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

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

The case involves Mountain Valley Pipeline, LLC (Appellee), which is constructing an interstate natural gas pipeline. The company acquired easements on properties along the pipeline’s route through condemnation actions under the Natural Gas Act. One such property was owned by Frank Terry, John Coles Terry, and Elizabeth Terry (Appellants), which was encumbered by temporary and permanent easements on 8.37 acres. After the district court granted Appellee immediate possession of the easements, the case proceeded to a jury trial to determine the amount of just compensation owed by Appellee to Appellants for the easements. The jury rendered a $523,327 verdict, which Appellee challenged, arguing that the verdict resulted from the jury improperly mixing expert testimony. The district court agreed with Appellee and granted judgment as a matter of law, vacating the jury verdict and entering a judgment for $261,033.The United States Court of Appeals for the Fourth Circuit reversed the district court’s judgment as a matter of law and remanded with instructions to reinstate the $523,327 verdict. The court held that the jury’s verdict was within the range of credited testimony and could be supported using residential values alone, without the need to venture beyond the credited testimony. The court also reversed the district court’s grant of a new trial. Additionally, the court vacated and remanded the district court’s order denying Appellants’ second motion for attorney’s fees and costs, leaving these issues for the district court to consider in the first instance. View "Mountain Valley Pipeline, LLC v. 8.37 Acres of Land" on Justia Law

The case revolves around two developers, SAS Associates 1, LLC and Military 1121, LLC, who filed a complaint against the City Council of Chesapeake, Virginia, alleging that their equal protection rights were violated when their rezoning applications were denied by the council. The developers owned several parcels of land in Chesapeake and sought to combine them to create a 90-acre development involving housing units, commercial space, and a conservation district. Their plans required rezoning, which was denied by the Council citing community opposition and the ability to develop under existing zoning classifications. The developers filed a complaint alleging that their application was denied even though similar applications from other developers were approved, and the council's reasons for denial were irrational and arbitrary.The United States Court of Appeals for the Fourth Circuit upheld the district court’s decision to dismiss the developers' claim. The Court of Appeals found that the developers failed to demonstrate that they were treated differently from others who were similarly situated and that the unequal treatment was the result of discriminatory animus. Furthermore, the court highlighted that zoning decisions are primarily the responsibility of local governments and that the Developers did not provide any valid comparators to support their claim of discriminatory treatment. The court noted the lack of any evidence to infer discriminatory intent on the part of the City Council members and ruled that the Developers' disagreement with the Council's decision does not render the Council's judgment call pretextual. The court affirmed the judgment of the district court dismissing the complaint. View "SAS Associates v. City Council of Chesapeake" on Justia Law

In this case, residents of the Waples Mobile Home Park in Fairfax, Virginia, challenged the park's policy that required all adult tenants to provide proof of their legal status in the United States in order to renew their leases. The plaintiffs, four Latino families, argued that this policy violated the Fair Housing Act (FHA) because it disproportionately ousted Latinos from the park. The district court initially granted summary judgment in favor of the park, reasoning that the policy was necessary to avoid criminal liability under a federal statute prohibiting the harboring of undocumented immigrants.However, the United States Court of Appeals for the Fourth Circuit reversed the district court's judgment. The court of appeals found that the district court had misunderstood the federal anti-harboring statute. The court of appeals noted that the statute requires more than simply entering into a lease agreement with an undocumented immigrant to be in violation. Rather, a person must knowingly or recklessly conceal, harbor, or shield undocumented immigrants from detection. The court of appeals concluded that the park's policy of verifying tenants' legal status did not serve the park's stated interest of avoiding liability under the anti-harboring statute. Consequently, the park had not met its burden at the second step of the three-step burden-shifting framework established for disparate-impact claims under the FHA. As such, the court of appeals reversed the grant of summary judgment for the park and remanded the case to the district court for further proceedings. View "Reyes v. Waples Mobile Home Park Limited Partnership" on Justia Law

