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

The petitioner pleaded guilty in 2003 to attempted bank robbery and to carrying and using a firearm during a crime of violence. At sentencing, he was classified as a career offender under the then-mandatory Sentencing Guidelines, resulting in a sentence of 274 months’ imprisonment. Over the years, he filed several postconviction motions, including a first motion under 28 U.S.C. § 2255, which was denied. After subsequent changes in Supreme Court precedent regarding the constitutionality of certain sentencing provisions, the petitioner argued that the mandatory Guidelines’ career-offender provision was unconstitutionally vague and sought habeas relief.The United States District Court for the Western District of Virginia dismissed his habeas petition brought under 28 U.S.C. § 2241, finding that he could not proceed under § 2241 because he did not satisfy the requirements of the “saving clause” in § 2255(e). The district court determined that the petitioner was procedurally barred from bringing a second or successive § 2255 motion and that this procedural bar did not render § 2255 “inadequate or ineffective” to test the legality of his detention.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s dismissal. The Fourth Circuit held that, under the Supreme Court’s decision in Jones v. Hendrix, the inability to satisfy the procedural requirements for a second or successive § 2255 motion does not make § 2255 inadequate or ineffective, and thus does not permit recourse to § 2241 via the saving clause. The court also held that this result does not violate the Suspension Clause of the Constitution, relying on its en banc precedent in In re Vial. Accordingly, the Fourth Circuit affirmed the dismissal for lack of jurisdiction. View "Bell v. Streeval" on Justia Law

A South Carolina resident brought a lawsuit in federal court against a Michigan-based bank, alleging that the bank engaged in three improper practices related to overdraft and ATM fees. Specifically, the plaintiff claimed the bank assessed overdraft fees even when accounts had sufficient funds, charged multiple insufficient-funds fees for a single transaction, and imposed two out-of-network fees for a single ATM withdrawal. The plaintiff sought to certify nationwide classes for each alleged wrongful fee practice.The United States District Court for the District of South Carolina denied the plaintiff’s motion for class certification. The court relied on South Carolina’s “Door Closing Statute” (S.C. Code Ann. § 15-5-150), as interpreted by the Supreme Court of South Carolina in Farmer v. Monsanto Corp., to conclude that nonresidents whose claims did not arise in South Carolina could not be included in the class. As a result, the court found that the plaintiff could not satisfy the numerosity requirement of Federal Rule of Civil Procedure 23 and denied class certification. The plaintiff appealed this decision under Rule 23(f), and the United States Court of Appeals for the Fourth Circuit granted review.The United States Court of Appeals for the Fourth Circuit held that Federal Rule of Civil Procedure 23, as interpreted by the Supreme Court in Shady Grove Orthopedic Associates, P.A. v. Allstate Insurance Co., directly conflicts with the Door Closing Statute’s additional requirements for class actions. The Fourth Circuit concluded that Rule 23 alone governs the certification of class actions in federal court and that the Door Closing Statute cannot limit class membership in this context. The court reversed the district court’s denial of class certification and remanded the case for further proceedings. View "Grice v. Independent Bank" on Justia Law

The case concerns a man who kidnapped his estranged wife by luring her to his home, forcibly taking her keys and phone, and compelling her into his truck, where she saw a gun in the back seat. Throughout the ordeal, the victim was aware of the gun’s presence and testified that it deterred her from attempting escape, as she feared for her safety and the safety of others. The kidnapping followed two prior incidents of violence by the defendant against the victim, one of which also involved a gun. During the kidnapping, the defendant made explicit and implicit threats, including referencing the gun and threatening to drive off a cliff. The victim ultimately escaped and reported the crime to law enforcement, who arrested the defendant and recovered the firearm.The United States District Court for the Western District of Virginia initially convicted the defendant on three counts: kidnapping, interstate domestic violence, and possession of a firearm in furtherance of a crime of violence. The court imposed a sentence that included a mandatory enhancement for the firearm offense. After subsequent Supreme Court and Fourth Circuit decisions clarified the definition of a “crime of violence,” the district court vacated the convictions for interstate domestic violence and the firearm offense, leaving only the kidnapping conviction. At resentencing, the government sought a sentencing enhancement for “use” of a dangerous weapon during the kidnapping, which the district court applied over the defendant’s objection.The United States Court of Appeals for the Fourth Circuit reviewed whether the district court properly applied the sentencing enhancement for “use” of a dangerous weapon. The Fourth Circuit held that the defendant’s conduct—employing the gun to convey an imminent threat, rather than merely intimidating the victim with the possibility of future harm—constituted “use” under the relevant Sentencing Guideline. The court affirmed the district court’s application of the enhancement and the resulting sentence. View "US v. Faulls" on Justia Law

