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

Stephen Bryant was sentenced to death by a South Carolina state court. During postconviction proceedings, Bryant filed a new application for relief, claiming his execution would violate the Eighth Amendment due to his intellectual disabilities, as defined in Atkins v. Virginia and Hall v. Florida. Later, Bryant sought to amend his application to include a claim that he suffers from fetal alcohol spectrum disorder (FASD) and that executing individuals with FASD should also be prohibited under the Eighth Amendment. The state postconviction court denied this request, ruling it was both impermissibly successive and filed too late.Bryant's initial appeal to the South Carolina Supreme Court, which focused on a single claim of evidentiary error, was denied. He then sought post-conviction relief on several grounds, none of which included the Eighth Amendment claim. The state trial court denied these claims, and the South Carolina Supreme Court denied discretionary review. Bryant subsequently filed for federal habeas corpus relief, which was stayed to allow him to exhaust state remedies. He filed two new applications in state court, one of which was allowed to proceed on the intellectual disability claim but not on the FASD claim. The state trial court ultimately denied the intellectual disability claim on its merits.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the state trial court's refusal to permit Bryant to amend his application to add the FASD claim rested on state procedural grounds that were independent of federal law and adequate to bar federal habeas review. The Fourth Circuit affirmed the district court's denial of habeas relief, concluding that Bryant's FASD claim was procedurally defaulted and could not be considered on its merits. View "Bryant v. Stirling" on Justia Law

Curtis Wells parked his car near Arlington Cemetery and was noticed by Officer Armstrong due to his animated gestures while on a phone call. Armstrong approached Wells and discovered that his car had an expired registration. Arlington County police were called, and they found that Wells did not have a driver's license and had weapons in his car. The police decided to tow Wells's car and conducted an inventory search, which revealed various weapons and tactical gear, including a ballistic plate carrier. Wells was sent home, but further investigation suggested that the plate might have been stolen from the Army. Nine days later, Wells was arrested for receiving stolen property.In the United States District Court for the Eastern District of Virginia, Wells brought state and federal claims against various officers and entities, alleging Fourth and Fifth Amendment violations, among other claims. The district court dismissed all his claims, reasoning that the officers were protected by qualified immunity and that Wells had not plausibly alleged the necessary elements for his state tort claims.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's dismissal. The court held that the officers' actions were protected by qualified immunity because Wells did not have a clearly established right against the officers' conduct. The court found that the initial approach by Officer Armstrong was justified under the community-caretaking exception, the inventory search of Wells's car was conducted according to standard procedures, and Wells had consented to the safekeeping of his property. Additionally, the court held that Wells's Second Amendment claims failed because the right to public carry was not clearly established in 2020. The court also dismissed Wells's state law claims, finding that he had not plausibly alleged the necessary elements for false imprisonment or malicious prosecution. View "Wells v. Fuentes" on Justia Law

Courthouse News Service, a news organization, sought remote online access to civil court records from the Circuit Court for Prince William County, Virginia, similar to the access granted to Virginia attorneys. Virginia law prohibits the clerk from providing such access to non-attorneys. Courthouse News sued, claiming this restriction violated its First Amendment and Equal Protection rights.The United States District Court for the Eastern District of Virginia dismissed Courthouse News's Equal Protection claim and granted summary judgment for the defendants on the First Amendment claims. The court found the restrictions to be content-neutral time, place, and manner regulations justified by the state's interests in the orderly administration of justice and protecting sensitive personal information.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court's ruling on the First Amendment and Equal Protection claims, holding that the access restriction was a content-neutral regulation narrowly tailored to serve significant governmental interests. The court found that the restriction did not violate the First Amendment as it provided ample alternative channels for accessing court records and did not burden more access than necessary. The court also concluded that the restriction did not violate the Equal Protection Clause for the same reasons it passed First Amendment scrutiny.However, the court vacated the district court's ruling on the Dissemination Restriction claim, finding that Courthouse News lacked standing to challenge it since the restriction only applied to those with remote access, which Courthouse News did not have. The case was remanded for the district court to dismiss this claim without prejudice. View "Courthouse News Service v. Smith" on Justia Law

Danny Fox, an active-duty servicemember, purchased a property in Norfolk, Virginia, in 2015. The City of Norfolk determined the property was unsafe and uninhabitable, repeatedly notifying Fox of building code violations. Despite these notices, Fox did not make the necessary repairs. In December 2018, the city demolished the house, deeming it a public nuisance. Fox subsequently sued the city, claiming inverse condemnation, among other things, arguing the property was not a nuisance and that the city's actions were pretextual to increase its tax base.The United States District Court for the Eastern District of Virginia granted summary judgment in favor of the city. The court held that Fox's federal constitutional claims were barred by the statute of limitations. It also ruled that Fox's inverse condemnation claim failed because, whether or not the property was a nuisance, he could not demonstrate the city's public use requirement. The court found no evidence to support Fox's claim that the city's actions were pretextual.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The appellate court agreed that Fox's inverse condemnation claim failed regardless of whether the property was a nuisance. If the property was a nuisance, the city had the authority to abate it without compensation. If it was not a nuisance, Fox could not show a public use, a necessary element for an inverse condemnation claim. The court also found that Fox provided no evidence to support his pretext argument. Thus, the court affirmed the district court's grant of summary judgment for the city. View "D.A. Realestate Investment, LLC v. City of Norfolk" on Justia Law

