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

The district court awarded summary judgment to the state and entered an injunction that required DOE to remove not less than one metric ton of defense plutonium from the State within two years. The Fourth Circuit held that the district court properly enforced the statutory responsibilities imposed on the DOE by Congress and that it also appropriately crafted and entered the injunction. The court rejected the DOE's contention that the principles governing mandamus proceedings, as well as fundamental principles of injunctive relief, control the award of an injunction under the Administrative Procedure Act. The court held that the district court, in carefully crafting the injunction, gave full consideration to the positions of the parties and the record. Therefore, the district court did not abuse its discretion or improperly burdened the DOE by imposing 50 U.S.C. 2566(c)'s two-year removal time frame. View "South Carolina v. United States" on Justia Law

The Fourth Circuit affirmed the district court's dismissal based on lack of subject matter jurisdiction of the Fund's action under the Tax Refund Statute, seeking to recover money paid to HHS as part of the Transitional Reinsurance Program of the Patient Protection and Affordable Care Act of 2010. The court held that the statute applies only to taxes and other sums collected by the Internal Revenue Service under the Internal Revenue Code, and thus the Court of Federal Claims has exclusive jurisdiction over the Fund's action. View "Electrical Welfare Trust Fund v. United States" on Justia Law

The Fourth Circuit affirmed the district court's dismissal of plaintiffs' constitutional and statutory challenges to Metropolitan Washington Airport Authority's (MWAA) ability to use toll revenues to fund projects enhancing access to Dulles airport. The court applied the standard from Lebron v. National Railroad Passenger Corporation, 513 U.S. 374 (1995), and held that MWAA was not a federal entity. The court held that MWAA's structure did not violate the non-delegation principle because MWAA exercises no power assigned elsewhere by the Constitution; MWAA did not violate the Guarantee Clause because it did not deny any state a republican form of government; and the court rejected plaintiff's claim that MWAA's use of toll road funds to build metro service to Dulles violates the command that funds only be spent on "capital and operating costs of the Metropolitan Washington Airports" and agreed with the Secretary of Transportation's interpretation of the Lease and Transfer Act. View "Kerpen v. Metropolitan Washington Airports Authority" on Justia Law

The Fourth Circuit vacated the district court's order denying the EEOC's request under the Age Discrimination in Employment Act (ADEA) for retroactive monetary relief from the county. The court held that retroactive monetary awards, such as the back pay sought here, were mandatory legal remedies under the ADEA upon a finding of liability. The court's conclusion was not altered by the county's contention that the EEOC unduly delayed in the investigation. Accordingly, the court remanded for a determination of the amount of back pay to which the affected employees were entitled under the ADEA. View "EEOC v. Baltimore County" on Justia Law

Sierra Club filed suit against Dominion under the citizen-suit provision of the Clean Water Act, alleging that Dominion was violating 33 U.S.C. 1311(a), which prohibits the unauthorized "discharge of any pollutant" into navigable waters. The Fourth Circuit held that the landfill and settling ponds on the Chesapeake site of a coal-fired power plant did not constitute "point sources" as that term was defined in the Clean Water Act, and thus reversed the district court's ruling that Dominion was liable under section 1311(a). The court held, however, that Dominion's discharge permit did not regulate the groundwater contamination at issue and affirmed as to those claims. View "Sierra Club v. Virginia Electric & Power Co." on Justia Law

Plaintiffs filed suit challenging a mobile home park's policy requiring all occupants to provide documentation evidencing legal status in the United States to renew their leases as violating the Fair Housing Act (FHA). The Fourth Circuit vacated the district court's grant of summary judgment for the mobile home park, holding that plaintiffs have made a prima facie case that the policy disparately impacted Latinos in violation of the FHA, satisfying step one of the disparate impact analysis, and that the district court therefore erred in concluding otherwise. The court also held that the district court seriously misconstrued the robust causality requirement described in Tex. Dep't of Housing & Cmty. Affairs v. Inclusive Communities Project, Inc., 135 S. Ct. 2507, 2513 (2015), and erroneously rejected plaintiffs' prima facie claim that the policy disparately impacted Latinos. Accordingly, the court remanded for further proceedings. View "Giron de Reyes v. Waples Mobile Home Park LP" on Justia Law

