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

The case involves Gabrielle Barbour, who alleges that she was denied employment as a Special Agent with the Drug Enforcement Administration (DEA) in retaliation for her participation in a class action lawsuit against the Federal Bureau of Investigation (FBI) for workplace discrimination. The district court dismissed Barbour's complaint under Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim upon which relief can be granted.The district court found that Barbour failed to establish a causal link between her protected activity (the lawsuit against the FBI) and the adverse employment action (non-selection by the DEA). The court also found that Barbour's complaint affirmatively pleaded legitimate nondiscriminatory reasons for her non-selection, which were not rebutted by Barbour.On appeal, the United States Court of Appeals for the Fourth Circuit reversed the district court's decision. The appellate court found that the district court erred in its analysis of the complaint's allegations and in requiring Barbour to rebut the DEA's proffered reasons for her non-selection at the motion to dismiss stage. The appellate court concluded that the complaint's allegations were sufficient to support a plausible inference of a causal link between Barbour's lawsuit against the FBI and the DEA's subsequent refusal to hire her. The case was remanded for further proceedings. View "Barbour v. Garland" on Justia Law

Family Health Physical Medicine, LLC, an Ohio-based company, filed a lawsuit against Pulse8, LLC and Pulse8, Inc., Maryland-based companies. The dispute arose when Pulse8 sent a fax to Family Health inviting it to a free webinar on medical coding technology, a product that Pulse8 sells. Family Health claimed that this fax was an unsolicited advertisement and thus violated the federal Telephone Consumer Protection Act (TCPA). Pulse8 argued that the fax did not qualify as an advertisement under the TCPA because the webinar was free.The United States District Court for the District of Maryland granted Pulse8's motion to dismiss the case, agreeing with Pulse8's argument that the fax did not qualify as an advertisement under the TCPA. Family Health appealed this decision to the United States Court of Appeals for the Fourth Circuit.The Fourth Circuit Court disagreed with the lower court's decision. The court found that the fax did have a commercial component, as it was sent by a company that sells a product related to the subject of the webinar. The court concluded that the fax was being used to market Pulse8's product. The court also found that Family Health had plausibly alleged that accepting the invitation to the webinar would trigger future advertising. However, the court rejected Family Health's argument that the fax was an advertisement because it offered a chance to win a gift card in exchange for completing a survey. The court reversed the district court's judgment and remanded the case for further proceedings. View "Family Health Physical Medicine, LLC v. Pulse8, LLC" 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 case involves a dispute between the Florida Division of Emergency Management (the Division) and a private company, Essential Diagnostics, LLC, over a contract for the purchase of COVID-19 test kits. The Division contracted with Essential Diagnostics to buy 200,000 COVID-19 test kits for $2.2 million. However, Essential claimed that the Division ordered 600,000 tests but only paid for 200,000. The Division, on the other hand, insisted that it only ever agreed to buy 200,000 tests and that it paid for them in full. Essential assigned its rights under the contract to Global Integrated Concepts, which sued the Division in Florida state court. However, the state court dismissed the complaint. Subsequently, Global and two other parties involved in the transaction sued the Division in federal district court in North Carolina, seeking to recover the same $4.4 million Global sought as damages in its state court suit.The Division moved to dismiss the suit on the grounds of sovereign immunity. The district court denied the motion to dismiss, concluding that the Division waived its sovereign immunity by contracting with the plaintiffs. The Division appealed this decision.The United States Court of Appeals for the Fourth Circuit vacated the district court’s order and remanded the case for further proceedings. The appellate court found that the district court erred in concluding that the Division waived its sovereign immunity by contracting with the plaintiffs. The court clarified that the rules governing waiver of federal-law sovereign immunity in federal court come from federal law, not state law. The court concluded that the district court failed to distinguish between the defenses and immunities a State might enjoy under state law and the constitutionally protected sovereign immunity that States enjoy from suit in federal court. The court also rejected the plaintiffs' argument that the court lacked jurisdiction over the appeal. View "Global Innovative Concepts, LLC v. State of Florida, Division of Emergency Management" on Justia Law

