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

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

Lisa Wheeler, a physician assistant and former Assistant Medical Director at Acadia Healthcare Company’s Asheville, North Carolina clinic, filed a complaint alleging that Acadia falsified medical records to claim payments from government healthcare programs. Wheeler claimed that Acadia, which provided methadone-assisted treatment for opioid use disorder, failed to provide required therapy and counseling services, instead fabricating therapy notes to submit fraudulent claims to Medicare, Medicaid, and other government programs.The United States District Court for the Western District of North Carolina dismissed Wheeler’s amended complaint, concluding that she failed to adequately plead that Acadia’s false claims were material or submitted to the government. The court found that Wheeler did not sufficiently allege that Acadia’s failure to provide therapy was material to the government’s payment decisions or that false claims were actually submitted to the government.The United States Court of Appeals for the Fourth Circuit reviewed the case and reversed the district court’s decision. The Fourth Circuit held that Wheeler adequately pled her claims of presentment, false statement, false certification, and fraudulent inducement under the False Claims Act. The court found that Wheeler’s allegations of falsified therapy notes and non-compliance with federal opioid treatment standards were material to the government’s payment decisions. The court also concluded that Wheeler sufficiently alleged that Acadia submitted false claims to government healthcare programs and that the fraudulent conduct was central to the government’s decision to pay.Additionally, the Fourth Circuit held that Wheeler adequately pled her reverse false claim, finding that the stipulated penalties in Acadia’s Corporate Integrity Agreement with the government constituted an obligation under the False Claims Act. The court remanded the case for further proceedings consistent with its opinion. View "United States ex rel. Wheeler v. Acadia Healthcare Company, Inc." on Justia Law

Environmental groups challenged the issuance of a permit by the U.S. Army Corps of Engineers for the development of the Cainhoy Plantation in South Carolina. The plaintiffs argued that the permit violated the Endangered Species Act (ESA) and the National Environmental Policy Act (NEPA). They claimed the permit improperly used a habitat surrogate to set the level of anticipated take of an endangered species and was issued after an Environmental Assessment (EA) rather than a more comprehensive Environmental Impact Statement (EIS).The United States District Court for the District of South Carolina denied the plaintiffs' motion for a preliminary injunction, finding that they did not have a sufficient likelihood of success on the merits of their claims. The court concluded that the Corps' decision to issue the permit based on an EA was reasonable and that the use of a habitat surrogate was justified under the circumstances.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The Fourth Circuit held that the Corps had taken the required "hard look" at the environmental consequences of the project as mandated by NEPA and that the use of a habitat surrogate was appropriate given the impracticality of monitoring the take of individual bats. The court found that the Corps' decision to rely on an EA instead of preparing an EIS was entitled to deference and that the plaintiffs had not demonstrated a likelihood of success on the merits of their claims. The court also noted that the surrogate used by the Service was enforceable and set a clear standard for determining when the level of anticipated take had been exceeded. View "South Carolina Coastal Conservation League v. United States Army Corps of Engineers" on Justia Law

The Pharmaceutical Coalition for Patient Access (the Coalition), a charitable organization involving drug manufacturers, challenged an unfavorable advisory opinion issued by the Office of the Inspector General (OIG) for the U.S. Department of Health and Human Services (HHS). The dispute centered on the Coalition’s proposed patient assistance program for Medicare beneficiaries, which aimed to subsidize co-pays for oncology drugs. The OIG determined that the program would violate the Anti-Kickback Statute if the required mens rea were present, as it would offer remuneration to induce the purchase of specific drugs.The United States District Court for the Eastern District of Virginia granted summary judgment in favor of the defendants, the United States, HHS, and related officials, and dismissed the Coalition’s claims. The court found that the OIG’s advisory opinion was not arbitrary or capricious and that the Coalition’s program would indeed fall within the Anti-Kickback Statute’s prohibitions.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The court affirmed the district court’s decision, agreeing that the word “induce” in the Anti-Kickback Statute should be construed under its ordinary meaning, not its specialized criminal law meaning. The court also concluded that “remuneration” in the statute includes any payment or compensation, not just corrupt payments that distort medical decision-making. The court found that the Coalition’s program involved a quid pro quo, as it offered subsidies for the purchase of specific drugs.The Fourth Circuit also upheld the district court’s dismissal of the Coalition’s disparate treatment claim for lack of subject matter jurisdiction, ruling that the OIG’s enforcement discretion is not subject to judicial review. The court concluded that the OIG had consistently applied the Anti-Kickback Statute to similar proposals and that the Coalition’s challenge was directed against the OIG’s enforcement discretion, which is unreviewable under the Administrative Procedure Act. View "Pharmaceutical Coalition for Patient Access v. United States" on Justia Law

