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

Mountain Valley Pipeline, LLC sought to condemn a 9.89-acre easement on Elizabeth Reynolds' 109-acre farmland in Roanoke County, Virginia, under the Natural Gas Act. The district court granted partial summary judgment and a preliminary injunction for immediate possession to Mountain Valley Pipeline, leaving the issue of just compensation unresolved. Reynolds submitted two expert reports to determine compensation, which the district court excluded, leading to a summary judgment in favor of Mountain Valley Pipeline.The United States District Court for the Western District of Virginia excluded Reynolds' expert reports, citing Rule 71.1(h) and Rule 702. The court found the first report speculative and the second unreliable due to insufficient data. Consequently, the court granted summary judgment to Mountain Valley Pipeline, awarding just compensation based on the higher estimate of the pipeline company's experts.The United States Court of Appeals for the Fourth Circuit reviewed the case and found that the district court erred in its application of Rule 71.1(h) and Rule 702. The appellate court held that the Federal Rules of Evidence should apply identically in eminent domain cases as in other cases, and the district court should not have conflated Rule 71.1(h) with Rule 702. The appellate court also determined that the district court should have made findings of fact and conclusions of law on the record when resolving contested factual issues under Rule 71.1(h). The Fourth Circuit vacated the district court's decision and remanded the case for further proceedings consistent with its opinion. View "Mountain Valley Pipeline, LLC v. 9.89 Acres of Land" on Justia Law

The plaintiffs, who are military members, filed a class action against Citibank, alleging violations of the Servicemembers Civil Relief Act (SCRA) and other statutes. They claimed Citibank improperly charged them higher interest rates and fees on their credit card balances after they left active duty, contrary to the SCRA's protections. The credit card agreements included arbitration clauses that required disputes to be resolved individually, not as class actions.The United States District Court for the Eastern District of North Carolina denied Citibank's motion to compel arbitration, holding that the SCRA allowed servicemembers to bring class actions in federal court despite any prior agreement to arbitrate. The court interpreted the SCRA's provision allowing class actions "notwithstanding any previous agreement to the contrary" as overriding the Federal Arbitration Act (FAA).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 the SCRA does not explicitly prohibit arbitration agreements and that the FAA requires enforcement of such agreements unless there is a clear congressional command to the contrary. The court found that the SCRA's language did not provide such a command and that the arbitration agreements should be enforced according to their terms, which included individual arbitration.The Fourth Circuit remanded the case with instructions to compel arbitration for all claims except those under the Military Lending Act (MLA). The court noted that the MLA explicitly prohibits arbitration agreements for disputes involving the extension of consumer credit to servicemembers. The district court was instructed to determine whether the MLA applied to the plaintiffs' credit card accounts and to address any related issues. View "Espin v. Citibank, N.A." on Justia Law

Mountain Valley Pipeline, LLC (MVP) condemned a 0.32-acre access easement on Grace Terry's land in southwestern Virginia to deliver heavy equipment to a section of its pipeline. The key issue in this case is the amount of just compensation MVP must pay Terry for the easement. Terry argued that the easement significantly devalued her land, blocking the best hiking trail and citing recent below-market sales of neighboring properties affected by MVP's actions. The district court excluded Terry's testimony on damages and an expert report she submitted, leading to her appeal.The United States District Court for the Western District of Virginia granted MVP partial summary judgment and a preliminary injunction for immediate possession of the easement. The court excluded Terry's testimony on damages, finding it speculative and without a rational basis. It also excluded the expert report by Dennis Gruelle, applying a heightened admissibility standard and determining contested facts at the evidentiary stage. The court then granted MVP summary judgment, awarding Terry $10,409 in just compensation.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the district court abused its discretion by excluding most of Terry's testimony and the Gruelle Report. The Fourth Circuit found that Terry's personal knowledge of her land and comparable sales were valid bases for her testimony. It also determined that the district court applied erroneous legal principles by using a heightened evidentiary standard for the expert report. The Fourth Circuit vacated the exclusion of the Gruelle Report and reversed the exclusion of most of Terry's testimony, remanding the case for further proceedings consistent with its opinion. View "Mountain Valley Pipeline, LLC v. 0.32 Acres of Land" on Justia Law

