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

After a jury trial, Appellants, Abukar Osman Beyle and Shani Nurani Shiekh Abrar, were convicted on twenty-six criminal counts arising from the armed abduction and murder of four U.S. citizens off the coast of Somalia. The Fourth Circuit affirmed, holding (1) the district court had jurisdiction over the charges of murder and concomitant use of a firearm because the site of the murders, thirty to forty nautical miles from the Somali coast, lay on the “high seas,” and thus, Appellants were within the reach of the U.S. criminal statutes under which they were convicted; and (2) Abrar was not denied his Fifth Amendment right to due process or his Sixth Amendment right to present witnesses material to his duress defense, and therefore, the district court did not err in denying Abrar’s motion to dismiss the indictment. View "United States v. Beyle" on Justia Law

Appellant pled guilty to one count of knowing possession of child pornography and was sentenced to sixty months’ imprisonment followed by a lifetime term of supervised release. The Fourth Circuit affirmed, holding (1) Appellant’s lifetime term of supervised release was procedurally reasonable because the sentencing judge satisfactorily explained the sentence at length; and (2) Appellant’s lifetime term of supervised release was substantively reasonable where it was necessary to deter Defendant, protect the public from additional crimes by him, and provide him with the mental health care and necessary corrective treatment he needed. View "United States v. Helton" on Justia Law

After a jury trial, Defendant was convicted of three counts relating to marijuana trafficking and was sentenced to 121 months of incarceration. Defendant filed a motion to vacate his conviction and sentence, alleging that his trial and appellate counsel had provided ineffective assistance. The district court denied the motion. The Fourth Circuit affirmed, holding (1) Defendant was not prejudiced by his trial counsel’s failure to request an instruction that the jury find a drug weight based on the amount attributable to or reasonably foreseeable by Defendant; (2) Defendant was not prejudiced by his appellate counsel’s failure to raise the failure to request that instruction as an issue on direct appeal; and (3) Defendant’s trial counsel was not ineffective for failing to challenge the drug weight and advisory guidelines range at sentencing. View "United States v. Rangel" on Justia Law

After a jury trial, Appellant was convicted of first degree murder. The conviction was upheld on direct appeal. After unsuccessfully seeking habeas corpus relief in state court, Appellant filed a federal habeas petition alleging that he received ineffective assistance of counsel due to his trial counsel’s failure to request a jury instruction defining heat of passion. The district court denied the petition. The Fourth Circuit reversed, holding (1) the state habeas court’s denial of Appellant’s ineffective assistance claim was based on an unreasonable application of clearly established federal law set forth in Strickland v. Washington; and (2) Appellant’s counsel erred in failing to request the heat of passion jury instruction, and Appellant suffered prejudice as a result of this error. Remanded. View "Lee v. Clarke" on Justia Law

This appeal arose from a convenience store robbery spree that occurred in Fayetteville, North Carolina over a four-day period in 2011. Appellants, three individuals, each plead guilty to Hobbs Act conspiracy and using and carrying a firearm during and in relation to a crime of violence. The district court sentenced all three Appellants to a combined sentence of 200 months. Appellants appealed, challenging both the procedural and substantive reasonableness of their sentences. The Fourth Circuit vacated and remanded for resentencing, holding that the sentences were procedurally unreasonable because the district court failed to explain its rejection of the Guidelines sentences and also failed to sufficiently explain the sentences imposed. View "United States v. Lymas" on Justia Law

Defendants in this case were three members of a violent street gang known as the Latin Kings who operated as part of the Greensboro, North Carolina chapter of the gang. After a jury trial, Defendants were convicted of conspiracy to violate the Racketeering Influenced and Corrupt Organizations Act based on their activities in connection with the gang. The Fourth Circuit affirmed, holding (1) the district court did not err in instructing the jury that the Government must prove the enterprise activity affected interstate in any way, “no matter how minimal”; (2) the district court did not err in its jury instruction requiring unanimity as to the types of racketeering acts that members of the conspiracy agreed to commit; (3) the district court did not abuse its discretion issuing two Allen charges; and (4) there was no error in the district court’s evidentiary rulings. View "United States v. Cornell" on Justia Law

Plaintiff, a former inmate in the Virginia Department of Corrections facilities, filed numerous complaints about repeated physical and sexual abuse he suffered while imprisoned in the facilities. Plaintiff brought suit against various prison officials alleging violations of his right under the Eighth Amendment to be free from cruel and unusual punishment. The magistrate judge found that Defendants should have been more diligent in handling Plaintiff’s complaints but recommended that because Defendants did not actually know of the substantial risk of harm Plaintiff faced, his claims failed. The district court adopted in its entirety the findings and recommendation of the magistrate judge. The Fourth Circuit vacated the dismissal of Plaintiff’s claims against certain defendants, holding that the magistrate judge and district court failed to appreciate that the subjective “actual knowledge” standard required to find prison officials deliberately indifferent to a substantial risk of serious injury may be proven by circumstantial evidence that a risk was so obvious that it had to have been known. Remanded. View "Makdessi v. Fields" on Justia Law

After a jury trial, Appellants, four individuals, were convicted of multiple offenses arising from a string of robberies they committed in December 2012. The Fourth Circuit affirmed the convictions, holding (1) the trial judge did not abuse his discretion or violate the Federal Rules of Evidence by admitting certain evidence; (2) assuming the admission of evidence recovered from one appellant’s cell phone violated the Sixth Amendment where not everyone in the phone’s chain of custody testified at trial, the error was harmless beyond a reasonable doubt; and (3) there was sufficient evidence to convict Appellants on every charged offense. View "United States v. Reed" on Justia Law

A written state policy mandates that all persons sentenced to death in Virginia be confined on “death row” while awaiting execution. Inmates on death row live in separate single cells, with minimal visitation and recreational opportunities. After incarceration on Virginia’s death row for almost six years, Plaintiff brought this 42 U.S.C. 1983 action alleging that his confinement on death row violated his procedural Due Process rights and seeking injunctive relief. The district court granted summary judgment for Plaintiff and issued an injunction ordering Virginia prison officials to either alter the policy or to improve the conditions. The Fourth Circuit reversed, holding (1) contrary to Plaintiff’s contention, harsh and atypical confinement conditions in and of themselves do not give rise to a liberty interest in their avoidance; and (2) Plaintiff failed to point to a Virginia law or policy providing him with an expectation of avoiding the conditions of his confinement and failed to establish that those conditions imposed an atypical and significant hardship in relation to the ordinary incidents of prison life. View "Prieto v. Clarke" on Justia Law

In 1998, Appellant was convicted of capital murder and sentenced to death. In 2005, the U.S. Supreme Court remanded Appellant’s case in light of its decision in Roper v. Simmons, which stated that the death penalty may not be imposed on juvenile offenders under the age of eighteen. The Virginia Supreme Court subsequently commuted Appellant’s sentence to life without the possibility of parole. In 2012, the Supreme Court decided Miller v. Alabama, which held that a mandatory life without the possibility of parole sentence imposed on a homicide offender who was a juvenile at the time of the offense violates the Eighth Amendment. One year later, Appellant sought collateral review of his sentence by filing a petition under 28 U.S.C. 2254, arguing that his sentence violates the Eighth Amendment because Miller applies retroactively on collateral review. The district court dismissed Appellant’s petition as untimely. The Supreme Court affirmed, holding that the Miller rule is not retroactively applicable to cases on collateral review. View "Johnson v. Ponton" on Justia Law