Courthouse News Service, a news organization, sought remote online access to civil court records from the Circuit Court for Prince William County, Virginia, similar to the access granted to Virginia attorneys. Virginia law prohibits the clerk from providing such access to non-attorneys. Courthouse News sued, claiming this restriction violated its First Amendment and Equal Protection rights.The United States District Court for the Eastern District of Virginia dismissed Courthouse News's Equal Protection claim and granted summary judgment for the defendants on the First Amendment claims. The court found the restrictions to be content-neutral time, place, and manner regulations justified by the state's interests in the orderly administration of justice and protecting sensitive personal information.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court's ruling on the First Amendment and Equal Protection claims, holding that the access restriction was a content-neutral regulation narrowly tailored to serve significant governmental interests. The court found that the restriction did not violate the First Amendment as it provided ample alternative channels for accessing court records and did not burden more access than necessary. The court also concluded that the restriction did not violate the Equal Protection Clause for the same reasons it passed First Amendment scrutiny.However, the court vacated the district court's ruling on the Dissemination Restriction claim, finding that Courthouse News lacked standing to challenge it since the restriction only applied to those with remote access, which Courthouse News did not have. The case was remanded for the district court to dismiss this claim without prejudice. View "Courthouse News Service v. Smith" on Justia Law

Danny Fox, an active-duty servicemember, purchased a property in Norfolk, Virginia, in 2015. The City of Norfolk determined the property was unsafe and uninhabitable, repeatedly notifying Fox of building code violations. Despite these notices, Fox did not make the necessary repairs. In December 2018, the city demolished the house, deeming it a public nuisance. Fox subsequently sued the city, claiming inverse condemnation, among other things, arguing the property was not a nuisance and that the city's actions were pretextual to increase its tax base.The United States District Court for the Eastern District of Virginia granted summary judgment in favor of the city. The court held that Fox's federal constitutional claims were barred by the statute of limitations. It also ruled that Fox's inverse condemnation claim failed because, whether or not the property was a nuisance, he could not demonstrate the city's public use requirement. The court found no evidence to support Fox's claim that the city's actions were pretextual.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The appellate court agreed that Fox's inverse condemnation claim failed regardless of whether the property was a nuisance. If the property was a nuisance, the city had the authority to abate it without compensation. If it was not a nuisance, Fox could not show a public use, a necessary element for an inverse condemnation claim. The court also found that Fox provided no evidence to support his pretext argument. Thus, the court affirmed the district court's grant of summary judgment for the city. View "D.A. Realestate Investment, LLC v. City of Norfolk" on Justia Law

Three plaintiffs, including a Virginia citizen, a Virginia entity, and an out-of-state entity, challenged Virginia Senate Bill 903, which regulates the retail sale of hemp products based on their total tetrahydrocannabinol (THC) concentration. The plaintiffs argued that the 2018 Farm Bill, which legalized hemp with a delta-9 THC concentration of no more than 0.3%, preempts the more restrictive Virginia law. They also claimed that the Virginia law violates the Dormant Commerce Clause of the U.S. Constitution.The United States District Court for the Eastern District of Virginia denied the plaintiffs' motion for a preliminary injunction. The court found that the plaintiffs were unlikely to succeed on their preemption arguments, as the 2018 Farm Bill does not expressly preempt state laws regulating hemp more stringently. The court also concluded that the plaintiffs did not sufficiently allege that they were licensed processors under Virginia law, thus lacking standing to challenge the provision preventing Virginia processors from selling hemp products to others who would use them in violation of the total THC standard. Additionally, the court rejected the plaintiffs' Dormant Commerce Clause claims, finding no evidence that the Virginia law discriminates against or unduly burdens interstate commerce.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court agreed with the district court that the plaintiffs lacked standing to challenge the sales restriction provision, as they did not allege sufficient facts showing they were licensed processors. The court vacated the district court's order regarding this claim and remanded with instructions to dismiss it without prejudice. However, the court affirmed the district court's denial of injunctive relief concerning the total THC standard, finding that the plaintiffs failed to show a likelihood of success on their preemption and Dormant Commerce Clause claims. View "Northern Virginia Hemp and Agriculture, LLC v. Commonwealth of Virginia" on Justia Law

