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

Brandon Williams was involved in a series of interactions with Norfolk, Virginia police officers. Initially, Officer John D. McClanahan falsely charged Williams with misdemeanor trespassing and perjured himself at trial to secure a conviction. Williams appealed and used a recording to expose McClanahan's perjury, leading to the dismissal of the charge by the state appellate court. Two weeks later, Williams was hit by a speeding drunk driver, and responding officers, including McClanahan, allegedly falsified the accident report to deprive Williams of his right to sue the other driver.Williams filed a lawsuit in the United States District Court for the Eastern District of Virginia, asserting claims of retaliation for exercising his First and Sixth Amendment rights, conspiracy, and intentional infliction of emotional distress (IIED). The district court dismissed Williams' retaliation claim, finding he failed to plead an adverse action, and dismissed his conspiracy claim for lack of a constitutional violation. The court also dismissed Williams' state law IIED claims without prejudice, declining to exercise supplemental jurisdiction.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that Williams adequately alleged that the officers' intentional misrepresentation on the accident report would likely deter him from recording police activity and defending himself at trial in the future. Therefore, the court reversed the district court's dismissal of his retaliation claim. The court also vacated the dismissal of his conspiracy claim, finding a plausible constitutional violation, and remanded the claim for reconsideration. Finally, the court vacated the dismissal of Williams' IIED claims and remanded them for further consideration. View "Williams v. Mitchell" on Justia Law

Empower Oversight Whistleblowers & Research (Appellant) filed a Freedom of Information Act (FOIA) request with the National Institutes of Health (NIH) seeking documents related to the removal of COVID-19 sequencing data from the NIH Sequence Read Archive. The Appellant alleged that NIH failed to meet FOIA statutory deadlines, conducted inadequate searches, and improperly withheld documents.The United States District Court for the Eastern District of Virginia granted summary judgment in favor of NIH. The court found that NIH's searches were adequate and that the documents were properly withheld under FOIA exemptions five and six. The Appellant appealed this decision.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The court held that there is no standalone cause of action for a violation of FOIA deadlines, and the remedy for such a violation is constructive administrative exhaustion, which allows the requester to proceed directly to court. The court also found that NIH's searches were reasonably calculated to uncover all relevant documents, as detailed in the declarations submitted by NIH's FOIA officer. The court further held that the redactions made by NIH under FOIA exemptions five and six were proper. Exemption five protects pre-decisional and deliberative documents, and exemption six protects personal privacy interests, which outweighed the public interest in this case.The Fourth Circuit affirmed the district court's grant of summary judgment to NIH, concluding that NIH complied with its FOIA obligations. View "Empower Oversight Whistleblowers & Research v. National Institutes of Health" on Justia Law

Rose-Marie Nsahlai was convicted for her involvement in a scheme to fraudulently obtain Paycheck Protection Program (PPP) loans. Nsahlai and her husband, Didier Kindambu, applied for two PPP loans using false information and then used the loan proceeds for unauthorized purposes. The fraudulent applications included fabricated payroll documentation created by Nsahlai, which falsely represented that the Papillon companies had substantial payroll expenses. The loans, totaling over $2.5 million, were approved and deposited into their accounts, and the funds were subsequently used for personal expenses, including the purchase of a new residence.The United States District Court for the Eastern District of Virginia convicted Nsahlai on charges of conspiracy to commit bank fraud, bank fraud, and unlawful monetary transactions. Before trial, the district court excluded evidence related to Nsahlai's claims of domestic abuse by Kindambu, ruling it irrelevant and prejudicial. Nsahlai argued that this evidence was necessary to explain her actions and lack of intent to commit fraud. The court allowed her to testify that she felt compelled by her relationship but prohibited specific references to abuse.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decisions. The appellate court found no reversible error in the exclusion of the domestic abuse evidence, concluding that it was not relevant to the charges and that any error was harmless given the overwhelming evidence of Nsahlai's guilt. The court also rejected Nsahlai's challenge to the jury instructions, determining that the instructions, when read as a whole, did not mislead the jury or affect her substantial rights. The court held that the instructions properly required the jury to find the elements of the charged offenses beyond a reasonable doubt. Thus, the Fourth Circuit affirmed Nsahlai's convictions. View "US v. Nsahlai" on Justia Law

