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

Plaintiff filed suit against CBS after the CBS Evening News aired two reports on the opioid crisis in West Virginia that featured plaintiff and his pharmacy. Plaintiff alleged claims of defamation, false light invasion of privacy, tortious interference, and intentional infliction of emotional distress. The district court granted summary judgment in favor of defendants on all claims. On appeal, plaintiff challenged the district court's rulings as to two allegedly defamatory statements in the report.The Fourth Circuit affirmed the district court's judgment as to the two allegedly defamatory statements in the reports: (1) "Records show Tug Valley was filling more than 150 pain prescriptions a day from one clinic alone," and (2) plaintiff "admit[ted] to filling 150 pain pill prescriptions daily for one clinic alone." The court held that, because plaintiff failed to offer evidence from which a reasonable juror could find that the allegedly defamatory statements in the CBS reports were false, rather than minor inaccuracies, and he bears the burden of proof on this element of his defamation and false light invasion of privacy claims, summary judgment on both claims was appropriate. Finally, the court held that plaintiff's attempt to raise for the first time on appeal two new implications of the news reports is foreclosed. View "Ballengee v. CBS Broadcasting, Inc." on Justia Law

Plaintiffs filed suit against the State Defendants, challenging the constitutionality of Maryland's handgun licensing law, which is part of the Maryland Firearm Safety Act of 2013 (FSA), for violating their Second Amendment rights. Plaintiffs also challenged other FSA regulations as vague and ambiguous in contravention of the Fourteenth Amendment and separately attacked certain FSA regulations as ultra vires under Maryland law. The district court granted summary judgment to the State Defendants based on plaintiffs' lack of Article III standing.The Fourth Circuit held that the district court erred in holding that Atlantic Guns lacks both independent and third-party standing to bring a Second Amendment claim. In this case, the district court erroneously weighed the evidence by focusing on the extent of the economic injury as opposed to the existence of one; Atlantic Guns' owner and presidents' uncontroverted testimony and declaration, as well as the pertinent Maryland State Police records and Atlantic Guns' year-over-year sales records, are sufficient to establish an injury in fact for purposes of Article III standing; Atlantic Guns' injuries are fairly traceable to the challenged statute; and the injuries are likely to be redressed by a favorable judicial decision. Furthermore, Atlantic Guns has standing to challenge the statute on behalf of potential customers like the Individual Plaintiffs and other similarly situated persons.The court also held that, because standing for one party on a given claim is sufficient to allow a case to proceed in its entirety on that issue, the court need not reach the question of whether the Individual Plaintiffs and MSI have standing to bring their Second Amendment claims. Accordingly, the court affirmed in part, reversed in part, and remanded with instructions. View "Maryland Shall Issue, Inc. v. Hogan" on Justia Law

The Fourth Circuit held that the district court did not err in denying defendant's motion to suppress evidence obtained from wiretaps. Defendant argued that because the wiretap orders did not include the name of each authorizing official, the orders were statutorily insufficient and therefore all evidence derived from them should have been suppressed.The court held that the wiretap orders were sufficient under the Wiretap Act because (1) the applications were in fact appropriately authorized by persons authorized by the Wiretap Act; (2) the orders on their face identified, albeit not by name, the Justice Department officials who authorized the applications; (3) the applications themselves, to which the orders on their face referred, did contain both the title and name of the official authorizing the application; and (4) the applications and proposed orders were submitted together as one package to the judge who signed the orders and later to defendant, whose communications were intercepted, such that both the judge and defendant actually knew both the title and name of the official authorizing each application. Furthermore, even if the court were to assume that the omission of the name of the authorizing official in the orders was a defect, it would not be the type of defect that rendered the orders "insufficient" under Section 2518(10)(a)(ii) of the Wiretap Act. View "United States v. Brunson" on Justia Law

The Government initiated a civil commitment proceeding under 18 U.S.C. 4248, seeking the commitment of appellee to the custody of the Attorney General as a "sexually dangerous person."The Fourth Circuit affirmed the district court's dismissal of the section 4248 civil commitment certification as untimely. The court held that once the Maryland district court determined appellee was incompetent to stand trial, appellee could remain committed to the Attorney General for only an additional reasonable period of time until his charges were disposed of in accordance with law. Absent a creditable explanation of the reasonableness of appellee's commitment post-December 2018 -- two years after his initial commitment and six full months after the Unrestorability Determination -- the statutory language and the court's precedent in United States v. Searcy, 880 F.3d 116, 122 (4th Cir. 2018), and United States v. Timms, 664 F.3d 436, 451–52 (4th Cir. 2012), compel the court to hold that appellee could no longer be considered legitimately committed to the Attorney General's custody in June 2019. View "United States v. Wayda" on Justia Law