A woman from El Salvador entered the United States without valid documents in 2014 after fleeing an abusive relationship with a gang member who had threatened her and her family. She experienced repeated physical assaults and threats, including an incident where her hand was cut with a knife. After reporting the abuse to local police, who dismissed her concerns, she relocated within El Salvador but continued to receive threats from the gang. Fearing for her life, she fled to the United States, where she sought asylum, claiming past persecution and a well-founded fear of future persecution based on her membership in a particular social group.An Immigration Judge denied her application for asylum, finding that her proposed social groups were not legally cognizable because they were defined by the harm suffered and lacked particularity and social distinction. The Board of Immigration Appeals (BIA) affirmed this decision, also concluding that her social groups were impermissibly circular and that she had not demonstrated a well-founded fear of future persecution. The BIA later denied her motion to reconsider, rejecting her argument that precedent supported recognition of her social group.The United States Court of Appeals for the Fourth Circuit reviewed the BIA’s denial of the motion to reconsider. The Fourth Circuit held that the BIA committed legal error by rejecting the petitioner’s proposed social group without conducting a substantive, fact-based analysis as required by law. The court vacated the BIA’s ruling on the social group issue and remanded for further proceedings, instructing the BIA to perform a proper analysis based on the facts and evidence of the case. The court also vacated the BIA’s analysis of future persecution, directing that it be reconsidered if the social group is found cognizable on remand. View "Guardado v. Bondi" on Justia Law

Law enforcement officers suspected that the defendant was involved in a drug trafficking operation based out of his apartment in a large, multi-unit building. To investigate further, officers, with the building management’s permission, conducted a warrantless dog sniff in the common hallway immediately outside the defendant’s apartment door. The trained dog alerted to the presence of drugs, and this information was used to obtain a search warrant. The subsequent search uncovered drugs, firearms, and other evidence. The defendant was indicted on drug and firearm charges.The United States District Court for the District of Maryland denied the defendant’s motion to suppress the evidence, rejecting his arguments that the dog sniff constituted an unlawful search under the Fourth Amendment. The court found that the dog sniff did not violate a reasonable expectation of privacy because it only revealed the presence of contraband, and that the area outside the apartment door was not protected “curtilage” since it was a common hallway accessible to other residents and building staff. The defendant was convicted by a jury on all counts and sentenced to 150 months in prison.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s legal conclusions de novo and factual findings for clear error. The Fourth Circuit held that a dog sniff at an apartment door in a common hallway does not violate a reasonable expectation of privacy, as established by United States v. Place and Illinois v. Caballes, because it only reveals the presence of contraband. The court also held that the common hallway outside the apartment door is not curtilage protected by the Fourth Amendment, as the defendant had no right to exclude others from that area. The judgment of the district court was affirmed. View "US v. Johnson" on Justia Law

Dorothy Seabrook, a black woman, was the Family Programs Manager for the U.S. Army Reserve Command at Fort Bragg, North Carolina. In 2013, she was involved in disciplinary actions against an employee, Scott Hamilton. Subsequently, the Army investigated Seabrook for creating a toxic work environment and making inappropriate comments and physical contact. In 2014, she was suspended for two weeks and reassigned to another division. Seabrook filed an Equal Employment Opportunity (EEO) complaint in January 2015, alleging discrimination based on race, color, and sex. She received a poor performance evaluation in February 2015, which she believed was retaliatory, leading her to file a second EEO complaint.The Equal Employment Opportunity Commission (EEOC) investigated and found no discrimination. Seabrook then filed a pro se complaint in federal court, which was construed as alleging disparate treatment, hostile work environment, and retaliation under Title VII. The United States District Court for the Eastern District of North Carolina dismissed her complaint for failure to state a claim and denied her motion to alter or amend the judgment.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court's dismissal, holding that Seabrook failed to plausibly allege that the Army's actions were motivated by discriminatory bias. The court found that Seabrook's allegations did not support claims of disparate treatment, as her comparators were not similarly situated. Her hostile work environment claim failed because the alleged actions were not objectively abusive or severe. Lastly, her retaliation claim was dismissed due to a lack of causal connection between her EEO activity and the adverse employment actions. The court concluded that Seabrook's complaint did not meet the pleading standards required to survive a motion to dismiss. View "Seabrook v. Driscoll" on Justia Law

In response to the COVID-19 pandemic, Congress enacted legislation to provide financial assistance to small businesses, including relief payments on certain small business loans. PACEM Solutions International, LLC applied for a $5 million loan under the Small Business Administration's (SBA) 7(a) loan program. Due to repeated missed payments, PACEM and its lender, Atlantic Union Bank, modified the loan multiple times. When the CARES Act was passed, PACEM's loan was not in "regular servicing status," a requirement for receiving relief payments under the Act. The SBA determined that PACEM's loan was ineligible for relief payments and requested the return of previously disbursed funds.The United States District Court for the Eastern District of Virginia granted summary judgment in favor of the SBA. The court found that the SBA did not violate the CARES Act, as PACEM's loan was not performing appropriately and was in default. The court also concluded that the SBA did not act arbitrarily or capriciously in its decision to withhold payments and that any notification defects were harmless.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 SBA acted reasonably in determining that PACEM's loan was ineligible for relief payments under the CARES Act. The court found that the SBA provided a satisfactory explanation for its actions and did not violate the terms of the CARES Act. The court also declined to address PACEM's constitutional claim regarding the Fifth Amendment's Due Process Clause, as PACEM sought only a declaratory judgment without requesting a hearing before the SBA. The court affirmed the district court's grant of summary judgment to the SBA. View "PACEM Solutions International, LLC v. U. S. Small Business Administration" on Justia Law