The case involves Erie Insurance Company and its affiliates (collectively, Erie) and the Maryland Insurance Administration (MIA). In 2021, the MIA initiated two separate administrative investigations into Erie following complaints alleging racial and geographic discrimination. The first investigation broadly examined Erie’s market conduct, while the second focused on the specific allegations in the individual complaints. In 2023, the MIA issued four public determination letters stating that Erie had violated state insurance laws. These letters referenced documents obtained during the market conduct investigation, which had not yet concluded. Erie requested and was granted administrative hearings on all four determination letters.Erie then filed a lawsuit against the MIA and its commissioner in federal district court, alleging due process violations under 42 U.S.C. § 1983 and violations of Maryland state law. Erie sought a declaration that the determination letters were unlawful, an injunction preventing the defendants from disseminating the letters, and a requirement for the defendants to publicly withdraw them. The district court dismissed Erie's complaint, citing the principles of abstention outlined in Younger v. Harris, which generally discourages federal courts from interfering with ongoing state proceedings.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court found that Erie had an adequate opportunity to raise its constitutional claims in the administrative hearings and subsequent state court review, as required for Younger abstention. The court also rejected Erie's argument that this case fell within an exception to Younger abstention due to extraordinary circumstances or unusual situations. The court concluded that Erie had not demonstrated that the MIA's actions were motivated by bias or that the administrative proceedings would not afford Erie constitutionally adequate process. View "Erie Insurance Exchange v. Maryland Insurance Administration" on Justia Law

In 2007, Jon Oberg filed a lawsuit under the False Claims Act against various student-loan companies, including Nelnet, Inc., Nelnet Education Loan Funding, Inc., Brazos Higher Education Services Corporation, and Brazos Higher Education Authority, Inc. Oberg alleged that the companies submitted false claims to the Department of Education to inflate their loan portfolios eligible for interest subsidies. The parties agreed to a protective order for discovery, and the companies filed a joint motion for leave to file confidential summary judgment materials under seal. The magistrate judge granted in part the motion to file under seal. The parties eventually settled, and the magistrate judge dismissed the actions against the companies with prejudice.On March 31, 2023, Michael Camoin—a documentary filmmaker who covers the student-loan industry—filed a pro se letter in the district court requesting access to the materials that Oberg filed under seal in connection to his opposition to summary judgment. Nelnet and Brazos eventually filed a joint brief opposing Camoin’s request. On July 3, 2023, the magistrate judge denied Camoin’s motion. The judge found that Camoin has “no common law or First Amendment right to access the sought documents and portions of documents” because “a document must play a relevant and useful part in the adjudication process for either the First Amendment or common law rights of public access to attach.”On appeal, the United States Court of Appeals for the Fourth Circuit reversed the magistrate judge’s order and remanded for consideration of whether maintaining the seal on the requested documents is “necessitated by a compelling government interest[] and . . . narrowly tailored to serve that interest.” The court held that Camoin has a presumptive First Amendment right to access Oberg’s summary judgment motion and the documents attached to that motion. The court found that the public has an interest in ensuring basic fairness and deterring official misconduct not only in the outcome of certain proceedings, but also in the very proceedings themselves. The court concluded that irrespective of whether a district court ever resolves a summary judgment motion, the public has a presumptive First Amendment right to access documents submitted in connection with it. View "Camoin v. Nelnet, Inc." 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 Vera and Trecika Dunlap, a mother and daughter who pleaded guilty to jury tampering. The Dunlaps had followed a juror from a separate criminal trial involving their family members and offered him money in exchange for a not-guilty vote. They entered into plea agreements under Federal Rule of Criminal Procedure 11(c)(1)(C), agreeing to serve twelve months and one day of incarceration. However, they argue that the district court accepted the plea agreements but then imposed a higher sentence than that stipulated in the plea agreements.The district court, which had presided over the trial during which the jury tampering occurred, expressed hesitation about imposing the stipulated sentence due to the seriousness of the offense. The court determined that it would reject the plea agreement provision that required a sentence of a year and a day, believing it was not a sufficient sentence for the offense under the circumstances. The court then informed the Dunlaps that they had the right to withdraw their plea and calculated the applicable guidelines range to be 46 to 57 months. The court eventually sentenced each of the Dunlaps to 36 months.The United States Court of Appeals for the Fourth Circuit held that when the record is ambiguous as to whether a district court accepted or rejected a Rule 11(c)(1)(C) plea agreement, such ambiguity must be construed in the defendant’s favor. The court concluded that the record in this case was ambiguous and thus construed it in the manner urged by the Dunlaps. Accordingly, the court deemed the district court to have accepted (and been bound by) the terms of the plea agreements between the Dunlaps and the government. The court vacated the judgments and remanded the case with instructions to reenter the judgments consistent with the terms of the plea agreements and this opinion. View "United States v. Dunlap" on Justia Law

