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

Mountain Valley Pipeline, LLC sought to condemn a 9.89-acre easement on Elizabeth Reynolds' 109-acre farmland in Roanoke County, Virginia, under the Natural Gas Act. The district court granted partial summary judgment and a preliminary injunction for immediate possession to Mountain Valley Pipeline, leaving the issue of just compensation unresolved. Reynolds submitted two expert reports to determine compensation, which the district court excluded, leading to a summary judgment in favor of Mountain Valley Pipeline.The United States District Court for the Western District of Virginia excluded Reynolds' expert reports, citing Rule 71.1(h) and Rule 702. The court found the first report speculative and the second unreliable due to insufficient data. Consequently, the court granted summary judgment to Mountain Valley Pipeline, awarding just compensation based on the higher estimate of the pipeline company's experts.The United States Court of Appeals for the Fourth Circuit reviewed the case and found that the district court erred in its application of Rule 71.1(h) and Rule 702. The appellate court held that the Federal Rules of Evidence should apply identically in eminent domain cases as in other cases, and the district court should not have conflated Rule 71.1(h) with Rule 702. The appellate court also determined that the district court should have made findings of fact and conclusions of law on the record when resolving contested factual issues under Rule 71.1(h). The Fourth Circuit vacated the district court's decision and remanded the case for further proceedings consistent with its opinion. View "Mountain Valley Pipeline, LLC v. 9.89 Acres of Land" on Justia Law

Mountain Valley Pipeline, LLC (MVP) condemned a 0.32-acre access easement on Grace Terry's land in southwestern Virginia to deliver heavy equipment to a section of its pipeline. The key issue in this case is the amount of just compensation MVP must pay Terry for the easement. Terry argued that the easement significantly devalued her land, blocking the best hiking trail and citing recent below-market sales of neighboring properties affected by MVP's actions. The district court excluded Terry's testimony on damages and an expert report she submitted, leading to her appeal.The United States District Court for the Western District of Virginia granted MVP partial summary judgment and a preliminary injunction for immediate possession of the easement. The court excluded Terry's testimony on damages, finding it speculative and without a rational basis. It also excluded the expert report by Dennis Gruelle, applying a heightened admissibility standard and determining contested facts at the evidentiary stage. The court then granted MVP summary judgment, awarding Terry $10,409 in just compensation.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the district court abused its discretion by excluding most of Terry's testimony and the Gruelle Report. The Fourth Circuit found that Terry's personal knowledge of her land and comparable sales were valid bases for her testimony. It also determined that the district court applied erroneous legal principles by using a heightened evidentiary standard for the expert report. The Fourth Circuit vacated the exclusion of the Gruelle Report and reversed the exclusion of most of Terry's testimony, remanding the case for further proceedings consistent with its opinion. View "Mountain Valley Pipeline, LLC v. 0.32 Acres of Land" on Justia Law

Phillip and Sara Alig, along with Daniel and Roxanne Shea, filed a class action lawsuit against Quicken Loans, Inc. (now Rocket Mortgage, LLC) and Title Source, Inc. (now Amrock, Inc.). They alleged that during the refinancing of their home mortgage loans, they paid for appraisals that were not independent because the defendants had provided appraisers with the homeowners' estimates of their homes' value. They claimed this made the appraisals worthless and asserted statutory, breach of contract, and conspiracy claims.The United States District Court for the Northern District of West Virginia certified a class of West Virginia citizens who refinanced mortgage loans with Quicken and received appraisals that included an estimate of the property's value. The court granted summary judgment to the plaintiffs, awarding over $10.6 million in damages. The court found that the plaintiffs had established a conspiracy between the defendants.The United States Court of Appeals for the Fourth Circuit affirmed the class certification and summary judgment on the statutory and conspiracy claims but vacated and remanded the breach of contract claim. The Supreme Court vacated the Fourth Circuit's judgment and remanded the case for reconsideration in light of TransUnion LLC v. Ramirez, which emphasized that every class member must have Article III standing to recover damages.On remand, the district court reinstated its original judgment, stating that TransUnion did not affect the class's standing. However, the Fourth Circuit concluded that the plaintiffs failed to establish that class members suffered concrete harm from the defendants' actions. The court reversed the district court's judgment certifying the class and awarding damages, affirming the judgment on the named plaintiffs' statutory and conspiracy claims, and vacating the judgment on the breach of contract claim, remanding it for further proceedings. View "Alig v. Rocket Mortgage, LLC" 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

