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

Defendant and another person were trespassing in a public park after it closed. When officers saw their car, they investigated the trespass. The officers found a gun abandoned in a nearby trash can, so they frisked Defendant and questioned him about the gun. After first denying the gun was his, Defendant admitted he was a felon and that he owned the gun. The officers arrested Defendant, who was then federally indicted for being a felon in possession of a firearm. He sought to suppress his incriminatory statements, arguing that his statements in the park were inadmissible because he was “in custody” under Miranda, and so the officers needed to read him his Miranda rights before questioning him about the gun. The district court disagreed, and Defendant pleaded guilty.   The Fourth Circuit affirmed. The court explained that Miranda warnings are not required every time an individual has their freedom of movement restrained by a police officer. Nor are they necessarily required every time “questioning imposes some sort of pressure on suspects to confess to their crimes.” Instead, they are required only when a suspect’s freedom of movement is restrained to the point where they do not feel free to terminate the encounter, and the circumstances reveal “the same inherently coercive pressures as the type of station house questioning at issue in Miranda.” The court found that, in this case, no such pressures existed. View "US v. Ervin Leggette" on Justia Law

A real estate development company PEM Entities LLC (PEM), asserts a North Carolina county violated the Federal Constitution and state law by imposing new rules for getting water and sewage services. The district court dismissed the complaint, concluding the company lacked standing to bring its takings and due process claims, its equal protection claim was too insubstantial to raise a federal question, and the court should not exercise jurisdiction over the state law claims once the federal claims were dismissed.   The Fourth Circuit affirmed. The court explained that without a constitutionally protected property interest, PEM’s takings and due process claims fail as a matter of law. Accordingly, the court affirmed the district court’s dismissal of PEM’s takings and due process claims because they fail to state a claim on which relief can be granted. Further, the court concluded the district court was right to dismiss PEM’s equal protection claim but should have done so for failure to state a claim rather than lack of jurisdiction. Thu, having concluded the district court correctly dismissed all of PEM’s federal claims, the court saw no abuse of discretion in the district court’s decision not to exercise supplemental jurisdiction over the state law claims. View "PEM Entities LLC v. County of Franklin" on Justia Law

Plaintiffs brought suit against Weinstein Management Co., Inc., and WMCI Charlotte XIII, LLC (collectively, Defendants). In relevant part, Plaintiffs alleged that Defendants violated the North Carolina Residential Rental Agreements Act (RRAA), and the North Carolina Debt Collection Act (NCDCA), by charging them out-of-pocket costs for summary ejectment proceedings, including filing fees, service fees, and attorney’s fees (collectively, out-of-pocket expenses). The district court granted Defendants’ motion for judgment on the pleadings on these claims, and Plaintiffs appealed. At issue on appeal is whether he 2021 amendment applies retroactively without violating vested rights, thereby extinguishing Plaintiffs’ RRAA and NCDCA claims.   The Fourth Circuit affirmed. The court explained that here, the 2021 amendment’s text provides that it “is effective when it becomes law and is intended to apply retroactively to all pending controversies as of that date.” The court wrote that given this explicit language from the General Assembly, the intent of the legislature to apply the 2021 amendment retroactively could not be clearer. The North Carolina Supreme Court has repeatedly held that the General Assembly cannot retroactively invalidate common-law rights, which Plaintiffs do not seek to vindicate here. Therefore, the district court was not precluded from applying the 2021 amendment retroactively. View "Tiffany Bass v. Weinstein Management Co., Inc." on Justia Law

