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

Davina Ricketts, a sophomore at a high school in North Carolina, decided to run for student council to address its lack of diversity. She faced racial harassment and cyberbullying from peers, and the school district allegedly failed to intervene. Ricketts filed a lawsuit claiming the school district was deliberately indifferent to her harassment. The district court dismissed her complaint and denied her motion to amend, stating her proposed amended complaint also failed to state a claim. Ricketts appealed the denial of her motion for leave to amend.The United States District Court for the Eastern District of North Carolina initially dismissed Ricketts' complaint and denied her motion to amend on futility grounds. The court reasoned that her proposed amended complaint did not sufficiently state claims for deliberate indifference, retaliation, or equal protection violations.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that Ricketts sufficiently alleged deliberate indifference, retaliation, and equal protection claims. The court held that Ricketts' allegations of racial harassment, the school administrators' authority and actual knowledge of the harassment, and their deliberate indifference were sufficient to state a Title VI claim. The court also found that Ricketts sufficiently alleged retaliation by showing she engaged in protected activity, faced materially adverse actions, and established a causal connection between the two. Additionally, the court held that Ricketts sufficiently alleged an equal protection claim against individual defendants and the Board of Education by showing discriminatory intent and a municipal custom or policy of indifference.The Fourth Circuit reversed the district court's judgment, directed the district court to allow Ricketts to amend her complaint, and remanded the case for further proceedings. View "Ricketts v. Wake County Public School System" on Justia Law

In 2018, Gary Washington was released from prison after serving 31 years for murder, following a writ of actual innocence. Washington filed a civil lawsuit against the police officers involved in his case, alleging they coerced a witness into providing false testimony, which was later recanted. The district court granted summary judgment in favor of the officers, dismissing Washington's claims of due process violations, malicious prosecution, detention without probable cause, failure to intervene, and intentional infliction of emotional distress. The court found Washington was collaterally estopped from relying on the witness's recantation because a prior state court had found it incredible. The district court also dismissed Washington's alternative due process Brady claim and his intentional infliction of emotional distress claim on independent grounds.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the state court decision granting Washington a writ of actual innocence was inconsistent with the prior post-conviction ruling that the recantation was incredible, precluding the application of collateral estoppel. The court also found that applying collateral estoppel to prohibit Washington from litigating the alleged misconduct was incompatible with equitable principles. The court agreed with the district court's dismissal of Washington's alternative due process Brady claim but reversed the dismissal of his intentional infliction of emotional distress claim, finding that wrongful incarceration for 31 years could constitute severe emotional distress.The Fourth Circuit reversed the district court's grant of summary judgment in part and affirmed it in part, allowing Washington's claims of due process violations, malicious prosecution, detention without probable cause, failure to intervene, and intentional infliction of emotional distress to proceed. View "Washington v. Pelligrini" on Justia Law

A service-disabled veteran and his company, MJL Enterprises, LLC, alleged that the Small Business Administration’s (SBA) Section 8(a) Business Development Program discriminated against him based on race. The program uses a race-conscious presumption to determine social disadvantage, which the plaintiffs argued was unconstitutional. They sought a declaration that the program's racial classifications were unconstitutional and an injunction against its enforcement.The United States District Court for the Eastern District of Virginia dismissed the case, ruling it moot due to changes in the 8(a) Program following an injunction in another case, Ultima Services Corp. v. U.S. Department of Agriculture. The district court also found that the plaintiffs lacked standing because they failed to demonstrate economic disadvantage and could not establish social disadvantage without the presumption.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court reversed the district court’s ruling on mootness, agreeing with the plaintiffs that the case was not moot because the changes to the 8(a) Program were not final and could be appealed. However, the Fourth Circuit affirmed the district court’s dismissal based on lack of standing. The court held that the plaintiffs failed to demonstrate an injury in fact, as they did not show they were "able and ready" to bid on 8(a) Program contracts due to their inability to meet the program’s social and economic disadvantage requirements. The court also found that the plaintiffs could not establish causation or redressability, as their ineligibility for the program was not solely due to the race-conscious presumption.The Fourth Circuit concluded that the plaintiffs lacked Article III standing to sue and affirmed the district court’s dismissal for lack of subject matter jurisdiction. The case was remanded for further proceedings consistent with the opinion. View "Hierholzer v. Guzman" on Justia Law

