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

Plaintiff, a state prisoner housed at Red Onion State Prison (ROSP), filed suit under the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. 2000 cc et seq., and 42 U.S.C. 1983, challenging ROSP's 2010 Ramadan policy. ROSP had devised a new eligibility policy for 2010 where, in addition to signing up to participate in Ramadan, inmates had to provide some physical indicia of Islamic faith. The court vacated the district court's summary judgment order granting defendants qualified immunity on plaintiff's claims for monetary relief where defendants have failed to establish as a matter of law that the 2010 Ramadan policy, as applied to plaintiff, did not violate his First Amendment rights and where their alleged actions violated plaintiff's clearly established rights; vacated the district court's decision that the prison's abandonment of the policy mooted the claims for equitable relief where defendants failed to meet their "heavy burden" of establishing that it was "absolutely clear" that the 2010 Ramadan policy would not be reinstated; and remanded for further proceedings. View "Wall v. Wade" on Justia Law

Defendant was convicted under the Arms Export Control Act, 22 U.S.C. 2778, for attempting to export small-arms ammunition to Jordan without a license. Defendant, working as a financial-management Foreign Service Officer at the U.S. embassy in Jordan, sought to ship certain personal possessions, including 366 pounds of ammunition, from his parent's house in Alabama to Jordan via a government contract carrier. The court concluded that, under the relevant standard of willfulness, defendant's true belief as to the illegality of transporting the ammunition at issue was sufficient to establish culpability under the Act even if unaccompanied by knowledge of the contents of the United States Munitions List. The court also concluded that there was sufficient evidence to support the district court's conclusion that defendant willfully violated the Act. Accordingly, the court affirmed the judgment of the district court. View "United States v. Bishop" on Justia Law

Defendant moved to dismiss an indictment charging him with one count of traveling in interstate commerce and knowingly failing to update his sex offender registration in violation of 18 U.S.C. 2250. Defendant argued that his plea of nolo contendere to attempted sexual battery in Florida state court did not qualify as a conviction within the meaning of the Sex Offender Registration and Notification Act (SORNA), 42 U.S.C. 16911 et seq. The court concluded that the district court correctly found defendant's plea of nolo contendere with adjudication withheld constituted a conviction for the purposes of SORNA because it resulted in a penal consequence. View "United States v. Bridges" on Justia Law

Defendant appealed his conviction of five felony counts relating to the sale of counterfeit prescription drugs. Defendant sought to introduce evidence establishing a gray market for prescription pills to argue that some of the pills that police seized from him could be genuine. The court concluded that the district court did not err in barring cross-examination regarding gray market evidence where there was no connection to the knowledge element and consequently no relevance; defendant cannot use the privilege against self-incrimination as a means to free himself from the basic rules of relevancy; if the evidence were relevant, the district court did not commit reversible error by directing the evidence to defendant's case-in-chief; and, in the alternative, the gray market evidence should be excluded under Federal Rule of Evidence 403. The court also held that, viewed in the light most favorable to the Government, the evidence sufficiently established defendant's knowledge and, therefore, defendant's sufficiency argument failed. Accordingly, the court affirmed the judgment of the district court. View "United States v. Shauaib Zayyad" on Justia Law

Defendant appealed his conviction of a firearm offense, contending that the evidence discovered during a traffic stop should have been suppressed at trial because the traffic offense for which he was cited - leaving a vehicle standing such that it obstructs traffic - did not apply to the road on which he had stopped his car. The court rejected this argument, concluding that closely related traffic law barred the conduct for which defendant was cited. The court rejected defendant's argument challenging the exclusion of prior police misconduct where the district court's decision to exclude the evidence was neither arbitrary nor irrational. Accordingly, the court affirmed the judgment of the district court. View "United States v. Williams, IV" on Justia Law

Defendant was convicted of three counts of filing false income tax returns. Defendant was subsequently denied habeas relief but the district court granted him a certificate of appealability (COA) on his Sixth Amendment challenge. The court concluded that the district court did not err in finding that defendant failed to establish that his trial counsel's representation was anything other than objectively reasonable where counsel's decision not to call certain witnesses was a reasonable strategic decision. Accordingly, the court affirmed the judgment of the district court. View "United States v. Dehlinger" on Justia Law

Defendant appealed his conviction of two counts of bank robbery. The court concluded that the district court's refusal to allow defendant to testify in narrative form was not arbitrary or disproportionate to its purpose; the court also rejected defendant's claim that the district court impermissibly forced him to choose between his right to represent himself and to choose between testifying pro se in question-answer form and testifying in response to questions from standby counsel who would then control the case; and, therefore, the court affirmed the judgment of the district court. View "United States v. Beckton" on Justia Law

Defendant, who is deaf and communicates through sign language, appealed the district court's order of civil commitment following an evidentiary hearing under 18 U.S.C. 4248. The court affirmed the judgment of the district court in denying defendant's request for consecutive interpretation; the district court did not clearly err in finding that defendant is a "sexually dangerous person;" and the district court did not err in rejecting defendant's equal protection and due process claims in light of United States v. Timms. Accordingly, the court affirmed the judgment of the district court. View "United States v. Heyer" on Justia Law

Defendant appealed the district court's order of restitution as part of his sentence for obstructing federal bankruptcy proceedings. Defendant contended that the purported victims suffered losses when he caused them to take out significant loans for the benefit of his church - conduct with which he was not charged or convicted. At issue was whether the purported victims were victims "of the offense" for the purpose of 18 U.S.C. 3563(b). The court concluded that the statute required the purported victims to be victims only of the offense of conviction; the Government failed to demonstrate that the purported victims' losses were "caused by the specific conduct that is the basis of" defendant's offense of conviction - obstruction of federal bankruptcy proceedings; and therefore, the district court abused its discretion in awarding restitution to the purported victims, as the award was contrary to the legal principles set out in the court's precedent. Accordingly, the court reversed and remanded. View "United States v. Freeman" on Justia Law

Defendant conditionally pled guilty to possession with intent to distribute 500 grams or more of a mixture or substance containing cocaine. On appeal, defendant challenged the district court's denial of his motions to suppress evidence. The court concluded that the district court correctly held that the traffic stop at issue was reasonable in scope and duration and that defendant was lawfully seized for a traffic violation when the dog sniff occurred. The court also concluded that the district court correctly held that the dog was sufficiently reliable and that his positive alert provided probable cause for the search of defendant's vehicle. Accordingly, the court affirmed the judgment of the district court. View "United States v. Green" on Justia Law