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

Plaintiffs filed a class action lawsuit in state court against Defendants, alleging violations of state securities laws. Defendants removed the case to federal court under the Securities Litigation Uniform Standards Act (SLUSA), arguing that the case involved covered securities. Plaintiffs amended their complaint to exclude any claims related to covered securities, leading the district court to remand the case to state court. After three years of state court litigation, Defendants removed the case again, citing an expert report that allegedly identified covered securities. The district court remanded the case again and awarded Plaintiffs $63,007.50 in attorneys' fees.The United States District Court for the District of South Carolina initially denied Plaintiffs' motion to remand but later granted it after Plaintiffs amended their complaint. The court found that the amended complaint excluded any claims related to covered securities, thus SLUSA did not apply, and no federal question remained. After Defendants removed the case a second time, the district court remanded it again and awarded attorneys' fees, finding the second removal lacked a reasonable basis.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's award of attorneys' fees. The court held that the second removal was improper because the amended complaint explicitly excluded claims related to covered securities, and thus SLUSA did not apply. Additionally, the court found that the removal was objectively unreasonable, as the district court had already addressed the issues in its first remand order. The Fourth Circuit also denied Plaintiffs' request for additional attorneys' fees for defending the appeal, stating that 28 U.S.C. § 1447(c) does not authorize fee awards on appeal. View "Black v. Mantei & Associates, Ltd." on Justia Law

Evy Orellana suffered serious injuries when a tactical canine bit her leg as a U.S. Marshals fugitive task force executed an arrest warrant for her boyfriend, Eric Trinidad. Orellana, Trinidad, and their baby lived in the basement of Trinidad’s mother’s home. The officers breached a sealed door to access the basement, and the dog bit Orellana during the search. Orellana sued the officers under Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics, claiming a violation of her Fourth Amendment rights due to unreasonable search and seizure.The United States District Court for the District of Maryland denied the officers' motion to dismiss, reasoning that the case was similar enough to Bivens to apply its cause of action. The court also denied the officers' motion for summary judgment on the grounds of qualified immunity.The United States Court of Appeals for the Fourth Circuit reviewed the case and reversed the district court's decision. The appellate court held that this case presented a new context for Bivens because the officers were part of a specialized federal-state task force operating under a warrant. The court emphasized that the Supreme Court has cautioned against extending Bivens to new contexts, particularly when Congress is better suited to create a cause of action. The court concluded that special factors, including federalism concerns and the existence of alternative remedial procedures, counseled against extending Bivens in this situation. Therefore, the appellate court reversed the district court's decision, denying Orellana a Bivens remedy. View "Orellana v. Deputy United States Marshal Godec" on Justia Law

James Gould was involuntarily committed to mental health facilities four times between May 2016 and July 2019. In February 2022, police found him in his West Virginia home with a twelve-gauge shotgun. A grand jury indicted him for violating 18 U.S.C. § 922(g)(4), which makes it unlawful for anyone who has been committed to a mental institution to possess a firearm. Gould pleaded guilty but appealed, arguing that the Second Amendment renders the statute facially unconstitutional.The United States District Court for the Southern District of West Virginia rejected Gould’s challenge, concluding that there is a historical basis for disarming individuals determined to be dangerous to themselves or the public. The court found that § 922(g)(4) is constitutional on its face. Gould then changed his plea to guilty and was sentenced to time served and three years of supervised release.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that § 922(g)(4) is consistent with the nation’s historical tradition of firearm regulation. The court noted that historically, legislatures incapacitated those suffering from mental illness when they posed a danger to themselves or others. Additionally, the court found that legislatures had the authority to disarm groups of people considered dangerous. The court emphasized that disarmament under § 922(g)(4) is not categorically permanent, as individuals can petition for relief to restore their firearm rights. The court concluded that § 922(g)(4) is facially constitutional because it can be applied in situations consistent with the Second Amendment. The Fourth Circuit affirmed Gould’s conviction. View "United States v. Gould" on Justia Law

