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

Brainchild Surgical Devices, LLC, a medical device developer, entered into a contract with CPA Global Limited for patent renewal services. Brainchild alleged that CPA overcharged it by marking up fees beyond the actual costs and sued for breach of contract and fraud. The district court excluded Brainchild’s expert witnesses, granted summary judgment for CPA on the breach of contract claim, dismissed the fraud claim, and denied leave to amend the fraud claim.The United States District Court for the Eastern District of Virginia dismissed Brainchild’s fraud claim for lack of particularity and denied leave to amend. The court granted summary judgment for CPA on the breach of contract claim, finding that Brainchild’s theories were inconsistent with the contract’s terms. The court excluded Brainchild’s expert witnesses, David Cass and John Keogh, for offering legal conclusions and lacking qualifications.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court’s exclusion of Cass’ testimony due to lack of qualification and improper legal conclusions. The court also affirmed the exclusion of Keogh’s testimony for failing to disclose the bases of his opinions and offering legal conclusions but reversed the decision to disqualify him based on confidential information. The court agreed with the district court that Brainchild’s pass-through cost and implied covenant of good faith theories failed to overcome summary judgment. However, the court reversed the summary judgment for CPA on the theory that CPA applied Country Charges unrelated to the required personnel, infrastructure, and third parties for renewals in particular jurisdictions. The case was remanded for further proceedings on this theory. The court also affirmed the denial of leave to amend the fraud claim. View "Brainchild Surgical Devices, LLC v. CPA Global Limited" on Justia Law

Shaheem Johnson was involved in a multi-state drug-trafficking enterprise during the 1990s, which led to the deaths of five people. Johnson was directly responsible for the deaths of Bernard Franklin and Richard Villa. He was charged with murder in aid of racketeering and other related offenses. Johnson was convicted by a jury and sentenced to two life terms plus 790 months in prison. His convictions were affirmed on direct appeal.Johnson filed a pro se motion for compassionate release in March 2021, which was supplemented by his counsel. The motion argued that the sentencing disparities between Johnson and his co-conspirators, who received significantly reduced sentences after cooperating with the government, constituted extraordinary and compelling reasons for a sentence reduction. The United States District Court for the Eastern District of Virginia granted Johnson's motion in part, reducing his sentence to 35 years in prison, citing the sentencing disparities as a key factor.The United States Court of Appeals for the Fourth Circuit reviewed the district court's decision. The court held that the district court did not abuse its discretion in finding that the sentencing disparities between Johnson and his co-conspirators, Damein Piranti, Rickey Piranti, and Eldon Brown, weighed in favor of granting compassionate release. The court noted that the district court was entitled to consider these disparities, especially given the jury's findings regarding Johnson's lesser role in the killings. The Fourth Circuit affirmed the district court's order reducing Johnson's sentence. View "United States v. Johnson" on Justia Law

The case involves Justin Michael Wolfe, who was convicted of hiring Owen Barber to murder Daniel Petrole in 2001. Barber, the key witness, initially testified against Wolfe, implicating him in the murder-for-hire scheme. Wolfe was sentenced to death, but Barber later recanted his testimony, claiming he was coerced by the Commonwealth of Virginia with threats of the death penalty. Wolfe's conviction was vacated by the district court due to Brady violations and other prosecutorial misconduct, and the Commonwealth was ordered to retry Wolfe or release him.The United States District Court for the Eastern District of Virginia granted Wolfe habeas relief, finding that the Commonwealth had withheld exculpatory evidence and engaged in misconduct. The Fourth Circuit Court of Appeals affirmed this decision, but the Commonwealth continued to pursue charges against Wolfe. In a subsequent interview, Commonwealth officials again coerced Barber, leading him to invoke his Fifth Amendment rights, making him unavailable as a witness for Wolfe's retrial. Wolfe ultimately pled guilty to avoid the death penalty, receiving a 41-year sentence.Wolfe filed a new habeas petition in the Eastern District of Virginia, asserting claims of vindictive prosecution and due process violations based on the Commonwealth's intimidation of Barber. The district court dismissed the petition as untimely and found that Wolfe failed to present new, reliable evidence of actual innocence under the Schlup standard. Wolfe appealed to the Fourth Circuit Court of Appeals.The Fourth Circuit held that Barber's new declaration, which exculpated Wolfe and explained his previous invocation of the Fifth Amendment due to Commonwealth threats, constituted new, reliable evidence. The court found that Barber's declaration was credible and that no reasonable juror would have convicted Wolfe if they had heard Barber's recantation. The court vacated the district court's judgment and remanded for adjudication of Wolfe's substantive claims. View "Wolfe v. Dotson" on Justia Law

