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

The case concerns an individual who was born in El Salvador in 1981 to unmarried parents. His biological father acknowledged paternity by signing the birth certificate, but the two did not have a relationship. At age 11, he immigrated to the United States as a lawful permanent resident to join his mother. When he was 16, his mother became a naturalized U.S. citizen. As an adult, he was convicted of drug-related offenses. Years later, removal proceedings were initiated against him despite an earlier case memorandum indicating he had derived citizenship through his mother.An immigration judge (IJ) initially denied his motion to terminate removal proceedings, finding that he failed to prove his paternity had not been legitimated under Salvadoran law, and ordered him removed. The Board of Immigration Appeals (Board) affirmed the removal order but remanded for reconsideration of his claim under the Convention Against Torture (CAT). Subsequent IJ and Board orders continued to find him removable and not a U.S. citizen, though relief under CAT was granted and later vacated. Both sides appealed these orders, leading to multiple remands and re-entries of removal orders. Ultimately, the Board reaffirmed its prior rulings, and the petitioner remained in immigration detention.The United States Court of Appeals for the Fourth Circuit reviewed the consolidated petitions. The court held that it had jurisdiction to review both the 2024 and 2025 Board orders. On the merits, the court determined that, under the relevant federal statute in effect when the petitioner’s mother naturalized, his paternity had not been “established by legitimation.” Because all other statutory requirements were met, he automatically became a U.S. citizen upon his mother’s naturalization. The court granted the petitions, vacated the Board’s orders, and remanded with instructions to terminate removal proceedings. View "Lopez v. Bondi" on Justia Law

A group of nine professional models brought suit against a nightclub in Greenville, South Carolina, alleging that the club took images from the models’ social media pages and used them in its promotional materials without their knowledge, consent, or compensation. The models claimed the advertising falsely implied their association, employment, or endorsement of the club. They asserted two claims under the Lanham Act as well as seven state law claims, including misappropriation of likeness.The defendant responded with a motion to dismiss all counts for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6), but did not challenge the sufficiency of the misappropriation of likeness claim. The plaintiffs did not respond to the motion within the time set by the District of South Carolina’s local rules. The United States District Court for the District of South Carolina granted the motion to dismiss as unopposed, dismissing the federal and most state law claims with prejudice and dismissing the misappropriation of likeness claim without prejudice, declining to exercise supplemental jurisdiction. The plaintiffs’ postjudgment motions for relief were denied by the district court.On appeal, the United States Court of Appeals for the Fourth Circuit held that a court may not grant a Rule 12(b)(6) motion solely because it is unopposed. The court emphasized that Rule 12(b)(6) requires an independent determination of whether the complaint states a plausible claim for relief, regardless of the parties’ failure to respond. Finding that the district court had not made such a determination, the Fourth Circuit vacated the judgment and remanded the case for further proceedings. The court did not reach the merits of the parties’ other arguments or the postjudgment orders. View "Guzman v. Acuarius Night Club LLC" on Justia Law

This case involves individuals who filed asbestos-related tort claims against DBMP LLC. The claims arise from injuries allegedly caused by asbestos-containing products manufactured by CertainTeed Corporation over several decades. Facing a growing number of lawsuits and significant financial exposure, CertainTeed underwent a "divisional merger" under Texas law, splitting into two entities: New CertainTeed, which received most assets and non-asbestos liabilities, and DBMP, which received all asbestos-related liabilities and certain assets. An uncapped funding agreement obligated New CertainTeed to cover DBMP’s asbestos liabilities. DBMP then filed for Chapter 11 bankruptcy, invoking 11 U.S.C. § 524(g) to manage current and future asbestos claims through a trust. As a result, pending tort actions were automatically stayed.The United States Bankruptcy Court for the Western District of North Carolina denied motions from the plaintiffs to lift the automatic stay and to stay a preliminary injunction that extended the stay to CertainTeed affiliates. Applying the standards from In re Robbins, the bankruptcy court found that lifting the stay would prejudice the debtor’s estate, harm judicial economy by returning a large volume of cases to the tort system, and undermine consistent treatment of claimants under a § 524(g) plan. The bankruptcy court also found insufficient evidence of bad faith by DBMP in filing for bankruptcy. The United States District Court for the Western District of North Carolina affirmed, holding that the bankruptcy court’s findings and application of the Robbins factors were not an abuse of discretion.On further appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The Fourth Circuit held that the bankruptcy court did not abuse its discretion in refusing to lift the automatic stay. It found that DBMP sought bankruptcy protection for legitimate purposes under § 524(g), was not shown to have acted in bad faith, and that the statutory framework does not require insolvency. View "Herlihy v. DBMP, LLC" on Justia Law