In consolidated appeals challenging the dismissal of petitioner's three habeas petitions, the Fourth Circuit held that petitioner adequately alleged that his due process rights were violated by (1) inadequate notice of the basis for revoking his suspended sentence, (2) undue delay in seeking revocation based on the violation, and (3) incarceration when he was previously adjudged not guilty by reason of insanity and civilly committed to receive treatment in a mental health hospital. Accordingly, the court vacated the dismissals and remanded with instructions to the district court to consider the merits of petitioner's due process and ineffective assistance of counsel claims. View "Farabee v. Clarke" on Justia Law

The Fourth Circuit affirmed the district court's grant of summary judgment in favor of state officials on petitioner's 28 U.S.C. 2254 petition for writ of habeas corpus. The court held that the state postconviction court reasonably denied petitioner's exhausted Strickland claims on the grounds that capital sentencing counsel thoroughly investigated and presented his available evidence in mitigation, and did not neglect a viable Confrontation Clause objection to his disciplinary record. The court also held that the district court properly denied petitioner's Strickland claim as insubstantial under Martinez v. Ryan, 566 U.S. 1 (2012). View "Owens v. Stirling" on Justia Law

After a group of borrowers filed suit against two online lenders, the Haynes Defendants filed a motion to compel arbitration. The Fourth Circuit affirmed the district court's denial of the motion to arbitrate, holding that the borrowers sufficiently challenged the validity of the delegation clauses and the district court was correct to consider the enforceability of the arbitration agreements.The court also held that the choice-of-law clauses amount to a prospective waiver such that the arbitration agreements, including the delegation clauses, are unenforceable. Therefore, the court explained that the district court had the authority to decide whether the arbitration agreements were valid, correctly decided they were not, and did not err in denying the motion to compel arbitration. View "Gibbs v. Haynes Investments, LLC" on Justia Law

After a group of borrowers filed suit against two online lenders, the Sequoia Defendants filed a motion to compel arbitration. The Fourth Circuit affirmed the district court's denial of the motion to arbitrate, holding that the borrowers sufficiently challenged the validity of the delegation clauses and the district court was correct to consider the enforceability of the arbitration agreements.Furthermore, because the effect of the choice-of-law provisions is to stymie the vindication of the federal statutory claims that the borrowers seek to enforce, they amount to a prospective waiver and render the delegation provisions unenforceable. The court therefore held that the entire arbitration agreement is unenforceable. The court explained that the district court had the authority to decide whether the arbitration agreements were valid, correctly decided they were not, and did not err in denying the motion to compel arbitration. View "Gibbs v. Sequoia Capital Operations, LLC" on Justia Law

The Fourth Circuit affirmed the district court's dismissal of an action challenging the "winner-take-all" aspect of South Carolina's process for appointing its nine Electors to the Electoral College.After determining that it has subject matter jurisdiction to address the merits of the appeal, the court held that the winner-take-all process does not violate the Equal Protection Clause, because it does not treat any particular group of voters in the State differently; the winner-take-all process does not violate plaintiffs' First and Fourteenth Amendment rights because it does not burden plaintiffs' right to freedom of association; and the winner-take-all process does not violate Section 2 of the Voting Rights Act. In this case, while plaintiffs allege that Black voters in South Carolina are a minority group sufficiently large and geographically compact to constitute a majority in a single-member district, the court stated that they fail to address what this means in the context of a statewide election. View "Baten v. McMaster" on Justia Law

Plaintiff, an inmate in custody of the VDOC, filed suit pro se alleging that the Director of the VDOC and three other VDOC officials violated his rights under Title II of the Americans with Disabilities Act (ADA) and the Fourteenth Amendment when they did not allow him to resume his job after a short hospitalization.The Fourth Circuit held that the district court erred in dismissing plaintiff's ADA claims for damages against the defendants in their official capacities, and in dismissing plaintiff's ADA and equal protection claims for injunctive relief against the Director in his official capacity. The court held that plaintiff's ADA and 42 U.S.C. 1983 equal protection claims were timely filed; plaintiff plausibly alleged a violation of Title II and an equal protection claim; and defendants are not entitled to Eleventh Amendment immunity at this juncture. Therefore, the court vacated the district court's dismissal of these claims. The court otherwise affirmed the district court's judgment. View "Fauconier v. Clarke" on Justia Law