Columbia Gas Transmission operates a natural gas pipeline that crosses a parcel of land owned by RDFS, LLC. Columbia holds an easement to operate and maintain the pipeline on this parcel. When a coal company planned to mine beneath the parcel, Columbia sought access to mitigate potential harm to its pipeline. RDFS denied access, leading Columbia to file a lawsuit. The district court granted a preliminary injunction allowing Columbia to proceed with its mitigation efforts.The United States District Court for the Northern District of West Virginia first considered Columbia's motion for a preliminary injunction. The court applied the four factors from Winter v. Natural Resources Defense Council, Inc., concluding that Columbia was likely to succeed on the merits, would suffer irreparable harm without access, and that the balance of equities and public interest favored Columbia. The court also granted Columbia's motion for partial summary judgment to condemn a temporary easement under the Natural Gas Act, finding that Columbia met all necessary requirements.The United States Court of Appeals for the Fourth Circuit reviewed the district court's grant of the preliminary injunction for abuse of discretion. The appellate court found that Columbia's easement provided broad authority to access the entire parcel for maintenance, including mitigation work. The court rejected RDFS's argument that the easement was vague and limited by Columbia's prior use. The court affirmed the district court's ruling, concluding that Columbia's right to access the parcel for mitigation was consistent with maintaining the pipeline and did not unreasonably burden RDFS's property. The ruling of the district court was affirmed. View "Columbia Gas Transmission, LLC v. RDFS, LLC" on Justia Law

Bank of America Corporation, after merging with Merrill Lynch in 2013, sought to recover interest on its pre-merger tax underpayments by netting them against pre-merger overpayments made by Merrill Lynch. The bank argued that the post-merger integration rendered it the "same taxpayer" as Merrill Lynch for purposes of the interest netting provision under 26 U.S.C. § 6621(d) of the Internal Revenue Code.The United States District Court for the Western District of North Carolina initially held jurisdiction over all of the Bank's claims. However, the Federal Circuit determined that the Court of Federal Claims had exclusive jurisdiction over claims for overpayment interest exceeding $10,000, leading to the severance and transfer of those claims. The district court then addressed the remaining claims, granting partial summary judgment in favor of the government. The court concluded that the "same taxpayer" requirement applies at the time the payments were made, and since Bank of America and Merrill Lynch were distinct entities when the payments were made, the interest netting provision did not apply.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 interest netting provision under § 6621(d) requires that the same taxpayer must have made the underpayments and overpayments at the time they were made. Since Bank of America and Merrill Lynch were separate entities when the relevant payments were made, they could not be considered the "same taxpayer" for the purposes of interest netting. The court also rejected the Bank's arguments based on state merger law and legislative history, emphasizing that the statutory text was clear and did not support the Bank's interpretation. View "Bank of America Corp. v. United States" on Justia Law

Robbie Plyler, a longtime farm worker, was injured when his leg became trapped in a running grain auger inside a grain bin on Cox Brothers Farms, resulting in the amputation of his right leg below the knee. The jury found that both Plyler and Cox Brothers Farms were negligent, but the farm had the last clear chance to avoid the injury. The jury awarded Plyler $2,000,000 in compensatory damages and $500,000 for loss of consortium to his wife, Deborah. Cox Brothers Farms appealed the decision.The United States District Court for the Western District of North Carolina denied Cox's pre-trial motions for summary judgment and its renewed motion for judgment as a matter of law on Plyler’s negligence and gross negligence claims. The court also denied Cox's motion to bifurcate the trial into separate liability and damages phases and its motion to exclude testimony from Plyler’s farm safety expert.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the jury’s verdict. The court found that the district court did not err in denying Cox's motions for summary judgment and judgment as a matter of law, as there was sufficient evidence to support the jury's finding that Cox had the last clear chance to avoid Plyler’s injury. The appellate court also upheld the district court’s decision to deny Cox's motion to bifurcate the trial and to admit the expert testimony, noting that the district court provided appropriate limiting instructions to the jury regarding the use of OSHA regulations as evidence. The court concluded that the district court acted within its discretion and that there were no exceptional circumstances warranting a new trial. View "Plyler v. Cox" on Justia Law

In 2023, Tovis Ation Richardson pled guilty to conspiracy to distribute and possess with intent to distribute methamphetamine, and possession with intent to distribute methamphetamine, under a written plea agreement. He was sentenced to 240 months in prison. Richardson appealed, raising two issues: whether the district court erred in applying a sentencing enhancement for firearm possession, and whether his counsel was ineffective for not objecting to this enhancement.The United States District Court for the Eastern District of North Carolina adopted the presentence report (PSR) which included a base offense level of 36, with two enhancements: one for firearm possession and another for maintaining a premises for drug distribution. The PSR also included reductions for acceptance of responsibility, resulting in a total offense level of 37 and a sentencing range of 210 to 262 months. Both parties recommended a 240-month sentence, which the district court imposed.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that Richardson had waived his right to appeal the firearm enhancement in his plea agreement, which was valid and enforceable. The court also determined that Richardson’s claim of ineffective assistance of counsel did not conclusively appear in the record, as required for direct appeal. The court noted that the firearm enhancement was properly applied based on the discovery of a shotgun in Richardson’s car, which was used in the drug conspiracy. The court concluded that counsel’s failure to object to the enhancement did not constitute deficient performance under the Strickland standard.The Fourth Circuit affirmed the judgment of the district court, upholding Richardson’s 240-month sentence. View "United States v. Richardson" on Justia Law

