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

Antonio Davis, who was serving a 210-month prison sentence for conspiracy to possess with intent to distribute heroin, petitioned the district court for compassionate release due to his elevated risk of severe COVID-19 and a change in the law regarding his career offender status. The district court denied his request, concluding that Davis was not due compassionate release based on his susceptibility to COVID-19 and did not fully consider each of Davis’s arguments.Davis was indicted on charges of conspiracy to distribute and conspiracy to possess with intent to distribute heroin in January 2013. He pled guilty to conspiracy to possess with intent to distribute heroin in June of that year. Davis received a career offender enhancement because he had previously been convicted of certain other offenses and because the offense at issue here was a “controlled substance offense” at the time of conviction. In February 2021, Davis filed a pro se motion for compassionate release under 18 U.S.C. § 3582(c)(1)(A), arguing that he was uniquely susceptible to the potential spread of COVID-19 due to his type-2 diabetes and hypertension. He also argued that a recent court decision invalidated his career offender Guidelines designation.The United States Court of Appeals for the Fourth Circuit affirmed in part, vacated and remanded in part the district court's decision. The court concluded that the district court did not abuse its discretion in finding that Davis failed to show extraordinary and compelling reasons for release based on the pandemic. However, the court found that the district court did not properly address Davis’s arguments regarding intervening changes in law and rehabilitation. Therefore, the court vacated the district court’s denial of compassionate relief and remanded for further proceedings. View "United States v. Davis" on Justia Law

The case revolves around a consent decree that was negotiated by the parties and previously approved by the district court. The decree prohibits the Receivership Estate of ERP Environmental Fund, Inc. from conducting surface coal mining at certain sites unless it is necessary for and incidental to reclamation of the site. The question presented is whether that prohibition also applies to a third-party permit transferee of a specific site—the Chestnut Oak Surface Mine in Lincoln County, West Virginia. The district court held that it did, stating that all third-party permit transferees are bound by the terms of the consent decree.The consent decree originated from a 2011 citizen suit under the Clean Water Act and the Surface Mining Control and Reclamation Act. The plaintiffs alleged that now-defunct Patriot Coal Corporation and three of its subsidiaries violated federal environmental laws by discharging excessive amounts of selenium in connection with its surface mining operations. To resolve the litigation, the parties negotiated a consent decree, which the U.S. District Court for the Southern District of West Virginia approved.In 2020, ERP ran out of money and ceased all operations. As a result, a West Virginia state court appointed Doss Special Receiver, LLC to administer ERP’s Receivership Estate. In 2022, the Receiver sought to finance its administration of the Receivership Estate by authorizing third parties to surface mine at a former Patriot Coal facility—the Buck Fork Surface Mine. The Conservation Groups intervened, arguing that such surface mining would violate Paragraph 63 of the Decree. The district court agreed.The United States Court of Appeals for the Fourth Circuit vacated the district court's decision and remanded the case with instructions. The court held that the district court's interpretation of the consent decree could not be squared with the plain text of the decree. The court found that the consent decree's prohibition on surface mining did not apply to a third-party permit transferee of a specific site. The court concluded that neither Paragraph 24 nor Paragraph 25 of the decree would bind a third-party permit transferee of the Chestnut Oak Surface Mine to Paragraph 63's prohibition on surface mining, a prohibition that expressly applies only to ERP and its Affiliated Companies. View "West Virginia Highlands Conservancy v. ERP Environmental Fund, Inc" on Justia Law

