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

In 2019, the FBI and DEA, along with local law enforcement, investigated a Mexican drug trafficking organization operating in Mexico, California, Georgia, and North Carolina. Oscar Pliego-Pineda, based in Atlanta, Georgia, was identified as a key figure in coordinating methamphetamine deliveries and managing drug proceeds. He arranged multiple drug transactions and coordinated logistics for methamphetamine shipments, including converting liquid methamphetamine to crystal form.The United States District Court for the Middle District of North Carolina sentenced Pliego-Pineda to 120 months in prison after he pled guilty to conspiracy to distribute methamphetamine and conspiracy to commit money laundering. The court applied a three-level managerial role enhancement under the United States Sentencing Guidelines, which Pliego-Pineda contested, arguing that the district court erred in applying the enhancement and that his sentence was substantively unreasonable.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court upheld the district court's application of the managerial role enhancement, finding that Pliego-Pineda exercised significant decision-making authority, participated extensively in the conspiracy, and managed the logistics of drug transactions. The court noted that the conspiracy involved at least ten individuals and large quantities of methamphetamine. Despite an error in considering Pliego-Pineda's supervision of an undercover officer, the court found sufficient evidence to support the enhancement.The Fourth Circuit also found Pliego-Pineda's sentence substantively reasonable, affirming the district court's decision. The court emphasized that the sentence was within the properly calculated Guidelines range and thus presumptively reasonable. The court concluded that the district court did not abuse its discretion in sentencing Pliego-Pineda. View "United States v. Pliego-Pineda" on Justia Law

Scott Rendelman was convicted in 2008 for mailing threatening communications under 18 U.S.C. § 876(c). The district court instructed the jury that the government only needed to prove that a “reasonable person” would find Rendelman’s communications threatening. In 2023, the Supreme Court held in Counterman v. Colorado that the First Amendment requires the government to prove that the defendant was subjectively aware of the threatening nature of his statements. Rendelman now seeks authorization to file a successive 28 U.S.C. § 2255 motion to vacate his conviction based on this new ruling.Previously, the district court denied Rendelman’s first § 2255 motion, and the United States Court of Appeals for the Fourth Circuit declined to authorize a second § 2255 motion. Rendelman’s conviction was affirmed on direct appeal.The United States Court of Appeals for the Fourth Circuit reviewed Rendelman’s motion for authorization to file a successive § 2255 motion. The court concluded that Rendelman satisfied the gatekeeping requirements of 28 U.S.C. § 2255(h), as the Supreme Court’s decision in Counterman announced a new rule of constitutional law that applies retroactively and was previously unavailable to Rendelman. The court rejected the government’s argument that Rendelman must also show a plausible claim for relief, adhering to the standard that a prima facie showing of possible merit is sufficient. Consequently, the Fourth Circuit granted Rendelman’s motion for authorization to file a successive § 2255 motion. View "In re Rendelman" on Justia Law

Jerry Lee Edwards pled guilty to escaping from a re-entry center in Charlotte, North Carolina, where he was completing a 130-month sentence for federal drug and firearm offenses. He left the center for work on April 29, 2023, and did not return, leading to his arrest after a brief police chase. During sentencing, the district court considered a presentence report that calculated ten criminal history points, including three points for a 2008 North Carolina fleeing-to-elude conviction, which initially involved special probation.The United States District Court for the Western District of North Carolina overruled Edwards's objection to the criminal history points. Edwards argued that his 2008 sentence should receive zero points because it did not exceed one year and was imposed over ten years ago. He contended that his original 53-day active term should not be counted separately from the 12-month suspended term. The district court, however, combined the 53-day term and the 12-month term, resulting in a total sentence of 12 months and 53 days, which merited three criminal history points.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The Fourth Circuit found that North Carolina’s special probation statute, N.C. Gen. Stat. § 15A-1351(a), clearly establishes two separate prison terms: an active term and a suspended term. The court held that the district court correctly combined these terms under U.S.S.G. § 4A1.2(k), resulting in a total sentence that exceeded one year and one month, thus justifying the three criminal history points. The Fourth Circuit concluded that the district court properly applied the Sentencing Guidelines and affirmed the 24-month sentence. View "United States v. Edwards" on Justia Law

