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

Willie Slocum, Jr. appealed the denial of his motion to correct, vacate, or set aside his convictions and sentences based on ineffective assistance of counsel. Slocum was indicted on two counts of drug conspiracy under 21 U.S.C. § 846, but argued that the two charged conspiracies were actually one. He claimed that he was punished twice for the same conspiracy in violation of the Fifth Amendment’s Double Jeopardy Clause, and that his trial counsel rendered ineffective assistance by failing to raise a double jeopardy challenge before the trial court. The district court denied his motion without ordering a response from the government or holding an evidentiary hearing.The United States Court of Appeals for the Fourth Circuit found that the district court erred in its decision. The appellate court determined that Slocum was indeed punished twice for a single conspiracy in violation of the Double Jeopardy Clause. However, the court noted that it was unclear whether trial counsel had a strategic reason for failing to raise a double jeopardy challenge. The court concluded that Slocum was entitled to an evidentiary hearing under 28 U.S.C. § 2255(b) where the performance of his trial counsel could be assessed. Therefore, the court vacated the district court’s denial of Slocum’s § 2255 motion and remanded for an evidentiary hearing on Slocum’s ineffective assistance claim. View "United States v. Slocum" on Justia Law

The case involves Douglas Damon Whitley, who was convicted of Hobbs Act robbery, federal carjacking, and a firearm offense in connection with his theft of a Peloton delivery van and its contents. Whitley was sentenced to concurrent 84-month prison terms for the robbery and carjacking convictions. On appeal, Whitley argued that his convictions and sentences for both offenses violated the Double Jeopardy Clause, as he believed Hobbs Act robbery to be a lesser included offense of carjacking. He also contended that there was insufficient evidence of the specific intent needed to convict him of federal carjacking.The case was first heard in the United States District Court for the Eastern District of Virginia. Whitley and his co-defendant, Kindal Robinson, pleaded not guilty and proceeded to a joint jury trial. The jury found them both guilty of all charges. Whitley then filed a motion for judgment of acquittal, arguing that his convictions for both Hobbs Act robbery and federal carjacking violated the Double Jeopardy Clause. He also argued that the government failed to produce sufficient evidence of his specific intent to cause death or serious bodily harm, an essential element of federal carjacking. The district court denied Whitley’s motion, determining that Hobbs Act robbery is not a lesser included offense of carjacking and that a reasonable jury could have found that Whitley had the specific intent to kill or seriously injure the van driver.The case was then reviewed by the United States Court of Appeals for the Fourth Circuit. The court disagreed with Whitley's arguments and affirmed the district court’s judgment. The court found that the jurisdictional elements of Hobbs Act robbery and federal carjacking differed, meaning that the two offenses were not the same under the Blockburger test. The court also found that there was sufficient evidence to support the jury’s finding that Whitley had the specific intent to cause death or serious bodily harm, thus rejecting Whitley's sufficiency challenge. View "US v. Whitley" on Justia Law

The case involves an incarcerated individual, Thomas Alexander, who alleged that two correctional officers violated his Fourth and Eighth Amendment rights by forcibly removing a contraband phone from his rectum in a prison shower. The officers, however, claimed that they found the phone in Alexander's pocket and used no more force than necessary. The incident was partially captured on video, but the footage did not conclusively resolve the dispute over where the phone was located.The United States District Court for the Eastern District of North Carolina granted summary judgment in favor of the officers. The court relied on the video footage, concluding that it discredited Alexander's version of events to such an extent that no reasonable jury could have believed him.On appeal, the United States Court of Appeals for the Fourth Circuit vacated the lower court's decision and remanded the case for further proceedings. The appellate court found that the video did not clearly depict what happened in the shower room and did not blatantly contradict Alexander's account. Therefore, the court held that the district court should have credited Alexander's version of events when considering the officers' summary judgment motion. The appellate court also concluded that, viewing the evidence in the light most favorable to Alexander, a reasonable jury could find that the officers violated Alexander's Fourth and Eighth Amendment rights. View "Alexander v. Connor" on Justia Law