Appellee filed suit against two Transportation and Security Administration (“TSA”) officers, (collectively “Appellants”), alleging they violated the First Amendment by prohibiting Appellee from recording a pat-down search and the Fourth Amendment by seizing Appellee and seizing and searching his cell phone. To state a cause of action for damages, Appellee brought his claims pursuant to Bivens v. Six Unknown Named Agents of the Federal Bureau of Narcotics, 403 U.S. 388 (1971). Appellants moved to dismiss, challenging Appellee’s reliance on Bivens and also asserting qualified immunity as to Appellee’s First Amendment claim. The district court denied Appellants’ motion, recognizing that both claims presented new Bivens contexts but finding that no special factor counseled hesitation in extending Bivens as to either claim.   The Fourth Circuit disagreed with the district court and concluded that Bivens remedies are unavailable in this case. The court explained that as “even a single sound reason to defer to Congress” will be enough to require the court refrain from creating a Bivens remedy, we decline to extend an implied damages remedy pursuant to Bivens against Appellants based on the existence of an alternative remedial structure and/or the interest of national security. And since Appellee has presented no cognizable claim for damages, we need not address Appellants’ qualified immunity defense as to Appellee’s First Amendment claim. Therefore, the court reversed the district court’s denial of Appellants’ motion to dismiss and remanded with instructions to dismiss. View "Dustin Dyer v. Shirrellia Smith" on Justia Law

Section 20.5 of North Carolina’s 2017 Farm Act contains provisions making it illegal to enter into two types of contractual agreements: (1) any settlement agreement conditioned on an agricultural producer’s union affiliation (the Settlement Provision) and (2) any agreement that would require an agricultural producer to process dues checkoffs for its farmworker-employees (the Dues Provision). The Farm Labor Organizing Committee and others (collectively, FLOC) contend that these prohibitions violate the First Amendment, Fourteenth Amendment, and 42 U.S.C. Section 1981. FLOC initiated this action against the Attorney General of North Carolina and the Governor of North Carolina (collectively, the State). The district court held that the Settlement Provision violated the Constitution and so enjoined it, but upheld the constitutionality of the Dues Provision, and then held that neither provision violated Section 1981.   The Fourth Circuit reversed the judgment of the district court as to the Settlement Provision and vacated the accompanying injunction, but affirmed in all other respects. The court explained that a rational basis supports Section 20.5. Agriculture is North Carolina’s largest industry, which makes it a subject of great interest for state legislators. The state also embraces its right-to-work policies and has worked repeatedly to strengthen them. In addition to these general bases for enacting Section 20.5, both challenged provisions respond to discrete legislative concerns. Further, the Settlement Provision prohibits parties from conditioning a settlement agreement on an agricultural producer’s union affiliation. Thus, the court rejected the broad reading advanced by FLOC and adopted by the district court that this statutory provision bars any settlement agreement between an agricultural producer and labor union. View "Farm Labor Organizing Committee v. Joshua Stein" on Justia Law

Plaintiff’s estate sued the Virginia Department of Corrections (“Department”) and several prison officials under 42 U.S.C. Section 1983 and Virginia law, alleging that they violated the Eighth Amendment and state law by failing to provide Plaintiff treatment for his chronic hepatitis C until it was too late.   Defendants in this appeal are Dr. A and Dr. W. Plaintiff alleges that Dr. A designed treatment guidelines for inmates with hepatitis C that unconstitutionally excluded Plaintiff from receiving treatment. Plaintiff also alleges that Dr. W failed to follow those guidelines and committed both medical malpractice and Eighth Amendment violations in denying him appropriate treatment. Defendants unsuccessfully moved for summary judgment, alleging that they were protected by qualified immunity and, on Dr. W’s part, derivative sovereign immunity.   The Eighth Circuit reversed the district court’s denial of sovereign immunity to Dr. W and denial of qualified immunity to Dr. A but affirm its denial of qualified immunity to Dr. W. The court declined to hold that Dr. A was clearly on notice that he should have ordered the Department’s primary care providers to prescribe this novel treatment rather than referring patients to specialists for treatment.  Further, the court explained a prisoner’s purported right not to be subjected to a treatment regimen that prioritized antiviral treatment to prisoners with the most advanced levels of fibrosis was not clearly established when Dr. A designed the Guidelines in 2015. Moreover, three of the four factors strongly weigh in favor of sovereign immunity, and one only moderately weighs against it. Therefore, the court concluded that the district court erred by rejecting Dr. W’s sovereign-immunity defense. View "Jacob Pfaller v. Mark Amonette" on Justia Law

