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

The case revolves around Dedre Feyijinmi, who filed for Chapter 13 bankruptcy and sought to discharge a restitution debt. In 2006, Feyijinmi was found guilty of welfare fraud in Maryland state court and was sentenced to three years' probation. The court also ordered $14,487 in restitution, which was recorded as a civil judgment. After Feyijinmi's probation ended, the outstanding balance was transferred to the State's Central Collection Unit. Later, Feyijinmi's criminal records were expunged, but her restitution obligation remained, leading to the garnishment of her wages.The bankruptcy court and the district court both rejected Feyijinmi's arguments that her restitution debt was dischargeable. Feyijinmi argued that the Bankruptcy Code's provision excluding a debt "for restitution...included in a sentence on the debtor's conviction of a crime" did not apply to her because she was not formally convicted under Maryland law. She also contended that the debt was discharged because the state of Maryland identified the debt as dischargeable court fees on its proof of claim.The United States Court of Appeals for the Fourth Circuit affirmed the lower courts' decisions. The court held that Feyijinmi's probation before judgment qualified as a conviction under federal law, as it was based on a finding of guilt. The court also ruled that the restitution was part of a sentence, even without a formal judgment. The court rejected Feyijinmi's claim that the State waived its right to collect the debt post-discharge by labeling it as "Court Ordered Fees" on its proof of claim. The court also dismissed Feyijinmi's claim of prejudice, finding no evidence of bad faith or unreasonable delay in filing the amendment, impact on other claimants, reliance by the debtor or creditors, or change of the debtor's position. View "Feyijinmi v. State of Maryland Central Collection Unit" on Justia Law

The case involves Koppers Performance Chemicals, Inc., a New York-based corporation that manufactures wood preservation chemicals, and Argonaut-Midwest Insurance Company. In 2014, Phillip H. Riley and his wife sued Koppers and other lumber industry entities in South Carolina state court, alleging that Riley developed cancer from exposure to a chemical used in the lumber provided by Koppers. Koppers sought coverage under four commercial general liability policies issued by Argonaut. Argonaut, however, disclaimed any duty to defend or indemnify Koppers, arguing that the policies limited coverage to Koppers' Hawaii operations and did not cover the claims in the Riley lawsuit.The case was initially heard in the District of South Carolina, where the court granted Argonaut's motion for summary judgment and denied Koppers' motion for partial summary judgment. The court found that the insurance policies were limited to Koppers' Hawaii operations and that the original complaint did not allege a potential for coverage under the policies, thus Argonaut had no duty to defend.Upon appeal, the United States Court of Appeals for the Fourth Circuit reversed the lower court's decision. The appellate court found that the insurance policies did not unambiguously limit coverage to Koppers' Hawaii operations. Furthermore, the court held that Argonaut was required to consider extrinsic evidence it specifically requested from Koppers when assessing its duty to defend. The court vacated the district court's order granting Argonaut's summary judgment motion and denying Koppers' partial summary judgment motion on the issue of Argonaut's duty to defend, and remanded the case for further proceedings. View "Koppers Performance Chemicals, Inc. v. Argonaut Midwest Insurance Co." 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

Gilbert Devon Melvin, after serving over 20 years in federal prison for drug and firearm offenses, was released in March 2021 and began a five-year term of supervised release. In August 2023, Melvin's mental health deteriorated, and he was arrested for trespassing. At the revocation hearing, the district court initially agreed to terminate Melvin's supervised release and enter a time-served sentence. However, Melvin had an outburst in court, which led the court to conclude that he posed a danger to the public and his probation officers. As a result, the court withdrew its initial agreement to a time-served sentence and instead decided to maintain Melvin's supervised release with an additional mental health condition.The district court's decision was based on Melvin's behavior during the revocation hearing. The court initially agreed to terminate Melvin's supervised release and enter a time-served sentence. However, after Melvin's outburst, the court concluded that he posed a danger to the public and his probation officers. The court then withdrew its initial agreement and decided to maintain Melvin's supervised release with an additional mental health condition.On appeal to the United States Court of Appeals for the Fourth Circuit, Melvin argued that the district court lacked the authority to withdraw or modify the time-served sentence it had initially agreed to impose. The Fourth Circuit disagreed, affirming the district court's decision. The court held that a sentence is not imposed until it has been unequivocally pronounced during the sentencing hearing, and there has been a formal break in the proceedings from which to logically and reasonably conclude that sentencing had finished. The court found that the district court's initial acceptance of a time-served sentence was tentative and that the court had the authority to modify that sentence when Melvin addressed the bench only moments later, during the course of the same sentencing hearing. View "US v. Melvin" on Justia Law

