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

Plaintiffs, a Maryland LLC and a Missouri nonprofit corporation, alleged that the Maryland State Board of Elections mismanaged state electoral operations in violation of state and federal laws during the 2020 and 2022 general elections. They claimed inaccuracies in voter registration records, excessive error rates in voting systems, improper certification of voting machines, use of uncertified machines, and failure to provide requested audit logs and configuration reports. They sought declaratory and injunctive relief, including the appointment of a Special Master to supervise changes before the November 2024 election.The United States District Court for the District of Maryland dismissed the complaint without prejudice for lack of subject-matter jurisdiction, concluding that the plaintiffs had not alleged injuries sufficiently concrete and particularized to support Article III standing. The court found that the plaintiffs did not satisfy the requirements for organizational standing, as they failed to allege any injury to their organizational activities or to their members that was concrete and particularized. The court also held that the alleged violations of the Maryland Public Information Act did not constitute a redressable injury in fact.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that the plaintiffs lacked representational standing to assert claims on behalf of their individual members. The court found that the alleged vote dilution and the possibility that members' ballots were cast blank were generalized grievances that did not constitute concrete, particularized injuries. Additionally, the court held that the plaintiffs did not demonstrate that any of their members made the public records requests, thus failing to establish standing for the alleged violations of the Maryland Public Information Act. Consequently, the appellate court affirmed the dismissal of the complaint and the denial of the motion for injunctive relief as moot. View "Maryland Election Integrity, LLC v. Maryland State Board of Elections" on Justia Law

Plaintiffs, a group of charter-boat operators and trade associations in Maryland, sued the Atlantic States Marine Fisheries Commission to enjoin the Commission’s striped-bass plan. The Commission, formed in 1942, recommends fishery management plans to its member states. Plaintiffs argued that the plan, which included a one-fish limit for charter boats, would significantly harm their businesses. They sought an injunction to prevent the implementation of the plan.The United States District Court for the District of Maryland denied Plaintiffs’ motion for a preliminary injunction. The court found that Plaintiffs likely lacked standing because they were regulated by Maryland, not the Commission. The court noted that even if the Commission’s plan were enjoined, it was unlikely that Maryland would rescind its own regulations, which were stricter than the Commission’s recommendations. The court also found that Plaintiffs did not plausibly state a claim for relief under 42 U.S.C. § 1983, as the Commission is not a “person” under the statute and does not act under “color of state law.”The United States Court of Appeals for the Fourth Circuit reviewed the case and concluded that Plaintiffs lacked standing to sue. The court held that Plaintiffs failed to plausibly allege that Maryland would likely rescind its regulations if the Commission’s plan were enjoined. The court emphasized that Maryland voluntarily adopted the regulations and had the authority to impose stricter measures than those recommended by the Commission. As a result, the court vacated the district court’s order denying the preliminary injunction and remanded the case with instructions to dismiss for lack of jurisdiction. View "Delmarva Fisheries Association, Inc. v. Atlantic States Marine Fisheries Commission" on Justia Law

Melvin Funez-Ortiz, a Honduran national, fled to the United States to escape violence and threats from a gang in Honduras. The gang had murdered several of his family members, shot him, and continued to threaten his family. After entering the U.S. in 2018, Funez was apprehended by immigration officials and later convicted of various offenses in Virginia. Following his imprisonment, he was transferred to immigration custody, where he applied for asylum, withholding of removal, and deferral of removal under the Convention Against Torture (CAT).An immigration judge (IJ) denied Funez’s requests for asylum and withholding of removal but granted his application for deferral of removal under the CAT. The IJ found that Funez would likely be tortured by the gang with the acquiescence of the Honduran government if he were returned to Honduras. The Department of Homeland Security (DHS) appealed the IJ’s decision to the Board of Immigration Appeals (BIA).The BIA reversed the IJ’s decision, concluding that the IJ’s finding that Funez could not safely relocate within Honduras was clearly erroneous. The BIA also disagreed with the IJ’s determination that the Honduran government would acquiesce to Funez’s torture, suggesting that the man in a military police uniform who threatened Funez’s family was likely a gang member rather than a government official.The United States Court of Appeals for the Fourth Circuit reviewed the BIA’s decision. The court found that the BIA had ignored significant evidence regarding the gang’s continued threats and activities after 2018, which could impact Funez’s ability to relocate safely within Honduras. The court also determined that the BIA improperly reweighed evidence regarding whether the man in uniform was a government official. Consequently, the Fourth Circuit granted Funez’s petition for review, vacated the BIA’s decision, and remanded the case for further proceedings. View "Funez-Ortiz v. McHenry" on Justia Law

