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

Articles Posted in Government & Administrative Law
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In 2018, Maryland State Trooper Kevin Caraballo used force while arresting 15-year-old Cameron Lewis. Lewis sued Caraballo for excessive force and battery. Caraballo sought summary judgment, arguing he was entitled to qualified and statutory immunity. The district court denied his motion, leading to this appeal.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court found that there were disputes of material fact that precluded summary judgment. Specifically, a reasonable jury could find that Caraballo struck Lewis when the teenager did not pose a threat, was not actively resistant, and was subdued. The court held that Lewis’s constitutional right to be free from excessive force in the form of head strikes was clearly established at the time of his arrest. Furthermore, the court held that there was a genuine dispute of material fact as to whether Caraballo’s actions amounted to gross negligence or malice, precluding summary judgment in his favor on his statutory immunity defense. View "Lewis v. Caraballo" on Justia Law

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The case involves Vanda Pharmaceuticals, a drug manufacturer, and the Centers for Medicare & Medicaid Services (CMS). Vanda challenged a 2020 regulation by CMS that expanded the definition of a "line extension" drug under the Medicaid Drug Rebate Program. This program requires drug manufacturers to reimburse Medicaid if they increase their prices faster than inflation. A "line extension" drug, which is a new formulation of an existing drug, can also be liable for price increases of the original drug. Vanda argued that the regulation expanded the definition of a line extension beyond what the Medicaid statute permitted.Previously, the district court granted summary judgment to CMS, disagreeing with Vanda's argument. The court held that the agency's regulation was within the bounds of the Medicaid statute.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court found that the agency's definitions of "line extension" and "new formulation" were within the Medicaid statute's ambit. It also held that the agency's interpretation of the oral-solid-dosage-form requirement was not contrary to law. The court rejected Vanda's argument that the agency's rulemaking process was arbitrary and capricious, finding that the agency had reasonably considered the relevant issues and explained its decision. View "Vanda Pharmaceuticals, Inc. v. Centers for Medicare & Medicaid Services" on Justia Law

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The case involves Saleh Shaiban, a Yemeni national who entered the U.S. in 1999 using a false passport and B-2 visitor visa. He was eventually granted asylum in 2006. He subsequently applied for adjustment of status to U.S. Citizenship and Immigration Services (USCIS), which was denied on terrorism grounds. Shaiban appealed the decision but the U.S. Court of Appeals for the Fourth Circuit concluded that it lacked jurisdiction over his appeal and dismissed it.Shaiban initially applied for asylum in December 2000, but his application was denied in 2002. He appealed to the Board of Immigration Appeals, which also dismissed his appeal. The U.S. Court of Appeals for the Second Circuit remanded his case to a new Immigration Judge for a de novo hearing, which resulted in his asylum grant.In 2008, Shaiban applied for permanent residence. USCIS put his case on hold in 2013 due to terrorism-related grounds of inadmissibility under the Immigration and Nationality Act. In 2018, USCIS denied his application after determining that his participation in certain Yemeni organizations qualified as terrorist activities.Shaiban filed a suit under the Administrative Procedures Act to compel adjudication of his application for permanent residence. He argued that the government was collaterally estopped from denying his application since his previous asylum grant had determined that the terrorism bar did not apply. However, the district court granted the government’s motion for summary judgment, leading to Shaiban’s appeal to the Fourth Circuit.The Fourth Circuit declared that it lacked jurisdiction to hear Shaiban's case, pointing to 8 U.S.C. § 1252, which identifies when courts of appeals have jurisdiction to review claims from noncitizens, and 8 U.S.C. § 1159(b), which states that the decision to adjust the status of a noncitizen granted asylum lies in the discretion of the Secretary of Homeland Security and the Attorney General of the United States. The court determined that the plain language of the statutes and the Supreme Court’s precedential interpretation in Patel v. Garland led to the conclusion that the court did not have jurisdiction over Shaiban’s appeal. View "Shaiban v. Jaddou" on Justia Law

