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

Rami Mhana operated businesses that purchased fraudulently obtained Apple iPhones and other electronics at below-market prices, paying in cash and often shipping these goods overseas in bulk. His suppliers included individuals who acquired electronics using stolen personal information to make purchases from major retailers and wireless carriers. Mhana did not verify his suppliers’ identities or the legitimacy of the goods, nor did he provide receipts. He also paid third-party services to unlock phones, enabling their use on any network. The government’s investigation began after a ruptured overseas shipment revealed the scheme, ultimately leading to the discovery of thousands of fraudulent transactions.A federal grand jury in the United States District Court for the Western District of North Carolina indicted Mhana on multiple counts, including transportation of stolen goods, conspiracy, and money laundering. Following a six-day trial, the jury convicted him on all charges. The indictment included a forfeiture notice, and the jury found a nexus between certain property and Mhana’s crimes. The district court initially granted a preliminary order of forfeiture but, at sentencing, declined to enter a final forfeiture judgment, citing concerns about double payment with restitution. The district court entered final judgment, prompting Mhana to appeal his convictions and the government to cross-appeal the forfeiture ruling.The United States Court of Appeals for the Fourth Circuit reviewed the case. It affirmed Mhana’s convictions, finding no reversible error in the district court’s evidentiary rulings, and determined that any assumed errors were harmless given the overwhelming evidence of guilt. However, the appellate court reversed the district court’s denial of forfeiture, holding that forfeiture is mandatory under federal law when the statutory prerequisites are satisfied, even if restitution is also imposed, and remanded the case for entry of a forfeiture judgment. View "US v. Mhana" on Justia Law

The defendant was arrested in March 2021 for unlawfully possessing a firearm as a convicted felon after a police encounter outside a convenience store. During the arrest, he resisted and threatened officers, and was found in possession of a loaded ghost gun and distributable amounts of fentanyl. He was charged with possession of ammunition as a convicted felon and possession with intent to distribute fentanyl, ultimately pleading guilty to the ammunition charge. At sentencing, the court weighed the seriousness of his offense and history, including his mental health issues and young age, and imposed a within-Guidelines sentence of 70 months' imprisonment.After sentencing, a retroactive amendment to the Federal Sentencing Guidelines (Amendment 821) reduced the impact of "status points," lowering the defendant's criminal history category and decreasing his advisory Guidelines range from 57-71 months to 51-63 months. In March 2024, he moved for a sentence reduction under 18 U.S.C. § 3582(c)(2), citing rehabilitation efforts while incarcerated. The government opposed, documenting three disciplinary violations by the defendant in prison, including threatening prison staff.The United States District Court for the Eastern District of Virginia found the defendant eligible for a reduction but denied the motion, concluding that the relevant § 3553(a) factors and his disciplinary record weighed against a reduction. The United States Court of Appeals for the Fourth Circuit reviewed the denial for abuse of discretion. The court held that a sentence reduction motion does not trigger a plenary resentencing or require a detailed explanation for retaining a sentence above the amended Guidelines range. The district court’s acknowledgment and consideration of relevant factors sufficed. The Fourth Circuit affirmed the district court’s decision, finding no abuse of discretion and that the presumption of judicial consideration was not rebutted. View "US v. Davis" on Justia Law

A former software developer and naval reservist from Virginia, the defendant became the subject of a federal investigation after participating in the events of January 6, 2021, for which he was later pardoned. In the following months, he purchased several firearms and accessories, including devices labeled as “solvent traps” from an online retailer. These devices, although purportedly for cleaning firearms, were constructed in a manner similar to silencers, with features such as threaded ends and internal baffles. The defendant discussed with an undercover FBI employee how these devices could be converted into silencers, despite not possessing the necessary tools for such modification.The United States District Court for the Eastern District of Virginia heard the case after a federal grand jury indicted the defendant for possessing unregistered silencers in violation of the National Firearms Act (NFA). The defendant moved to dismiss the indictment, contending that the statutory definition of a silencer was unconstitutionally vague and that his conviction would violate the Second Amendment. The district court denied these motions and, after a mistrial, the second jury found the defendant guilty on all counts. He was sentenced to 36 months in prison.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the district court’s jury instructions accurately reflected the statutory definition of a silencer, which does not require operability or exclude dual-use devices. The court found sufficient evidence for the conviction, as the devices’ design and the defendant’s statements supported their classification as silencers. The court also determined the NFA was not unconstitutionally vague as applied. Finally, the court concluded that, even if silencers are protected by the Second Amendment, the NFA’s shall-issue registration regime is presumptively constitutional and the defendant had not shown otherwise. The conviction was affirmed. View "US v. Hatchet Speed" on Justia Law

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