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

A nonprofit organization based in Virginia, which advocates for election integrity, requested access to South Carolina’s statewide voter registration list from the state’s Election Commission. The request was made under the National Voter Registration Act of 1993 (NVRA), which generally requires states to make certain records about voter list maintenance available for public inspection and copying. South Carolina’s Election Commission denied the request, citing a state law that restricts disclosure of the voter list to individuals registered to vote within the state. The nonprofit responded by notifying the Election Commission that this refusal violated the NVRA and, after receiving a reiteration of the Commission’s position, filed a federal lawsuit seeking disclosure of the list.The United States District Court for the District of South Carolina reviewed the case. Both parties filed motions for summary judgment. The district court granted summary judgment to the nonprofit, concluding that the NVRA requires disclosure of the voter list and preempts the conflicting state law. The district court ordered the Election Commission to disclose the list. The Election Commission then moved for reconsideration, but the district court denied this motion. The Election Commission appealed both the grant of summary judgment and the denial of reconsideration.The United States Court of Appeals for the Fourth Circuit reviewed the case. On appeal, the Election Commission argued for the first time that the nonprofit lacked Article III standing to sue under the NVRA. The Fourth Circuit held that standing is a threshold jurisdictional issue and that the record lacked sufficient factual findings on standing, as the issue was not previously addressed in the district court. The Fourth Circuit remanded the case to the district court to determine whether the nonprofit has standing to bring the suit. The merits of the case were not addressed on appeal. View "Public Interest Legal Foundation, Inc. v. Wooten" on Justia Law

Darrell Meade worked as a coal miner for 37 years and applied for benefits under the Black Lung Benefits Act, which provides compensation to miners totally disabled by pneumoconiosis. A Labor Department claims examiner initially found that Meade qualified for benefits and that Dominion Coal Corporation was responsible for payment. However, the administrative law judge reviewing the case denied the claim, concluding that Meade’s medical evidence—including x-rays, biopsies, and CT scans—did not establish the irrebuttable presumption of complicated pneumoconiosis required for benefits.Meade appealed to the Benefits Review Board. The Board agreed with the judge’s findings regarding the x-ray and biopsy evidence but determined that the judge had not sufficiently evaluated or explained his analysis of the conflicting expert opinions on the CT scans. The Board vacated the denial in part and remanded the case, instructing the judge to address the competing expert rationales and to provide a clear explanation for his findings. On remand, the judge found Dr. DePonte’s interpretation of the scans more persuasive than Dr. Adcock’s and concluded that the evidence supported a diagnosis of complicated pneumoconiosis, awarding benefits to Meade. Dominion Coal Corporation appealed, challenging both the Board’s standard of review and the judge’s authority based on alleged unconstitutional removal protections.The United States Court of Appeals for the Fourth Circuit reviewed the Board’s interlocutory and final orders. The court held that it had jurisdiction to review interlocutory Board orders after a final order was issued. It found that the Board properly remanded the case when the administrative law judge failed to adequately explain his reasoning and that substantial evidence supported the final award of benefits. The court also rejected Dominion’s constitutional challenge, holding that Dominion had not shown harm from the removal protections. The Fourth Circuit denied Dominion’s petition for review. View "Dominion Coal Corporation v. DOWCP" on Justia Law