The case concerns the non-reappointment of a local general registrar of elections in Lynchburg, Virginia. The plaintiff, previously appointed unanimously by a bipartisan electoral board, reapplied for her position after her term expired in 2023. By that time, the board’s partisan makeup had shifted to include two Republicans and one Democrat, reflecting state law. The board interviewed four candidates, including the plaintiff, but ultimately appointed a different candidate who was a registered Republican. The plaintiff, describing herself as an independent, alleged her non-reappointment was due to partisan bias rather than job performance.Following the board’s decision, the plaintiff sued the board and its two Republican members, alleging First Amendment violations tied to political animus. The United States District Court for the Western District of Virginia dismissed the claim against the board itself on sovereign immunity grounds, but allowed the suit against the individual members to proceed. After a jury trial, the verdict favored the defendants. The plaintiff then appealed, raising concerns about jury selection procedures and the exclusion of certain evidence.The United States Court of Appeals for the Fourth Circuit reviewed the appeal. It held that the district court did not abuse its discretion in managing voir dire, including its refusal to allow more pointed questioning about potential jurors’ political affiliations and beliefs. The Fourth Circuit also determined that the plaintiff had not preserved most evidentiary challenges for appellate review, as she failed to make sufficient proffers or obtain definitive rulings on excluded evidence. For the limited evidentiary exclusions properly preserved, the appellate court found no abuse of discretion. Thus, the Fourth Circuit affirmed the judgment in favor of the defendants. View "Gibbons v. Gibbs" on Justia Law

Two individuals were seriously injured during a 2022 mass shooting at the Edmund Burke School in Washington, D.C. The shooter, a 23-year-old man from Virginia, used an AR-15 and various accessories and ammunition manufactured by multiple U.S. and foreign companies. The shooter built his arsenal by purchasing and assembling these products, which were then used in the attack. Both plaintiffs, a parent picking up her child and a school security guard, survived but suffered severe physical and emotional injuries.The plaintiffs filed suit in the United States District Court for the Eastern District of Virginia, asserting claims under Virginia’s False Advertising Statute and Consumer Protection Act, and alleging negligence and negligence per se for violations of the National Firearms Act and Virginia’s Uniform Machine Gun Act. The defendants moved to dismiss, arguing that the plaintiffs lacked Article III standing because their injuries were not “fairly traceable” to the defendants’ conduct. The district court agreed, dismissing the case for lack of subject-matter jurisdiction under Rule 12(b)(1). Despite this, the court also reached the merits and dismissed the claims under Rule 12(b)(6), finding them barred by the Protection of Lawful Commerce in Arms Act (PLCAA).On appeal, the United States Court of Appeals for the Fourth Circuit reversed the district court’s standing ruling, holding that the plaintiffs had alleged sufficient facts to demonstrate that their injuries were “fairly traceable” to the defendants’ alleged misconduct, thus satisfying Article III’s requirements. The Fourth Circuit vacated the district court’s alternative merits ruling under the PLCAA as advisory and beyond its jurisdiction, remanding the case for further proceedings consistent with its opinion. View "Lowy v. Daniel Defense, LLC" on Justia Law

