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

The Fourth Circuit affirmed the district court's decision to vacate an arbitration award that the Farm won against a private insurance company that sold federal crop insurance policies to the Farm. The court held that, despite the strong presumption in favor of confirming arbitration awards pursuant to the Federal Arbitration Act (FAA), the insurance company met its heavy burden to prove that the arbitrator exceeded her powers by awarding extra-contractual damages, contrary to both the policy and binding authority from the Federal Crop Insurance Corporation (FCIC). In this case, the arbitrator exceeded her powers by both interpreting the policy herself without obtaining an FCIC interpretation for the disputed policy provisions, and awarding extra-contractual damages, which the FCIC has conclusively stated in multiple Final Agency Determinations could not be awarded in arbitration and can only be sought through judicial review. View "Williamson Farm v. Diversified Crop Insurance Services" on Justia Law

Defendant challenged the validity of his guilty plea for aggravated identity theft, and various aspects of sentencing for possession of at least fifteen access devices with intent to defraud and possession of device-making equipment with intent to defraud. The Fourth Circuit affirmed the district court's judgment and held that defendant never objected to purported errors in the Rule 11 proceeding, and his challenges on appeal were insubstantial and did not come close to meeting a plain error standard. The court also held that the district court did not err in calculating the amount of loss; even if there was error in calculating the amount of loss, it was harmless; the district court did not err in concluding that the eighteen persons identified were victims; and the district court did not clearly err by denying defendant an acceptance of responsibility reduction under USSG 3E1.1(a). View "United States v. Carver" on Justia Law

Defendant appealed his conviction for conspiracy to commit drug trafficking, conspiracy to use firearms while drug trafficking, attempted possession of heroin with intent to distribute, using or carrying a firearm while drug trafficking, and three counts of federal programs bribery. The Fourth Circuit affirmed the conspiracy, attempted possession and firearms convictions, but vacated the federal programs bribery convictions. The court held that the government failed to produce evidence from which a jury could find that defendant's services to the drug trafficking organization had a value of $5,000 or more. Because defendant's sentence could not be affected by the vacation of his federal programs bribery convictions, the court need not remand for resentencing. View "United States v. Tillmon" on Justia Law

The Fourth Circuit vacated the district court's denial of defendants' motions for sentence reductions under 18 U.S.C. 3582(c)(2). Although there is no right to a sentence reduction under section 582(c)(2), a district court cannot ignore a host of mitigation evidence and summarily deny a motion to reduce a sentence and leave both the defendant and the appellate court in the dark as to the reasons for its decision. In this case, the court held that the district court failed to provide defendants with individualized explanations for its rulings on their respective motions. Accordingly, the court remanded for further proceedings. View "United States v. Martin" on Justia Law

The Fourth Circuit affirmed the district court's judgment after a jury found defendant civilly liable to plaintiff under the Trafficking Victims Protection Act (TVPA). Plaintiff filed suit against defendant for her role in the sexual abuse that plaintiff suffered at the hands of defendant's husband when plaintiff worked as their housekeeper in housing provided by the Embassy of the United States in Yemen.The court held, in light of RJR Nabisco, Inc. v. European Cmty., 136 S. Ct. 2090 (2016), that the TVPA's civil remedy provision applied to defendant's conduct in Yemen in 2007. The court confined its analysis to the text of 18 U.S.C. 1595 and held that section 1595 applied extraterritorially to defendant's conduct. The court also held that the district court did not abuse its discretion by admitting another housekeeper's evidence concerning sexual abuse she suffered while working for defendant and her husband. View "Roe v. Howard" on Justia Law

The Fourth Circuit vacated the district court's decision affirming the denial of plaintiff's application for supplemental security income (SSI). The court held that the ALJ erred by not sufficiently explaining the reasoning underlying plaintiff's residual functional capacity evaluation. Furthermore, the ALJ neither identified nor resolved an apparent conflict between the testimony of a vocational expert and the Dictionary of Occupational Titles. Accordingly, the court remanded for further proceedings. View "Thomas v. Berryhill" on Justia Law