Vernon Vanderpool worked underground for over twenty years in coal mines, primarily as a roof bolter and section foreman. After retiring due to a back injury, he developed progressively worsening respiratory symptoms and was eventually diagnosed with pneumoconiosis, commonly known as black lung disease. In 2014, Vanderpool filed a claim for benefits under the Black Lung Benefits Act, asserting that his respiratory ailments rendered him totally disabled.Following his claim, the District Director of the U.S. Department of Labor’s Office of Workers’ Compensation Programs issued a decision awarding benefits. Clinchfield Coal Company, Vanderpool’s former employer, contested this decision. An Administrative Law Judge (ALJ) held a hearing and upheld the award, finding total disability based on pulmonary function tests and medical opinion evidence. Clinchfield then appealed to the Benefits Review Board, arguing that the ALJ erred in crediting certain pulmonary function tests and in weighing medical opinions. The Board rejected these arguments and affirmed the ALJ’s decision.The United States Court of Appeals for the Fourth Circuit reviewed Clinchfield’s petition, applying a highly deferential standard to the ALJ’s findings. The court held that the ALJ properly applied regulatory standards regarding pulmonary function tests, treating deviations from quality standards as affecting the weight rather than admissibility of the evidence. The ALJ’s assessment of medical opinions, including his rationale for crediting one expert over others, was sufficiently explained and satisfied the requirements of the Administrative Procedure Act. Substantial evidence supported the finding of total disability, permitting invocation of the statutory presumption of disability under the Act. As a result, the Fourth Circuit affirmed the Board’s decision and denied Clinchfield’s petition for review. View "Clinchfield Coal Company v. DOWCP" on Justia Law

The plaintiff, a long-term employee at a private aviation services provider, was diagnosed with breast cancer during the COVID-19 pandemic. Initially, she was permitted to work entirely from home as business slowed, with her in-person duties reassigned to another employee. As business returned to normal, management repeatedly asked her to resume a hybrid work schedule to address essential accounting functions that required physical presence. Although she verbally agreed to return on a part-time basis, she failed to attend in person as promised, communicated sporadically about her schedule, and ultimately missed multiple days of work without proper notice. After this pattern continued for several months, she was discharged for job abandonment.The United States District Court for the Western District of North Carolina granted summary judgment for the employer. The court found that the plaintiff failed to establish a prima facie case of discrimination, retaliation, or failure to accommodate under the Americans with Disabilities Act (ADA). The court determined that, even if such a case were made, the employer had provided legitimate business reasons for its decisions and had made substantial efforts to accommodate the plaintiff’s medical condition.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the decision de novo. The appellate court held that the plaintiff did not qualify as a “qualified individual” under the ADA because she could not perform the essential functions of her position, even with reasonable accommodation. The court emphasized that the employer’s repeated attempts to accommodate her were sufficient, and her failure to cooperate or consistently communicate precluded liability. The court also rejected her retaliation claim, finding no causal connection between her protected activity and her termination. The judgment of the district court was affirmed. View "Haggins v. Wilson Air Center, LLC" on Justia Law

Osvaldo Figueroa worked as a night-shift turkey loader for a poultry company. His main duties included catching and loading turkeys onto trucks, and sometimes fueling, sanitizing, and washing the trucks before the loading process. Employees recorded their work hours using a punch clock, and paystubs included entries for overtime hours, load trips (base pay per trip), and attendance hours. Figueroa alleged that he and other turkey loaders were not paid promised hourly wages and overtime, claiming violations of both the North Carolina Wage and Hour Act (NCWHA) and the Fair Labor Standards Act (FLSA).The United States District Court for the Eastern District of North Carolina first dismissed Figueroa’s amended complaint, concluding that he was paid under a piece-rate system rather than an hourly wage system, and that he failed to sufficiently allege entitlement to unpaid overtime or hourly wages. The district court also found that he received adequate notice of his compensation structure under the NCWHA. After Figueroa amended his complaint again, the district court dismissed his NCWHA claims but allowed the FLSA claim to proceed to discovery. On summary judgment, the district court found that Figueroa was a piece-rate employee, that overtime was properly calculated according to FLSA regulations, and that Butterball kept accurate records. The court rejected Figueroa’s assertions of improper hour-shifting and unpaid pre-shift work due to lack of supporting evidence for his own situation.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s rulings. The appellate court held that Figueroa was properly classified as a piece-rate employee, not an hourly worker, and that Butterball correctly calculated and paid overtime according to FLSA provisions. The court also found that Figueroa did not establish a viable claim under the NCWHA, as any error in dismissal was harmless in light of the record, and that Butterball provided sufficient notice of pay terms. The district court’s orders were affirmed. View "Osvaldo Figueroa v. Butterball, LLC" on Justia Law