A group of nine individuals, representing a putative class, alleged that a credit union systematically discriminated against racial minorities in its residential mortgage lending practices. The plaintiffs varied in racial background (eight Black, one Latino), state of residence, type of loan product sought, and financial circumstances. Despite these differences, they claimed the credit union used a single, semi-automated underwriting process for all applicants, which, through its proprietary algorithm, resulted in discriminatory outcomes against minority applicants. The complaint sought both damages and injunctive relief, and proposed a class consisting of all minority applicants for mortgage-related products from 2018 to the present who faced adverse actions compared to similarly situated non-minority applicants.The United States District Court for the Eastern District of Virginia partially granted the defendant’s motion to dismiss and struck the class allegations, relying on Federal Rules of Civil Procedure 12(f) and 23(d)(1)(D). The district court focused on the diversity of the plaintiffs’ circumstances, suggesting that the variations in loan types and applicant characteristics defeated the possibility of class certification, particularly under Rule 23(b)(3).On interlocutory appeal, the United States Court of Appeals for the Fourth Circuit addressed the standards governing class certification denials at the pleading stage before discovery. The Fourth Circuit held that district courts should only deny class certification at this stage if, on the face of the complaint, the Rule 23 requirements are not met as a matter of law. The appellate court affirmed the district court’s denial of class certification under Rule 23(b)(3), finding the lack of predominance and superiority apparent from the complaint due to the differences among the plaintiffs. However, the Fourth Circuit vacated the district court’s order as to Rule 23(b)(2), concluding that the complaint sufficiently alleged commonality for classwide declaratory and injunctive relief, and that the district court acted prematurely in denying certification under that provision. View "Oliver v. Navy Federal Credit Union" on Justia Law

After President Donald J. Trump began his second term, he issued two executive orders requiring federal agencies to end “diversity, equity, and inclusion” (DEI) programs in their grant and contracting processes. These directives included provisions for agencies to terminate DEI-related offices, positions, and funding (“Termination Provision”); to require federal grantees and contractors to certify compliance with anti-discrimination laws and the absence of DEI programs that violate those laws (“Certification Provision”); and to prepare a report on steps to deter illegal DEI programs (“Enforcement Threat Provision”). The plaintiffs—a city government and two organizations involved in higher education and academic advocacy—alleged that these provisions violated their constitutional rights and sought a preliminary injunction to halt their enforcement.The United States District Court for the District of Maryland found the plaintiffs likely to succeed on their constitutional claims and issued a nationwide preliminary injunction against most of the challenged provisions, except for the preparation of the enforcement report. The defendants appealed and the United States Court of Appeals for the Fourth Circuit granted a stay of the injunction pending appeal. The plaintiffs later sought to have the injunction vacated so they could amend their complaint, but the district court denied this request.Reviewing the case, the United States Court of Appeals for the Fourth Circuit held that the plaintiffs lacked standing to challenge the Enforcement Threat Provision because their alleged injuries were too speculative and intertwined with intra-governmental processes. However, the court found the plaintiffs had standing to challenge the Termination and Certification Provisions because these provisions resulted in concrete and imminent injuries, such as loss of funding or compelled changes in organizational activities.On the merits, the Fourth Circuit concluded the plaintiffs were unlikely to succeed on their facial constitutional challenges. The court ruled that the Termination Provision was not unconstitutionally vague under the Fifth Amendment, and that the Certification Provision did not violate the First Amendment on its face. The court vacated the preliminary injunction and remanded the case for further proceedings. View "Natl. Assoc. of Diversity Officers in Higher Edu. v. Trump" on Justia Law

