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

After defendant pled guilty to federal drug trafficking, the district court held that his prior state convictions for marijuana possession, for which he faced no possibility of imprisonment, was for an offense "punishable by imprisonment for more than one year," triggering a sentencing enhancement under the Controlled Substances Act, 21 U.S.C. 841. This enhancement doubled defendant's minimum sentence. The court affirmed in an unpublished opinion. The Supreme Court vacated that judgment and remanded the case to the court for "further consideration in light of Carachuri-Rosendo v. Holder." A panel of the court then held that Carachuri did not require any change in the court's prior holding. The court voted to rehear the case en banc and subsequently vacated defendant's sentence and remanded for further proceedings.

Defendant conditionally plead guilty to one count of possession of a firearm by a drug user and one count of possession of marijuana where he had moved to suppress the gun and drugs on the ground that the officer's frisk was unlawful. At issue was whether evidence seized during a street encounter between law enforcement and citizens was properly admitted into evidence during a subsequent criminal prosecution. The court held that the seizure of the evidence did not comport with settled Fourth Amendment principles, and therefore, the court reversed the district court's denial of defendant's motion to suppress and remanded for further proceedings.

Defendant pled guilty to maintaining a place at his residence for the purpose of manufacturing, distributing, and using cocaine base. The United States subsequently appealed the district court's grant of defendant's motion for a reduced sentence pursuant to 18 U.S.C. 3582(c)(2), arguing that the district court lacked the authority to grant such relief because defendant's sentence was not "based on" a sentencing range that was subsequently lowered but, rather, on his plea agreement entered pursuant to Federal Rule of Civil Procedure 11(c)(1)(C). The court held that, in light of the Supreme Court's recent opinion in Freeman v. United States, defendant's agreement did not satisfy the limited exception recognized in Justice Sotomayor's concurrence. Consequently, the plea agreement was the foundation for the term of imprisonment imposed and the district court lacked the authority under section 3582(c)(2) to grant defendant's motion for a reduced sentenced. Accordingly, the court reversed the district court's order granting defendant's motion.

Appellant challenged the grant of summary judgment for her employer when her boss forcibly kissed her, fondled her leg, propositioned her, asked sexually explicit questions, described sexual activities he wished to perform, and then, after she spurned the advances and filed a harassment complaint, fired her. The court held that because those allegations were sufficient to make out claims of hostile work environment, quid pro quo harassment, and retaliation, the court vacated and remanded for further proceedings.

Defendant was convicted of armed robbery and, after a renewed motion for a judgment of acquittal, the district court overturned his conviction based on insufficient evidence. At issue was what constituted a proper inference for a jury to draw when making determinations of guilt. The court held that the government failed to produce sufficient "identity" evidence placing defendant at the robbery and relied on unsubstantiated, unscientific inferences to bolster its minimal evidence. Therefore, the court held that no reasonable jury could find defendant guilty beyond a reasonable doubt based on the evidence presented at trial. Accordingly, the court affirmed the district court's judgment.

Plaintiffs filed suit against the county, alleging that the December 17 prayer at the Forsyth County Board of Commissioners (Board) meeting represented one instance of the Board's broader practice of sponsoring sectarian opening prayers at its meetings. After conducting a thorough review of the factual record, the district court concluded that the Board's legislative prayer policy violated the Establishment Clause by advancing and endorsing Christianity to the exclusion of other faiths. The court held that the district court's ruling accorded with both Supreme Court precedent and the court's own precedent where those cases established that in order to survive constitutional scrutiny, an invocation must consist of the type of nonsectarian prayers that solemnize the legislative task and seek to unit rather than divide. Accordingly, the court affirmed the judgment of the district court.

Defendant was charged with possession of a firearm and ammunition by a convicted felon. At issue was whether the good-faith exception to the exclusionary rule permitted the admission of evidence obtained by a police officer who conducted a search in objectively reasonable reliance on binding appellate precedent that was later overruled. The Supreme Court resolved this issue in Davis v. United States, holding that "searches conducted in objectively reasonable reliance on binding appellate precedent are not subject to the exclusionary rule." Because the district court's decision in this case granting the motion to suppress by defendant was inconsistent with Davis, the court vacated the district court's judgment and remanded for further proceedings.

Plaintiff sued defendants under 42 U.S.C. 1983, contending that in disciplining her for a MySpace.com webpage, which was largely dedicated to ridiculing a fellow student, defendants violated her free speech and due process rights under the First and Fourteenth Amendments. Plaintiff alleged, among other things, that defendants were not justified in regulating her speech because it did not occur during a "school-related activity," but rather was "private out-of-school speech." The court held that defendants' imposition of sanctions was permissible where plaintiff used the Internet to orchestrate a targeted attack on a classmate and did so in a manner that was sufficiently connected to the school environment as to implicate defendants' recognized authority to discipline speech which "materially and substantially interfere[d] with the requirements of appropriate discipline in the operation of the school and collid[ed] with the rights of others." Accordingly, the court affirmed the district court's grant of summary judgment in favor of defendants.

This case stemmed from a federal grand jury indictment charging defendant with possession with intent to distribute Oxycodone where defendant moved to suppress the physical evidence seized following a search and certain statements he made to law enforcement officers. At issue was whether the district court properly granted the motion to suppress. The court held that reasonable suspicion was not present to turn a routine traffic stop into a drug investigation. Furthermore, under an extremely deferential standard of review, the court rejected the government's challenge to the district court's finding that defendant's consent was involuntary. Accordingly, the judgment was affirmed.

Employees of the Maryland Department of Public Safety and Correctional Services filed suit against defendants, alleging principally that the searches conducted on them as a result of a portable ion scanning machine, which was capable of detecting minute amounts of controlled substances, violated their Fourth Amendment rights. The district court held that defendants were entitled to qualified immunity and dismissed the suit. The court affirmed and held that, although it was clearly established that intrusive prison employee searches required reasonable suspicion, it was far from clear that the devices at issue could not meet that standard. The court further held that because no clearly established federal law placed the officers on notice that fighting contraband in the prison environment in this manner was unlawful, the district court correctly held that immunity attached.