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

Late at night in downtown Raleigh, police were investigating a stolen vehicle when Milton Allen repeatedly interfered with the officers’ work, ignoring their commands and disrupting the scene while riding his bicycle. Allen’s actions, which included impeding traffic and resisting multiple direct orders to leave, led officers to attempt an arrest. During the arrest, Allen resisted and struggled with officers, who eventually subdued him using handcuffs and ankle restraints. While Allen was restrained but still squirming, officers searched two cross-body bags he had been wearing and found firearms, illegal drugs, cash, and related items. Based on these discoveries, Allen was charged with firearm and drug offenses.The United States District Court for the Eastern District of North Carolina reviewed Allen’s motion to suppress the evidence found in the bags. The district court found that the search of the bags was not a lawful search incident to arrest because Allen was already secured and could not access the bags, relying on United States v. Davis and Arizona v. Gant. The court also rejected the government’s argument that the evidence would inevitably have been discovered under established inventory search policies, concluding that the government had not sufficiently demonstrated that the policies were particular enough to limit officer discretion or that the bags would have inevitably been searched.On appeal, the United States Court of Appeals for the Fourth Circuit addressed whether the evidence should have been suppressed. The Fourth Circuit held that the search of Allen’s bags would inevitably have occurred pursuant to standardized inventory search policies of both the Raleigh Police Department and Wake County Detention Center, which required the search of all arrestees’ personal property and limited officer discretion. The Fourth Circuit concluded that the evidence would have been lawfully discovered and thus should not have been suppressed, reversing the district court’s order. View "United States v. Allen" on Justia Law

A federal prisoner was sentenced in December 2020 and, due to pending charges in another jurisdiction, was held at a detention center in Rhode Island rather than being promptly transferred to his designated Bureau of Prisons (BOP) facility in South Carolina. During this period of post-sentencing detention, the prisoner claims to have participated in programs under the First Step Act (FSA), thereby accruing approximately 150 days of time credits, which could reduce his time in custody. However, the BOP did not recognize these credits because he had not undergone a formal risk and needs assessment—the BOP’s prerequisite for awarding such credits—until his eventual arrival at the designated facility in March 2022.After exhausting administrative remedies, the prisoner filed a pro se habeas petition in the United States District Court for the District of South Carolina, seeking recognition of his alleged FSA credits. The magistrate judge, without briefing or discovery, recommended dismissal. The district court adopted this recommendation, concluding that the BOP’s regulation reasonably required an initial assessment before credits could be earned, and applied Chevron deference to uphold the agency's interpretation. The district court also found no evidence the prisoner had “successfully participated” in qualifying programs before arrival at the BOP facility and dismissed the petition without prejudice, refusing to require a government response.On appeal, the United States Court of Appeals for the Fourth Circuit vacated the district court’s judgment and remanded. The Fourth Circuit held that the case was not moot, as the prisoner could still benefit from the FSA credits if his risk status changed or a warden approved his release. The court further held that, in light of the Supreme Court’s decision in Loper Bright Enterprises v. Raimondo, which overturned Chevron deference, the district court must independently determine whether the BOP’s interpretation of “successful participation” aligns with the best reading of the statute. View "Benson v. Warden FCI Edgefield" on Justia Law

The defendant was serving a term of supervised release after prior convictions for drug and firearm offenses. While on supervision, he was alleged to have committed new offenses, including strangulation and assault and battery of a family member, based on an incident with his then-girlfriend, Jessica Rodriguez, in May 2021. Ms. Rodriguez did not report the incident to law enforcement until over a year later, in June 2022, saying she had become fearful of the defendant. The evidence at the revocation hearing included her testimony, corroboration by her daughter, text messages in which the defendant appeared to admit and apologize for the conduct, and photographs of Ms. Rodriguez’s injuries. The defendant denied strangling or striking Ms. Rodriguez, offering an alternative explanation for the events, but the district court found his testimony not credible.Previously, the United States District Court for the Eastern District of Virginia had revoked the defendant’s supervised release and imposed an 18-month sentence after similar violations. The new violations resulted in another revocation petition, but the resolution of the matter was delayed for several years due to continuances while related state charges were pending. Ultimately, in January 2025, the district court held hearings, credited the testimony of Ms. Rodriguez and her daughter, and found by a preponderance of the evidence that the defendant had violated the mandatory condition not to commit new crimes. The court sentenced him to 24 months in prison.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s revocation of supervised release, holding there was no clear error in finding the violations or in crediting the complainant’s testimony after considering all relevant evidence. However, the Fourth Circuit vacated the 24-month sentence and remanded for resentencing, because the district court failed to address the defendant’s non-frivolous argument that he should receive credit for an additional 19 months he spent on supervised release while the revocation petition was pending. View "US v. Mills" on Justia Law

