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

A group associated with gangs in Franklin, Virginia, including members of the “Low Lives” and subsets of the Bloods, became involved in a violent series of events after their leader, Brandon Leonard, was killed. The group, which operated from a house called the “Railroad,” engaged in drug trafficking, shared firearms, and sought control over local drug operations. Tensions with a rival gang, the 00s (Crips), escalated after Leonard’s death, leading to retaliatory shootings against suspected rivals. In addition, one defendant, while detained pretrial, attempted to persuade witnesses to provide false alibis.The United States District Court for the Eastern District of Virginia tried the defendants—Jenkins, Brooks, and Newsome—on various charges, including conspiracy to commit murder in aid of racketeering (VICAR), attempted murder, firearms offenses, and witness tampering. The jury convicted all three on some counts. The district court denied their motions for acquittal and sentenced Jenkins, Brooks, and Newsome to lengthy prison terms. All three defendants appealed, challenging the sufficiency of the evidence and their sentences.The United States Court of Appeals for the Fourth Circuit reviewed the case. It affirmed the convictions and sentences of Jenkins and Newsome—including upholding the existence of an “enterprise” under VICAR, Jenkins’ attempted murder conviction, and Newsome’s conviction and sentence for witness tampering. However, the appellate court found insufficient evidence to support Brooks’ convictions for VICAR attempted murder (Count II) and the related firearms offense (Count III), concluding the government failed to prove Brooks had the specific intent to kill required under Virginia law. The court reversed and vacated those convictions, vacated Brooks’ sentence, and remanded for resentencing. The remainder of the district court’s judgment was affirmed. View "United States v. Jenkins" on Justia Law

Two former employees of a financial services company, each a participant in the employer’s defined contribution retirement plan, sued the company on behalf of themselves and other similarly situated plan participants. They alleged that the company, as plan sponsor and fiduciary, breached its duties under the Employee Retirement Income Security Act (ERISA) by selecting and retaining certain BlackRock LifePath Index Funds as investment options, which they claimed were imprudent and caused monetary losses to their individual plan accounts. The plaintiffs sought recovery of losses under ERISA sections 502(a)(2) and 409(a).The United States District Court for the Eastern District of Virginia denied the defendant’s motion to dismiss most of the claims, holding that the plaintiffs plausibly alleged a breach of fiduciary duty. It then certified a class of all plan participants and beneficiaries with investments in the BlackRock funds during the relevant period, under Federal Rule of Civil Procedure 23(b)(1), finding that ERISA fiduciary-duty claims are inherently suitable for class treatment because they are brought on behalf of the plan and that allowing individual suits would risk inconsistent standards or impair interests of absent participants. The district court also found that the commonality requirement of Rule 23(a)(2) was satisfied.On interlocutory appeal, the United States Court of Appeals for the Fourth Circuit reversed and vacated the class certification order. The Fourth Circuit held that, in the context of a defined contribution plan, claims under ERISA § 502(a)(2) for monetary losses to individual accounts are inherently individualized and cannot be joined in a mandatory class under Rule 23(b)(1), which does not provide for notice or opt-out rights. The court also held that the claims failed to satisfy the commonality prerequisite because many class members did not experience the same injury. The district court’s order was thus reversed and vacated. View "Trauernicht v. Genworth Financial Inc." on Justia Law