William White, a federal prisoner serving a lengthy sentence, was transferred from one federal correctional institution to another, spending three days at a federal transfer center in Oklahoma City, where he was held in a Special Housing Unit for security reasons. During this brief transit period, he was not offered, nor did he participate in, any evidence-based recidivism reduction programming required under the First Step Act of 2018 (FSA). White later sought to have his time at the transfer center count toward FSA time credits, which could reduce his period of incarceration.The United States District Court for the District of Maryland denied White’s habeas corpus petition under 28 U.S.C. § 2241. The court found that the Bureau of Prisons’ (BOP) refusal to award FSA time credits for the three-day transfer period was consistent with BOP regulations and policy statements, which generally do not consider prisoners in transit or in certain housing statuses to be “successfully participating” in qualifying programs. The court also rejected White’s claim that his due process rights were violated, holding that the FSA does not create a protected liberty interest in earning time credits during every day of incarceration.Reviewing the case, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The Fourth Circuit held that, under the plain text of the FSA, a prisoner is entitled to time credits only for days in which he actually participates in qualifying programming or productive activities. Because White did not participate in any such programming during his three days in transit, he was not statutorily entitled to those time credits. The court further held that the FSA does not create a constitutionally protected liberty interest in earning time credits, so the BOP’s actions did not violate due process. View "White v. Warden of Fed Correctional Ins - Cumberland" on Justia Law

Ali Al-Timimi, a respected lecturer at an Islamic center in Virginia, became acquainted with a group of young Muslim men who engaged in activities including paintball, which some saw as preparation for “jihad in the form of combat.” While Al-Timimi did not directly participate in these preparations, he offered advice on discretion after FBI attention. Following the September 11, 2001 attacks, Al-Timimi attended a gathering where he urged attendees to repent, leave the United States, and join militant groups abroad, including Lashkar-e-Taiba (LET) in Pakistan. His statements inspired several individuals to make concrete plans to travel overseas for training, though he did not provide operational details or set timelines. Some group members subsequently traveled to Pakistan but did not engage in combat.The United States District Court for the Eastern District of Virginia indicted and convicted Al-Timimi on multiple counts, including conspiracy, solicitation, and aiding terrorist groups. He was sentenced to life imprisonment and other consecutive terms. Over two decades, his case saw numerous appeals and remands, including vacatur of certain counts based on changes in law regarding “crimes of violence” (as in Johnson v. United States and United States v. Davis). Ultimately, Al-Timimi appealed his remaining convictions (Counts 2–6, 9, and 10), asserting First Amendment protection for his speech.The United States Court of Appeals for the Fourth Circuit reviewed de novo whether Al-Timimi’s speech constituted unprotected incitement, solicitation, or facilitation of criminal acts. The court held that his speech, though inflammatory and disturbing, did not incite imminent lawless action nor did it intentionally solicit or assist a specific crime. As his advocacy did not meet the narrow exceptions to First Amendment protection, the court vacated Al-Timimi’s remaining convictions and remanded for judgments of acquittal. View "US v. Al-Timimi" on Justia Law

The defendant operated an immigration services business, preparing self-petition visa applications under the Violence Against Women Act (VAWA) for clients who claimed abuse by U.S. citizen or lawful permanent resident spouses. Investigators found that the defendant submitted applications containing forged psychological evaluations—some altered from a psychologist’s prior reports—and fabricated residential lease documents for multiple clients. These documents were used as evidence to satisfy VAWA eligibility criteria, such as establishing residence and proof of abuse. The defendant was not a licensed attorney and did not sign the applications as preparer.The United States District Court for the District of Maryland presided over the defendant’s trial. After the government presented its case, the defendant moved for judgment of acquittal, arguing that the fraudulent documents were not “required” by immigration law and that the statute required submission under oath, which he claimed was not satisfied. The district court denied the motion, ruling that while the regulations did not mandate specific documents, any evidence submitted to establish eligibility became “required” for that application. The jury subsequently convicted the defendant on all counts, and he was sentenced to 57 months’ imprisonment and two years of supervised release. The defendant did not renew his acquittal motion and later appealed, challenging the sufficiency of the evidence for several counts and alleging a sentencing error based on a discrepancy between oral and written conditions of supervised release.The United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment and sentence. The court held that documents submitted to establish eligibility in VAWA self-petitions—including psychological evaluations and lease agreements—constitute “required” documents under 18 U.S.C. § 1546(a) once chosen and presented. It further held that the statute’s “knowingly presents” clause does not require an oath for criminal liability. Regarding sentencing, the court found no material discrepancy between oral and written supervised release conditions and concluded that resentencing was not warranted. View "US v. Aborisade" on Justia Law

