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

A West Virginia defendant was indicted in 2018 on multiple sexual offense charges involving a seven-year-old girl. Prior to trial, the court granted the defendant’s motions to exclude a video interview of the victim and records from her therapy sessions, limiting both the State and the defense from introducing certain hearsay evidence. During opening statements at the first trial, defense counsel referenced specific statements made by the victim in the excluded materials, suggesting an alternative perpetrator. The State objected after the opening statements, arguing that the defense had violated pretrial evidentiary rulings. The trial court found that the defense’s actions had gone “far afield” of its orders and, over the defendant’s objection, granted the State’s motion for a mistrial.The defendant moved to dismiss the indictment on double jeopardy grounds, arguing that the mistrial was not required by “manifest necessity.” The trial court denied the motion, finding that the defense had created the necessity for a mistrial. The Supreme Court of Appeals of West Virginia later affirmed, holding that the defendant’s right against double jeopardy was not violated because defense counsel’s conduct in opening statement created a manifest necessity for the mistrial. The defendant subsequently filed a federal habeas petition in the United States District Court for the Northern District of West Virginia, which granted relief, concluding that the defense had not violated any pretrial orders and that manifest necessity was lacking.On appeal, the United States Court of Appeals for the Fourth Circuit reversed the district court’s judgment. The Fourth Circuit held that, under the highly deferential standard of review required by AEDPA, the state court’s conclusion that manifest necessity justified the mistrial was neither contrary to nor an unreasonable application of clearly established Supreme Court precedent. The case was remanded with instructions to deny the habeas petition. View "Wood v. Straughn" on Justia Law

A Jamaican citizen who entered the United States on a work visa married a U.S. citizen and later experienced domestic violence from his spouse, who was eventually arrested. After his visa expired, removal proceedings were initiated, and an immigration judge ordered his removal. Under the Violence Against Women Act (VAWA), survivors of domestic violence have a one-year deadline to file a motion to reopen removal proceedings. On the last day of this period, the petitioner’s counsel attempted to file the motion electronically, but the system rejected it. When he tried to file in person, a court clerk refused to accept the paper copy, insisting it be filed electronically. After continued unsuccessful attempts, the motion was finally mailed and accepted, but after the deadline.The Immigration Judge denied the motion to reopen, finding it untimely and concluding that the petitioner did not provide sufficient proof he was prevented from timely filing. The Board of Immigration Appeals (BIA) affirmed, with the majority agreeing that the record did not support the claim of impeded filing and that no exception to the deadline applied. One BIA member dissented, noting clear evidence of repeated filing attempts thwarted by the court.The United States Court of Appeals for the Fourth Circuit reviewed both the Immigration Judge and BIA decisions. Applying de novo review to legal and constitutional questions and substantial evidence review to factual findings, the Fourth Circuit held that the record compelled the conclusion that the petitioner was prevented from timely filing. The court found this defect rendered the proceedings fundamentally unfair and prejudiced the petitioner’s case, thus violating his Fifth Amendment due process rights. The court granted the petition for review, reversed the BIA’s denial, and remanded for further proceedings. View "Burey v. Blanche" on Justia Law

A traveler arriving in the United States from Bolivia was subject to inspection by U.S. Customs and Border Protection at Washington Dulles International Airport. The officer requested that the traveler unlock his two iPhones, which he did. Within approximately two minutes, the officer accessed the photo galleries, including hidden folders, and discovered sexually explicit images of prepubescent girls. The traveler was subsequently arrested and indicted by a federal grand jury in the United States District Court for the Eastern District of Virginia on multiple counts relating to child pornography.The defendant moved to suppress the evidence obtained from the search of his phones, arguing that the search violated the Fourth Amendment. The district court held an evidentiary hearing, during which the officer explained her suspicions. The court denied the motion to suppress, finding that either individualized suspicion was present or, alternatively, that the officer acted in good faith. The defendant entered a conditional guilty plea to all counts, preserving his right to appeal the suppression ruling. He was sentenced to 18 years in prison and 25 years of supervised release.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed whether manual searches of cell phones at the border are “routine” and thus exempt from the requirement of individualized suspicion under the Fourth Amendment. The Fourth Circuit held that manual searches of cell phones at the border are routine border searches and do not require individualized suspicion, distinguishing such searches from forensic searches, which are nonroutine and require some level of individualized suspicion. The court affirmed the district court’s denial of the motion to suppress. View "US v. Cardozo" on Justia Law