David Shanton, Sr. was involved in two armed bank robberies in Hagerstown, Maryland, shortly after completing a 20-year sentence for a previous bank robbery. During the first robbery, Shanton threatened to kill anyone who called the police and pointed a shotgun at a deputy sheriff while fleeing with nearly $34,000. He was apprehended during the second attempted robbery. Shanton was indicted and convicted on multiple counts, including armed bank robbery, discharging and brandishing a firearm during a crime of violence, and possessing a firearm as a felon.The United States District Court for the District of Maryland sentenced Shanton to 188 months for each armed bank robbery and firearm possession conviction, to be served concurrently, plus consecutive terms for the firearm offenses, totaling 608 months. Shanton's sentence was enhanced under the Armed Career Criminal Act (ACCA) due to his prior convictions, including Maryland robbery. Shanton did not initially object to the enhancement. On direct appeal, the Fourth Circuit affirmed his convictions and sentence.Shanton later filed a motion under 28 U.S.C. § 2255, challenging the constitutionality of his ACCA-enhanced sentences based on the Supreme Court's decision in Samuel Johnson v. United States, which invalidated the ACCA's residual clause. The district court allowed Shanton to supplement his motion, arguing that his Maryland robbery convictions no longer qualified as violent felonies under ACCA's elements clause. The district court rejected this argument, relying on Fourth Circuit precedent, and denied the motion but issued a certificate of appealability.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's judgment. The court held that Maryland robbery qualifies as a violent felony under ACCA's elements clause, consistent with prior Fourth Circuit decisions and the Supreme Court's ruling in Stokeling v. United States. The court concluded that Maryland robbery involves the use of force against a person, meeting the ACCA's definition of a violent felony. View "United States v. Shanton" on Justia Law

Charles Pittman pleaded guilty to violating a federal law that criminalizes burning or attempting to burn buildings owned by institutions that receive federal funding. He was charged with aiding and abetting others in maliciously damaging and destroying the Market House, a building owned by the City of Fayetteville, which receives federal financial assistance. During his plea hearing, Pittman confirmed his understanding of the charges and admitted to committing acts constituting the elements of the crime.The United States District Court for the Eastern District of North Carolina accepted Pittman's guilty plea and later sentenced him to 60 months of imprisonment. Before sentencing, Pittman moved to dismiss Count 1, arguing that the statute required a nexus between the federal financial assistance and the damaged property, and that the criminal information failed to allege such a nexus. He also argued that the City of Fayetteville is not an "institution or organization" under the statute. The district court denied the motion to dismiss.The United States Court of Appeals for the Fourth Circuit reviewed the case. Pittman argued that his conduct did not violate the statute and that the statute was unconstitutional as applied to him. The court held that Pittman waived his statutory construction arguments by pleading guilty, as a guilty plea admits that the conduct violated the statute. The court also found that Pittman's as-applied constitutional challenge was forfeited because he did not timely raise it before the district court, and he failed to show plain error.The Fourth Circuit affirmed the district court's judgment, holding that Pittman's guilty plea waived his statutory arguments and that his constitutional challenge was both forfeited and failed to meet the plain-error standard. View "United States v. Pittman" on Justia Law

Johnnie Franklin Wills, a state prisoner, filed a habeas petition challenging his life sentence under West Virginia’s recidivist statute. He argued that the judicially crafted test for determining whether a recidivist life sentence is proportional to the crime is unconstitutionally vague. Wills was convicted of grand larceny and conspiracy to commit grand larceny in 2016, and due to his prior eight felony convictions, he was sentenced to life imprisonment with parole eligibility after fifteen years under the recidivist statute.The West Virginia courts denied Wills relief, stating that the void-for-vagueness doctrine does not apply to their proportionality test. The Supreme Court of Appeals of West Virginia affirmed this decision, distinguishing Wills’s case from the U.S. Supreme Court’s decisions in Johnson v. United States and Sessions v. Dimaya, which invalidated certain statutory provisions as unconstitutionally vague. The state court maintained that the proportionality test was clear and did not fall under the same scrutiny as the statutes in Johnson and Dimaya.Wills then filed a federal habeas petition under 28 U.S.C. § 2254, which the United States District Court for the Northern District of West Virginia also denied. The district court found that the state court’s decision was not contrary to or an unreasonable application of clearly established federal law. The court noted that the proportionality test serves as a judicial limitation on the recidivist statute, unlike the statutory mandates in Johnson and Dimaya.The United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The court held that the state court’s ruling was not an unreasonable application of clearly established federal law, as the U.S. Supreme Court has not extended the void-for-vagueness doctrine to judicially crafted proportionality tests. Therefore, Wills’s habeas petition was denied. View "Wills v. Pszczolkowski" on Justia Law