The case involves Andris Pukke, Peter Baker, and John Usher, who were found liable for violations of the Federal Trade Commission Act, the Telemarketing Sales Rule, and a permanent injunction from a prior fraud case. They were involved in a real estate scam, selling lots in a development called "Sanctuary Belize" through deceptive practices. The district court issued an equitable monetary judgment of $120.2 million for consumer redress, imposed an asset freeze, and appointed a receiver.The United States District Court for the District of Maryland found the defendants liable after a bench trial and issued permanent injunctions against them. The court also held them in contempt for violating a prior judgment in a related case, ordering them to pay the same $120.2 million in consumer redress. The defendants appealed, and the United States Court of Appeals for the Fourth Circuit affirmed the district court's decision, except for vacating the monetary judgment to the extent it relied on FTC Act Section 13(b).The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision to maintain the receivership and asset freeze. The court held that the receivership and asset freeze were necessary to effectuate the injunctive relief and ensure that the defendants did not continue to profit from their deceptive practices. The court also found that the contempt judgment supported maintaining the receivership and asset freeze until the judgment was satisfied. The court emphasized the defendants' history of deceptive conduct and the need for a professional receiver to manage and distribute the assets to defrauded consumers. The judgment was affirmed. View "Federal Trade Commission v. Pukke" on Justia Law

The case revolves around a dispute between the Estate of Ke Zhengguang and Stephany Yu, concerning the enforcement of an arbitral award issued in Hong Kong. The award was the result of a business dispute involving real estate in China. The arbitration panel ordered Yu and her two sisters to pay the Estate and Xu Hongbiao a sum of money for the losses they sustained. After Yu paid Xu his share, the Estate sought to collect the remaining half from Yu, a U.S. citizen residing in Maryland.Yu challenged the enforcement of the award in the District Court of Maryland, arguing that the court was an inconvenient forum, that necessary parties were not included in the proceedings, and that enforcing the award would violate Chinese currency control laws, thereby violating U.S. policy favoring international comity. She also argued that the judgment should be in Renminbi (RMB), as provided in the arbitral award, not in U.S. dollars. The district court rejected all of Yu's arguments and confirmed the award under the New York Convention, entering judgment in favor of the Estate against Yu in a total amount of $3.6 million.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court found none of Yu's arguments persuasive and held that the district court was correct in confirming and enforcing the arbitral award. The court also held that the district court did not err in entering the judgment in U.S. dollars, as it was within its discretion to do so. View "In re Estate of Ke Zhengguang v. Yu" on Justia Law

Adams Outdoor Advertising Limited Partnership, a company that constructs, manages, designs, and repairs billboards, clashed with Beaufort County over the county's billboard policy. The county sought to phase out billboards within its borders by prohibiting the construction of new billboards and restricting structural repairs of old ones. Adams was issued a criminal citation for performing structural repairs on two old billboards without seeking authorization. Additionally, Adams filed eleven applications requesting permits to construct new commercial billboards with digital displays, each of which was denied. Adams sought to challenge Beaufort County’s local ordinance regulating billboards, along with several other local sign regulations.The district court dismissed all of Adams’s claims with prejudice. The claims related to the criminal citation were dismissed under the Younger abstention doctrine, and those related to the permit denials were dismissed for lack of jurisdiction. Adams appealed the decision.The United States Court of Appeals for the Fourth Circuit agreed with each of the district court’s dismissal determinations. However, it noted that the claims dismissed for lack of jurisdiction should have been dismissed without prejudice. The court remanded those claims with the instruction that their dismissal be amended to dismissal without prejudice. The court also found that Adams did not have standing to challenge certain provisions of the county's sign ordinance, as it had not demonstrated that it had been adversely affected by those provisions. The court concluded that the case belongs in state court due to the state's interest in land-use planning and development, the ongoing state court proceedings, and the jurisdictional hurdles faced by Adams. View "Adams Outdoor Advertising Limited Partnership v. Beaufort County" on Justia Law