Nathaniel Martin was a passenger in a vehicle stopped by a United States Forest Service law enforcement officer in the Monongahela National Forest after the vehicle was found illegally parked on a single-lane bridge. The officer, Joshua Radford, initially cited the parking violation as the reason for the stop. However, as soon as the stop began, Radford immediately shifted focus, asking about firearms in the vehicle and then further questioning both the driver and Martin regarding other possible contraband. Firearms were discovered, and Martin was eventually arrested after a check revealed prior felony convictions. Notably, the officer did not issue a citation for the parking offense, and the initial minutes of the stop were not captured on bodycam video.After more than two years, Martin was charged in the United States District Court for the Southern District of West Virginia with being a felon in possession of a firearm. He moved to suppress the evidence and his statements, arguing that the stop violated his Fourth Amendment rights because the officer had abandoned the original purpose of the stop. The district court denied the motion to suppress, finding that the officer’s actions remained within the permissible scope of the stop and did not unlawfully extend it. Martin then entered a guilty plea, preserving his right to appeal the suppression ruling.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the officer’s immediate pivot from addressing the parking violation to investigating potential criminal activity was not reasonably related in scope to the original justification for the stop. The court distinguished this situation from prior precedent by noting the absence of circumstances suggesting officer safety concerns. The court reversed the district court’s denial of the suppression motion and vacated Martin’s guilty plea. View "US v. Martin" on Justia Law

A noncitizen from El Salvador entered the United States and was released on bond after expressing fear of returning home. Removal proceedings were held before the Executive Office for Immigration Review (EOIR), but he failed to appear at a hearing and was ordered removed in absentia in 2019. The order became final immediately upon entry. Over three years later, the Department of Homeland Security (DHS) issued a warrant for his removal after he was arrested for an unrelated offense. He was placed in Immigration and Customs Enforcement (ICE) custody, but escaped before his scheduled deportation. After being apprehended, he was indicted for escape and for corruptly obstructing a pending proceeding under 18 U.S.C. § 1505.The United States District Court for the Eastern District of Virginia acquitted him on the escape charge but convicted him under § 1505, finding that the execution of an EOIR-issued removal order by ICE was part of a “pending proceeding” before EOIR. The district court denied the defendant’s motion for acquittal, reasoning that the statute’s term “proceeding” should be interpreted broadly to include ICE’s execution of the removal order, as this act was under the authority and direction of the EOIR order.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the statutory interpretation issue de novo. The appellate court held that, under the plain text and statutory context, ICE’s execution of a removal order after EOIR has issued a final order does not constitute a “pending proceeding . . . being had before” EOIR under § 1505. The court further found that ICE enforcement actions are not “proceedings” within the meaning of § 1505, but rather are akin to routine law enforcement activity. Accordingly, the Fourth Circuit reversed the district court’s judgment, vacated the conviction, and remanded for further proceedings. View "US v. Hernandez" on Justia Law

After pleading guilty in 2014 to Hobbs Act robbery and brandishing a firearm during and in relation to the robbery, the defendant was sentenced to consecutive prison terms and concurrent terms of supervised release. Following his release in early 2024, he soon violated several conditions of his supervised release, including testing positive for illicit drugs on multiple occasions, violating location restrictions, and leaving the judicial district without permission. The Probation Officer filed a petition for revocation alleging four violations, including drug testing failures and other conduct, and submitted a supplemental report that incorrectly classified the drug-related violation as a more serious offense.The United States District Court for the Middle District of North Carolina held a revocation hearing at which the defendant admitted the charged conduct. The court dismissed the felony possession allegation but found that the most serious remaining violation was the drug testing violation. Without explanation, the court classified this as a Grade B violation under the Sentencing Guidelines, resulting in a Guidelines range of 8 to 14 months. The court then imposed a sentence of 19 months’ imprisonment with additional terms of supervised release, exceeding the Guidelines range and possibly the statutory maximum.On appeal, the United States Court of Appeals for the Fourth Circuit found that the district court erred in characterizing the drug testing violation as a Grade B violation, rather than the less severe Grade C violation that the record supported. The appellate court held that this misclassification was plain error affecting the defendant’s substantial rights and impacted the fairness of the proceedings. The Fourth Circuit vacated the district court’s judgment and remanded the case for resentencing under the correct Guidelines classification. The court also directed the district court to consider whether the new sentence complies with the statutory limits on supervised release. View "US v. Jones" on Justia Law