Jake's Fireworks Inc., a large importer and distributor of consumer fireworks, sought judicial review of several warning notices it received from the U.S. Consumer Product Safety Commission. The notices were issued after the Commission's staff sampled fireworks imported by Jake's Fireworks and found that about one-third of those samples indicated that the fireworks were dangerously overloaded with explosive material, rendering them "banned hazardous substances" under the agency’s regulations. The Commission's Compliance Office accordingly sent Jake's Fireworks several “Notice[s] of Non-Compliance,” requesting that the distribution of the sampled lots not take place and that the existing inventory be destroyed.Jake's Fireworks first sued the Commission in federal court in 2019, seeking injunctive and declaratory relief from the agency’s enforcement of its fireworks regulations via the Notices. The district court dismissed the lawsuit, determining that the Notices did not constitute final agency actions under the Administrative Procedure Act because they did not consummate the Commission’s decisionmaking process. After the dismissal of its first lawsuit, Jake's Fireworks requested an informal hearing with the Compliance Office to contest the Notices. The Compliance Office declined to hold a hearing or to revisit its findings, and Jake's Fireworks filed a second lawsuit, which was also dismissed by the district court on the same grounds as the first lawsuit.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court held that the Notices did not constitute final agency actions under the Administrative Procedure Act. The court reasoned that the Compliance Office’s Notices of Noncompliance did not mark the consummation of the agency’s decisionmaking process, as it is the Commission itself, not its Compliance Office, that makes final determinations on whether goods are banned hazardous substances. The court also found that the language of the Notices confirmed that they conveyed preliminary findings and advice from agency staff rather than a final determination from the Commission itself. View "Jake's Fireworks Inc. v. United States Consumer Product Safety Commission" on Justia Law

The case involves the 68th Street Site Work Group (the "Group"), a collective of entities that had settled their liability for environmental cleanup costs with the Environmental Protection Agency (EPA). The Group sought to recoup some of these costs by filing a contribution action under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) against several non-performing and non-settling entities, alleging that each defendant incurred arranger liability by arranging for the disposal of waste at the Superfund Alternative Site.The District Court for the District of Maryland dismissed the claims against each of these defendants, concluding that the Group failed to allege that the defendants took intentional steps with the specific intent to dispose of hazardous waste and knew that the disposed-of waste was hazardous. The Group then sought to amend its complaint against seven of the defendants, but the district court denied the motion, standing by its prior interpretation of CERCLA’s arranger-liability provision.The United States Court of Appeals for the Fourth Circuit vacated the district court's decision and remanded the case for further proceedings. The appellate court held that under CERCLA’s arranger-liability provision, a defendant is liable whenever they intentionally arrange for the disposal of a substance and the substance is hazardous. The court concluded that the district court erred by requiring the Group to allege that the defendants knew the disposed-of waste was hazardous. View "68th Street Site Work Group v. Alban Tractor Co., Incorporated" on Justia Law

