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

Petitioner sought habeas relief under 28 U.S.C. 2254 after he was convicted of crimes related to the murder of his ex-girlfriend and sentenced to death. The district court denied or stayed all of petitioner's claims, except Ground Six, which asserted a claim of ineffective assistance of counsel resulting from trial counsel's failure to investigate potentially mitigating evidence of Fetal Alcohol Syndrome (FAS).The Fourth Circuit affirmed and held that counsel's investigation into potentially mitigating evidence of FAS failed to meet an objective standard of reasonableness. Therefore, the postconviction relief court erred in concluding that petitioner had failed to establish deficient performance by counsel. Furthermore, the district court correctly determined that petitioner had established prejudice under Strickland v. Washington. Therefore, the postconviction relief court's prejudice determination was contrary to or an unreasonable application of Supreme Court precedent, or an objectively unreasonable factual determination. View "Williams v. Stirling" on Justia Law

The Fourth Circuit affirmed the district court's denial of defendant's motions to suppress evidence obtained by law enforcement officers during their encounter with him prior to his arrest. The court held that the district court did not clearly err in finding that the officers received voluntary consent from defendant's fiancee to enter his residence. Therefore, the entry did not violate the Fourth Amendment.The court also held that defendant's freedom of action was not curtailed to a degree associated with formal arrest, and thus he was not in custody and Miranda warnings were not required. Accordingly, the district court did not err in concluding that defendant was not subject to custodial interrogation in violation of the Fifth Amendment. View "United States v. Azua-Rinconada" on Justia Law

The Fourth Circuit reversed the district court's denial of petitioner's federal habeas petition, claiming actual innocence of his first degree murder conviction. The court held that no reasonable juror would likely find petitioner guilty beyond a reasonable doubt if it knew the high likelihood that he was misidentified both outside and inside the courtroom as a murder suspect because of impermissibly suggestive procedures. The court held that petitioner has overcome the exacting standard for actual innocence through sufficiently alleging and providing new evidence of a constitutional violation and through demonstrating that the totality of the evidence, both old and new, would likely fail to convince any reasonable juror of his guilt beyond a reasonable doubt. View "Finch v. McKoy" on Justia Law

The Fourth Circuit held that the government did not breach its plea agreement with defendant by disclosing relevant and accurate information to the sentencing court. However, the court held that the government's conduct at the sentencing hearing denied him the benefit of the bargain. In this case, the government crossed the line and breached its plea agreement when it failed at sentencing to honor its drug conduct stipulation. Accordingly, the court vacated the sentence and remanded for resentencing. View "United States v. Edgell" on Justia Law

Brandishing a firearm in connection with a "crime of violence," as defined in 18 U.S.C. 924(c)(3)(B), is unconstitutionally vague. The Fourth Circuit reversed defendant's conviction under section 924(c)(3) and held that neither the statutory language nor controlling precedent offered any support for the Government's proposed reinterpretation of "crime of violence." In this case, the text, structure, and context of section 924(c)(3)(B) clearly mandated use of the ordinary-case categorical approach, as do all relevant precedents. The court held that section 924(c)(3)(B) effectively required judges to define the scope of criminal liability, and it directed them to do so using an unmoored, subjective abstraction that deprived the public of fair notice. View "United States v. Simms" on Justia Law

SOS challenged the agencies' decision to replace a segment of North Carolina Highway 12 (NC-12) with a bridge across the Pamlico Sound. The Fourth Circuit affirmed the district court's grant of the agencies' motion for summary judgment, holding that they did not violate the National Environmental Policy Act (NEPA) or the Department of Transportation Act (DTA) when they approved the bridge. In this case, the agencies were not required to prepare a supplemental environmental impact statement to consider the alignment of the Jug-Handle Bridge or to consider beach nourishment alternatives; the agencies adequately considered the effects of construction traffic as a result of the Jug-Handle Bridge in the 2016 record of decision; and the agencies' choice of the Jug-Handle Bridge was not impermissibly predetermined. The court also affirmed the district court's denial of SOS's motion to amend its complaint. View "Save Our Sound OBX, Inc. v. North Carolina Department of Transportation" on Justia Law

Three municipalities who use the National Instant Criminal Background Check System (NICS) to carry out their obligations under state law filed suit against the DOD and its constituent military departments, seeking to compel the department to more thoroughly comply with federal law requiring the department to provide records to the NICS.The Fourth Circuit affirmed the district court's dismissal of the municipalities' claim and held that they lacked constitutional standing and failed to establish subject matter jurisdiction under the Administrative Procedure Act. The court explained that there was simply no basis in the APA's text for such a broad incursion into internal agency management. The court noted that the APA did not permit the municipalities' efforts to include judicial supervision of the myriad programmatic workings of the federal government. View "City of New York v. DOD" on Justia Law

The Fourth Circuit vacated the district court's award of summary judgment for Virtus, plaintiff's former employer, in an action seeking to collect on a state court judgment entered against defendants. The court held that plaintiff's claims were not precluded under Virginia's doctrine of res judicata, because he could not have brought those claims at the time of his earlier litigation. In this case, plaintiff could not have brought his fraudulent transfer claims in the arbitration proceedings, because it was only after the state court judgment was entered that plaintiff would have actual notice of any potential fraudulent transfer claims. Similarly, because plaintiff was required to obtain a judgment against Virtus before bringing his alter-ego claim, the claim had not accrued at the time of the arbitration proceedings. View "Bennett v. Garner" on Justia Law

The Fourth Circuit vacated defendant's sentence for two counts of receipt of child pornography and one count of possession of child pornography. The court held the district court failed to address defendant's non-frivolous mitigation arguments and to properly explain its rationale for his term of confinement and his special conditions. The court remanded for the district court to provide a sufficient explanation for the significant deprivation of liberty defendant faced as a result of his criminal conduct. Finally, the court made no assessment regarding the fairness or propriety of defendant's term of confinement or special conditions of supervised release. View "United States v. Ross" on Justia Law

A Reinsurance Participation Agreement (RPA) executed by AUCRA and Minnieland was an insurance contract under Virginia law. The Fourth Circuit held that the district court did not violate the court's prior mandate by looking at the EquityComp program as a whole; the RPA and insurance policies constituted an integrated transaction and must be read as one contract; and the integrated contract was a contract of insurance under Virginia Code 38.2–312. Finally, the court noted that it was not the first to determine that the program marketed by Applied Underwriters was insurance. View "Minnieland Private Day School v. Applied Underwriters Captive Risk Assurance Co." on Justia Law