David Chang participated in a drug-trafficking conspiracy from March to October 2021, supplying large quantities of cocaine from California to Harold Campbell, a mid-level distributor in Virginia Beach, Virginia. After an investigation, Chang and Campbell were indicted for conspiracy to distribute cocaine, which carries a mandatory minimum sentence of five years’ imprisonment and four years’ supervised release. Both pleaded guilty, and Chang was initially sentenced to 72 months’ imprisonment and four years’ supervised release.The United States District Court for the Eastern District of Virginia found Chang eligible for the safety valve under 18 U.S.C. § 3553(f) but erroneously applied the statutory minimum sentence. On appeal, the Fourth Circuit vacated the sentence and remanded for resentencing. At the resentencing, the district court imposed a sentence of 69 months’ imprisonment and ten years’ supervised release, citing Chang’s significant role in the drug conspiracy and his criminal history.The United States Court of Appeals for the Fourth Circuit reviewed the case and found that the increased term of supervised release, despite a slight reduction in imprisonment, constituted a harsher sentence. The court held that this harsher sentence raised a presumption of vindictiveness under North Carolina v. Pearce, which was not adequately rebutted by the district court. Consequently, the Fourth Circuit vacated Chang’s sentence and remanded for resentencing, emphasizing the need to avoid any appearance of vindictiveness in the sentencing process. View "United States v. Chang" on Justia Law

Jay Folse, a pro se litigant, attempted to initiate a lawsuit by faxing a complaint to a federal district court. The court clerk stamped the complaint as "filed," created an electronic docket, and added the complaint to the docket. However, two weeks later, the district court dismissed the complaint without prejudice, citing local rules that did not permit filing complaints by fax and denying Folse's request for permission to do so.The United States District Court for the Northern District of West Virginia dismissed Folse's complaint without prejudice and without granting leave to amend. Folse appealed the decision, arguing that the district court's local rules should not have been enforced in a way that caused him to lose his right to file the complaint.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The court held that Federal Rule of Civil Procedure 5(d)(3)(B)(i) allows pro se litigants to file electronically only if permitted by court order or local rule. The court found that the relevant local rule, N.D. W. Va. LR Gen. P. 5.05(a), explicitly excluded complaints or petitions from being filed by fax. The court also determined that Folse did not identify any local rule or court order that authorized him to file his complaint via fax. Additionally, the court noted that the district court had the discretion to permit fax filing but did not abuse its discretion in denying Folse's request. The court concluded that the district court's enforcement of the local rules did not cause Folse to lose any right due to a nonwillful failure to comply, as the complaint was dismissed without prejudice, allowing for refiling. The judgment of the district court was affirmed. View "Folse v. Hoffman" on Justia Law

The case involves Russell Lucius Laffitte, who was convicted of bank and wire fraud in the United States District Court for the District of South Carolina. The government alleged that between 2006 and 2021, Laffitte, as CEO of Palmetto State Bank, conspired with Alex Murdaugh, a disbarred attorney, to defraud Murdaugh’s clients. Laffitte was accused of using his position to access settlement accounts, collecting fees, and extending unsecured loans to Murdaugh, resulting in nearly two million dollars being stolen from the accounts. Laffitte was charged with conspiracy to commit wire and bank fraud, bank fraud, wire fraud, and misapplication of bank funds.During the trial, the government presented fifteen witnesses, and Laffitte called eight witnesses and testified in his own defense. After the jury began deliberations, the court received notes from jurors indicating issues, including one juror needing medication and another feeling pressured. The district court decided to remove two jurors, Juror No. 88 and Juror No. 93, and replaced them with alternates. The jury then returned a guilty verdict on all counts.Laffitte appealed, arguing that the removal of the jurors violated his Fifth Amendment right to be present and his Sixth Amendment right to an impartial jury. The Fourth Circuit Court of Appeals reviewed the case and found that the removal of Juror No. 88 violated Laffitte’s Sixth Amendment right because there was a reasonable and substantial possibility that her removal was related to her views on the case. The court also found that the removal violated Laffitte’s Fifth Amendment right to be present, as he was not present during the in camera interview when the decision to remove Juror No. 88 was made. The court concluded that these errors were not harmless and vacated Laffitte’s convictions and sentence, remanding the case for a new trial. View "US v. Russell Laffitte" on Justia Law

The plaintiff, Siddhanth Sharma, a convicted felon, challenged North Carolina's felony-disclosure requirement for candidates running for federal office. This state law mandates that candidates disclose any felony convictions and provide additional information about the convictions and the restoration of citizenship rights. Sharma, who announced his candidacy for North Carolina’s Thirteenth Congressional District seat, argued that this requirement violated the Qualifications Clause and the First Amendment.The United States District Court for the Eastern District of North Carolina dismissed Sharma's claims. The court found that Sharma had standing to challenge the felony-disclosure requirement but concluded that it did not constitute an additional qualification for office. The court also held that the requirement did not violate the First Amendment, as it served a substantial interest in promoting an informed electorate and posed only a modest burden. Sharma's challenge to the address-disclosure requirement was dismissed for lack of standing, as the court found his injury insufficiently particularized.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court's decision, holding that the felony-disclosure requirement is constitutional. The court reasoned that the requirement does not exclude candidates from the ballot or disadvantage political viewpoints, and it falls within the state's authority to regulate elections. The court also found that the requirement imposes only a light burden on First Amendment rights and serves the state's interest in fostering an informed electorate. However, the court vacated the judgment on the address-disclosure challenge and remanded it to the district court with instructions to dismiss it as moot, as Sharma's address was already publicly available in the voter-search database. View "Siddhanth Sharma v. Alan Hirsch" on Justia Law