Stephen Simmons pled guilty to violating the National Firearms Act by possessing an unregistered auto sear, a device that converts semi-automatic firearms to fire like machineguns. On the day of his offense, Simmons tested positive for methamphetamine and marijuana. Although he was not prosecuted for any drug-related crime, the district court applied multiple sentencing enhancements, penalizing him for possessing the unregistered auto sear, additional auto sears, silencers, and firearms as an unlawful user of controlled substances. Simmons argued that these enhancements violated his Second Amendment rights and that the term "unlawful user of any controlled substance" was unconstitutionally vague.The United States District Court for the Southern District of West Virginia applied sentencing enhancements that increased Simmons's offense level due to his status as an unlawful user of controlled substances and his possession of multiple and stolen firearms. The court calculated his total offense level as 25, resulting in an advisory Sentencing Guidelines range of 57 to 71 months' imprisonment. After applying a downward variance, the district court sentenced Simmons to 36 months in prison.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court rejected Simmons's Second Amendment challenge, noting that he conceded he had no constitutional right to possess auto sears or silencers, which are not protected by the Second Amendment. The court also dismissed his vagueness claim, as Simmons's conduct clearly fell within the definition of an "unlawful user" of controlled substances. However, the court found that the district court erred in applying sentencing enhancements for possessing ordinary firearms not covered by the National Firearms Act, as these firearms were not relevant to the offense for which Simmons was convicted. Consequently, the Fourth Circuit vacated Simmons's sentence and remanded the case for resentencing. View "US v. Simmons" on Justia Law

Rashun Suncar was convicted of distributing fentanyl and challenged the application of a career offender enhancement to his sentence. This enhancement was based on two prior Pennsylvania state convictions for delivery of a controlled substance. Suncar argued that the Pennsylvania statute criminalizes offers to sell and attempted transfers of drugs, making it broader than the federal guidelines' definition of a controlled substance offense.The United States District Court for the Northern District of West Virginia applied the career offender enhancement, referencing the Third Circuit's decision in United States v. Dawson, which held that the Pennsylvania statute was an appropriate predicate for a career offender finding. The district court imposed a sentence of 92 months, noting that it would impose the same sentence even if the guideline determination was found incorrect.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court rejected Suncar's argument that the Pennsylvania statute includes offers to sell, noting that the statute's language does not support this interpretation. The court also found that the statute's criminalization of attempted transfers does not make it overbroad, as an attempted transfer is considered a completed delivery under federal law and analogous state statutes. The court affirmed the district court's judgment, holding that the Pennsylvania statute is not categorically overbroad compared to the federal guidelines. View "United States v. Suncar" on Justia Law

Demmerick Brown, an inmate at Red Onion State Prison in Virginia, violated the prison’s COVID-19 policy by removing his face mask to get a shave at the barber shop. As a result, the prison fined him fifteen dollars, which was deducted from his prison trust account. Brown claimed that he was not provided the necessary forms to present evidence and call witnesses at his disciplinary hearing, and his request to postpone the hearing was denied. He was found guilty and fined.Brown sued three prison officials under 42 U.S.C. § 1983, alleging a violation of his Fourteenth Amendment due process rights. The United States District Court for the Western District of Virginia dismissed his case, concluding that Brown lacked a property interest in the money in his prison trust account, and thus, the fine did not trigger due process protections.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court vacated the district court’s dismissal, holding that inmates do have a property interest in the money in their prison trust accounts, as established in Henderson v. Harmon. The court found that the fifteen-dollar fine deprived Brown of this property interest, and thus, the Due Process Clause was applicable. The court rejected the argument that the fine was de minimis, noting its significance within the prison context.The Fourth Circuit vacated the district court’s decision and remanded the case for further proceedings to determine what process was due and whether any errors in Brown’s disciplinary proceedings were harmless. View "Brown v. Stapleton" on Justia Law

Joel Aaron Burrell, a prisoner, filed a lawsuit against several correctional officers under 42 U.S.C. § 1983. Burrell sought to proceed in forma pauperis, which allows indigent prisoners to file lawsuits without prepaying filing fees. The district court denied his request, citing the three-strike rule under the Prison Litigation Reform Act, which prevents prisoners from proceeding in forma pauperis if they have had three prior lawsuits dismissed for being frivolous, malicious, or failing to state a claim. The district court identified three such dismissals in Burrell's case history and dismissed his current action when he did not pay the filing fee.Burrell appealed, arguing that two of the prior dismissals should not count as strikes. The first case was dismissed under the Younger abstention doctrine, which prevents federal courts from interfering with ongoing state proceedings. The second case was dismissed after Burrell failed to amend his complaint following a court order that found his initial complaint failed to state a claim.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court concluded that a dismissal under Younger abstention does not count as a strike because it does not assess the merits of the complaint. Regarding the second case, the court determined that while a failure to amend following a finding of failure to state a claim can count as a strike, it should not be counted if the dismissal occurred after the current lawsuit was filed.The Fourth Circuit held that the district court erred in applying the three-strike rule to Burrell's case. Since Burrell had only one valid strike at the time he filed the current lawsuit, the district court's dismissal was vacated and the case was remanded for further proceedings. View "Burrell v. Shirley" on Justia Law

