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

Steven Clark Lefemine participated in an anti-abortion protest at a reproductive healthcare facility in Columbia, South Carolina, where he intentionally blocked the entrance by sitting in front of the doorway, preventing patients and staff from entering. After refusing requests to move, the police were called, and Lefemine was arrested. He was initially charged with trespassing under state law, for which he was fined, and subsequently indicted by a federal grand jury for violating the Freedom of Access to Clinic Entrances Act (FACE Act) under 18 U.S.C. § 248.In the United States District Court for the District of South Carolina, Lefemine was first charged under a provision of the FACE Act carrying a maximum penalty of one year in prison. However, the government amended the penalty sheet—an auxiliary document to the indictment—to reflect a lower maximum penalty: six months’ imprisonment and/or a fine of $10,000. The indictment was also amended to conform to this reduced penalty. Lefemine’s counsel acknowledged and consented to these amendments. The district court denied Lefemine’s request for a jury trial, finding that the charged offense was a “petty” offense not subject to the Sixth Amendment right to a jury trial, and proceeded with a bench trial that resulted in Lefemine’s conviction.On appeal to the United States Court of Appeals for the Fourth Circuit, Lefemine argued that he was entitled to a jury trial both because of the original indictment and because Congress intended all FACE Act violations to require a jury trial. The Fourth Circuit held that the amendments did not require resubmission to a grand jury and that the maximum penalty Lefemine faced rendered the offense “petty” under Supreme Court precedent. The court affirmed that the first-time, nonviolent exception under the FACE Act does not require a jury trial, joining the Second, Seventh, and Eleventh Circuits, and affirmed the district court’s judgment. View "United States v. Lefemine" on Justia Law

A defendant was charged with distributing fentanyl and possessing a firearm in furtherance of a drug trafficking crime. During jury selection, one of the prospective jurors, a retired police chief with decades of law enforcement experience, disclosed his background in policing and drug task force work, but did not reveal that he had previously been the target of a federal investigation into corruption involving local officials. When asked if he or his family had been involved in any controversy or litigation with a federal agency, the juror answered “no.” The defendant was convicted on all counts.After trial, defense counsel discovered the juror’s undisclosed involvement as a target in a prior federal investigation. The defendant moved for a new trial in the United States District Court for the Southern District of West Virginia, arguing that the juror’s dishonesty during voir dire deprived him of an impartial jury. The district court held an evidentiary hearing, found that the juror had given dishonest answers to material questions, but concluded that there was no evidence of actual bias or that the juror should have been struck for cause if he had answered truthfully. The court denied the motion for a new trial.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s denial for abuse of discretion. The Fourth Circuit held that the district court did not commit manifest error in finding no actual bias and did not abuse its discretion in concluding that the juror’s prior experience did not require exclusion under any per se rule of implied or inferred bias. The court affirmed the district court’s decision, holding that under the standard of review, the defendant was not deprived of a trial by an impartial jury. View "US v. Williamson" on Justia Law

Law enforcement officers pursued the defendant, Austin Lodge, after a traffic stop in Clarksburg, West Virginia. During the pursuit, Lodge attempted to place a camouflage backpack inside a residence where his children’s grandmother lived, but was turned away by the occupant. He then fled to the backyard and discarded the backpack next to a shed. Lodge was apprehended without the backpack. Later, officers searched the area, found the bag, and searched it without a warrant, uncovering controlled substances. Lodge admitted ownership of the backpack but argued that his actions were meant to conceal, not abandon, the bag because it was left on familiar, semi-private property.The United States District Court for the Northern District of West Virginia first reviewed Lodge’s motion to suppress evidence obtained from the warrantless search. The case was referred to a magistrate judge, who conducted an evidentiary hearing and found that Lodge had abandoned the bag, thus forfeiting any reasonable expectation of privacy in its contents. The district court adopted these findings and denied the suppression motion, concluding that Lodge’s conduct amounted to abandonment, relying on the Fourth Circuit’s precedent in United States v. Small.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s findings for clear error and the legal conclusions de novo. The appellate court emphasized that abandonment is a factual finding based on the objective circumstances known to officers at the time. The Fourth Circuit held that the district court’s finding—that Lodge abandoned the backpack when he discarded it after being denied entry at the residence—was not clearly erroneous. Because Lodge abandoned the backpack, he lacked a reasonable expectation of privacy in it, and the denial of the motion to suppress was affirmed. The court declined to resolve whether a different result would obtain if the property had not been abandoned but was merely concealed on private property. View "US v. Lodge" on Justia Law

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