A hospital employee discovered that someone had posted on social media a screenshot from the hospital’s internal system, revealing Supreme Court Justice Ruth Bader Ginsburg’s name, dates of ten medical visits, and the types of services she received. The post, which first appeared on an anonymous online forum, fueled conspiracy theories regarding the Justice’s health. The hospital investigated and identified two employees who had inappropriately searched for the Justice’s information, ultimately focusing on Trent Russell, who worked for a non-profit with access to patient records. Forensic analysis linked Russell’s home computer to the search, and evidence showed he formatted his hard drive after his access was revoked. He was charged with unlawfully obtaining health information, unlawfully destroying records, and disclosing health information.The United States District Court for the Eastern District of Virginia denied Russell’s motion to suppress statements made to federal agents during an interview at his workplace. The court found no coercion despite the presence of his employer’s CEO. The court also limited cross-examination of an agent regarding Russell’s explanations for the search, sustaining a hearsay objection but allowing other avenues to explore bias. At trial, the jury convicted Russell of obtaining individually identifiable health information and destroying records, but acquitted him of disclosing health information. The district court sentenced him to 24 months’ imprisonment.The United States Court of Appeals for the Fourth Circuit reviewed the case. It held that Russell’s interview statements were voluntary, as there was no evidence of coercion or threats. The court found no abuse of discretion in the district court’s limitation of cross-examination, and any error was harmless given the other evidence of bias. It also held that the information Russell obtained qualified as “individually identifiable health information” under federal law. The Fourth Circuit affirmed the judgment in full. View "US v. Russell" on Justia Law

The defendant owned and operated a company that provided paycard services to restaurant employees, allowing them to receive wages on debit cards. Over time, he misused the funds entrusted to his company by transferring payroll money to his personal brokerage account and engaging in risky options trading, without disclosing these actions to his clients. When losses mounted and funds were missing, he misled both the client company and cardholders about the shortfall, imposed new fees retroactively, and restricted access to account information under the guise of privacy concerns. After the business relationship ended and his company lost its only client, he applied for a Paycheck Protection Program loan using falsified bank records, misrepresenting his company’s operations, and diverted those funds to his brokerage account as well.The United States District Court for the Eastern District of Virginia indicted him on multiple counts of wire and mail fraud based on both the paycard and PPP loan schemes. He moved to sever the count relating to the PPP loan, arguing that combining the two schemes in one trial was improper and prejudicial, but the district court denied severance, finding the counts properly joined and prejudice curable. After a jury convicted him on all counts, the district court applied a sentencing enhancement for the use of sophisticated means, resulting in an 87-month prison sentence.On appeal, the United States Court of Appeals for the Fourth Circuit held that the evidence was sufficient to support the jury’s finding of fraudulent intent and that the sophisticated-means sentencing enhancement was supported by the record. The court also found that joinder of the paycard and PPP fraud schemes was proper, as there were material overlaps in method and evidence, and affirmed the district court’s discretion in denying severance. The judgment was affirmed. View "US v. Lawrence" on Justia Law

The defendant pleaded guilty to transporting child sexual abuse material and was sentenced to 144 months in prison. Upon release, he was placed on lifetime supervised release with a special condition prohibiting access to any pornographic material, including legal pornography. The defendant repeatedly violated conditions of his supervised release, resulting in multiple revocations and returns to prison. Each time he was released, similar conditions were imposed. The defendant later consented to a special condition that barred him from viewing or possessing any visual depiction of sexually explicit conduct on electronic devices, but later contested the imposition of a broader ban.After the defendant’s initial appeal, the United States Court of Appeals for the Fourth Circuit (in Castellano I) vacated the district court’s imposition of the pornography ban, finding it was not supported by individualized evidence, and remanded with instructions to strike the special condition. The district court complied. However, after subsequent violations and revocations, the government requested a new special condition banning all pornography, this time presenting testimony and a written evaluation from the defendant’s treatment provider, who offered individualized clinical reasons for the restriction based on years of treating the defendant.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed whether the district court abused its discretion in imposing the pornography ban. The court held that the special condition was supported by individualized evidence specific to the defendant and his treatment needs. The court further held that neither the mandate rule from Castellano I nor other legal doctrines barred the district court from imposing the new condition in light of changed circumstances and new evidence. The judgment of the district court was affirmed. View "US v. Castellano" on Justia Law

The case concerns a defendant who pleaded guilty to two drug offenses and was sentenced in the United States District Court for the Eastern District of North Carolina. During the sentencing hearing, the court orally pronounced certain discretionary conditions for supervised release, including a condition regarding warrantless searches. The court stated that such searches would be allowed only upon reasonable suspicion of a violation or, without suspicion, for safety issues. Later that day, the court entered a written judgment that imposed broader conditions, permitting warrantless searches by probation officers as part of their general supervision functions, without limiting such searches to the occasions described orally.After sentencing, the defendant appealed, arguing that the written judgment contained conditions of supervised release that materially differed from those announced in open court. The government raised several arguments in response, including claims about waiver and harmlessness, and noted that the written condition matched the presentence report’s recommendation, which the defendant had not objected to. The United States Court of Appeals for the Fourth Circuit reviewed these arguments de novo, consistent with its precedent.The Fourth Circuit held that there was a material discrepancy between the oral pronouncement and the written judgment regarding the scope of warrantless searches, which constituted error under its Rogers–Singletary line of cases. The court rejected the government’s arguments that the error was harmless or waived by the plea agreement, emphasizing that the oral pronouncement controls and that a defendant has standing to challenge such discrepancies. Accordingly, the Fourth Circuit vacated the judgment and remanded the case for resentencing. View "United States v. Tostado" on Justia Law