The case revolves around Ronald Lee Morgan, who filed for Chapter 7 bankruptcy in North Carolina. Morgan owned a home jointly with his wife as tenants by the entirety. He sought to exempt this home from the bankruptcy estate to the extent of his outstanding tax debt to the Internal Revenue Service (IRS). However, the bankruptcy court disallowed the exemption. Morgan's wife did not jointly owe the debt to the IRS and did not file for bankruptcy. The trustee of the bankruptcy estate objected to Morgan's claim for an exemption, arguing that under North Carolina state law, tenancy by the entireties property is generally exempt from execution by creditors of only one spouse, but this rule does not apply to tax obligations owing to the United States.The bankruptcy court sustained the trustee's objection, and on appeal, the district court affirmed this decision. Morgan then appealed to the United States Court of Appeals for the Fourth Circuit, arguing that for his IRS debt to override the entireties exemption, the IRS must have obtained a perfected tax lien on the property prior to the filing of the bankruptcy petition.The Court of Appeals for the Fourth Circuit affirmed the district court's ruling. The court concluded that Morgan's interest in his home as a tenant by the entirety is not "exempt from process" under "applicable nonbankruptcy law." The court rejected Morgan's argument that the IRS must have actually obtained a lien prior to the bankruptcy filing, stating that the absence of a judgment or lien has no bearing on the hypothetical issue of whether the debtor's interest would be exempt from process. The court also dismissed Morgan's contention that the IRS must perfect a lien against his property before he filed for bankruptcy. The court concluded that nothing in the Supreme Court's decision in United States v. Craft limits its holding to instances where the IRS has perfected a tax lien against the property. View "Morgan v. Bruton" on Justia Law

A West Virginia law, known as the "Save Women's Sports Act," stipulates that athletic teams or sports designated for females, women, or girls shall not be open to students of the male sex, with "male" defined as an individual whose biological sex determined at birth is male. The law was challenged by a 13-year-old transgender girl, B.P.J., who has been taking puberty-blocking medication and has publicly identified as a girl since the third grade. B.P.J. argued that the law violated the Equal Protection Clause and Title IX by preventing her from participating in her school's cross country and track teams.The United States District Court for the Southern District of West Virginia initially granted a preliminary injunction, allowing B.P.J. to participate in her school's sports teams. However, upon review of cross-motions for summary judgment, the court reversed its decision, rejecting B.P.J.'s claims and ruling that the law was constitutional and did not violate Title IX.On appeal, the United States Court of Appeals for the Fourth Circuit disagreed with the lower court's decision. The appellate court held that the law could not lawfully be applied to prevent B.P.J. from participating in her school's sports teams. The court found that the law's sole purpose and effect were to prevent transgender girls from playing on girls' teams, which was not substantially related to an important government interest. The court also found that the law violated Title IX by treating B.P.J. worse than people to whom she was similarly situated, depriving her of any meaningful athletic opportunities, and doing so on the basis of sex. The court dismissed the cross-appeal, vacated in part, reversed in part, and remanded the case with instructions to enter summary judgment for B.P.J. on her Title IX claims. View "B.P.J. v. West Virginia State Board of Education" on Justia Law

The United States Court of Appeals for the Fourth Circuit affirmed the convictions of seven members of the "36th Street Bang Squad" gang. The gang members were charged with racketeering conspiracy, murder, attempted murder, and related crimes, following a string of murders, attempted murders, and assaults in 2015 and 2017. The defendants appealed, raising several issues including challenges to the classification of their racketeering offenses as crimes of violence, the denial of their motions to exclude testimony of three forensic experts, and the denial of their motions for judgment of acquittal and for a mistrial. The court found no reversible error and affirmed the convictions. The court also held that an attempt offense qualifies as a crime of violence if the completed offense invariably requires the use of physical force. View "United States v. Hunt" on Justia Law

The case involves TBL Licensing, LLC, commonly known as Timberland, and its attempt to register certain features of its popular boot design as trade dress under the Lanham Act. The United States Patent and Trademark Office (USPTO) refused to register the design, concluding it was not distinctive. Timberland appealed to the federal district court, which agreed with the USPTO and added that the design was impermissibly functional. The district court granted the USPTO's motion for summary judgment.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court held that the district court did not err in concluding that the subset of design features that Timberland sought to register lacked distinctiveness in the public's view. The court did not decide on the issue of functionality. The court emphasized that the question was not whether the public recognizes the entire product as Timberland's boot, but whether the specific design features that Timberland sought to register have acquired a distinctive meaning in the public's view. View "TBL Licensing, LLC v. Vidal" on Justia Law