In a case brought before the United States Court of Appeals for the Fourth Circuit, residents of the Waples Mobile Home Park in Fairfax, Virginia, challenged the Park's policy requiring all adult tenants to provide proof of their legal status in the United States in order to renew their leases. The plaintiffs, noncitizen Latino families, argued that this policy disproportionately ousted Latinos from the Park and therefore violated the Fair Housing Act (FHA). The district court initially granted summary judgment in favor of the Park, reasoning that the policy was necessary to avoid criminal liability under a federal statute prohibiting the harboring of undocumented immigrants.On appeal, the Fourth Circuit reversed the district court's decision. The court determined that the anti-harboring statute did not plausibly put the Park at risk for prosecution simply for leasing to families with undocumented immigrants. Furthermore, the court found that the Park's policy did not serve a valid interest in any realistic way to avoid liability under the anti-harboring statute. Therefore, the Park did not meet its burden at the second step of the three-step burden-shifting framework established for disparate-impact claims in Texas Department of Housing and Community Affairs v. Inclusive Communities Project, Inc. Given these findings, the Court of Appeals did not need to reach the third step to determine whether a less discriminatory alternative was available. As such, the court reversed the grant of summary judgment for the Park and remanded the case to the district court for further proceedings. View "Reyes v. Waples Mobile Home Park Limited Partnership" on Justia Law

In this case, Nagla Abdelhalim, an Egyptian immigrant and a Muslim woman, filed suit against her neighbors Aaron and Dinara Lewis and Andrew and Roxana McDevitt, alleging that they violated the Fair Housing Act by engaging in a year-long campaign of harassment against her in an attempt to drive her out of the neighborhood because of her race, national origin, and religion. The dispute began when Abdelhalim started a short-term rental business, renting out her basement on platforms such as Airbnb, which violated a local ordinance at the time and was disapproved by her neighbors. The United States District Court for the Eastern District of Virginia granted summary judgment to the defendants, concluding that Abdelhalim had not produced evidence of intentional discrimination based on a protected ground.On appeal, the United States Court of Appeals for the Fourth Circuit considered only whether the district court erred in granting the defendants' motions for attorneys’ fees. The Fourth Circuit ruled that the district court had applied the wrong legal standard and thus abused its discretion in granting attorneys’ fees to the defendants. The court noted that while a plaintiff’s failure to prevail is a factor to consider, it alone cannot be the basis for concluding that a claim was without foundation. The court found that Abdelhalim had provided sufficient evidence to support her belief that the defendants intended to discriminate against her based on her race, religion, or national origin. Thus, her claims were not without foundation, and the award of attorneys' fees to the defendants was vacated. View "Abdelhalim v. Lewis" on Justia Law

In passing the Water Infrastructure Improvements for the Nation Act (“WIIN Act”), Congress directed the U.S. Army Corps of Engineers to design a fish-passage structure for the New Savannah Bluff Lock and Dam. The Corps settled on a design that would lower the pool of water by about three feet. The State of South Carolina and several of its agencies responded by suing the Corps and various federal officials. Their complaint alleged that the Corps’ design violated the WIIN Act, the National Environmental Policy Act, the Administrative Procedure Act, state law, a previous settlement agreement, and certain easements. The district court held that the Corps’ plan didn’t “maintain the pool” since it would lower it from its height on the date of the Act’s enactment. Corps argued that this reading ignores the clause “for water supply and recreational activities” and that a lowered pool that still fulfills these functions would comply with the Act.   The Fourth Circuit vacated the district court’s judgment for Plaintiffs on their WIIN Act claim and the resulting permanent injunction against the Corps. The court left it to the district court to decide whether the Corps’ chosen design can maintain the pool’s then-extant water-supply and recreational purposes. The court explained that it agreed with the Corps that pinning the required pool height to the “arbitrary and unknowable-to-Congress date that the President signed the legislation” leads to “absurd results.” Plaintiffs suggest that the statute only obligates the Corps to maintain the pool at its “normal operating range.” But neither the statute nor the district court’s order makes clear this permissible “range.” View "State of South Carolina v. United States Army Corps of Engineers" on Justia Law

Plaintiffs own a beach house in Dare County, North Carolina. In the early days of the COVID-19 pandemic, Dare County banned nonresident property owners from entering the county. As a result, Plaintiffs could not reach their beach house for forty-five days. In response, they sued Dare County, alleging that their property was taken without compensation in violation of the Fifth Amendment. After the district court found that the ban was not a Fifth Amendment taking and dismissed Plaintiffs’ suit for failure to state a claim, Plaintiffs appealed.   The Fourth Circuit affirmed. The court held that the ban did not physically appropriate Plaintiffs’ beach house. And though it restricted their ability to use the house, compensation is not required under the ad hoc balancing test that determines the constitutionality of most use restrictions. The court further explained that Dare County’s order is neither a physical appropriation, a use restriction that renders the property valueless, nor a taking under Penn Central. The effects of the order were temporary, Plaintiffs had a chance to occupy their property before it took effect, and while the order was operative they could still exercise significant ownership rights over their property. View "Joseph Blackburn, Jr. v. Dare County" on Justia Law