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

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

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