Between September 2021 and January 2022, agents from the Bureau of Alcohol, Tobacco, Firearms and Explosives, along with local law enforcement in Sanford, North Carolina, coordinated controlled buys of narcotics using a confidential informant (CI). The CI purchased drugs from various individuals, including the appellant, Brian Thomas Bright. The CI primarily interacted with Keyonta McDougald, who facilitated drug buys from Bright. Bright also directed William Samuel Pergerson to assist in drug transactions. Bright and seven others were indicted for conspiracy to possess with intent to distribute fentanyl, methamphetamine, heroin, and cocaine.The United States District Court for the Middle District of North Carolina sentenced Bright to 97 months of imprisonment after he pled guilty to conspiracy to possess with intent to distribute fentanyl. The Presentence Investigation Report (PSR) calculated Bright’s base offense level as 26, with a three-point enhancement for a managerial role under the United States Sentencing Guidelines (Guidelines) § 3B1.1(b). Bright objected to the enhancement, arguing that his criminal activity involved fewer than five participants. The district court overruled the objection, finding that the three-level enhancement was appropriate due to the extent of Bright’s involvement in the conspiracy.The United States Court of Appeals for the Fourth Circuit reviewed the case and found that the district court committed procedural error by not making the necessary findings regarding the scope of the criminal activity and the number of participants involved, as required by Guidelines § 1B1.3 and United States v. Evans. The Fourth Circuit vacated Bright’s sentence and remanded the case for resentencing, instructing the district court to make the requisite particularized findings or determine if the criminal activity was "otherwise extensive." View "US v. Bright" on Justia Law

Plaintiffs, representing West Virginia Parents for Religious Freedom and others, filed a lawsuit challenging West Virginia's mandatory vaccination requirement for children, claiming it violates the Free Exercise Clause of the First Amendment. The law mandates immunizations for children attending public, private, or parochial schools, with medical exemptions but no religious exemptions. Plaintiffs sought declaratory and injunctive relief against state health officials.The United States District Court for the Northern District of West Virginia applied the Pullman abstention doctrine, deciding not to resolve the Free Exercise claim and staying the case. The court reasoned that a recent state law, the Equal Protection for Religion Act (EPRA), might impact the vaccination mandate and should be interpreted by state courts first. The district court denied the plaintiffs' motion for summary judgment and granted the defendants' motion to abstain.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the district court erred in applying the Pullman abstention doctrine because the plaintiffs' claim did not present an unclear issue of state law requiring interpretation. The court emphasized that federal courts have a duty to exercise their jurisdiction and that abstention is only appropriate in special circumstances. The Fourth Circuit vacated the district court's abstention ruling and remanded the case for further proceedings, including addressing the defendants' arguments regarding Ex Parte Young and Article III standing, and if necessary, resolving the Free Exercise claim. View "West Virginia Parents for Religious Freedom v. Christiansen" on Justia Law

Felix Jacobo Salomon-Guillen, a native of El Salvador, entered the United States in 2009 on an O-3 visa as the spouse of Lucia Parker Salomon, a recording artist who later became a naturalized citizen. Salomon-Guillen became a permanent resident and managed his wife's music career. In 2013, he began working as a marketing director for a book publisher and engaged in a fraudulent scheme that cost the company $1.4 million. He was indicted for wire fraud, pleaded guilty, and was sentenced to 18 months in prison.The government sought to remove Salomon-Guillen from the country due to his aggravated felony conviction. He conceded removability and applied for adjustment of status and an inadmissibility waiver. The immigration judge denied his applications, finding that he failed to demonstrate that his removal would cause "extreme hardship" to his wife or mother, both U.S. citizens. The judge also concluded that Salomon-Guillen did not merit a waiver or adjustment of status as a matter of discretion due to the severity of his fraud offense.The Board of Immigration Appeals (BIA) affirmed the immigration judge's decision. The BIA, with Temporary Appellate Immigration Judge Denise G. Brown participating, found that Salomon-Guillen failed to show that his wife would suffer extreme hardship if she accompanied him to El Salvador. The BIA also agreed that he did not merit a waiver or adjustment of status as a matter of discretion.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the regulation allowing temporary Board members to serve six-month terms did not preclude their reappointment for additional terms. The court also found that it lacked jurisdiction to review the BIA's discretionary denial of the inadmissibility waiver. Consequently, the petition for review was denied in part and dismissed in part. View "Saloman-Guillen v. Garland" on Justia Law

Matthew Ryan Hunt was charged with violating 18 U.S.C. § 922(g)(1), which prohibits individuals convicted of a crime punishable by imprisonment for a term exceeding one year from possessing firearms. Hunt's 2017 conviction for breaking and entering in West Virginia served as the predicate offense. In May 2022, Hunt pleaded guilty without raising a Second Amendment challenge. On appeal, Hunt argued that § 922(g)(1) violated the Second Amendment both facially and as applied to him. He also contended that the district court erred in applying a four-point enhancement to his offense level under the federal sentencing guidelines.The United States District Court for the Southern District of West Virginia accepted Hunt's guilty plea and applied the four-point enhancement, finding that Hunt had fired a gun inside an apartment building during a domestic violence incident, which constituted wanton endangerment under West Virginia law. Hunt appealed the decision, arguing that the statute was unconstitutional and that the district court's factual findings were erroneous.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court reaffirmed that § 922(g)(1) is facially constitutional, consistent with its prior decision in United States v. Canada. The court also rejected Hunt's as-applied challenge, holding that neither the Supreme Court's decisions in New York State Rifle & Pistol Association, Inc. v. Bruen nor United States v. Rahimi abrogated the Fourth Circuit's precedent foreclosing as-applied challenges to § 922(g)(1). Additionally, the court concluded that § 922(g)(1) would survive Second Amendment scrutiny even if decided anew.The Fourth Circuit also upheld the district court's application of the four-point enhancement, finding no clear error in the factual determination that Hunt fired a gun in the apartment. Consequently, the court affirmed the district court's judgment. View "US v. Hunt" on Justia Law