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The United States Court of Appeals for the Fourth Circuit ruled on a case involving a plaintiff, Joann Ford, and a healthcare provider, Sandhills Medical Foundation, Inc. Ford, a former patient of Sandhills, alleged negligence, breach of implied contract, invasion of privacy, and breach of confidentiality against Sandhills for failure to protect her personally identifying information (PII). Her PII was stolen from Sandhills' third-party computer system in a cyberattack after she had ceased being a patient.The district court had previously granted Sandhills immunity from the suit, concluding that the theft of Ford's PII arose out of Sandhills' performance of “medical, surgical, dental, or related functions,” as per 42 U.S.C. § 233(a), thus substituting the United States as the defendant. However, the Fourth Circuit Court disagreed with the lower court's interpretation of § 233(a).The appellate court determined that data security does not fall under a “related function” within the meaning of the statute. The court emphasized that § 233(a) immunity applies when alleged damages arise from the provision of healthcare, which was not the case here. Ford’s injury did not arise from Sandhills’ provision of healthcare, but from a data security breach that occurred at least a year after she ceased being a patient at Sandhills.Therefore, the court concluded that Sandhills was not immune from the suit under § 233(a) and that the United States could not be substituted as the defendant. The case was vacated and remanded for further proceedings. View "Ford v. Sandhills Medical Foundation, Inc." on Justia Law

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The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision that the Federal Bureau of Investigation (FBI) could withhold records relating to a criminal investigation based on Exemption 7(A) of the Freedom of Information Act (FOIA). This exemption allows federal agencies to withhold records if their release could reasonably be expected to interfere with law enforcement proceedings.In the case, Mark Zaid, an attorney, requested records related to the FBI's criminal investigation into one of his clients, Zackary Sanders, who had been charged with production and possession of child pornography. The FBI refused to release the requested records, citing Exemption 7(A) of FOIA. Zaid then sued the FBI to release the records, but the district court found the records were exempt from disclosure.The appeals court agreed with the district court's decision, stating that the disclosure of these records could reasonably be expected to interfere with ongoing or future investigations and prosecutions of child pornography cases. The court also noted that forcing the FBI to disclose information exchanged between law enforcement agencies could make those agencies hesitant to share information in the future, which would harm FBI investigations. The court also dismissed Zaid's arguments that cited two decisions from the Middle District of Florida, stating those decisions were not binding on the district court or the appeals court. View "Zaid v. Department of Justice" on Justia Law

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In this case, the plaintiff, Ricky Pendleton, is an inmate in the West Virginia prison system who follows the "Sufi Original Traditions" of Islam. His religious beliefs require a diet that promotes "compassion and harmlessness to living creatures," which he interprets to mean a diet of "vegetables, fruits and certain fish." In 2014, prison officials introduced a new diet program for those with religious dietary restrictions. However, the program only offered one "religious special diet" designed to meet the needs of all faiths by following the rules of the most diet-restrictive ones. This diet used soy as its primary protein source, which Pendleton's body had problems digesting. Pendleton requested a religious accommodation, but this request was denied. He filed two grievances, which were also denied. Pendleton then filed a pro se complaint against three prison officials. The district court dismissed Pendleton’s complaint, concluding he had not adequately alleged he was being forced to consume any foods forbidden by his religion.The United States Court of Appeals for the Fourth Circuit vacated and remanded the district court's judgment. The court held that Pendleton had plausibly alleged that prison officials imposed a substantial burden on his religious practice by forcing him to choose between a government-provided benefit (the diet) and his religious convictions. The court also rejected the argument that Pendleton could obtain a meat-free and soy-free diet by obtaining test results showing he has a medically significant allergy to soy. The court concluded that Pendleton need not produce documentation of his alleged soy allergy to survive a motion to dismiss. Instead, it was enough that he had plausibly alleged that he cannot digest soy and that he suffered gastrointestinal distress after switching to the religious special diet. The court also held that Pendleton’s Free Exercise Clause claim and his motion to be severed from the prison’s diet program should be reconsidered by the district court. View "Pendleton v. Jividen" on Justia Law

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This case was before the United States Court of Appeals for the Fourth Circuit where the City of Huntington and Cabell County Commission (plaintiffs) brought a suit against AmerisourceBergen Drug Corporation, Cardinal Health, Inc., and McKesson Corporation (defendants), three distributors of opioids. The plaintiffs alleged that these companies perpetuated the opioid epidemic by repeatedly shipping excessive quantities of opioids to pharmacies, thus creating a public nuisance under West Virginia common law. The district court ruled in favor of the distributors, holding that West Virginia’s common law of public nuisance did not cover the plaintiffs’ claims.After a bench trial in 2021, the district court held that the common law of public nuisance in West Virginia did not extend to the sale, distribution, and manufacture of opioids. The court found that the application of public nuisance law to the sale, marketing, and distribution of products would invite litigation against any product with a known risk of harm, regardless of the benefits conferred on the public from proper use of the product. The court also rejected the plaintiffs’ proposed remedy, a 15-year “Abatement Plan” developed by an expert in opioid abatement intervention. The court held that this relief did not qualify as an abatement as it did not restrict the defendants' conduct or their distribution of opioids but generally proposed programs and services to address the harms caused by opioid abuse and addiction.The plaintiffs appealed the decision to the United States Court of Appeals for the Fourth Circuit, which certified the following question to the Supreme Court of Appeals of West Virginia: Under West Virginia’s common law, can conditions caused by the distribution of a controlled substance constitute a public nuisance and, if so, what are the elements of such a public nuisance claim? View "City of Huntington v. Amerisourcebergen Drug Corporation" on Justia Law