Georgia-Pacific LLC, a large corporation in the pulp and paper industry, acquired Bestwall Gypsum Co. in 1965, inheriting significant asbestos-related liabilities. By 2017, Bestwall faced around 64,000 pending asbestos claims, prompting Georgia-Pacific to implement a divisional merger known as the Texas two-step. This maneuver split Georgia-Pacific into two entities: Georgia-Pacific retained most assets, while Bestwall assumed the asbestos liabilities and filed for Chapter 11 bankruptcy to manage these claims through a § 524(g) trust.The United States Bankruptcy Court for the Western District of North Carolina granted Bestwall's motion for an injunction to prevent asbestos claimants from pursuing claims outside the bankruptcy process. The Official Committee of Asbestos Claimants opposed this and moved to dismiss the bankruptcy case, arguing it was filed in bad faith since Bestwall was solvent. The bankruptcy court denied the motion, stating that filing for Chapter 11 to resolve asbestos claims is a valid purpose, even for solvent debtors.The Committee later moved to dismiss the case for lack of subject-matter jurisdiction, arguing that the Constitution does not grant jurisdiction over bankruptcy cases involving solvent debtors. The bankruptcy court rejected this argument, holding that Congress has the authority to define bankruptcy jurisdiction, which includes cases filed by solvent debtors.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the bankruptcy court's decision. The Fourth Circuit held that federal courts have subject-matter jurisdiction over bankruptcy cases involving solvent debtors because the Bankruptcy Code is a federal law, and petitions for relief under it arise under the laws of the United States. The court clarified that challenges to a debtor's eligibility for bankruptcy protection are not jurisdictional issues. View "Bestwall LLC v. Official Committee of Asbestos Claimants" on Justia Law

Keith Moore was stopped by Richmond, Virginia police officers after they observed his vehicle displaying a temporary license tag number that matched two other vehicles they had stopped earlier that day. Moore fled from the police, leading to a chase that ended with him crashing his car. Upon his arrest, officers found a gun in his vehicle and discovered that Moore had a prior felony conviction. He was subsequently indicted for illegal possession of a firearm.The United States District Court for the Eastern District of Virginia dismissed Moore’s indictment, finding that the traffic stop was racially motivated and thus violated the Equal Protection Clause of the Fourteenth Amendment. The court based its decision on statistical evidence showing that Black drivers were disproportionately stopped by Richmond police and historical evidence of racial discrimination in Richmond. The court concluded that Moore’s stop was part of a pattern of selective enforcement against Black drivers.The United States Court of Appeals for the Fourth Circuit reviewed the case and reversed the district court’s decision. The appellate court found that the evidence was insufficient to prove that Moore’s stop and arrest were motivated by racial discrimination. The court noted that the officers had probable cause to stop Moore due to the fake license tag and his subsequent flight. The statistical evidence presented did not adequately demonstrate a discriminatory purpose, and the historical evidence was not contemporaneous with the events in question. The Fourth Circuit remanded the case with instructions to reinstate the indictment against Moore. View "US v. Moore" on Justia Law

Darrell J. Austin, Jr. filed a lawsuit against Experian Information Solutions, Inc., alleging violations of the Fair Credit Reporting Act (FCRA). Austin claimed that Experian reported inaccurate and derogatory information about his credit history, even after he had disputed the inaccuracies. He had enrolled in CreditWorks, a free online credit-monitoring service offered by an Experian affiliate, to understand why his credit applications were being denied despite the discharge of much of his debt through bankruptcy.The United States District Court for the Eastern District of Virginia denied Experian’s motion to compel arbitration and excluded the declaration of David Williams, an Experian affiliate employee, which was submitted to support the motion. The court found that Williams lacked personal knowledge and relied on hearsay documents. Additionally, the court concluded that the CreditWorks enrollment page was deceptive and did not provide sufficient notice to Austin that he was agreeing to arbitration.The United States Court of Appeals for the Fourth Circuit reviewed the case and reversed the district court’s decision. The appellate court found that the district court erred in excluding the Williams declaration, as Williams had adequately demonstrated personal knowledge of the enrollment process and the terms of use. The court also determined that the CreditWorks enrollment page provided clear and conspicuous notice of the terms of use, including the arbitration agreement, and that Austin had manifested assent to those terms by creating an account.The Fourth Circuit held that Experian had met its burden to establish the existence of a binding arbitration agreement and remanded the case for further proceedings consistent with its opinion. View "Austin v. Experian Information Solutions, Inc." on Justia Law