The district court did not abuse its discretion by sanctioning plaintiff for her "flagrant and unremitting" violations of the Federal Rules of Civil Procedure. After plaintiff was constructively discharged as a nurse practitioner by the University, she filed four separate actions alleging claims arising out of the same course of events and alleging state torts of defamation and interference with prospective advantage, as well as violations of the False Claims Act, the Maryland False Health Claims Act, Title VII, and 42 U.S.C. 1981. The Fourth Circuit held that plaintiff's conduct under the procedural rules was inept and abusive to the degree that it rendered virtually useless five years of proceedings before the district court, and such abuse would likely have continued in any future proceedings. View "Rangarajan v. Johns Hopkins University" on Justia Law

A jury convicted Young of attempting to provide material support to the Islamic State of Iraq and the Levant (ISIL), a designated foreign terrorist organization, 18 U.S.C. 2339B, and two counts of attempting to obstruct justice, 18 U.S.C. 1512(c)(2). The Fourth Circuit affirmed the material support conviction, vacated the obstruction convictions, and remanded for resentencing. The court upheld the district court’s admission of the Nazi and white supremacist paraphernalia found during a search of Young’s home; the rejection of an entrapment defense; various evidentiary rulings; and the certification of an expert witness on militant Islamist and Nazi “convergence.” The evidence was insufficient to prove the nexus and foreseeability requirements of the obstruction statute; the government was required to prove Young “corruptly” attempted to “obstruct[], influence[], or impede[]” “an official proceeding. In neither specified situation in which Young made statements to the FBI or to others was Young’s conduct connected to a specific official proceeding, nor was such a specific official proceeding reasonably foreseeable to Young. View "United States v. Young" on Justia Law

In this case arising from a bond transaction involving a municipal golf course in the City of Buena Vista, Virginia (the City), the Fourth Circuit affirmed the district court’s motion to dismiss a ten-count complaint filed by ACA Financial Guaranty Corporation (ACA) and SunTrust Bank (Bank) against the City and the Public Recreational Facilities Authority (Authority), holding that the complaint failed to allege claims for which relief could be granted.In an effort to refinance a loan that the Authority took out to finance the construction of the golf course, the Authority issued over $9 million in bonds. The Authority and the Bank entered into a trust agreement regarding the bonds. To repay the bonds, the Authority leased the golf course to the City. The City and the Authority then issued deeds of trust to the Bank pledging certain property as security. The City later failed to pay the rent due on the golf course lease, and the Authority could not repay the bonds. ACA, which provided insurance on the bonds, and the Bank sued. The district court dismissed the complaint. The Fourth Circuit affirmed, holding that the City’s obligation to make rent payments was not legally enforceable when the obligation was expressly subject to the city’s annual decision to appropriate funds. View "ACA Financial Guaranty v. City of Buena Vista, Virginia" on Justia Law

The Fourth Circuit affirmed Appellant’s conviction of production of child pornography, holding that the good faith exception to the exclusionary rule applies to evidence obtained through a military warrant and that evidence subsequently obtained through a federal warrant supported by the military warrant evidence is likewise admissible.Appellant, a member of the United States Navy, was accused of sexual assault and suspected of possession of child pornography. Investigators with the Naval Criminal Investigation Service obtained a military warrant to search Appellant’s cell phone for evidence of sexual assault. During the search, the investigators found child pornography. The investigators then obtained a federal warrant to search Appellant’s phone a second time and again found child pornography. Appellant moved to suppress the evidence obtained from the two searches of the phone, arguing that the Military Rules of Evidence applied in his case and required suppression. The district court denied the motion. The Fourth Circuit affirmed, holding (1) the Fourth Amendment governs whether evidence is admissible in federal criminal proceedings, and the Military Rules of Evidence cannot supplant the Fourth Amendment; and (2) even assuming the initial warrant violated the Fourth Amendment, the good faith exception saved the evidence obtained from both searches. View "United States v. Seerden" on Justia Law