The Pharmaceutical Coalition for Patient Access (the Coalition), a charitable organization involving drug manufacturers, challenged an unfavorable advisory opinion issued by the Office of the Inspector General (OIG) for the U.S. Department of Health and Human Services (HHS). The dispute centered on the Coalition’s proposed patient assistance program for Medicare beneficiaries, which aimed to subsidize co-pays for oncology drugs. The OIG determined that the program would violate the Anti-Kickback Statute if the required mens rea were present, as it would offer remuneration to induce the purchase of specific drugs.The United States District Court for the Eastern District of Virginia granted summary judgment in favor of the defendants, the United States, HHS, and related officials, and dismissed the Coalition’s claims. The court found that the OIG’s advisory opinion was not arbitrary or capricious and that the Coalition’s program would indeed fall within the Anti-Kickback Statute’s prohibitions.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The court affirmed the district court’s decision, agreeing that the word “induce” in the Anti-Kickback Statute should be construed under its ordinary meaning, not its specialized criminal law meaning. The court also concluded that “remuneration” in the statute includes any payment or compensation, not just corrupt payments that distort medical decision-making. The court found that the Coalition’s program involved a quid pro quo, as it offered subsidies for the purchase of specific drugs.The Fourth Circuit also upheld the district court’s dismissal of the Coalition’s disparate treatment claim for lack of subject matter jurisdiction, ruling that the OIG’s enforcement discretion is not subject to judicial review. The court concluded that the OIG had consistently applied the Anti-Kickback Statute to similar proposals and that the Coalition’s challenge was directed against the OIG’s enforcement discretion, which is unreviewable under the Administrative Procedure Act. View "Pharmaceutical Coalition for Patient Access v. United States" on Justia Law

Andre Le Doux was driving on Interstate 81 in Virginia when he encountered a sudden traffic standstill due to a torrential downpour. As he braked, a vehicle behind him pushed his van into another vehicle, leaving his van exposed in the left lane. Ervin Worthy, driving a Western Express tractor trailer, saw the heavy rain and braked, but could not stop in time and collided with Le Doux’s van, causing severe injuries to Le Doux.Le Doux sued Worthy for negligence and willful and wanton negligence, and Western Express for vicarious liability and negligent hiring. The United States District Court for the Western District of Virginia excluded expert testimony from Le Doux’s meteorologist and accident reconstructionist due to gaps in radar data and inaccurate GPS timestamps. The court also excluded testimony from Le Doux’s trucking expert, finding it unnecessary for the jury to understand the standard of care for a tractor trailer driver in rainy conditions. Additionally, the court dismissed Le Doux’s negligent hiring claim against Western Express, reasoning that since Worthy was acting within the scope of his employment, the claim was redundant.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court’s exclusion of the expert testimonies, agreeing that the gaps in data and potential jury confusion justified the decision. The court also upheld the exclusion of the trucking expert’s testimony, finding that the jury could understand the necessary standard of care without it. Finally, the court affirmed the dismissal of the negligent hiring claim, holding that since the jury found Worthy not negligent, Western Express could not be liable for negligent hiring. The Fourth Circuit concluded that the district court did not abuse its discretion in its rulings. View "Le Doux v. Western Express, Inc." on Justia Law

Phillip and Sara Alig, along with Daniel and Roxanne Shea, filed a class action lawsuit against Quicken Loans, Inc. (now Rocket Mortgage, LLC) and Title Source, Inc. (now Amrock, Inc.). They alleged that during the refinancing of their home mortgage loans, they paid for appraisals that were not independent because the defendants had provided appraisers with the homeowners' estimates of their homes' value. They claimed this made the appraisals worthless and asserted statutory, breach of contract, and conspiracy claims.The United States District Court for the Northern District of West Virginia certified a class of West Virginia citizens who refinanced mortgage loans with Quicken and received appraisals that included an estimate of the property's value. The court granted summary judgment to the plaintiffs, awarding over $10.6 million in damages. The court found that the plaintiffs had established a conspiracy between the defendants.The United States Court of Appeals for the Fourth Circuit affirmed the class certification and summary judgment on the statutory and conspiracy claims but vacated and remanded the breach of contract claim. The Supreme Court vacated the Fourth Circuit's judgment and remanded the case for reconsideration in light of TransUnion LLC v. Ramirez, which emphasized that every class member must have Article III standing to recover damages.On remand, the district court reinstated its original judgment, stating that TransUnion did not affect the class's standing. However, the Fourth Circuit concluded that the plaintiffs failed to establish that class members suffered concrete harm from the defendants' actions. The court reversed the district court's judgment certifying the class and awarding damages, affirming the judgment on the named plaintiffs' statutory and conspiracy claims, and vacating the judgment on the breach of contract claim, remanding it for further proceedings. View "Alig v. Rocket Mortgage, LLC" on Justia Law

Tytus Lamaar Shields pleaded guilty to possession of a firearm as a felon, violating 18 U.S.C. § 922(g)(1). In November 2021, law enforcement in Parkersburg, West Virginia, received information that Shields was transporting drugs. Shields, on bond for pending charges in Ohio and considered a fugitive, was arrested at his residence, where officers seized drugs, cash, and a loaded firearm. Shields admitted the firearm was his. He was charged with being a felon in possession of a firearm, knowing he had prior Ohio felony convictions, including one for drug trafficking.The United States District Court for the Southern District of West Virginia calculated an advisory Sentencing Guidelines range of 51 to 63 months and sentenced Shields to 51 months. Shields argued for a downward variance, citing an unwarranted sentencing disparity between his case and similar cases in West Virginia, but the district court did not address this argument. The court focused on Shields’s criminal history and sustained the government’s objection to the Presentence Investigation Report, which had not applied the increased base offense level for a "controlled substance offense."The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that the district court committed procedural error by failing to address Shields’s non-frivolous argument for a downward variance based on sentencing disparities. The appellate court held that the district court must consider and explain its reasoning regarding such arguments to allow for meaningful appellate review. Consequently, the Fourth Circuit vacated Shields’s sentence and remanded the case for resentencing, emphasizing the need for the district court to address all non-frivolous arguments presented by the defendant. View "United States v. Shields" on Justia Law