Several individuals who participate in West Virginia’s Medicaid program and have been diagnosed with gender dysphoria sought surgical treatments that are excluded from coverage under West Virginia’s Medicaid plan. The state plan expressly excludes coverage for “sex change” or “transsexual” surgeries, though it covers these procedures for other medical indications, such as cancer or congenital abnormalities. The plaintiffs, representing a class of similarly situated individuals, alleged that this exclusion discriminates against them in violation of the Equal Protection Clause, Section 1557 of the Affordable Care Act, and certain provisions of the Medicaid Act.In proceedings before the United States District Court for the Southern District of West Virginia, the court granted summary judgment to the plaintiffs on all claims. The court found that the exclusion was unlawful under the Equal Protection Clause, the Affordable Care Act’s anti-discrimination provision, and the Medicaid Act’s comparability and availability requirements. The district court issued a declaratory judgment and enjoined enforcement of the exclusion. On appeal, the United States Court of Appeals for the Fourth Circuit sitting en banc affirmed the district court’s judgment. The state defendants then sought review by the Supreme Court, which granted certiorari, vacated the Fourth Circuit’s en banc decision, and remanded for reconsideration in light of two recent Supreme Court cases: United States v. Skrmetti and Medina v. Planned Parenthood South Atlantic.Upon reconsideration, the United States Court of Appeals for the Fourth Circuit reversed the district court. The court held that, under Skrmetti, West Virginia’s exclusion does not violate the Equal Protection Clause or the Affordable Care Act, because the exclusion is based on medical diagnosis rather than sex or transgender status and is supported by rational, non-discriminatory reasons. Applying Medina, the court further held that the Medicaid Act’s comparability and availability requirements do not provide a private right of action, and thus plaintiffs could not sue under those provisions. The Fourth Circuit reversed and remanded the case with instructions to enter summary judgment for the defendants. View "Anderson v. Crouch" on Justia Law

A plaintiff obtained a default judgment in Texas state court against Hugh D. Dale, Jr. and two companies he controlled. To enforce the judgment, the plaintiff registered it in West Virginia, where the Circuit Court of Calhoun County issued writs of execution and approved a process known as “suggestion” to identify assets belonging to the judgment debtors. Peoples Bank, which held several accounts listing the judgment debtors as co-owners along with various partnerships, was notified and, pursuant to statutory procedure, debited the accounts and sent the funds to the judgment creditor. The partnerships, also named on the accounts, claimed the funds belonged exclusively to them and not to Dale or his companies.The partnerships filed suit in the United States District Court for the Northern District of West Virginia against Peoples Bank and its employees, alleging negligence and conversion. The district court dismissed the negligence claim as untimely and the conversion claim as implausible, concluding the bank had merely complied with the statutory mechanism for judgment enforcement. The partnerships appealed only the dismissal of the conversion claim.The United States Court of Appeals for the Fourth Circuit reviewed the conversion claim de novo. It held that Peoples Bank’s actions were authorized by West Virginia law, specifically West Virginia Code § 38-5-14, which allows a bank to turn over property belonging to a judgment debtor upon receipt of a suggestion and provides immunity from liability for doing so. The court found no wrongful exercise of dominion by the bank, as required for conversion, and rejected arguments that the bank acted improperly by not affording the partnerships or Dale prior notice. The Fourth Circuit affirmed the district court’s dismissal of the conversion claim. View "Cin Dale 3 v. Peoples Bank Corp." on Justia Law

The case involves a defendant who, in 2012, pled guilty to a federal drug conspiracy charge and was sentenced in 2013 to a 120-month prison term followed by five years of supervised release. At sentencing, the district court orally imposed four special conditions of supervised release but did not mention any standard, non-mandatory conditions. However, the written judgment issued later that day included both the special conditions and fourteen standard conditions. Years later, after his release from prison, the defendant was accused of violating several of these standard conditions, specifically those requiring notification of changes in residence or employment and permitting home visits by a probation officer.After allegations of these violations, the United States District Court for the District of Maryland held a revocation hearing. The defendant admitted to violating the standard conditions regarding home visits, and the government agreed to dismiss the other violations. The court revoked supervised release and imposed a new sentence of 90 days’ imprisonment and an additional 42 months of supervised release with the same conditions as previously imposed. The defendant appealed, arguing that, under United States v. Rogers, the standard conditions were invalid because they were not orally pronounced at his sentencing.The United States Court of Appeals for the Fourth Circuit reviewed whether the defendant’s appellate waiver barred the claim, whether the appeal was procedurally proper, and whether there was plain error. The court held that the appellate waiver did not bar the challenge because the defendant was not appealing the original sentence but the revocation based on conditions never validly imposed. The court found the appeal timely and procedurally proper under recent circuit precedent. Applying plain error review, the court ruled that revocation based on unpronounced, discretionary conditions was error, affected substantial rights, and undermined the integrity of the proceedings. The Fourth Circuit vacated the district court’s revocation judgment and remanded for resentencing. View "United States v. McLaurin" on Justia Law