The case involves Capitol Broadcasting Company, McClatchy Company LLC, and James S. Farrin, P.C. (the plaintiffs) who sought access to certain accident reports from the City of Raleigh, the City of Salisbury, the City of Kannapolis, the North Carolina Department of Public Safety, and the North Carolina State Highway Patrol Department (the defendants). The plaintiffs claimed they were entitled to these reports under North Carolina state law. However, the defendants refused to release the reports, arguing that a federal privacy statute prohibited them from doing so. The plaintiffs then sought a declaratory judgment in federal court that the federal law did not apply.The case was initially heard in the United States District Court for the Middle District of North Carolina. The district court dismissed the plaintiffs' declaratory judgment action for lack of subject matter jurisdiction. The court concluded that the plaintiffs' complaint failed to raise a federal question on its face, as the right the plaintiffs asserted was a state law right and the federal law was only relevant as a potential defense.The plaintiffs appealed to the United States Court of Appeals for the Fourth Circuit. The appellate court affirmed the district court's decision, agreeing that the plaintiffs' complaint failed to raise a federal question on its face. The court explained that the plaintiffs' claim was based on state law, and the federal law was only relevant as a potential defense. The court also rejected the plaintiffs' argument that the complaint presented a substantial question of federal law because it sought to assert their First Amendment rights. The court concluded that the First Amendment concerns were not sufficient to create federal question jurisdiction as they were not dispositive in resolving the core dispute of the interplay between the state law and the federal law. View "Capitol Broadcasting Company, Inc. v. City of Raleigh" on Justia Law

The petitioner, Virginia Garcia Cortes, a Mexican citizen, sought review of a Board of Immigration Appeals decision affirming an Immigration Judge's denial of her application for cancellation of removal. The Immigration Judge and Board of Immigration Appeals denied Garcia Cortes’s application on the basis that she failed to make the requisite showing under 8 U.S.C. § 1229b(b)(1)(D) that her removal would impose “exceptional and extremely unusual hardship” on her daughter.The Immigration Judge found that Garcia Cortes satisfied the first three statutory eligibility requirements for cancellation of removal. However, he rejected Garcia Cortes’s request after concluding that she could not satisfy the fourth statutory requirement—whether her removal would impose “exceptional and extremely unusual hardship” on a family member who was an American citizen or lawful permanent resident. The Immigration Judge ordered that Garcia Cortes either voluntarily leave the country or be removed. Garcia Cortes appealed to the Board of Immigration Appeals (“the Board”). A divided three-member panel of the Board adopted and affirmed the Immigration Judge’s decision.The United States Court of Appeals for the Fourth Circuit concluded that the facts as found by the Immigration Judge do not support a determination that Garcia Cortes’s daughter would suffer exceptional and extremely unusual hardship if Garcia Cortes was removed. However, because the Immigration Judge failed to consider key portions of a therapist’s letter that was central to Garcia Cortes’s argument, the court vacated and remanded for further proceedings. View "Garcia Cortes v. Garland" on Justia Law