed a motion to dismiss, asserting that the plaintiffs lacked standing, that the Commission was immune under the Eleventh Amendment, and that the complaint failed to state a claim upon which relief could be granted.However, the district court abstained from ruling on the federal constitutional claims, citing the Pullman abstention doctrine, and ordered the proceeding stayed pending the outcome of a state court action that the plaintiffs may file. The Commission appealed the district court's abstention order.The Fourth Circuit Court of Appeals reversed the district court's order and remanded for further proceedings, noting that the district court had erred by applying the Pullman abstention doctrine without first ensuring it had jurisdiction. The court directed the district court to first address the Commission's argument challenging the plaintiffs' Article III standing. The court did not express an opinion about the merits of the standing issue or any others before the district court. View "Sonda v. West Virginia Oil & Gas Conservation Commission" on Justia Law