Plaintiff, an inmate at U.S. Penitentiary Lee in western Virginia, commenced this action pro se against officials and employees of the Federal Bureau of Prisons, seeking monetary damages and other relief against Defendants, based on the manner in which he was treated in prison and the conditions of his confinement. Defendants filed a motion to dismiss, arguing, as relevant here, that Plaintiff’s claims were not cognizable under Bivens. The district court granted Defendants’ motion and dismissed Plaintiff’s action.   The Fourth Circuit affirmed. The court concluded that the inmate’s claim is, under the applicable standard, different from any Supreme Court decision finding a Bivens cause of action and that the relief he seeks in this new context should be provided by Congress, if at all. The court wrote its conclusion is based on the broad nature of the inmate’s claim and the separation-of-powers implications of recognizing a Bivens cause of action in the new context of his claim. View "Raymond Tate v. D. J. Harmon" on Justia Law

A jury convicted Defendant of various offenses relating to his leadership of a drug-trafficking ring, including a charge of distribution of fentanyl resulting in death. On appeal, Defendant advanced three main arguments. First, he contends he was denied his right to a speedy trial under the Sixth Amendment and 18 U.S.C. Section 3161. Second, he argued the government failed to prove that fentanyl was the but-for cause of the victim’s death and that the district court erred in denying his proposed instruction on but-for causation. Finally, he challenged the sufficiency of the evidence supporting his other convictions.   The Fourth Circuit affirmed. The court first concluded that the eight-month period between the filing of the indictment and the appearance of Defendant’s codefendant was a “reasonable period of delay” that the district court properly excluded under the Act. Next, the court wrote that on balance, the four constitutional speedy-trial factors weigh in the government’s favor. Thus the court held that the district court didn’t err in denying Defendant’s motion. Further, the court concluded that the jury could have found that “the [fentanyl] was not only a necessary, but-for cause of the death, but it was also independently sufficient, by itself, to cause the victim’s death, even without the influence of any other factors.” As such, while this case may have been more appropriately tried under a but-for causation theory, the court found no reversible error on Count Ten. View "US v. Terrick Robinson" on Justia Law

Defendant appeals the district court’s order denying relief on her 28 U.S.C. Section 2255 motion to vacate, set aside, or correct her sentence. Defendant claimed that her trial counsel rendered ineffective assistance by failing to move to suppress information obtained from a search warrant that relied, in part, on the Government’s warrantless procurement of certain data from her cell phone service provider.   The Fourth Circuit affirmed. The court explained that because the Government relied in good faith on court orders issued in accordance with the Federal Stored Communications Act (“SCA”), 18 U.S.C. Section 2703 et. seq., did not request the data in its subpoenas, and the use of a subpoena to obtain the data was lawful at the time; the court held the district court’s admission of the challenged evidence must be sustained. Thus, any motion to suppress filed before Defendant’s trial would not have been meritorious. View "US v. Gloria Taylor" on Justia Law

Respondent has long struggled with mental illness and a proclivity to violent outbursts. In 2017, Williams assaulted a security guard in Portland, Oregon—a federal crime because it happened at a Social Security office. Respondent pleaded guilty and was sentenced to just over four years in prison, to be followed by three years of supervised release. Federal prisoners on the cusp of being released may be civilly committed if they are “presently suffering from a mental disease or defect as a result of which [their] release would create a substantial risk” to the person or property of others. Here, the primary question is whether—in making such a risk assessment—a court must consider any terms of supervision that would govern the prisoner’s conduct post-release.   The Fourth Circuit held that a court must consider any terms of supervision that would govern the prisoner’s conduct post-release. Thus, because the record offers no assurances the district court appropriately considered the terms of Respondent’s supervised release before ordering him committed, the Fourth Circuit vacated the district court’s order and remanded for further proceedings. View "US v. Nathaniel Williams" on Justia Law