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

Defendant was convicted of armed robbery and, after a renewed motion for a judgment of acquittal, the district court overturned his conviction based on insufficient evidence. At issue was what constituted a proper inference for a jury to draw when making determinations of guilt. The court held that the government failed to produce sufficient "identity" evidence placing defendant at the robbery and relied on unsubstantiated, unscientific inferences to bolster its minimal evidence. Therefore, the court held that no reasonable jury could find defendant guilty beyond a reasonable doubt based on the evidence presented at trial. Accordingly, the court affirmed the district court's judgment.

Defendant was charged with possession of a firearm and ammunition by a convicted felon. At issue was whether the good-faith exception to the exclusionary rule permitted the admission of evidence obtained by a police officer who conducted a search in objectively reasonable reliance on binding appellate precedent that was later overruled. The Supreme Court resolved this issue in Davis v. United States, holding that "searches conducted in objectively reasonable reliance on binding appellate precedent are not subject to the exclusionary rule." Because the district court's decision in this case granting the motion to suppress by defendant was inconsistent with Davis, the court vacated the district court's judgment and remanded for further proceedings.

This case stemmed from a federal grand jury indictment charging defendant with possession with intent to distribute Oxycodone where defendant moved to suppress the physical evidence seized following a search and certain statements he made to law enforcement officers. At issue was whether the district court properly granted the motion to suppress. The court held that reasonable suspicion was not present to turn a routine traffic stop into a drug investigation. Furthermore, under an extremely deferential standard of review, the court rejected the government's challenge to the district court's finding that defendant's consent was involuntary. Accordingly, the judgment was affirmed.

Employees of the Maryland Department of Public Safety and Correctional Services filed suit against defendants, alleging principally that the searches conducted on them as a result of a portable ion scanning machine, which was capable of detecting minute amounts of controlled substances, violated their Fourth Amendment rights. The district court held that defendants were entitled to qualified immunity and dismissed the suit. The court affirmed and held that, although it was clearly established that intrusive prison employee searches required reasonable suspicion, it was far from clear that the devices at issue could not meet that standard. The court further held that because no clearly established federal law placed the officers on notice that fighting contraband in the prison environment in this manner was unlawful, the district court correctly held that immunity attached.

Petitioner, a citizen of Mexico, petitioned the court to review the decision of the BIA denying his petition for cancellation of removal and his motion to reopen removal proceedings so that he could pursue cancellation of removal after adjustment of status for which he had an application pending. As a preliminary matter, the court denied the government's motion to dismiss or transfer the matter on the basis of improper venue. The court held, however that petitioner raised no constitutional claims or questions of law and therefore, the court lacked jurisdiction to review the discretionary denial of cancellation of removal. The court further held that because the BIA based its denial of petitioner's motion to reopen on a determination that petitioner did not merit the discretionary relief of cancellation, the court also lacked jurisdiction to review the denial of that motion. Accordingly, the appeal was dismissed.

An officer shot an unarmed man wanted for failure to pay child support, when he started running away. In an action under 42 U.S.C. 1983, the parties stipulated that the officer intended to use his Taser rather than his gun. The district court granted him summary judgment on the basis of qualified immunity. The Fourth Circuit reversed, analyzing the shooting as a "seizure" under the Fourth Amendment and applying an objective standard of reasonableness. The use of force could be viewed by a jury as objectively unreasonable. The officer knew he carried his Taser in the holster on his thigh, about a foot lower than the holster on his hip; he knew that the gun weighed twice what the Taser weighed; and he knew that the Taser had a thumb safety that the gun did not have. The shooting was not a split-second decision; well-established precedent prohibits shooting suspects who pose no significant threat of death or serious physical threat. A reasonable jury could also find that the officer was grossly negligent and not protected by the Maryland Tort Claims Act, Md. Code State Govt, 12-101.

Defendant pled guilty to possession with intent to distribute cocaine where he signed an acceptance of responsibility statement but declined to sign a plea agreement waiving certain rights to appellate review and collateral attack. Solely because defendant would not waive these rights, the government refused to move for an additional one-level reduction for acceptance of responsibility under U.S.S.G. 3E1.1(b). Defendant appealed, challenging the district court's failure to compel the government to move for the U.S.S.G. 3E1.1(b) reduction. The court held that the government retained discretion to refuse to move for an additional one-level reduction, but only on the basis of an interest recognized by the guidelines itself. Therefore, the court vacated defendant's sentence and remanded for further proceedings. The court held that, if the government could not provide a valid reason for refusing to move for an additional one-level enhancement reduction under U.S.S.G. 3E1.1(b) and continued to refuse to move for such a reduction, the district should order the government to file the motion.

Defendant pled guilty to one count of wire fraud and one count of aggravated felony theft where she posed as a bail bondsman at a North Carolina jail and secured identifying information, cash, and the title of two properties from an octogenarian attempting to post bond for his granddaughter. At issue was whether an abuse-of-trust enhancement was properly applied to defendant's sentence where defendant contended that a bail bondsman did not occupy a position of public or private trust. The court held that the Guidelines simply required that a position of trust "significantly facilitate[] the commission or concealment of the offense." The court also held that, because it was undisputed that defendant gained initial access to the octogenarian's personal information by posing as a bail bondsman and later used this information to commit her wire-fraud offenses, that standard was clearly met here. Therefore, the district court did not err, plainly or otherwise, in imposing the enhancement for abuse of trust. Accordingly, the judgment of the district court was affirmed.

This appeal stemmed from the district court's grant of a motion for reduction of sentence for substantial assistance under Federal Rule of Criminal Procedure 35(b). In granting the motion, the district court reduced defendant's sentence for distribution of child pornography from 96 months imprisonment to one day. At issue was whether the district court exceeded its authority under Rule 35(b) because it did not base its grant of the motion on defendant's assistance to the government, but instead grounded the reduction solely on the court's concern that defendant would not receive his preferred medication while in prison. The court held that the district court exceeded its authority under Rule 35(b) by granting the motion based on factors other than the defendant's cooperation with the government. The court also held that the mere possibility that a change in treatment of the defendant's ADHD, based on the professional judgment of a prison's medical team, simply did not give rise to an Eighth Amendment violation. The court further held that, because reconsideration of the motion by the original sentencing judge would inevitably invite speculation as to whether the medical issue continued to play a role in the ultimate ruling, the court ordered the case reassigned to a new judge on remand.

Petitioner sought habeas relief from his capital sentence for convictions of murdering a husband and wife, as well as robbing the husband. At issue was whether petitioner received ineffective assistance of counsel and whether the State of North Carolina violated his Eighth Amendment and due process rights by presenting to the jury evidence and argument that contradicted those presented in the trials of his co-defendants. The court affirmed the denial of the petition for habeas relief and held that, in light of the circumstances and the evidence presented at trial, the federal district court correctly determined that the state court's decision did not constitute an unreasonable application of clearly established law or an unreasonable determination of the facts.