A service-disabled veteran and his company, MJL Enterprises, LLC, alleged that the Small Business Administration’s (SBA) Section 8(a) Business Development Program discriminated against him based on race. The program uses a race-conscious presumption to determine social disadvantage, which the plaintiffs argued was unconstitutional. They sought a declaration that the program's racial classifications were unconstitutional and an injunction against its enforcement.The United States District Court for the Eastern District of Virginia dismissed the case, ruling it moot due to changes in the 8(a) Program following an injunction in another case, Ultima Services Corp. v. U.S. Department of Agriculture. The district court also found that the plaintiffs lacked standing because they failed to demonstrate economic disadvantage and could not establish social disadvantage without the presumption.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court reversed the district court’s ruling on mootness, agreeing with the plaintiffs that the case was not moot because the changes to the 8(a) Program were not final and could be appealed. However, the Fourth Circuit affirmed the district court’s dismissal based on lack of standing. The court held that the plaintiffs failed to demonstrate an injury in fact, as they did not show they were "able and ready" to bid on 8(a) Program contracts due to their inability to meet the program’s social and economic disadvantage requirements. The court also found that the plaintiffs could not establish causation or redressability, as their ineligibility for the program was not solely due to the race-conscious presumption.The Fourth Circuit concluded that the plaintiffs lacked Article III standing to sue and affirmed the district court’s dismissal for lack of subject matter jurisdiction. The case was remanded for further proceedings consistent with the opinion. View "Hierholzer v. Guzman" on Justia Law

Jerry L. Blankenship applied for living miner benefits under the Black Lung Benefits Act, claiming he suffered from coal dust-induced pneumoconiosis and was totally disabled. An Administrative Law Judge (ALJ) found Blankenship entitled to a rebuttable presumption of total disability due to pneumoconiosis under 30 U.S.C. § 921(c)(4) and determined that his former employer, Island Creek Coal Company, failed to rebut this presumption. Consequently, Blankenship was awarded benefits. The Benefits Review Board affirmed the ALJ’s decision.Island Creek petitioned for review, arguing that the ALJ improperly conflated the presence of pneumoconiosis and disability causation with the separate total disability analysis. Additionally, Island Creek contended that the ALJ failed to adequately explain his decision to credit the opinions of Blankenship’s medical experts over those of Island Creek’s experts.The United States Court of Appeals for the Fourth Circuit reviewed the case and agreed with Island Creek. The court found that the ALJ improperly relied on the presence of pneumoconiosis and the causation of Blankenship’s impairment in concluding that he was totally disabled. The court also determined that the ALJ failed to provide a sufficient explanation for crediting the medical opinions of Drs. Nader and Green over those of Drs. McSharry and Sargent, violating the duty of explanation under the Administrative Procedure Act.The Fourth Circuit granted Island Creek’s petition for review, vacated the decision of the Benefits Review Board, and remanded the case with instructions for the Board to return Blankenship’s case to the ALJ for reconsideration consistent with the court’s opinion. View "Island Creek Coal Co. v. Blankenship" on Justia Law

The plaintiffs in this case are retail pet stores, a dog broker, and a dog breeder who want to sell dogs through physical retail stores in Maryland. However, a Maryland law restricts their ability to do so. The plaintiffs sued, alleging that the Maryland statute is preempted by the federal Animal Welfare Act (AWA) and violates the Commerce Clause of the United States Constitution.The United States District Court for the District of Maryland dismissed the plaintiffs' complaint, concluding that they failed to state plausible claims. The plaintiffs then appealed to the United States Court of Appeals for the Fourth Circuit.The Fourth Circuit reviewed the case de novo and affirmed the district court's decision. The court held that the AWA does not preempt the Maryland statute because the AWA expressly contemplates state and local regulation on the same subject. The court also found that the Maryland statute does not pose an impermissible obstacle to achieving the purposes and objectives of the AWA.Regarding the Commerce Clause claims, the court held that the Maryland statute does not discriminate against interstate commerce in purpose or effect. The statute applies equally to in-state and out-of-state breeders and brokers, and it does not prohibit the flow of interstate goods or place added costs upon them. The court also found that the statute does not violate the Pike balancing test because the plaintiffs failed to plausibly allege that the statute imposes a substantial burden on interstate commerce that is clearly excessive in relation to its putative local benefits.In conclusion, the Fourth Circuit affirmed the district court's dismissal of the plaintiffs' complaint, holding that the Maryland statute is not preempted by the AWA and does not violate the Commerce Clause. View "Just Puppies, Inc. v. Brown" on Justia Law