Officers responding to reports of suspected drug activity at a public housing development in Asheville, North Carolina, began surveilling individuals frequenting the area. One individual, Jermaine Derrick Carson, Jr., was observed as a passenger in a vehicle whose driver had a suspended license. Weeks later, during a joint law enforcement operation targeting crime near downtown bars, officers recognized the same vehicle at a gas station and initiated a traffic stop before it returned to the housing complex. During the stop, officers detected the odor of marijuana and observed drug paraphernalia in the car. Carson was frisked and found to possess a loaded firearm.After Carson was indicted for possession of a firearm by a convicted felon in the United States District Court for the Western District of North Carolina, he moved to suppress the firearm, arguing that the traffic stop was unlawfully prolonged and that the frisk lacked reasonable suspicion. A magistrate judge held an evidentiary hearing, during which officers testified and body camera footage was reviewed. The magistrate judge recommended denial of the suppression motion, finding the officers had probable cause to search the vehicle after the detection of marijuana and that the frisk was lawful. The district court adopted the recommendation, denied the motion, and subsequently accepted Carson’s conditional guilty plea, sentencing him to 24 months imprisonment.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s decision, applying de novo review for legal questions and clear error for factual findings. The court held that the officers had independent reasonable suspicion—specifically, the detection of marijuana odor—which justified the extension of the stop and the search. Additionally, the frisk was permissible due to reasonable suspicion of illegal drugs in the vehicle. The Fourth Circuit affirmed the district court’s denial of Carson’s suppression motion. View "US v. Carson" on Justia Law

A South Carolina budget provision, known as the “Proviso,” prohibits public schools from using state funds to teach certain concepts related to race and sex. Several Black students, the South Carolina State Conference of the NAACP (SC NAACP), and author Ibram Kendi challenged the Proviso, alleging it led to the removal of an Advanced Placement African American Studies (AP AAS) course and one of Kendi’s books from school libraries. The students and SC NAACP asserted that eliminating the AP AAS course infringed upon students’ First Amendment right to receive information, while Kendi claimed the book’s removal constituted viewpoint discrimination. Plaintiffs further alleged that the Proviso was void for vagueness and violated the Equal Protection Clause.The United States District Court for the District of South Carolina dismissed the complaint for lack of Article III standing. The court concluded that the individual students did not allege a concrete injury as they had not actually enrolled in AP AAS, and found that even a student who had enrolled failed to establish that her injury was traceable to the Proviso rather than an unrelated curriculum review. The district court also held that Kendi’s injury was not redressable because the school district cited an alternative, unchallenged rationale for removing his book.The United States Court of Appeals for the Fourth Circuit affirmed in part, reversed in part, vacated in part, and remanded. It affirmed dismissal with respect to a student who had graduated and another who had not taken concrete steps to enroll in AP AAS. However, it held that SC NAACP adequately alleged standing for at least one member with an ongoing injury, and Kendi sufficiently alleged standing for his viewpoint discrimination claim. The court vacated dismissal of other claims and remanded for the district court to address unresolved standing and merits questions. View "South Carolina State Conference of the NAACP v. Weaver" on Justia Law

Kenneth Deal was appointed to the City of Monroe, North Carolina’s board of adjustment, a quasi-judicial municipal body responsible for handling certain appeals and permits. After completing one three-year term, he was reappointed to a second term. However, during this second term, the City Council voted to remove him from the board without cause or prior notice. Deal was not present at the meeting where the removal occurred, nor was he informed that his removal would be considered.Deal filed suit in the United States District Court for the Western District of North Carolina, alleging that the City violated his procedural due process rights when it deprived him of his board seat without notice or an opportunity to be heard. He sought relief under 42 U.S.C. § 1983 and requested a declaratory judgment to void his removal. Deal moved for partial summary judgment on liability, while the City sought summary judgment on all claims. The district court granted summary judgment in favor of the City, concluding that Deal did not have a constitutionally protected property interest in his board seat because the City Council retained discretion to remove board members at any time, with or without cause.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s summary judgment ruling de novo. The Fourth Circuit affirmed the district court’s decision, holding that Deal lacked a constitutionally protected property interest in his seat. The court reasoned that because the City had broad discretion under its code and state law to appoint, remove, or even abolish the board, Deal’s interest in his seat did not amount to a legitimate claim of entitlement protected by the Fourteenth Amendment. The court rejected Deal’s reliance on state cases and found that local discretion was dispositive, affirming the district court’s judgment. View "Deal v. City of Monroe" on Justia Law

An inmate at Red Onion State Prison in Virginia, who is a Sunni Muslim, requested accommodations to observe both the Ramadan fast and to maintain a diet prepared according to Jewish Kashrut law, as he sincerely believed both were religious requirements. The prison had an Orthodox Jewish Kosher Diet (OJKD) and a Common Fare menu, but in 2020 could not provide a version of the OJKD that also allowed for Ramadan fasting on short notice. The inmate was offered a choice between maintaining the OJKD without fasting or switching to the Common Fare menu to fast, but with restrictions on switching back. He tried to fast by saving OJKD meals for sunset, but this led to food poisoning. By 2021, the prison had created a Ramadan-compliant OJKD.The United States District Court for the Western District of Virginia granted summary judgment to the prison officials on all claims. The court held that the officials were protected by Eleventh Amendment immunity for damages in their official capacities and found that damages were not available under RLUIPA. The court also found the request for injunctive relief moot after the policy change. The remaining claims for damages under the Constitution were dismissed on qualified immunity grounds, as the court determined the rights were not clearly established or that there was no constitutional violation.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the denial of a discovery motion and agreed that injunctive and declaratory relief were moot, and that summary judgment was proper on the Establishment Clause and Equal Protection claims. However, the Fourth Circuit held that the inmate’s right to a religious diet consistent with his sincerely held beliefs was clearly established and that the district court erred by failing to apply the proper standard to his Free Exercise claim. The court reversed in part, vacated in part, and remanded for the district court to consider whether the failure to accommodate in 2020 was reasonably related to legitimate penological interests under the Turner standard. View "Roberts v. Engelke" on Justia Law