Three plaintiffs, including a Virginia citizen, a Virginia entity, and an out-of-state entity, challenged Virginia Senate Bill 903, which regulates the retail sale of hemp products based on their total tetrahydrocannabinol (THC) concentration. The plaintiffs argued that the 2018 Farm Bill, which legalized hemp with a delta-9 THC concentration of no more than 0.3%, preempts the more restrictive Virginia law. They also claimed that the Virginia law violates the Dormant Commerce Clause of the U.S. Constitution.The United States District Court for the Eastern District of Virginia denied the plaintiffs' motion for a preliminary injunction. The court found that the plaintiffs were unlikely to succeed on their preemption arguments, as the 2018 Farm Bill does not expressly preempt state laws regulating hemp more stringently. The court also concluded that the plaintiffs did not sufficiently allege that they were licensed processors under Virginia law, thus lacking standing to challenge the provision preventing Virginia processors from selling hemp products to others who would use them in violation of the total THC standard. Additionally, the court rejected the plaintiffs' Dormant Commerce Clause claims, finding no evidence that the Virginia law discriminates against or unduly burdens interstate commerce.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court agreed with the district court that the plaintiffs lacked standing to challenge the sales restriction provision, as they did not allege sufficient facts showing they were licensed processors. The court vacated the district court's order regarding this claim and remanded with instructions to dismiss it without prejudice. However, the court affirmed the district court's denial of injunctive relief concerning the total THC standard, finding that the plaintiffs failed to show a likelihood of success on their preemption and Dormant Commerce Clause claims. View "Northern Virginia Hemp and Agriculture, LLC v. Commonwealth of Virginia" on Justia Law

A service-disabled veteran and his company, MJL Enterprises, LLC, alleged that the Small Business Administration’s (SBA) Section 8(a) Business Development Program discriminated against him based on race. The program uses a race-conscious presumption to determine social disadvantage, which the plaintiffs argued was unconstitutional. They sought a declaration that the program's racial classifications were unconstitutional and an injunction against its enforcement.The United States District Court for the Eastern District of Virginia dismissed the case, ruling it moot due to changes in the 8(a) Program following an injunction in another case, Ultima Services Corp. v. U.S. Department of Agriculture. The district court also found that the plaintiffs lacked standing because they failed to demonstrate economic disadvantage and could not establish social disadvantage without the presumption.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court reversed the district court’s ruling on mootness, agreeing with the plaintiffs that the case was not moot because the changes to the 8(a) Program were not final and could be appealed. However, the Fourth Circuit affirmed the district court’s dismissal based on lack of standing. The court held that the plaintiffs failed to demonstrate an injury in fact, as they did not show they were "able and ready" to bid on 8(a) Program contracts due to their inability to meet the program’s social and economic disadvantage requirements. The court also found that the plaintiffs could not establish causation or redressability, as their ineligibility for the program was not solely due to the race-conscious presumption.The Fourth Circuit concluded that the plaintiffs lacked Article III standing to sue and affirmed the district court’s dismissal for lack of subject matter jurisdiction. The case was remanded for further proceedings consistent with the opinion. View "Hierholzer v. Guzman" on Justia Law

Plaintiffs, representing West Virginia Parents for Religious Freedom and others, filed a lawsuit challenging West Virginia's mandatory vaccination requirement for children, claiming it violates the Free Exercise Clause of the First Amendment. The law mandates immunizations for children attending public, private, or parochial schools, with medical exemptions but no religious exemptions. Plaintiffs sought declaratory and injunctive relief against state health officials.The United States District Court for the Northern District of West Virginia applied the Pullman abstention doctrine, deciding not to resolve the Free Exercise claim and staying the case. The court reasoned that a recent state law, the Equal Protection for Religion Act (EPRA), might impact the vaccination mandate and should be interpreted by state courts first. The district court denied the plaintiffs' motion for summary judgment and granted the defendants' motion to abstain.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the district court erred in applying the Pullman abstention doctrine because the plaintiffs' claim did not present an unclear issue of state law requiring interpretation. The court emphasized that federal courts have a duty to exercise their jurisdiction and that abstention is only appropriate in special circumstances. The Fourth Circuit vacated the district court's abstention ruling and remanded the case for further proceedings, including addressing the defendants' arguments regarding Ex Parte Young and Article III standing, and if necessary, resolving the Free Exercise claim. View "West Virginia Parents for Religious Freedom v. Christiansen" on Justia Law