Dashawn Leonard Garrett pled guilty to three charges related to a drug trafficking investigation in Wilson County, North Carolina, after withdrawing his suppression motion. He later discovered information suggesting police and prosecutorial misconduct, which he argued rendered his plea involuntary. Garrett contended that the misconduct included misidentification by a confidential informant and the use of multiple informants, one of whom was paid and had never identified him.The United States District Court for the Eastern District of North Carolina initially denied Garrett's co-defendant's suppression motion. Garrett withdrew his own motion, fearing it would be risky to proceed, and accepted a plea deal. After his sentencing, Garrett learned from a Government disclosure that multiple confidential informants were used, and one was compensated, which had not been disclosed earlier. This led to his appeal, arguing that the new information would have influenced his decision to plead guilty.The United States Court of Appeals for the Fourth Circuit reviewed the case and found that the newly discovered information about the informants and the misidentification issue constituted egregious police and prosecutorial misconduct. The court held that a reasonable defendant in Garrett's position would not have pled guilty if aware of all the relevant information. The court determined that the misconduct affected the integrity of the prosecution and Garrett's ability to make an informed plea. Consequently, the Fourth Circuit vacated Garrett's guilty plea and remanded the case for further proceedings. View "United States v. Garrett" on Justia Law

Ganesa Rosales, a nurse, filed a False Claims Act (FCA) complaint against Amedisys North Carolina, LLC, Dr. Sanjay Batish, and Batish Medical Service, PLLC, alleging fraudulent practices in admitting and recertifying patients for hospice care who did not meet the requirements. Rosales claimed that these practices were widespread and systematic within the company. She also added a claim under the Anti-Kickback Statute in her amended complaint.The United States District Court for the Eastern District of North Carolina dismissed Rosales's federal claims without prejudice, citing the FCA’s first-to-file rule, which bars subsequent related actions based on the same facts as a pending action. The court declined to exercise supplemental jurisdiction over her state-law claim. Rosales appealed, arguing that her claims were distinct and that the district court should have considered her amended complaint.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The court concluded that the first-to-file rule applies claim-by-claim and defendant-by-defendant, and it should consider the most recent properly filed complaint. However, the court found that Rosales's claims against Amedisys NC, Dr. Batish, and his practice were based on the same material elements of fraud as the earlier-filed complaint by Jackie Byers against Amedisys Holding and its South Carolina subsidiary. The court also noted that Rosales failed to develop an argument distinguishing her Anti-Kickback Statute claim from the earlier complaints.The Fourth Circuit affirmed the district court's dismissal of Rosales's complaint without prejudice for lack of jurisdiction, adhering to its precedent that the first-to-file rule is jurisdictional. View "United States ex rel. Rosales v. Amedisys North Carolina, L.L.C." on Justia Law

Angelo Jackson was identified as a suspect in a double murder in Montgomery County, Maryland, based on information from law enforcement officers. Detective Michael Carin used this information to obtain an arrest warrant for Jackson. After Jackson's arrest, Carin continued the investigation and found exculpatory evidence, including DNA and cellphone records, which led to the charges being dropped and Jackson's release after 65 days of detention.Jackson filed a lawsuit against Carin, alleging that Carin's affidavit for the arrest warrant and his grand jury testimony were deliberately false or made with reckless disregard for the truth. Jackson claimed that if the commissioner and grand jury had been presented with truthful evidence, they would not have found probable cause for his arrest and indictment.The United States District Court for the District of Maryland granted summary judgment in favor of Carin, finding that even with disputed material removed, the affidavit still provided probable cause for Jackson's arrest. The court also found that Carin was protected by qualified immunity on Jackson's federal claims and dismissed Jackson's gross negligence claim under Maryland law.The United States Court of Appeals for the Fourth Circuit affirmed the district court's judgment. The court concluded that Carin did not violate legal standards in his investigation and was shielded by qualified immunity. The court also found that Carin's actions were reasonable and based on information he received from other officers, and that Jackson failed to meet the burden of proving that Carin's statements were false, made with reckless disregard for the truth, or material to the probable cause determination. View "Jackson v. Carin" on Justia Law

Rojay Lawson was involved in a telemarketing sweepstakes scheme based in Jamaica that targeted elderly individuals in the United States. Lawson, operating from South Carolina, collected and laundered the fraudulent proceeds, keeping a portion for himself and sending the rest to his co-conspirators in Jamaica. The scheme defrauded at least 179 victims, most of whom were elderly, out of approximately $720,000. Lawson pleaded guilty to multiple counts, including wire fraud conspiracy, money laundering conspiracy, wire fraud, and mail fraud.The United States District Court for the District of South Carolina sentenced Lawson to 78 months in prison and ordered him to pay $405,401 in restitution. Lawson challenged his sentence, arguing against the application of a vulnerable victim enhancement, the denial of a minor role reduction, and the calculation of the loss amount. The district court overruled his objections, finding that the scheme specifically targeted elderly victims and that Lawson played a significant role in the conspiracy.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the vulnerable victim enhancement was appropriate because the elderly victims were particularly susceptible to the telemarketing fraud, and Lawson knew or should have known about their vulnerability. The court also upheld the denial of a minor role reduction, noting that Lawson's involvement in collecting and laundering the funds was substantial and essential to the scheme. Additionally, the court found no error in the calculation of the loss amount, which was based on actual losses suffered by the victims. The appellate court concluded that Lawson's sentence was both procedurally and substantively reasonable. View "United States v. Lawson" on Justia Law