Two plainclothes detectives in Baltimore, acting on a tip about drug activity, observed Robert Gary Moore and another individual near a parked vehicle. When approached, Moore dropped a plastic bag and fled but was apprehended. The police recovered the bag, which was later analyzed in a laboratory report stating it contained cocaine. During Moore’s trial for possession and possession with intent to distribute, the State introduced two chain-of-custody reports: one disclosed before trial and another (the ECU report) disclosed only mid-trial. The latter did not mention the chemist who performed the analysis, raising questions about whether the correct bag was tested. Moore’s counsel did not object to the late disclosure or use the discrepancy in his defense. Moore was convicted by a jury.After his conviction was affirmed on appeal by Maryland’s intermediate appellate court, Moore sought postconviction relief in Maryland state court, arguing that the State’s belated disclosure of the ECU report violated his due process rights under Brady v. Maryland and that his counsel was ineffective. The Maryland trial court initially granted relief under Brady but, upon remand from the intermediate appellate court for further factfinding, ultimately denied both claims, finding that disclosure during trial did not constitute suppression under Brady. Moore’s application for leave to appeal this denial was rejected.Moore then filed a federal habeas petition in the United States District Court for the District of Maryland. The district court found a Brady violation and granted habeas relief, ordering Moore’s conviction vacated unless retried within sixty days. On appeal, the United States Court of Appeals for the Fourth Circuit agreed that the state court had unreasonably applied federal law and that a Brady violation warranted habeas relief. However, it held that federal district courts lack authority to vacate state convictions directly and thus vacated the district court’s order, remanding for a new order consistent with the proper bounds of federal habeas relief. View "Moore v. State of Maryland" on Justia Law

An African American police officer employed by the Baltimore Police Department attended a nightclub event in August 2018, where an altercation occurred between a member of her party and an on-duty police sergeant, resulting in the sergeant striking her friend. The officer testified against the sergeant before a grand jury and at his criminal trial, after which she was warned by colleagues that she was being targeted. Though criminal charges against her were declined, the department initiated internal disciplinary proceedings, ultimately filing charges against her in June 2020 for assault and making false statements. She was suspended with pay and later, after filing an EEOC complaint in February 2021 alleging race discrimination and retaliation, was forced to resign in lieu of termination in June 2022.The United States District Court for the District of Maryland reviewed her claims under Title VII and 42 U.S.C. § 1983, including allegations of race discrimination, retaliation, and municipal liability under Monell v. Department of Social Services of City of New York. The district court dismissed her original and amended complaints, concluding that she failed to plead plausible claims for relief, specifically finding her comparator evidence insufficient for the discrimination claim and that her retaliation and Monell claims lacked factual support.On appeal, the United States Court of Appeals for the Fourth Circuit applied de novo review to the district court’s dismissal. The court held that the officer had sufficiently alleged a Title VII racial discrimination claim by identifying multiple white or non-black comparators who engaged in similar conduct but received less severe discipline. However, it affirmed the dismissal of her retaliation claim, finding she failed to plausibly allege a causal connection between her protected activity and the adverse employment action. The court also affirmed the dismissal of the Monell claim, holding the complaint did not include specific factual allegations of a widespread pattern or practice. The judgment was therefore affirmed in part, reversed in part, and remanded. View "Johnson v. Baltimore City, Maryland" on Justia Law