In 2018, Maryland State Trooper Kevin Caraballo used force while arresting 15-year-old Cameron Lewis. Lewis sued Caraballo for excessive force and battery. Caraballo sought summary judgment, arguing he was entitled to qualified and statutory immunity. The district court denied his motion, leading to this appeal.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court found that there were disputes of material fact that precluded summary judgment. Specifically, a reasonable jury could find that Caraballo struck Lewis when the teenager did not pose a threat, was not actively resistant, and was subdued. The court held that Lewis’s constitutional right to be free from excessive force in the form of head strikes was clearly established at the time of his arrest. Furthermore, the court held that there was a genuine dispute of material fact as to whether Caraballo’s actions amounted to gross negligence or malice, precluding summary judgment in his favor on his statutory immunity defense. View "Lewis v. Caraballo" on Justia Law

The case involves Jerod Montrel Askew, who was convicted of various crimes related to drug trafficking, including two counts of possession of a firearm in furtherance of a drug trafficking crime. Askew appealed his convictions on several grounds, including erroneous jury instructions, insufficient evidence to support a guilty verdict for the firearm-related convictions, an abuse of discretion in offering a sua sponte jury instruction about the legality of the search warrants, and an abuse of discretion in denying his motion for a mistrial after the prosecution referred to his invocation of the right to counsel during closing arguments.The United States District Court for the Eastern District of Virginia had previously denied Askew's motions for a new trial and for a judgment of acquittal. Askew was sentenced to a total term of 198 months of imprisonment and five years of supervised release.The United States Court of Appeals for the Fourth Circuit affirmed Askew’s conviction. The court found no error in the jury instructions, no insufficiency in the evidence supporting the firearm-related convictions, no abuse of discretion in the district court's sua sponte jury instruction about the legality of the search warrants, and no abuse of discretion in denying Askew's motion for a mistrial. The court concluded that the prosecution's brief remark about Askew's invocation of his right to counsel did not amount to impermissible exploitation. View "United States v. Askew" on Justia Law

The case involves Vanda Pharmaceuticals, a drug manufacturer, and the Centers for Medicare & Medicaid Services (CMS). Vanda challenged a 2020 regulation by CMS that expanded the definition of a "line extension" drug under the Medicaid Drug Rebate Program. This program requires drug manufacturers to reimburse Medicaid if they increase their prices faster than inflation. A "line extension" drug, which is a new formulation of an existing drug, can also be liable for price increases of the original drug. Vanda argued that the regulation expanded the definition of a line extension beyond what the Medicaid statute permitted.Previously, the district court granted summary judgment to CMS, disagreeing with Vanda's argument. The court held that the agency's regulation was within the bounds of the Medicaid statute.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court found that the agency's definitions of "line extension" and "new formulation" were within the Medicaid statute's ambit. It also held that the agency's interpretation of the oral-solid-dosage-form requirement was not contrary to law. The court rejected Vanda's argument that the agency's rulemaking process was arbitrary and capricious, finding that the agency had reasonably considered the relevant issues and explained its decision. View "Vanda Pharmaceuticals, Inc. v. Centers for Medicare & Medicaid Services" on Justia Law

The case involves Darryl Colton Frazer, who was convicted and sentenced on drug and firearm offenses in 2023 in the District of Maryland. The charges stemmed from an incident in 2019 when Frazer was stopped by police officers who had reasonable suspicion to conduct an investigatory stop. Frazer had thrown away a black bag just before he was apprehended, which was later found to contain a firearm and approximately 100 grams of marijuana. Frazer unsuccessfully moved to suppress this evidence, arguing that the officers lacked reasonable suspicion to stop him and that they needed a warrant to search the bag.The District Court rejected Frazer's suppression effort, ruling that the police officers had reasonable suspicion to conduct an investigatory stop and could constitutionally search the bag that Frazer had discarded. Frazer was subsequently convicted for three offenses and sentenced to 72 months in prison. He appealed, challenging the denial of his suppression motion and the court’s failure to give a reasonable doubt instruction.The United States Court of Appeals for the Fourth Circuit affirmed the lower court's decision. The court found that the officers had reasonable suspicion to stop Frazer, based on his headlong flight and noncompliance with the officers' commands. The court also ruled that Frazer had voluntarily abandoned his bag, and thus lacked Fourth Amendment standing to challenge the search. Regarding the reasonable doubt instruction, the court held that the district court was not required to define reasonable doubt to the jury, and thus did not abuse its discretion by declining to give the instruction. View "United States v. Frazer" on Justia Law