Roger Mullins, a coal miner, filed a claim for Black Lung benefits in 2012, asserting he was totally disabled due to pulmonary disease caused by coal dust exposure. His initial claim was denied. In 2019, Mullins sought modification of the denial, alleging a mistake of fact and a change in conditions. During the modification proceedings, Mullins submitted new evidence, including medical reports, pulmonary function tests, and treatment records. His medical experts attributed his total disability to legal pneumoconiosis, a chronic pulmonary condition substantially aggravated by coal dust exposure. Cedar Coal Company, his last coal mine employer, contested this, arguing that his impairment was due to other causes such as asthma, obesity, and coronary bypass surgery.An Administrative Law Judge (ALJ) heard the case and determined that Mullins was totally disabled due to legal pneumoconiosis, awarding Black Lung benefits. The ALJ gave greater weight to the medical opinion of Dr. Go, Mullins’ expert, over those of the employer’s experts, finding Dr. Go’s interpretation of the evidence more persuasive and his experience more relevant. Cedar Coal Company appealed this decision to the Benefits Review Board, which affirmed the ALJ’s award of benefits.The United States Court of Appeals for the Fourth Circuit reviewed the case. Cedar Coal Company argued that Mullins exceeded the regulatory limitations on affirmative medical evidence and that the ALJ’s finding of legal pneumoconiosis was not supported by substantial evidence. The Fourth Circuit rejected both arguments. It held that the ALJ properly considered all admissible evidence, including treatment records and expert analysis, without violating evidentiary limits. The court found the ALJ’s factual determinations were supported by substantial evidence and adequately explained. The petition for review was denied, and the award of benefits was affirmed. View "Cedar Coal Company v. DOWCP" on Justia Law

A man from Honduras, who had been granted asylum in the United States, sought to obtain derivative asylee status for his wife by filing a Form I-730 petition. His wife, however, had previously been removed from the United States after being apprehended at the border in 2014. Although she returned with her husband in 2020, she was ineligible for asylum and instead applied for withholding of removal and protection under the Convention Against Torture. An immigration judge denied her request for withholding of removal, and she appealed to the Board of Immigration Appeals. While that appeal was pending, her husband’s I-730 petition for her was denied by United States Citizenship and Immigration Services (USCIS), which reasoned that a statutory provision (Section 1231(a)(5)) barred any form of relief for noncitizens with prior removal orders.The petitioner challenged USCIS’s denial in the United States District Court for the Eastern District of Virginia. The District Court did not address the merits of his complaint, instead dismissing the case for lack of jurisdiction. The District Court held that the Immigration and Nationality Act (INA) barred judicial review of the USCIS’s decision because the act gave the agency discretionary authority over such petitions.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed whether the District Court had jurisdiction to consider the legal question of the agency’s statutory interpretation. The Fourth Circuit held that when the agency’s decision is based solely on a question of law—specifically, the interpretation of statutes—rather than the exercise of discretion, federal courts retain jurisdiction to review that decision. Accordingly, the Fourth Circuit reversed the District Court’s dismissal and remanded the case for further consideration of the merits. View "Ortez Reyes v. United States Citizenship and Immigration Services" on Justia Law