Dan G. Martin prevailed against Deborah Faye Parker in a Virginia state court for breach of contract. Instead of paying the judgment, Deborah filed for Chapter 7 bankruptcy. Dan then initiated an adversary action, claiming his judgment was nondischargeable under 11 U.S.C. § 523(a)(4) for embezzlement. The bankruptcy court ruled in Dan's favor, finding the judgment nondischargeable. Deborah appealed to the district court, which reversed the bankruptcy court's decision, ruling that Dan had not proven Deborah's fraudulent intent.The bankruptcy court found that Deborah embezzled funds by liquidating accounts she held jointly with her father, Morton, despite knowing the terms of Morton's will and a post-marital agreement. The court concluded that Deborah's actions met the definition of embezzlement. However, the district court found that Deborah had disclosed the will and agreement to the bank, which advised her that she was entitled to the funds. This led the district court to conclude that Deborah had a good-faith belief that the funds were hers, precluding a finding of fraudulent intent.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The court held that the bankruptcy court's finding of fraudulent intent was clearly erroneous because Deborah had disclosed the relevant documents to the bank and acted on the bank's advice. The court concluded that Deborah's good-faith belief that the funds were hers negated the fraudulent intent required for embezzlement under § 523(a)(4). Therefore, the district court correctly reversed the bankruptcy court's judgment for Dan, and the judgment for Deborah was affirmed. View "Parker v. Martin" on Justia Law

Amanda Watts received two vaccines, Pneumovax 23 and Boostrix, at a CVS Pharmacy in 2017. She claimed that both vaccines were negligently administered in the same improper location on her arm, leading to a chronic pain condition. However, CVS is immune from suit for the administration of Boostrix under the National Childhood Vaccine Injury Act of 1986. Consequently, Watts's complaint focused solely on the alleged negligence in administering Pneumovax.The United States District Court for the District of Maryland granted summary judgment to CVS, finding that Watts presented no evidence from which a jury could determine that her injury was caused by the Pneumovax vaccine rather than the Boostrix vaccine. The court also struck an errata sheet submitted by Watts's expert, Dr. Akhil Chhatre, which attempted to amend his deposition testimony to suggest that both vaccines contributed to Watts's injury.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The Fourth Circuit agreed that Watts failed to provide evidence to establish that her injury was caused by the Pneumovax shot, as required to overcome CVS's immunity for the Boostrix shot. The court noted that both of Watts's experts could not definitively attribute her injury to the Pneumovax vaccine alone. The court also upheld the district court's decision to strike Dr. Chhatre's errata sheet, which materially altered his original testimony.The Fourth Circuit concluded that without evidence to separate the effects of the two vaccines, a jury could only speculate on the cause of Watts's injury. Therefore, Watts could not satisfy the causation element of her negligence claim, and the summary judgment in favor of CVS was affirmed. View "Watts v. Maryland CVS Pharmacy, LLC" on Justia Law

Cristian Cabrera-Rivas was convicted by a jury of two drug offenses related to a methamphetamine deal. Cabrera-Rivas, who grew up in Honduras and has limited education and English proficiency, was involved in negotiating a meth deal with a confidential informant named Hector, who was working with the Department of Homeland Security. During the deal, Cabrera-Rivas vouched for the meth supplier, Marco Ramos-Garcia, and was present when the meth was delivered. The police arrested Cabrera-Rivas at the scene and found cash and nearly pure methamphetamine.The United States District Court for the Western District of North Carolina found Cabrera-Rivas competent to stand trial based on a government psychologist's evaluation. The court denied his motion for a judgment of acquittal and precluded him from presenting certain affirmative defenses but allowed him to argue entrapment. The jury convicted him on both counts. Post-trial, the district court denied his motions for a new trial and a retrospective competency hearing, finding sufficient evidence for the convictions and no bad faith in the destruction of a recorded interview.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decisions. The appellate court found no clear error in the magistrate judge's competency ruling and held that the district court did not abuse its discretion in denying a second competency hearing. The court also found sufficient evidence to support the convictions, noting that a reasonable jury could infer that Cabrera-Rivas had constructive possession of the meth. The court rejected Cabrera-Rivas's due process claim regarding the destroyed interview recording, as there was no evidence of bad faith. Finally, the court upheld the district court's refusal to instruct the jury on the public authority, innocent intent, outrageous conduct, and entrapment by estoppel defenses. View "US v. Cabrera-Rivas" on Justia Law