Margaret Ann Sutton was involved in a drug trafficking operation with Vicente Andres, a known drug dealer. Sutton initially visited Andres's house to buy and distribute drugs. Their relationship turned romantic, and they traveled together to California to purchase a large quantity of methamphetamine and marijuana. Upon returning to Virginia, they continued distributing the drugs. Sutton was actively involved in the drug sales, including a transaction with an undercover officer. During a police raid, Sutton was found with marked bills from a drug sale, and a large quantity of marijuana was discovered in a puzzle box in the house.The United States District Court for the Eastern District of Virginia convicted Sutton in a bench trial of various federal criminal offenses, including possession with intent to distribute marijuana and use of a drug-involved premises. Sutton was sentenced to twenty-nine years in prison. She appealed her convictions and sentence, arguing insufficient evidence and procedural and substantive unreasonableness in her sentencing.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that there was sufficient evidence to support Sutton's convictions. The court held that Sutton constructively possessed the marijuana found in the puzzle box, as she had control over the drugs and was aware of their presence. Additionally, the court determined that Sutton actively employed the house for the purpose of drug distribution, satisfying the requirements of 21 U.S.C. § 856(a)(1). The court also found that Sutton's sentence was neither procedurally nor substantively unreasonable, noting that her sentence was below the Guidelines range and that the district court had considered her background and history.The Fourth Circuit affirmed the district court's decision, upholding Sutton's convictions and sentence. View "United States v. Sutton" on Justia Law

Banorte, a group of five associated entities of the Mexican bank Grupo Financiero Banorte, sued Cartograf S.A. de C.V. (Cartograf Mexico) in the Fourth Civil Court of Mexico City in 2021. Banorte alleged that Cartograf Mexico and its sole administrator, José Páramo Riestra, defaulted on loans and concealed assets. Banorte filed an ex parte application in the Eastern District of Virginia to conduct discovery on Cartograf Mexico’s American subsidiary, Cartograf USA, Inc., under 28 U.S.C. § 1782. The district court granted the application, allowing Banorte to serve Cartograf USA with a subpoena. Cartograf USA moved to quash the subpoena, but the district court denied the motion.The United States District Court for the Eastern District of Virginia granted Banorte’s application for discovery under 28 U.S.C. § 1782, finding that the statutory requirements and discretionary factors set out in Intel Corp. v. Advanced Micro Devices, Inc. weighed in Banorte’s favor. The court allowed Banorte to serve subpoenas on Cartograf USA, seeking documents and deposition testimony related to Cartograf USA’s relationship with Cartograf Mexico and Páramo. Cartograf USA argued that the discovery was not for use in a foreign proceeding and that Banorte’s requests were made in bad faith, but the district court rejected these arguments.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 Banorte satisfied the statutory requirements of § 1782, including the “for use” requirement, as the requested discovery had a reasonable possibility of being useful in the Mexican civil proceedings. The court also found that the district court did not abuse its discretion in analyzing the Intel factors, including the receptivity of the foreign tribunal and whether the request was an attempt to circumvent foreign proof-gathering restrictions. The Fourth Circuit concluded that the district court’s careful consideration of the factors and its decision to grant the application and deny the motion to quash were appropriate. View "Banco Mercantil Del Norte, S.A v. Cartograf USA, Inc." on Justia Law

Curtis Wells parked his car near Arlington Cemetery and was noticed by Officer Armstrong due to his animated gestures while on a phone call. Armstrong approached Wells and discovered that his car had an expired registration. Arlington County police were called, and they found that Wells did not have a driver's license and had weapons in his car. The police decided to tow Wells's car and conducted an inventory search, which revealed various weapons and tactical gear, including a ballistic plate carrier. Wells was sent home, but further investigation suggested that the plate might have been stolen from the Army. Nine days later, Wells was arrested for receiving stolen property.In the United States District Court for the Eastern District of Virginia, Wells brought state and federal claims against various officers and entities, alleging Fourth and Fifth Amendment violations, among other claims. The district court dismissed all his claims, reasoning that the officers were protected by qualified immunity and that Wells had not plausibly alleged the necessary elements for his state tort claims.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's dismissal. The court held that the officers' actions were protected by qualified immunity because Wells did not have a clearly established right against the officers' conduct. The court found that the initial approach by Officer Armstrong was justified under the community-caretaking exception, the inventory search of Wells's car was conducted according to standard procedures, and Wells had consented to the safekeeping of his property. Additionally, the court held that Wells's Second Amendment claims failed because the right to public carry was not clearly established in 2020. The court also dismissed Wells's state law claims, finding that he had not plausibly alleged the necessary elements for false imprisonment or malicious prosecution. View "Wells v. Fuentes" on Justia Law