A noncitizen and lawful permanent resident was arrested in Virginia after participating in a cocaine transaction observed and recorded by law enforcement. He was indicted for conspiracy to distribute cocaine and possession with intent to distribute. Through retained counsel, he negotiated a plea agreement in which he pleaded guilty to the conspiracy charge, avoiding a mandatory minimum sentence, while the government dropped the other charge. The final agreement omitted certain adverse immigration provisions, but included an acknowledgment that he wished to plead guilty regardless of immigration consequences, including potential automatic removal.After sentencing, the defendant learned he would be subject to mandatory deportation. He filed a motion under 28 U.S.C. § 2255 in the United States District Court for the Eastern District of Virginia, claiming his attorney provided ineffective assistance by failing to advise him that his guilty plea would result in mandatory deportation. The district court initially denied relief, finding he had not shown prejudice, relying on his plea agreement’s language. On appeal, the United States Court of Appeals for the Fourth Circuit held that he had demonstrated prejudice and remanded for the district court to consider whether counsel’s performance was constitutionally deficient.On remand, following an evidentiary hearing, the district court found the attorney had advised the defendant he was “deportable” and would face deportation proceedings, but did not state he would definitely be deported or was subject to “mandatory deportation.” The court held that, given the complexities and uncertainties of immigration outcomes, counsel’s advice met constitutional standards.The United States Court of Appeals for the Fourth Circuit affirmed. The court held that, when the clear consequence of a plea is deportability, counsel need only advise that the plea will render the defendant deportable and subject to removal proceedings; there is no constitutional requirement for counsel to state that deportation is mandatory or absolutely certain. View "United States v. Murillo" on Justia Law

This case arises from multi-district litigation involving claims that certain aqueous film-forming foam products caused injuries, and that Illinois Union Insurance Company issued excess liability policies to BASF Corporation, which allegedly designed and sold components of those products. Plaintiffs, who originally filed their cases in Wisconsin state court, assert that Illinois Union is directly liable under Wisconsin law for BASF’s conduct. After removal to federal court, the cases were consolidated for pretrial proceedings in the United States District Court for the District of South Carolina under the multi-district litigation statute.The District Court for the District of South Carolina, managing the consolidated proceedings, had entered case management orders requiring motions either to be signed by lead counsel or, if not, to be preceded by a motion for leave of court. Illinois Union sought leave to file a motion to stay the proceedings against it pending arbitration, contending that its insurance policies required arbitration of the dispute. The district court denied Illinois Union’s motion for leave, first citing a failure to consult with lead counsel as required, but then acknowledging that consultation had ultimately occurred. The decisive reason for denial was that lead counsel did not consent to Illinois Union’s motion, and the district court ruled that, absent such consent, the motion could not be filed.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s order. It held that, while district courts have broad discretion to manage multi-district litigation, they may not exercise this authority in a way that prevents a party from asserting its statutory right under the Federal Arbitration Act to seek a stay of litigation pending arbitration. Because the district court’s order effectively barred Illinois Union from filing its stay motion based on lack of lead counsel’s consent, the Fourth Circuit vacated the district court’s order and remanded for further proceedings. View "Bouvet v. Illinois Union Insurance Company" on Justia Law

A former employee of a company signed a document as a condition of her employment that purported to shorten the period in which she could sue her employer for workplace disputes, including discrimination claims, to 180 days. This agreement included a tolling provision for the period when a charge was pending before an administrative agency. The employee was terminated and, after filing timely administrative charges with the EEOC and the Maryland Commission on Civil Rights, she received a right-to-sue letter. She then filed suit in federal court, alleging violations of Title VII, the ADEA, and the Maryland Fair Employment Practice Act (MFEPA).After the employer moved to dismiss on the grounds that the lawsuit was untimely under the agreement, the United States District Court for the District of Maryland, treating the motion as one for summary judgment, ruled in favor of the employer. The district court concluded the parties had validly agreed to shorten the limitations period, making the employee’s claims untimely.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The court held that, as to the Title VII and ADEA claims, private parties may not, by advance agreement, prospectively shorten the statutory time periods for filing suit provided by Congress. The court reasoned that judicial enforcement of such agreements would undermine the comprehensive and uniform remedial schemes established by those statutes. Therefore, the court vacated the district court’s grant of summary judgment on the Title VII and ADEA claims and remanded for further proceedings. However, the court affirmed the dismissal of the MFEPA claims, finding that Maryland law permits reasonable contractual modifications of limitations periods and that the employee had not demonstrated the provision was unreasonably short or otherwise invalid under state law. View "Thomas v. EOTech, LLC" on Justia Law