The case involves an incarcerated individual, Thomas Alexander, who alleged that two correctional officers violated his Fourth and Eighth Amendment rights by forcibly removing a contraband phone from his rectum in a prison shower. The officers, however, claimed that they found the phone in Alexander's pocket and used no more force than necessary. The incident was partially captured on video, but the footage did not conclusively resolve the dispute over where the phone was located.The United States District Court for the Eastern District of North Carolina granted summary judgment in favor of the officers. The court relied on the video footage, concluding that it discredited Alexander's version of events to such an extent that no reasonable jury could have believed him.On appeal, the United States Court of Appeals for the Fourth Circuit vacated the lower court's decision and remanded the case for further proceedings. The appellate court found that the video did not clearly depict what happened in the shower room and did not blatantly contradict Alexander's account. Therefore, the court held that the district court should have credited Alexander's version of events when considering the officers' summary judgment motion. The appellate court also concluded that, viewing the evidence in the light most favorable to Alexander, a reasonable jury could find that the officers violated Alexander's Fourth and Eighth Amendment rights. View "Alexander v. Connor" on Justia Law

The case involves United Therapeutics Corporation (UTC), a biotechnology company, and the Commissioner of Internal Revenue. The dispute centers on the interpretation of a tax provision that coordinates two tax credits: the research credit and the orphan drug credit. The Commissioner claimed that UTC disregarded one of the provision’s two commands, improperly reducing its tax liability by over a million dollars. UTC argued that the relevant half of the coordination provision lost effect in 1989 and has been moribund since.The United States Tax Court disagreed with UTC's argument. The court interpreted the statute’s terms by reference to their ordinary meaning, giving effect to the full coordination provision. The court rejected UTC's argument that changes to the tax law since its enactment rendered part of the coordination provision ineffective. The court also disagreed with UTC's interpretation of two regulations it relied on for support.The United States Court of Appeals for the Fourth Circuit affirmed the tax court's decision. The appellate court agreed with the tax court's interpretation of the coordination provision according to its ordinary meaning. The court also found that the tax court correctly rejected UTC's arguments based on the interpretation of predecessor statutes and regulations. The court concluded that the tax court correctly resolved the case in favor of the Commissioner. View "United Therapeutics Corporation v. Commissioner of Internal Revenue" on Justia Law

The case involves Quentin Lowell Horsley, who was convicted of conspiring to distribute, and possession with intent to distribute, cocaine, methamphetamine, heroin, and cocaine base, as well as three counts of distributing cocaine. The evidence against Horsley included witness testimony, text messages, evidence of controlled buys, and drugs and cash seized during searches. Horsley challenged the admission of several items of evidence, including a cellphone seized without a warrant and the search of a car tied to him. He also challenged the testimony of an officer who interpreted text messages and the handling of the verdict form by the district court.The United States District Court for the Western District of Virginia denied Horsley's motion to suppress the cellphone and the fruits of the car search. The court also allowed the officer's testimony and handled the verdict form in a way that Horsley contested.On appeal, the United States Court of Appeals for the Fourth Circuit held that the district court erred in failing to suppress the evidence from the cellphone seized at the time of Horsley's arrest, but given the weight of the evidence against Horsley, the error was harmless. The court also held that the search of the car and its contents was proper, and that the district court did not plainly err in allowing the officer's testimony. The court found no error in connection with the district court’s handling of the verdict form. Therefore, the court affirmed the conviction. View "US v. Horsley" on Justia Law

The case revolves around the murder of Sallie Copeland Evans by her grandson, Isaiah Evans Ceasar, a lance corporal in the United States Marine Corps. Sallie's son, Mitchell Garnet Evans, acting as the executor of her estate, filed a wrongful death claim against the United States under the Federal Tort Claims Act, alleging that the Marine Corps was negligent in its handling of Ceasar, who had previously expressed suicidal intentions and violent tendencies. The district court dismissed the claim for lack of subject-matter jurisdiction.The United States Court of Appeals for the Fourth Circuit found that the district court had erred in dismissing the claim under Federal Rule of Civil Procedure 12(b)(1) because the jurisdictional question and the merits of the case were inextricably intertwined. However, the court also found that Evans failed to state a wrongful death claim under North Carolina law. The court concluded that even if the Marine Corps had a duty to Sallie, her murder was not foreseeable under the circumstances. Therefore, while the district court's decision was procedurally incorrect, it was substantively proper. The court affirmed the district court's decision on alternative grounds and dismissed the case under Rule 12(b)(6). View "Evans v. US" on Justia Law