In June 2015, Dylann Roof shot and killed nine people at Mother Emanuel AME Church in Charleston, South Carolina, including M.P.'s father, Reverend Clementa Pinckney. M.P., a minor, filed a lawsuit against Meta Platforms, Inc. (formerly Facebook, Inc.) and its subsidiaries, alleging that Facebook's algorithm recommended harmful content that radicalized Roof, leading to the murders. M.P. asserted claims of strict products liability, negligence, and negligent infliction of emotional distress under South Carolina law, as well as a federal claim under 42 U.S.C. § 1985(3) for conspiracy to deprive her of her civil rights.The United States District Court for the District of South Carolina dismissed M.P.'s complaint under Federal Rule of Civil Procedure 12(b)(6), concluding that Section 230 of the Communications Decency Act barred her state law tort claims. The court also found that M.P. failed to plausibly allege a claim under 42 U.S.C. § 1985(3).The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that M.P.'s state law tort claims were barred by Section 230 because they sought to hold Facebook liable as a publisher of third-party content. The court also determined that M.P. failed to plausibly allege proximate causation under South Carolina law, as her complaint did not provide sufficient factual foundation linking Roof's Facebook use to his crimes. Additionally, the court found that M.P. forfeited her challenge to the dismissal of her Section 1985 claim by not adequately addressing it in her appellate brief. The court also concluded that any potential claim under 42 U.S.C. § 1986 was barred by the one-year statute of limitations. Thus, the Fourth Circuit affirmed the district court's judgment granting Facebook's motion to dismiss. View "M.P. v. Meta Platforms Inc." on Justia Law

Jeremy Smith, a customer care technician for Cox Enterprises, Inc., received long-term disability benefits for seven years due to severe back pain and multiple surgeries. In 2019, Aetna, the plan administrator, terminated his benefits, concluding he could work under certain conditions. Smith appealed, providing additional medical evidence, including a consultative examination from Dr. Harris, which supported his disability claim. Aetna upheld the termination, leading Smith to file a lawsuit under the Employee Retirement Income Security Act (ERISA).The United States District Court for the Eastern District of Virginia granted summary judgment in favor of Cox Enterprises, Inc. Welfare Benefits Plan. The court found that Aetna's decision was supported by substantial evidence and that it was reasonable for Aetna to discount the opinions of Smith's primary care physician and the Social Security Administration's disability determination.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that Aetna abused its discretion by failing to adequately discuss and consider conflicting evidence, particularly Dr. Harris's consultative examination and the Social Security Administration's disability determination. The court found that Aetna did not engage in a deliberate and principled reasoning process, as required by ERISA regulations. Consequently, the Fourth Circuit reversed the district court's decision and remanded the case for further proceedings, instructing the district court to remand the matter to Aetna for reconsideration of Smith's claim. View "Smith v. Cox Enterprises, Inc. Welfare Benefits Plan" on Justia Law

Lisa Wheeler, a physician assistant and former Assistant Medical Director at Acadia Healthcare Company’s Asheville, North Carolina clinic, filed a complaint alleging that Acadia falsified medical records to claim payments from government healthcare programs. Wheeler claimed that Acadia, which provided methadone-assisted treatment for opioid use disorder, failed to provide required therapy and counseling services, instead fabricating therapy notes to submit fraudulent claims to Medicare, Medicaid, and other government programs.The United States District Court for the Western District of North Carolina dismissed Wheeler’s amended complaint, concluding that she failed to adequately plead that Acadia’s false claims were material or submitted to the government. The court found that Wheeler did not sufficiently allege that Acadia’s failure to provide therapy was material to the government’s payment decisions or that false claims were actually submitted to the government.The United States Court of Appeals for the Fourth Circuit reviewed the case and reversed the district court’s decision. The Fourth Circuit held that Wheeler adequately pled her claims of presentment, false statement, false certification, and fraudulent inducement under the False Claims Act. The court found that Wheeler’s allegations of falsified therapy notes and non-compliance with federal opioid treatment standards were material to the government’s payment decisions. The court also concluded that Wheeler sufficiently alleged that Acadia submitted false claims to government healthcare programs and that the fraudulent conduct was central to the government’s decision to pay.Additionally, the Fourth Circuit held that Wheeler adequately pled her reverse false claim, finding that the stipulated penalties in Acadia’s Corporate Integrity Agreement with the government constituted an obligation under the False Claims Act. The court remanded the case for further proceedings consistent with its opinion. View "United States ex rel. Wheeler v. Acadia Healthcare Company, Inc." on Justia Law

Environmental groups challenged the issuance of a permit by the U.S. Army Corps of Engineers for the development of the Cainhoy Plantation in South Carolina. The plaintiffs argued that the permit violated the Endangered Species Act (ESA) and the National Environmental Policy Act (NEPA). They claimed the permit improperly used a habitat surrogate to set the level of anticipated take of an endangered species and was issued after an Environmental Assessment (EA) rather than a more comprehensive Environmental Impact Statement (EIS).The United States District Court for the District of South Carolina denied the plaintiffs' motion for a preliminary injunction, finding that they did not have a sufficient likelihood of success on the merits of their claims. The court concluded that the Corps' decision to issue the permit based on an EA was reasonable and that the use of a habitat surrogate was justified under the circumstances.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 Corps had taken the required "hard look" at the environmental consequences of the project as mandated by NEPA and that the use of a habitat surrogate was appropriate given the impracticality of monitoring the take of individual bats. The court found that the Corps' decision to rely on an EA instead of preparing an EIS was entitled to deference and that the plaintiffs had not demonstrated a likelihood of success on the merits of their claims. The court also noted that the surrogate used by the Service was enforceable and set a clear standard for determining when the level of anticipated take had been exceeded. View "South Carolina Coastal Conservation League v. United States Army Corps of Engineers" on Justia Law