The case involves Marshall and Tiffany Todman, who were evicted from their rental property in Baltimore. According to the Baltimore City Code, any personal property left in or around the premises after eviction is immediately considered abandoned, and the landlord takes ownership. The Todmans were evicted earlier than expected and lost their belongings under this ordinance. They sued the Mayor and City Council of Baltimore, alleging that the city had deprived them of their personal property without due process in violation of the Fourteenth Amendment. The district court agreed and granted summary judgment in favor of the Todmans.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court found that the Todmans were owed more process than they received and that the city was responsible for that failure of process. The court held that the city's Abandonment Ordinance violated the Todmans' constitutional rights by depriving them of their property without due process of law and that the city is liable for that violation. The court also dismissed the Todmans' conditional cross-appeal, which asked the court to review the district court's dismissal of their takings claim if the court found their due process claims lacked merit. View "Todman v. The Mayor and City Council of Baltimore" on Justia Law

The case involves Angel Cartagena, an inmate in the Virginia Department of Corrections (VDOC) prison system, who challenged the conditions of his 18-month confinement at the River North Correctional Center. Cartagena alleged that his confinement was too restrictive and caused him emotional distress and severe mental anguish, in violation of his First, Eighth, and Fourteenth Amendment rights, as well as statutory prohibitions against discrimination. VDOC officials had determined that Cartagena was seriously mentally ill and unable to function in the general prison population, so they assigned him to the VDOC’s Secure Diversionary Treatment Program (SDT Program) at the River North facility. Cartagena refused to comply with the treatment regimen prescribed for him and complained about the consequential restrictions of the Program.The district court granted the prison officials’ motion to dismiss Cartagena’s complaint, concluding that Cartagena had failed to state plausible claims for relief. The court found that Cartagena had not sufficiently alleged a deliberate indifference by prison officials to his condition, the deprivation of a constitutionally protected liberty interest, or discrimination because of his disability.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court found that Cartagena failed to demonstrate the required mens rea for an Eighth Amendment violation, as the prison officials had offered him treatment, which he refused. The court also found that Cartagena failed to adequately allege a cognizable liberty interest in his placement in the SDT Program, and therefore, the Due Process Clause requires no process related to his placement in the Program. Finally, the court concluded that Cartagena failed to plausibly allege that he was “otherwise qualified” for the benefits that he seeks and therefore to state a claim for discrimination under the Americans with Disabilities Act and the Rehabilitation Act. View "Cartagena v. Lovell" on Justia Law

The case involves 360 Virtual Drone Services LLC and its owner, Michael Jones, who sought to provide customers with aerial maps and 3D digital models containing measurable data. However, the North Carolina Board of Examiners for Engineers and Surveyors argued that doing so would constitute engaging in the practice of land surveying without a license, in violation of the North Carolina Engineering and Land Surveying Act. Jones and his company sued the Board, arguing that the restriction on their ability to offer these services without first obtaining a surveyor’s license violates their First Amendment rights.The district court granted summary judgment in favor of the Board. The court concluded that Jones had standing to challenge the statute based on his desire to create “two-dimensional and three-dimensional maps with geospatial data.” It also concluded that the Engineering and Land Surveying Act implicated the First Amendment. However, it found that the Act constituted “a generally applicable licensing regime that restricts the practice of surveying to those licensed” and primarily regulated conduct rather than speech, such that intermediate scrutiny applied. Finally, the court concluded that the Act survived intermediate scrutiny.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The appellate court concluded that the Act, as applied to the plaintiffs, was a regulation of professional conduct that only incidentally impacts speech. Therefore, it applied a more relaxed form of intermediate scrutiny that mandates only that the restriction be “sufficiently drawn” to protect a substantial state interest. The court found that the Act met this standard and therefore did not violate the plaintiffs' First Amendment rights. View "360 Virtual Drone Services LLC v. Ritter" on Justia Law