Christopher Ladariss Mitchell was charged with conspiracy to commit Hobbs Act robbery and one substantive count of Hobbs Act robbery. The indictment alleged that Mitchell and his co-defendants conspired to rob employees of two wireless communication retailers, referred to as Company A and Company B, at various locations within the Middle District of North Carolina and elsewhere. Mitchell pleaded guilty to the charges in January 2023.The United States District Court for the Middle District of North Carolina sentenced Mitchell based on a presentence investigation report (PSR) that included four separate robberies in the calculation of his total offense level. Mitchell objected, arguing that only two robberies should be considered. The district court rejected his argument, finding that the evidence supported his involvement in all four robberies beyond a reasonable doubt, and sentenced him to 108 months in prison.On appeal to the United States Court of Appeals for the Fourth Circuit, Mitchell contended that the district court erred in including the four robberies in the offense level calculation. He argued that the conspiracy count should only include two robberies, one for each company. The Fourth Circuit reviewed the case de novo and affirmed the district court's decision. The court held that under U.S.S.G. § 1B1.2(d), a conviction on a count charging a conspiracy to commit more than one offense should be treated as if the defendant had been convicted on a separate count of conspiracy for each offense. The court found that the indictment's broad language encompassed the four robberies and that the district court correctly applied the guideline by including all four robberies in the offense level calculation. View "United States v. Mitchell" on Justia Law

In 2016, a suicide bombing occurred at the U.S. military base in Bagram Airfield, Afghanistan. The bomber, an Afghan national employed by a subcontractor of Fluor Corporation, detonated an explosive vest, injuring Specialist Winston Tyler Hencely, among others. Hencely sued Fluor, alleging negligence in supervision, entrustment, and retention of the bomber, and breach of contract with the U.S. Government.The U.S. District Court for the District of South Carolina granted judgment to Fluor on all claims. The court found that federal law preempted Hencely’s tort claims and that he was not a third-party beneficiary entitled to enforce the Government’s contract with Fluor. Hencely appealed these decisions.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court’s judgment, holding that the Federal Tort Claims Act’s combatant activities exception preempted Hencely’s state-law tort claims. The court concluded that Fluor was integrated into combatant activities and that the military retained command authority over Fluor’s supervision of Local Nationals at Bagram Airfield. The court also held that Hencely was not an intended third-party beneficiary of the contract between Fluor and the U.S. Government, as the contract did not express an intent to benefit individual soldiers or confer upon them the right to enforce its provisions.Thus, the Fourth Circuit affirmed the district court’s judgment, precluding Hencely’s tort claims and denying his breach of contract claim. View "Hencely v. Fluor Corporation" on Justia Law

The case involves the Republican National Committee (RNC) and the North Carolina Republican Party (NCGOP) filing two state law claims against the North Carolina State Board of Elections (State Board) and its members. The claims, one statutory and one constitutional, allege that the State Board failed to comply with the Help America Vote Act of 2002 (HAVA), which mandates certain voter registration and maintenance procedures. The Democratic National Committee (DNC) intervened as a defendant. The plaintiffs argue that the State Board's noncompliance with HAVA led to improper voter registrations, potentially affecting 225,000 voters.The United States District Court for the Eastern District of North Carolina initially reviewed the case. The district court found it had original jurisdiction over the state statutory claim but not the state constitutional claim. It dismissed the statutory claim, ruling that the relevant statutory provision did not provide a private right of action. Consequently, the district court declined to exercise supplemental jurisdiction over the state constitutional claim and remanded it to state court, also holding that Section 1443 did not provide a valid basis for removal.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the district court's remand order was improper. It found that the district court possessed original jurisdiction over the state constitutional claim under Section 1331 because the claim contained an embedded federal question. The court also determined that removal was permissible under Section 1441. Additionally, the court held that the defendants validly removed the constitutional claim pursuant to Section 1443(2), which allows for removal in cases involving the refusal to perform an act on the grounds that it would be inconsistent with laws providing for equal rights. The court reversed the district court’s remand order and remanded the case for further proceedings consistent with its opinion. View "RNC v. North Carolina State Board of Elections" on Justia Law