The Ministry of Defence of the State of Kuwait entered into three contracts with Joseph M. Naffa and his fictitious law firm, Naffa & Associates, LLP, for legal advice and representation in real estate transactions. The Ministry later discovered that Naffa was not authorized to practice law in the United States and that he had kept a credit meant for the Ministry from one of the real estate transactions. The Ministry sued Naffa and his firm for breach of contract and conversion of funds.The United States District Court for the Eastern District of Virginia dismissed the Ministry's claims under Rule 12(b)(1), ruling that the Ministry had not pleaded damages sufficient to meet the amount in controversy requirement for federal court jurisdiction. The court also held that the agreements did not require Naffa to be a licensed attorney and that the Ministry could not show that it did not receive legal advice or that its outcome would have been different if it was represented by a licensed attorney.The United States Court of Appeals for the Fourth Circuit reversed the district court's decision. The appellate court held that the district court erred in dismissing the Ministry's claims for lack of subject matter jurisdiction because the complaint contained sufficient allegations to invoke the court's diversity jurisdiction. The court concluded that the Ministry had pleaded damages of at least $635,000, an amount that substantially exceeds the statutory minimum for federal court jurisdiction. The court vacated all other determinations made by the district court and remanded the case for further proceedings. View "Ministry of Defence of the State of Kuwait v. Naffa" on Justia Law

The case involves Marshall and Tiffany Todman, who were evicted from their rental property in Baltimore. According to the Baltimore City Code, any personal property left in or around the premises after eviction is immediately considered abandoned, and the landlord takes ownership. The Todmans were evicted earlier than expected and lost their belongings under this ordinance. They sued the Mayor and City Council of Baltimore, alleging that the city had deprived them of their personal property without due process in violation of the Fourteenth Amendment. The district court agreed and granted summary judgment in favor of the Todmans.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court found that the Todmans were owed more process than they received and that the city was responsible for that failure of process. The court held that the city's Abandonment Ordinance violated the Todmans' constitutional rights by depriving them of their property without due process of law and that the city is liable for that violation. The court also dismissed the Todmans' conditional cross-appeal, which asked the court to review the district court's dismissal of their takings claim if the court found their due process claims lacked merit. View "Todman v. The Mayor and City Council of Baltimore" on Justia Law

The case revolves around a dispute over a 15,000 square foot vacation home, the Chesapeake, located in Currituck County, North Carolina. The home is owned by Elizabeth LeTendre and has been the subject of litigation for over a decade regarding its compliance with county and state zoning requirements. The home's design includes a central area and two side wings, each structurally independent and less than 5,000 square feet. LeTendre's neighbors, Marie and Michael Long, contested that the Chesapeake violated a county zoning ordinance, which was upheld by the North Carolina Court of Appeals. The County then sued LeTendre to enforce the mandate and hold her in contempt if she refused to comply.LeTendre removed the case to federal court, seeking a declaratory judgment that the Chesapeake now complies with both county and state requirements. She argued that a recent amendment to North Carolina’s state zoning law abrogated the previous ruling. The district court agreed with LeTendre, holding that the County’s interpretation of a single-family detached dwelling, as applied to the Chesapeake, is “inconsistent with the State Building Code’s definition of a dwelling.”The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court held that the Building Code Council’s determination that the Chesapeake is “a building” controls. The court rejected the appellants' arguments that the district court's ruling violated principles of res judicata and the Rooker-Feldman doctrine, stating that the court was not reviewing whether the previous rulings correctly interpreted the Ordinance, but rather that the zoning amendment made the Council decision controlling. View "Currituck County v. LeTendre" on Justia Law