Jarvis Mikel Jackson pled guilty to possession of a firearm as a felon, violating 18 U.S.C. § 922(g)(1). The district court calculated an advisory Sentencing Guidelines range of 110 to 120 months and sentenced Jackson to 115 months in prison. Jackson appealed, arguing that the district court erred in treating his two prior South Carolina drug distribution convictions as "controlled substance offenses" under the Guidelines, which increased his base offense level.Initially, the district court overruled Jackson's objection, distinguishing the South Carolina statute from the West Virginia statute in United States v. Campbell, which did not qualify as a controlled substance offense. The district court adopted the PSR's base offense level and sentenced Jackson to 115 months. Jackson appealed, and the Fourth Circuit vacated his sentence, agreeing that the South Carolina statute included attempted deliveries, making it broader than the Guidelines definition.Before Jackson's resentencing, the Fourth Circuit issued decisions in United States v. Groves and United States v. Davis. Groves held that a federal drug distribution conviction is a controlled substance offense under the Guidelines, while Davis held that South Carolina's statute is materially distinguishable from West Virginia's and qualifies as a controlled substance offense. At resentencing, the district court followed Davis, overruled Jackson's objection, and again sentenced him to 115 months without addressing his arguments for a downward variance based on post-sentencing conduct.The United States Court of Appeals for the Fourth Circuit reviewed Jackson's appeal, agreeing with the district court's reliance on Davis but finding procedural error in the lack of individualized explanation for the sentence. The court vacated Jackson's sentence and remanded for resentencing, requiring the district court to address Jackson's arguments and provide an adequate explanation for the sentence. View "United States v. Jackson" on Justia Law

Ikeviaun Johnson, a passenger in a black Ford Explorer, fired eight shots at a white Hyundai sedan, which was actually an unmarked car occupied by federal law enforcement officers. The incident occurred in Greenville, North Carolina, during an investigation. Johnson was charged and convicted of assaulting federal officers and discharging a firearm in furtherance of a crime of violence. The district court sentenced him to 198 months’ imprisonment, an above-Guidelines sentence.The United States District Court for the Eastern District of North Carolina handled the initial trial. Johnson was convicted by a jury on both counts. At sentencing, the court calculated a Guidelines range of 150 to 157 months but imposed a 198-month sentence, citing the severity of Johnson's actions and his lack of remorse.The United States Court of Appeals for the Fourth Circuit reviewed the case. Johnson appealed on three grounds: a defective indictment, insufficient evidence of assault, and an inadequately justified above-Guidelines sentence. The Fourth Circuit rejected all three arguments. The court held that the indictment, despite omitting the word "forcibly," provided sufficient notice of the charges. The court also found ample evidence that Johnson's actions caused the officers to apprehend immediate bodily harm, satisfying the assault element. Lastly, the court ruled that the district court had adequately justified the upward variance in Johnson's sentence, considering the seriousness of the offense and Johnson's conduct.The Fourth Circuit affirmed the district court's judgment, upholding Johnson's conviction and 198-month sentence. View "US v. Johnson" on Justia Law

Stephen Bryant was sentenced to death by a South Carolina state court. During postconviction proceedings, Bryant filed a new application for relief, claiming his execution would violate the Eighth Amendment due to his intellectual disabilities, as defined in Atkins v. Virginia and Hall v. Florida. Later, Bryant sought to amend his application to include a claim that he suffers from fetal alcohol spectrum disorder (FASD) and that executing individuals with FASD should also be prohibited under the Eighth Amendment. The state postconviction court denied this request, ruling it was both impermissibly successive and filed too late.Bryant's initial appeal to the South Carolina Supreme Court, which focused on a single claim of evidentiary error, was denied. He then sought post-conviction relief on several grounds, none of which included the Eighth Amendment claim. The state trial court denied these claims, and the South Carolina Supreme Court denied discretionary review. Bryant subsequently filed for federal habeas corpus relief, which was stayed to allow him to exhaust state remedies. He filed two new applications in state court, one of which was allowed to proceed on the intellectual disability claim but not on the FASD claim. The state trial court ultimately denied the intellectual disability claim on its merits.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the state trial court's refusal to permit Bryant to amend his application to add the FASD claim rested on state procedural grounds that were independent of federal law and adequate to bar federal habeas review. The Fourth Circuit affirmed the district court's denial of habeas relief, concluding that Bryant's FASD claim was procedurally defaulted and could not be considered on its merits. View "Bryant v. Stirling" on Justia Law