Eric Walton, whose life sentence was commuted by the President, was found in possession of drugs and drug proceeds within a year of his release, violating the terms of his supervised release. Walton represented himself in the revocation proceedings, and the district court sentenced him to 60 months' imprisonment. Walton appealed, arguing that the court erred in allowing him to represent himself, lacked jurisdiction over his commuted sentence, and imposed an unreasonable sentence.The United States District Court for the Northern District of West Virginia revoked Walton's supervised release based on multiple violations, including committing new offenses and possessing controlled substances. Walton admitted to these violations during the revocation hearing. The court appointed counsel for Walton, but he chose to proceed pro se, with stand-by counsel available.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the district court retained jurisdiction over Walton's supervised release, as the commutation order explicitly left the supervised release term intact. The court also found that Walton knowingly and voluntarily chose to represent himself, given his extensive experience with the legal system and his clear and repeated requests to proceed pro se.Regarding the sentence, the Fourth Circuit determined that the district court did not err in its calculation of the Guidelines range or in its explanation of the sentence. The court noted that Walton's violations included a Grade A violation, justifying the 60-month sentence. The court also found that the district court adequately considered the relevant statutory factors and provided a sufficient explanation for the sentence imposed.The Fourth Circuit affirmed the district court's judgment, upholding Walton's 60-month imprisonment sentence for violating the terms of his supervised release. View "United States v. Walton" on Justia Law

Wheeling Power Company operates the Mitchell Plant, where employees are represented by Local 492 under a collective bargaining agreement. After a fire at another plant owned by the same parent company, employees from that plant were temporarily assigned to the Mitchell Plant. These employees were not covered by Local 492’s agreement, leading the union to file a grievance. The grievance was denied, and the union took the matter to arbitration. The arbitrator found that assigning work to non-union employees violated the agreement but left the remedy to be determined by the parties, retaining jurisdiction in case of an impasse.The United States District Court for the Northern District of West Virginia upheld the arbitrator’s liability award. Wheeling Power appealed, arguing that the arbitrator exceeded his authority and that the award was not final because the remedy had not been determined.The United States Court of Appeals for the Fourth Circuit reviewed the case and concluded that the complete arbitration rule applied, meaning the arbitrator’s decision was not final since he retained jurisdiction over the remedy. The court noted that the district court should have dismissed the case as premature. Despite Local 492 not raising this issue in the lower court, the appellate court chose to overlook the forfeiture to reinforce the complete arbitration rule’s importance and to avoid piecemeal litigation.The Fourth Circuit vacated the district court’s judgment and remanded the case with instructions to dismiss it without prejudice, allowing the parties to return to court once the arbitrator’s award becomes final. View "Wheeling Power Company - Mitchell Plant v. Local 492 Utility Workers Union of America" on Justia Law

Wilbert Finley, a production manager at Kraft Heinz’s Newberry, South Carolina plant, was responsible for overseeing product quality and food safety. Finley raised concerns about food safety, particularly regarding improperly sealed bacon packages and bone fragments in the meat. He reported these issues to his supervisors and HR, but was criticized and told not to stop production. On March 24, 2020, Finley was suspended and then terminated two days later, allegedly for dishonesty during an HR investigation into the botched firing of another employee, Yolanda Gaines.The United States District Court for the District of South Carolina granted summary judgment to Kraft Heinz, adopting the magistrate judge’s report and recommendation. The magistrate judge concluded that Finley could not establish that his safety complaints were a “contributing factor” in his dismissal, citing the March 24 investigation as a legitimate intervening event that severed any causal connection. The district court agreed, also finding that Kraft Heinz had shown by clear and convincing evidence that it would have terminated Finley regardless of his complaints.The United States Court of Appeals for the Fourth Circuit vacated the district court’s judgment and remanded the case. The appellate court held that the district court and magistrate judge failed to properly consider all the evidence, including the close temporal proximity between Finley’s complaints and his termination, and the disputed facts regarding the March 24 investigation. The court found that a reasonable jury could infer that Finley’s food safety complaints contributed to his termination and that Kraft Heinz’s rationale for firing him was pretextual. Thus, the case was remanded for further proceedings. View "Finley v. Kraft Heinz Inc." on Justia Law