The case centers around an accrediting agency’s decision to withdraw accreditation from an online university operated by a nonprofit educational organization. After years of below-benchmark graduation and employment rates, probation, and repeated warnings, the accrediting agency concluded the university was not compliant with its accreditation standards. The university responded by investing in improvement initiatives and shifting enrollment to a single online institution, but continued to struggle with student achievement. When accreditation was finally withdrawn, the university appealed internally and subsequently sought binding arbitration, arguing that the agency’s process was unfair, especially in its refusal to consider evidence about probationary treatment of other schools.Following arbitration, the arbitrator affirmed the agency’s decision, finding substantial evidence to support the withdrawal and concluding that the excluded evidence regarding other schools was irrelevant. The university then filed a motion to vacate the arbitration award and a complaint in the United States District Court for the Eastern District of Virginia, asserting due process violations and tortious interference. The district court denied the motion to vacate and granted judgment on the pleadings for the accrediting agency, holding that the university’s claims amounted to an impermissible collateral attack on the arbitration award, barred by the exclusivity provisions of the Federal Arbitration Act.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s rulings de novo. It affirmed both the denial of the motion to vacate and the grant of judgment on the pleadings. The Fourth Circuit held that the arbitration process did not deprive the university of a fair hearing and that the university’s complaint constituted an impermissible collateral attack on the arbitration award. The court formally adopted the impermissible-collateral-attack rule, concluding that such claims must be dismissed and the district court’s judgment was affirmed. View "Center for Excellence v. Accreditation Alliance" on Justia Law

An individual who served as Executive Director of a local economic development authority in Virginia was indicted on thirty-four counts stemming from multiple fraudulent schemes. These included wire fraud, bank fraud, money laundering, and aggravated identity theft. The prosecution presented evidence that the defendant used forged documents and misrepresentations to divert public funds for personal gain. One scheme involved a $2 million wire transfer, where the defendant lied to both her employer and others, using another person’s identity to facilitate the movement of funds. The trial was repeatedly delayed due to health issues experienced by the defendant and her counsel, resulting in significant breaks and several motions for mistrial by the defense.The United States District Court for the Western District of Virginia presided over the trial, ultimately entering judgments of acquittal on four counts of bank fraud but allowing the remaining convictions to stand. The court denied the defendant’s motions for mistrial, a new trial, and to introduce certain grand jury testimony. After the jury returned guilty verdicts on the remaining counts, the defendant was sentenced accordingly. The defendant appealed, challenging the aggravated identity theft conviction, the handling of trial delays, evidentiary rulings, and a supplemental jury instruction given after closing arguments.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that, under Dubin v. United States, the aggravated identity theft conviction could not stand because the use of another’s identity was not at the “crux” of the predicate wire fraud offense. The court vacated the conviction and sentence on that count and remanded for resentencing. However, the Fourth Circuit affirmed the district court’s rulings on all other issues, including denial of a mistrial, exclusion of grand jury testimony, and the propriety of the additional jury instruction. View "United States v. McDonald" on Justia Law

Lawrence Levon Jones was investigated by Raleigh police as a suspected drug supplier during a larger drug-trafficking operation in 2020. Officers monitored a suspected stash house and wiretapped Jones’s phone, observing frequent visits by Jones and connections with other individuals involved in drug distribution. Jones financed marijuana purchases via Wesley Kelly, who transported drugs between California and North Carolina. Coordinated arrests and searches in July 2020 resulted in the seizure of large quantities of drugs, cash, and firearms from the stash house and related locations. Jones was arrested at the stash house and later made jail calls directing associates to move large sums of money.The United States District Court for the Eastern District of North Carolina charged Jones and others with several drug and firearms offenses. Jones was specifically indicted on four counts, including drug conspiracy and firearms possession. At trial, the government presented testimony from investigators and Kelly, a cooperating witness. The district court excluded evidence of Kelly’s decades-old federal drug convictions under Federal Rule of Evidence 609(b). After the government’s case, Jones moved for acquittal on the firearms charges, arguing lack of evidence of possession; the court denied the motion. The jury found Jones guilty on all counts. During sentencing, Jones objected to enhancements for obstruction and leadership, but the district court overruled these objections and imposed a sentence of 480 months.On appeal to the United States Court of Appeals for the Fourth Circuit, Jones challenged the exclusion of Kelly’s convictions, the denial of his motion for acquittal, and the sentencing enhancements. The Fourth Circuit held that the district court did not abuse its discretion in excluding impeachment evidence, that sufficient evidence supported the firearms convictions under constructive possession principles, and that the sentencing enhancements were not clearly erroneous. The Court also found that any error would have been harmless given Jones’s guidelines range. The judgment of the district court was affirmed. View "United States v. Jones" on Justia Law