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The United States Court of Appeals for the Fourth Circuit upheld the convictions of three South Carolina law enforcement officers who were found guilty of various abuses of power. The trio, Sheriff George Underwood, Chief Deputy Robert Sprouse, and Lieutenant Johnny Neal, were convicted on multiple counts, including financial corruption, civil rights violations, and conspiracy.Underwood used his position as sheriff to enrich himself through illegal means, including forcing deputies to perform work on his personal property while on public payroll. He also orchestrated a scheme with Neal to skim money from the extra compensation meant for deputies at drunk-driver checkpoints. Additionally, Underwood and Sprouse misused county money for personal travel expenses.The court also found that Underwood abused his authority by targeting enforcement against opponents and refusing to investigate offenses reported against friends and supporters. Notably, Underwood unlawfully arrested a citizen for recording a car accident scene, which led to a violation of the citizen's civil rights.After the Federal Bureau of Investigation uncovered the corruption, Sprouse and Neal conspired to lie and fabricate documents to cover up their misconduct. The jury convicted the defendants on various counts, and the appeals court affirmed those convictions. The court also ruled that the district court's calculation of restitution for the losses sustained was reasonable. View "United States v. Underwood" on Justia Law

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In this case, the plaintiffs filed a lawsuit against the United States under the Federal Tort Claims Act (FTCA) alleging negligence, wrongful death, and survival claims arising from the death of Eleusipa Van Emburgh who was treated at a Navy medical center. The United States District Court for the Eastern District of Virginia dismissed the plaintiffs' claims for lack of subject matter jurisdiction. The plaintiffs appealed this decision.The United States Court of Appeals for the Fourth Circuit held that regulations enacted under 28 U.S.C. § 2672 do not impose additional jurisdictional requirements beyond those listed in 28 U.S.C § 2675. As such, the court reversed the district court's decision for six of the plaintiffs and remanded the case for further proceedings. However, the court affirmed the dismissal of one plaintiff, Imelda Crovetto, who failed to satisfy one of the jurisdictional requirements listed in § 2675.The Court of Appeals held that the jurisdictional requirements laid out in 28 U.S.C. § 2675 were the sole source of jurisdictional requirements for the FTCA’s administrative exhaustion requirement. The court found that the implementing regulations did not impose additional jurisdictional requirements. The plaintiffs satisfied these jurisdictional requirements when they submitted their claims to the agency, included a specific valuation of their claims, and waited until after their claims were denied before filing suit. View "Estate of Eleusipa Van Emburgh v. US" on Justia Law

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The case involved Martin William Luther Hamilton, who pleaded guilty to one count of possession with intent to distribute fentanyl and one count of unlawful possession of a firearm by a felon. The probation agent preparing Hamilton's presentence report determined that three of Hamilton’s prior North Carolina convictions qualified as violent felonies under the Armed Career Criminal Act (ACCA), which mandates a minimum of fifteen years for defendants who have three prior convictions for offenses that qualify as a “violent felony or a serious drug offense.”Hamilton objected to the ACCA classification, disputing that the third conviction for attempted robbery with a dangerous weapon met the requirements of the ACCA. The district court followed a previous court's unpublished decision which held that a North Carolina conviction for attempted robbery with a dangerous weapon qualifies as a crime of violence for purposes of the career-offender provisions of the Sentencing Guidelines. As a result, the court concluded that Hamilton qualified as an armed career criminal and sentenced him to 180 months’ imprisonment.Hamilton appealed, challenging only the district court’s determination that the attempted robbery conviction was a predicate offense under the ACCA. In response, the United States Court of Appeals for the Fourth Circuit affirmed the district court's decision, finding no error in the determination that Hamilton’s conviction under N.C. Gen. Stat. 14-87(a) qualifies as a violent felony for purposes of the ACCA. View "US v. Hamilton" on Justia Law