The case involves a class action lawsuit against Bojangles’ Restaurants, Inc. by several plaintiffs who allege that the company required them to perform unpaid off-the-clock work and made unauthorized edits to their time records. The plaintiffs, who worked as shift managers, claim that Bojangles violated its own policies and the Fair Labor Standards Act (FLSA) by not compensating them for all hours worked, including overtime.The United States District Court for the Western District of North Carolina conditionally certified a collective action for the FLSA claims and later certified class actions for state wage-and-hour law claims in North Carolina and South Carolina. The district court found that the proposed classes met the requirements for numerosity, commonality, and predominance under Federal Rule of Civil Procedure 23. The court relied on the fact that most class members worked opening shifts and were subject to Bojangles’ Opening Checklist, which allegedly required pre-shift work. The court defined the classes broadly to include all shift managers who worked at Bojangles in North Carolina or South Carolina within three years of the complaint.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s certification order. The appellate court found that the district court abused its discretion by employing an overly general approach in identifying the policies that allegedly unified the class members’ claims and by creating overly broad class definitions. The Fourth Circuit held that the district court failed to provide specific evidence of a common policy that mandated off-the-clock work and time-record edits for all class members. The court vacated the certification order and remanded the case for further proceedings, instructing the district court to refine the class definitions and ensure that common questions predominate over individualized issues. View "Stafford v. Bojangles' Restaurants, Inc." on Justia Law

In early 2022, Abel Gaspar, Jr. and his co-defendant, Sergio Emmanuel Cervantes Moran, sold methamphetamine to undercover officers on multiple occasions. On January 26, Gaspar delivered 111 grams of methamphetamine to a confidential source in a Walmart parking lot. On February 15, Gaspar sold 419 grams of methamphetamine to a DEA officer in Raleigh. On February 25, Gaspar was pulled over for speeding and fled, leaving behind 2,002 grams of methamphetamine, a firearm, and other drugs. On May 4, officers arrested Moran and searched Gaspar’s home, finding more drugs, cash, and firearms.The United States District Court for the Middle District of North Carolina sentenced Gaspar after he pled guilty to conspiracy to possess with intent to distribute methamphetamine. The presentence investigation report recommended a downward variance to 210 months’ imprisonment. Gaspar requested a further reduction to 120 months, arguing he participated in the conspiracy out of fear for his family’s safety due to threats from Moran. The district court sentenced Gaspar to 188 months, considering the seriousness of the offense, his criminal history, and mitigating factors including his family support and childhood exposure to drugs.The United States Court of Appeals for the Fourth Circuit reviewed Gaspar’s appeal, in which he argued that the district court failed to adequately address his claim of duress. The Fourth Circuit found that the district court had considered Gaspar’s argument, noting the court’s acknowledgment of the presentencing memorandum and the bench conference where Gaspar’s concerns were discussed. The court concluded that the district court’s explanation was sufficient and affirmed the 188-month sentence, finding it procedurally reasonable. View "United States v. Gaspar" on Justia Law

Jerry L. Blankenship applied for living miner benefits under the Black Lung Benefits Act, claiming he suffered from coal dust-induced pneumoconiosis and was totally disabled. An Administrative Law Judge (ALJ) found Blankenship entitled to a rebuttable presumption of total disability due to pneumoconiosis under 30 U.S.C. § 921(c)(4) and determined that his former employer, Island Creek Coal Company, failed to rebut this presumption. Consequently, Blankenship was awarded benefits. The Benefits Review Board affirmed the ALJ’s decision.Island Creek petitioned for review, arguing that the ALJ improperly conflated the presence of pneumoconiosis and disability causation with the separate total disability analysis. Additionally, Island Creek contended that the ALJ failed to adequately explain his decision to credit the opinions of Blankenship’s medical experts over those of Island Creek’s experts.The United States Court of Appeals for the Fourth Circuit reviewed the case and agreed with Island Creek. The court found that the ALJ improperly relied on the presence of pneumoconiosis and the causation of Blankenship’s impairment in concluding that he was totally disabled. The court also determined that the ALJ failed to provide a sufficient explanation for crediting the medical opinions of Drs. Nader and Green over those of Drs. McSharry and Sargent, violating the duty of explanation under the Administrative Procedure Act.The Fourth Circuit granted Island Creek’s petition for review, vacated the decision of the Benefits Review Board, and remanded the case with instructions for the Board to return Blankenship’s case to the ALJ for reconsideration consistent with the court’s opinion. View "Island Creek Coal Co. v. Blankenship" on Justia Law