A group of parents in Montgomery County, Maryland, challenged the local school board's decision to include LGBTQ-inclusive books in the English Language Arts curriculum without providing parents notice or the option to opt their children out of exposure to these books. The parents, who held various religious beliefs, argued that the board's decision violated their rights under the Free Exercise and Due Process Clauses of the U.S. Constitution.The United States District Court for the District of Maryland denied the parents' motion for a preliminary injunction, which would have required the board to provide notice and an opt-out option. The parents appealed this decision to the United States Court of Appeals for the Fourth Circuit.The Fourth Circuit affirmed the district court's decision. The court found that the parents had not shown a likelihood of success on the merits of their claims, a necessary requirement for a preliminary injunction. Specifically, the court found that the parents had not provided sufficient evidence to show that the board's decision coerced them or their children to act or believe contrary to their religious faith. The court also found that the parents had not shown that their due process rights were likely to be violated. The court noted that the parents still had the right to instruct their children on their religious beliefs and to discuss the topics raised in the books with their children. View "Mahmoud v. McKnight" on Justia Law

Lonnie Billard, a former teacher at Charlotte Catholic High School (CCHS), sued the school for sex discrimination under Title VII after he was fired for his plans to marry his same-sex partner. The district court granted Billard's motion for summary judgment and denied CCHS's motion, which raised several affirmative defenses, both statutory and constitutional.The district court found that CCHS had indeed fired Billard because of his plans to marry his same-sex partner, which amounted to sex discrimination as defined by Title VII. The court rejected CCHS's affirmative defenses, including its interpretation of Title VII's religious exemption, its defense under the Religious Freedom Restoration Act, and its First Amendment defenses. The court also ruled on the ministerial exception, despite CCHS's waiver of that defense, and found that Billard did not satisfy the criteria for the ministerial exception.On appeal, the United States Court of Appeals for the Fourth Circuit reversed the district court's decision. The appellate court concluded that because Billard played a vital role as a messenger of CCHS's faith, he falls under the ministerial exception to Title VII. Therefore, the court instructed the district court to enter judgment for CCHS. View "Billard v. Charlotte Catholic High School" on Justia Law

Andre Ricardo Briscoe was involved in the purchase and sale of narcotics in Baltimore. He learned from a contact, Kiara Haynes, that Jennifer Jeffrey had received a large supply of heroin. Briscoe and Haynes decided to rob Jeffrey. Briscoe went to Jeffrey’s house, robbed her of at least 80 grams of narcotics, shot and killed her, and shot and killed her seven-year-old son, K.B., whom Briscoe feared might testify against him. Briscoe was arrested and initially charged with possession with intent to distribute narcotics, conspiracy to distribute narcotics, and possessing a firearm as a convicted felon. A later superseding indictment added three new counts: two counts of murder with a firearm during the commission of a drug trafficking crime and one count of killing a witness to prevent communication with law enforcement. After a twelve-day jury trial, Briscoe was convicted on all charges.The United States District Court for the District of Maryland denied Briscoe's motion to dismiss the indictment as barred by the statute of limitations, concluding that the indictment related back to the earlier filed information. The court also denied Briscoe's motion to suppress evidence obtained through the use of a cell site simulator, finding that the police had obtained a tracking order which authorized them to use the simulator. The court further found that the police had obtained consent to search the apartment where Briscoe was found and that their subsequent actions were part of a lawful protective sweep of the apartment.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court held that the government properly tolled the statute of limitations by filing an information within the five-year period and that the subsequent indictment related back to that filing. The court also held that the police had authority to use a cell site simulator to obtain Briscoe's location information and to search the apartment where he was found. The court rejected Briscoe's arguments that the government committed a Brady violation by failing to follow up on whether any footage was contained on a broken camera and that the government knowingly relied upon false testimony to secure his conviction. The court further held that the evidence was sufficient to convict Briscoe on all counts. View "United States v. Briscoe" on Justia Law

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