Javier Chavez Dominguez, a Mexican citizen, was arrested in North Carolina in August 2022 on state drug charges. After confirming his identity and criminal history, he was charged with Illegal Reentry after Removal Subsequent to Conviction for Aggravated Felony under 8 U.S.C. §§ 1326(a), (b)(2). Dominguez pleaded guilty and received a 48-month prison sentence followed by three years of supervised release. He appealed the sentence, presenting new arguments not raised in the district court.The United States District Court for the Middle District of North Carolina handled the initial proceedings. Dominguez faced both state and federal charges, first pleading guilty to state charges and receiving a 10 to 21-month sentence. Upon release, he was detained by ICE and later charged federally. He pleaded guilty to the federal charge without filing any motions and did not object to the presentence investigation report (PSR), which calculated his advisory Guidelines range as 30 to 37 months.The United States Court of Appeals for the Fourth Circuit reviewed the case. Dominguez raised four main challenges: the classification of his 2015 Arizona conviction as an aggravated felony, the constitutionality of his prior removal proceedings, the calculation of his Sentencing Guidelines range, and the substantive reasonableness of his upward variant sentence. The court found no reversible error in the district court's decisions. It held that Dominguez's guilty plea waived his right to challenge the constitutionality of his prior removals and that the district court did not plainly err in its Guidelines calculation or in imposing the upward variant sentence. The court affirmed the district court's judgment. View "US v. Dominguez" on Justia Law

Jarvis Mikel Jackson pled guilty to possession of a firearm as a felon, violating 18 U.S.C. § 922(g)(1). The district court calculated an advisory Sentencing Guidelines range of 110 to 120 months and sentenced Jackson to 115 months in prison. Jackson appealed, arguing that the district court erred in treating his two prior South Carolina drug distribution convictions as "controlled substance offenses" under the Guidelines, which increased his base offense level.Initially, the district court overruled Jackson's objection, distinguishing the South Carolina statute from the West Virginia statute in United States v. Campbell, which did not qualify as a controlled substance offense. The district court adopted the PSR's base offense level and sentenced Jackson to 115 months. Jackson appealed, and the Fourth Circuit vacated his sentence, agreeing that the South Carolina statute included attempted deliveries, making it broader than the Guidelines definition.Before Jackson's resentencing, the Fourth Circuit issued decisions in United States v. Groves and United States v. Davis. Groves held that a federal drug distribution conviction is a controlled substance offense under the Guidelines, while Davis held that South Carolina's statute is materially distinguishable from West Virginia's and qualifies as a controlled substance offense. At resentencing, the district court followed Davis, overruled Jackson's objection, and again sentenced him to 115 months without addressing his arguments for a downward variance based on post-sentencing conduct.The United States Court of Appeals for the Fourth Circuit reviewed Jackson's appeal, agreeing with the district court's reliance on Davis but finding procedural error in the lack of individualized explanation for the sentence. The court vacated Jackson's sentence and remanded for resentencing, requiring the district court to address Jackson's arguments and provide an adequate explanation for the sentence. View "United States v. Jackson" on Justia Law

Stephen Bryant was sentenced to death by a South Carolina state court. During postconviction proceedings, Bryant filed a new application for relief, claiming his execution would violate the Eighth Amendment due to his intellectual disabilities, as defined in Atkins v. Virginia and Hall v. Florida. Later, Bryant sought to amend his application to include a claim that he suffers from fetal alcohol spectrum disorder (FASD) and that executing individuals with FASD should also be prohibited under the Eighth Amendment. The state postconviction court denied this request, ruling it was both impermissibly successive and filed too late.Bryant's initial appeal to the South Carolina Supreme Court, which focused on a single claim of evidentiary error, was denied. He then sought post-conviction relief on several grounds, none of which included the Eighth Amendment claim. The state trial court denied these claims, and the South Carolina Supreme Court denied discretionary review. Bryant subsequently filed for federal habeas corpus relief, which was stayed to allow him to exhaust state remedies. He filed two new applications in state court, one of which was allowed to proceed on the intellectual disability claim but not on the FASD claim. The state trial court ultimately denied the intellectual disability claim on its merits.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the state trial court's refusal to permit Bryant to amend his application to add the FASD claim rested on state procedural grounds that were independent of federal law and adequate to bar federal habeas review. The Fourth Circuit affirmed the district court's denial of habeas relief, concluding that Bryant's FASD claim was procedurally defaulted and could not be considered on its merits. View "Bryant v. Stirling" on Justia Law