The Fourth Circuit held that the district court did not abuse its discretion in declining to grant preliminary injunctive relief under section 10(j) of the National Labor Relations Act (NLRA), 29 U.S.C. 160(j), as requested to preserve the ability of the National Labor Relations Board to award relief after the completion of the ongoing agency process adjudicating unfair labor practice charges against two hospitals because the Board failed sufficiently to demonstrate that the effectiveness of its remedial power was in jeopardy in this case.A union filed unfair labor practice charges with the Board alleging that two hospitals had refused to bargain collectively and in good faith with the union. The Board later filed petitions in the district court against the hospitals under section 10(j) requesting preliminary injunctions - pending the final disposition of the matters pending before the Board - that would direct the hospitals to bargain with the union in good faith. The Board alleged that preliminary injunctive relief was necessary to prevent declining employee support for the union. The district court declined to grant relief. The Fourth Circuit affirmed, holding that the Board’s arguments for injunctive relief failed to demonstrate that the Board’s ability to redress the alleged unfair labor practices will be impaired or frustrated. View "Henderson v. Bluefield Hospital Co." on Justia Law

The Fourth Circuit affirmed Defendant’s convictions for possession with intent to distribute heroin and cocaine based and possession of a firearm, holding that there was no reversible error in the proceedings below.Specifically, the Court held that the district court (1) did not abuse its discretion in denying Defendant’s motion to suppress statements he made to officers during the execution of a search warrant for his residence; (2) did not abuse its discretion in admitting “other acts” evidence under Fed. R. Evid. 404(b); (3) did not err in denying Defendant’s motion to disclose the identity of a confidential informant who provided information used to obtain the search warrant; and (4) did not err in enhancing Defendant’s sentence on the basis of his prior Maryland convictions. View "United States v. Bell" on Justia Law

Defendants moved for judgment as a matter of law after a jury returned verdicts awarding compensatory and punitive damages for each plaintiff in three wrongful death nursing home malpractice claims. Defendants argued that plaintiffs failed to produce evidence of an aggravating factor necessary to support an award of punitive damages under North Carolina law and failed to produce evidence necessary to support a verdict regarding Plaintiff Jones.The Fourth Circuit held that the district court correctly found plaintiffs presented sufficient evidence that defendants' negligence proximately caused the death of Elizabeth Jones but erred in finding plaintiffs failed to present evidence sufficient for a reasonable jury to award punitive damages. The court affirmed the district court's denial of the motion for judgment as a matter of law as to Plaintiff Jones' award of compensatory damages; reversed as to plaintiffs' award of punitive damages; and remanded with instructions to enter judgment for plaintiffs consistent with North Carolina's statutory limits on punitive damages. View "VanDevender v. Blue Ridge of Raleigh, LLC" on Justia Law

The Fourth Circuit reversed the decision of the district court denying Appellant’s motion to vacate his sentence under 28 U.S.C. 2255, holding that Appellant’s ACCA-enhanced sentence was unlawful where the sentencing court relied on three ACCA predicate convictions and one of those predicates was no longer valid.Appellant received a mandatory sentence enhancement under the Armed Career Criminal Act (ACCA) based on three prior convictions. Appellant filed this motion to vacate his sentence arguing that one of his ACCA predicate convictions no longer qualified as an ACCA predicate in light of Johnson v. United States, 135 S. Ct. 2551 (2015). Assuming without deciding that the offense no longer qualified as an ACCA predicate, the district court found that another conviction listed in Appellant’s presentence investigation report but never designated as an ACCA predicate could replace the now-invalid predicate. The Fourth Circuit disagreed and remanded for resentencing, holding that the government may not use a conviction never before designated as an ACCA predicate to support an ACCA sentence enhancement on collateral review. View "United States v. Hodge" on Justia Law