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

Modern filed suit against Turner, alleging claims arising from a subcontract outlining Modern's role in the construction of an FBI facility. The Fourth Circuit held that the district court properly applied West Virginia's law and rejected all of Modern's claims based on the plain language of the contract. In this case, the district court granted Turner summary judgment on the field verification claim, and subsequently ruled in favor of Turner on the remaining claims.The court held that Modern and Turner were two sophisticated parties that entered into a detailed contract spelling out their rights and responsibilities in the construction of the FBI facility, and the provisions of that contract directly addressed the very issues raised in this appeal. Furthermore, the provisions of the contract compelled the result reached by the district court. Accordingly, the court affirmed the judgment. View "US f/u/b of Modern Mosaic, Ltd v. Turner Construction Co." on Justia Law

Plaintiffs filed suit challenging the "methods and means" that the Census Bureau has adopted for the 2020 Census, and the contention that the 2020 Census will produce an even greater differential undercount. Plaintiffs represent hard-to-count communities that historically have suffered the greatest harms from differential undercounts, and that directly will lose federal funding if the differential undercount increases in 2020. The district court dismissed plaintiffs' claims under the Enumeration Clause and the Administrative Procedures Act (APA).The Fourth Circuit affirmed in part, holding that plaintiffs' APA claims, as pleaded, did not satisfy the jurisdictional limitations on judicial review set forth in the APA. However, mindful of the Supreme Court's recent guidance affirming judicial review of "both constitutional and statutory challenges to census-related decision-making," Dep't of Commerce v. New York, 139 S. Ct. 2551, 2568 (2019), the court held that the district court erred in dismissing plaintiffs' Enumeration Clause claims as unripe, and in precluding plaintiffs from filing an amended complaint regarding those claims after defendants' plans for the 2020 Census became final. Therefore, the court reversed in part and remanded to allow plaintiffs to file an amended complaint setting forth their Enumeration Clause claims. View "NAACP v. Bureau of the Census" on Justia Law

Defendant was convicted of unlawful possession of a firearm by a convicted felon and sentenced to 51 months in prison. The Fourth Circuit affirmed defendant's conviction, holding that the district court's failure to give a limiting instruction sua sponte and its decision to permit the government to cross-examine defendant did not constitute plain error.However, the court vacated defendant's sentence, holding that defendant's prior conviction for robbery under Maryland law was a violent felony under the force clause of the Armed Career Criminal Act (ACCA). The court also held that Maryland possession with intent to distribute constitutes a controlled substance offense under the sentencing guidelines. Because the district court erred in holding otherwise, the court remanded for resentencing. View "United States v. Johnson" on Justia Law

Petitioner appealed the district court's grant of summary judgment denying his 28 U.S.C. 2254 petition for habeas corpus relief. Petitioner alleged due process violations stemming from a prison disciplinary proceeding that resulted in the revocation of twenty days of his good-time credits.The Fourth Circuit affirmed the denial of petitioner's claim regarding the DHO's failure to review the requested surveillance video during his hearing, because there was no clearly established violation of petitioner's right at the time. Therefore, the North Carolina Supreme Court did not act unreasonably in denying petitioner's claim. However, the court vacated the district court's determination that petitioner's conviction was supported by "some evidence" in the record. The court held that this case presented the exceedingly rare circumstance where the record contained no probative evidence to support petitioner's conviction. Therefore, petitioner's disciplinary conviction amounted to a violation of his due process rights. Accordingly, the court remanded with instructions to grant habeas relief as to the good-time credits. View "Tyler v. Hooks" on Justia Law

Defendants Peterson and Bun appealed their convictions for crimes related to their involvement in a methamphetamine distribution ring in prison. The Fourth Circuit affirmed the convictions and held that the district court did not abuse its discretion in dismissing the indictment without prejudice, having carefully weighed the relevant set of non-exclusive factors set out in the Interstate Agreement on Detainers Act (IADA). The court explained that, by affording district courts substantial discretion over this determination, Congress sought to ensure that violations of the IADA's anti-shuttling provision would not needlessly encumber federal prosecutions. Therefore, the court rejected defendants' claim that the district court should have dismissed their initial indictment with prejudice because they were improperly transferred from federal to state custody.The court joined every federal court to address the question and held that a superseding indictment filed 30 days after an arrest does not violate 18 U.S.C. 3161(b) so long as the original indictment was filed within the Speedy Trial Act's 30-day window. The court found defendants' remaining claims regarding their speedy trial rights and claims of evidentiary error were without merit. View "United States v. Peterson" on Justia Law

The Fourth Circuit granted the government's motion to dismiss defendant's appeal after he pleaded guilty to identity theft and fraud. The court held that Federal Rule of Appellate Procedure 4(b)'s deadline was a mandatory claim-processing rule that must be strictly applied and thus the district court's error in failing to advise defendant of his right to appeal could not excuse defendant's untimely filing and equitable doctrines were unavailable to extend the deadline. The court noted, however, that its conclusion did not render Federal Rule of Criminal Procedure 32(j) a nullity. Rather, defendant may seek to remedy the district court's error in a collateral proceeding. View "United States v. Marsh" on Justia Law

The Fourth Circuit affirmed defendant's conviction for carjacking, conspiracy to commit carjacking, and destruction of government property. The court held that the district court did not err by denying defendant's motion for judgment of acquittal on the carjacking and conspiracy charges, because there was sufficient evidence to support the charges; motion to suppress evidence related to a cell phone search, because the district court's inference that defendant abandoned his phone while fleeing was reasonable; and motion to excuse and question two jurors, because defendant failed to show that the extrajudicial communications or contacts at issue were more than innocuous interventions. View "United States v. Small" on Justia Law

Plaintiff, an inmate at a state prison, filed suit against officials at the VDOC under the Religious Land Use and Institutionalized Persons Act (RLUIPA) and the Free Exercise Clause of the First Amendment, alleging that the VDOC was denying him the ability to practice central tenets of his Muslim religion. The district court granted summary judgment to the VDOC.The Fourth Circuit vacated and remanded, holding that the VDOC's stated justifications for denying plaintiff access to a Friday prayer service known as Jum'ah and interfering with his ability to maintain a four-inch beard were invalid under both RLUIPA and the First Amendment. The court commended for consideration by the VDOC in further proceedings the full practical effect of observations made by former correctional officials that providing robust support for inmates' genuine religious exercise would actually enhance prison security and inmate rehabilitation. View "Greenhill v. Clarke" on Justia Law

A Maryland law requiring newspapers, among other platforms, to publish on their websites, as well as retain for state inspection, certain information about the political ads they decide to carry, violates the First amendment. The Fourth Circuit affirmed the preliminary injunctive relief awarded by the district court and explained that, while Maryland's law tries to serve important aims, the state has gone about this task in too circuitous and burdensome a manner to satisfy constitutional scrutiny. The court agreed with the district court that the law is a content-based law that targets political speech and compels newspapers, among other platforms, to carry certain messages on their websites. The court declined to decide whether strict or exacting scrutiny should apply to a disclosure law like the one at issue, and held that the law failed under the more forgiving exact scrutiny standard. View "The Washington Post v. McManus" on Justia Law

The Fourth Circuit affirmed defendant's conviction for possession of a firearm by a felony, holding that the district court did not err by denying his motion to suppress. The court held that the evidence presented to the district court supported a finding that the firearm inevitably would have been discovered during an inventory search of the plastic bag. The court declined to address the government's alternative argument that the firearm was discovered during a valid search incident to arrest. View "United States v. Seay" on Justia Law