Police officers responded to an anonymous 911 call reporting that individuals inside a white Mercedes sedan parked near the pool area of an apartment complex might be selling or possessing narcotics. The officers received this information through their department’s computer-aided dispatch system. Upon arrival, the officers stopped their marked police vehicles in the roadway, positioning themselves such that one car was partially in front of the Mercedes and another behind. They exited their vehicles, approached the Mercedes, and immediately smelled marijuana. Williams, the defendant, admitted to smoking marijuana, after which he and the other occupants were directed to exit the vehicle. In the ensuing search, officers found a handgun, and Williams admitted ownership.The United States District Court for the Western District of North Carolina denied Williams’ motion to suppress the evidence found during the search. The district court found that Williams was not seized when the officers stopped their cars, reasoning that there was physical room for him to leave and a reasonable person would have felt free to do so. The court further concluded that the officers had reasonable suspicion to seize Williams after smelling marijuana and that the search was supported by probable cause. Williams was subsequently convicted of being a felon in possession of a firearm after a bench trial.On appeal, the United States Court of Appeals for the Fourth Circuit held that Williams was seized for Fourth Amendment purposes when the officers blocked his vehicle with their marked patrol cars, as a reasonable person would not have felt free to leave under the circumstances. The court further held that the officers lacked reasonable suspicion to justify this seizure based solely on the anonymous tip and the fact the encounter occurred in a high-crime area. The court reversed the district court’s denial of the suppression motion, vacated Williams’ conviction, and remanded for further proceedings. View "US v. Williams" on Justia Law

After a robbery at a Chinese restaurant owner’s home in South Carolina, three masked men assaulted the family and stole their earnings. The victims could not identify the attackers, and no forensic evidence was left behind. Weeks later, a tip led investigators to three suspects, including K.C. Langford, who was arrested and indicted along with two co-defendants. Langford’s trial was delayed for nearly two years, partly due to difficulties in securing an interpreter for the victims and because one co-defendant, Alvin, initially refused to testify after being pressured by Langford and another defendant. The trial eventually proceeded, with Alvin testifying against Langford. Langford was convicted of criminal conspiracy, armed robbery, first-degree burglary, and kidnapping.After conviction, Langford appealed to the South Carolina Supreme Court, which affirmed his convictions. The court found that although the prosecutor’s control over the trial docket violated the state constitution, Langford suffered no prejudice from it. Applying the Barker v. Wingo framework, the court determined the nearly two-year delay did not violate Langford’s Sixth Amendment right to a speedy trial, considering the reasons for the delay and lack of prejudice to Langford’s defense. Langford’s postconviction relief application in the Court of Common Pleas was denied, as the court found no ineffective assistance of counsel regarding a hearsay issue in the trial. The South Carolina Court of Appeals denied certiorari. Langford’s co-defendant, Bryan, received postconviction relief in a separate proceeding.Langford then sought federal habeas corpus relief in the United States District Court for the District of South Carolina, which granted the writ on claims of speedy trial violation and ineffective assistance of counsel. The United States Court of Appeals for the Fourth Circuit reversed, holding that the South Carolina courts’ decisions were not unreasonable applications of clearly established federal law nor based on unreasonable factual determinations. The Fourth Circuit ordered reversal of the district court’s grant of habeas corpus. View "Langford v. Stonebreaker" on Justia Law

A maximum security prison in Virginia faced a surge in near-fatal drug overdoses among inmates in May and June 2023. In response, prison officials implemented a policy requiring every inmate who accessed the no-contact video visitation rooms to undergo a strip search both before and after each visit. Marcus Ingram, an inmate who used these rooms to call his wife, was subjected to 26 strip searches in a single month as a result. The policy was based on uncorroborated tips from inmates suggesting that contraband was being circulated through these rooms, despite no evidence of any actual contraband being found in connection with the video visitation rooms.Ingram filed a pro se lawsuit under 42 U.S.C. § 1983 in the United States District Court for the Western District of Virginia against the prison warden and the officer who conducted most of the searches. He alleged violations of his Fourth and Eighth Amendment rights, along with a claim of supervisory liability against the warden. The district court granted summary judgment to the defendants on the basis of qualified immunity, holding that the searches were reasonable due to the drug problem and that there was no evidence of harassment or intimidation. The court also dismissed the supervisory liability claim as there was no underlying constitutional violation.On appeal, the United States Court of Appeals for the Fourth Circuit assumed without deciding that some of the strip searches may have violated the Fourth Amendment. However, it held that the right at issue was not clearly established at the time, as neither controlling precedent nor a consensus of persuasive authority made the unconstitutionality of the policy beyond debate. Therefore, the Fourth Circuit affirmed the district court’s grant of qualified immunity to the defendants. View "Ingram v. Hamilton" on Justia Law