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

Phillip and Sara Alig, along with Daniel and Roxanne Shea, filed a class action lawsuit against Quicken Loans, Inc. (now Rocket Mortgage, LLC) and Title Source, Inc. (now Amrock, Inc.). They alleged that during the refinancing of their home mortgage loans, they paid for appraisals that were not independent because the defendants had provided appraisers with the homeowners' estimates of their homes' value. They claimed this made the appraisals worthless and asserted statutory, breach of contract, and conspiracy claims.The United States District Court for the Northern District of West Virginia certified a class of West Virginia citizens who refinanced mortgage loans with Quicken and received appraisals that included an estimate of the property's value. The court granted summary judgment to the plaintiffs, awarding over $10.6 million in damages. The court found that the plaintiffs had established a conspiracy between the defendants.The United States Court of Appeals for the Fourth Circuit affirmed the class certification and summary judgment on the statutory and conspiracy claims but vacated and remanded the breach of contract claim. The Supreme Court vacated the Fourth Circuit's judgment and remanded the case for reconsideration in light of TransUnion LLC v. Ramirez, which emphasized that every class member must have Article III standing to recover damages.On remand, the district court reinstated its original judgment, stating that TransUnion did not affect the class's standing. However, the Fourth Circuit concluded that the plaintiffs failed to establish that class members suffered concrete harm from the defendants' actions. The court reversed the district court's judgment certifying the class and awarding damages, affirming the judgment on the named plaintiffs' statutory and conspiracy claims, and vacating the judgment on the breach of contract claim, remanding it for further proceedings. View "Alig v. Rocket Mortgage, LLC" on Justia Law

Tytus Lamaar Shields pleaded guilty to possession of a firearm as a felon, violating 18 U.S.C. § 922(g)(1). In November 2021, law enforcement in Parkersburg, West Virginia, received information that Shields was transporting drugs. Shields, on bond for pending charges in Ohio and considered a fugitive, was arrested at his residence, where officers seized drugs, cash, and a loaded firearm. Shields admitted the firearm was his. He was charged with being a felon in possession of a firearm, knowing he had prior Ohio felony convictions, including one for drug trafficking.The United States District Court for the Southern District of West Virginia calculated an advisory Sentencing Guidelines range of 51 to 63 months and sentenced Shields to 51 months. Shields argued for a downward variance, citing an unwarranted sentencing disparity between his case and similar cases in West Virginia, but the district court did not address this argument. The court focused on Shields’s criminal history and sustained the government’s objection to the Presentence Investigation Report, which had not applied the increased base offense level for a "controlled substance offense."The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that the district court committed procedural error by failing to address Shields’s non-frivolous argument for a downward variance based on sentencing disparities. The appellate court held that the district court must consider and explain its reasoning regarding such arguments to allow for meaningful appellate review. Consequently, the Fourth Circuit vacated Shields’s sentence and remanded the case for resentencing, emphasizing the need for the district court to address all non-frivolous arguments presented by the defendant. View "United States v. Shields" on Justia Law

Margaret Ann Sutton was involved in a drug trafficking operation with Vicente Andres, a known drug dealer. Sutton initially visited Andres's house to buy and distribute drugs. Their relationship turned romantic, and they traveled together to California to purchase a large quantity of methamphetamine and marijuana. Upon returning to Virginia, they continued distributing the drugs. Sutton was actively involved in the drug sales, including a transaction with an undercover officer. During a police raid, Sutton was found with marked bills from a drug sale, and a large quantity of marijuana was discovered in a puzzle box in the house.The United States District Court for the Eastern District of Virginia convicted Sutton in a bench trial of various federal criminal offenses, including possession with intent to distribute marijuana and use of a drug-involved premises. Sutton was sentenced to twenty-nine years in prison. She appealed her convictions and sentence, arguing insufficient evidence and procedural and substantive unreasonableness in her sentencing.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that there was sufficient evidence to support Sutton's convictions. The court held that Sutton constructively possessed the marijuana found in the puzzle box, as she had control over the drugs and was aware of their presence. Additionally, the court determined that Sutton actively employed the house for the purpose of drug distribution, satisfying the requirements of 21 U.S.C. § 856(a)(1). The court also found that Sutton's sentence was neither procedurally nor substantively unreasonable, noting that her sentence was below the Guidelines range and that the district court had considered her background and history.The Fourth Circuit affirmed the district court's decision, upholding Sutton's convictions and sentence. View "United States v. Sutton" on Justia Law

Banorte, a group of five associated entities of the Mexican bank Grupo Financiero Banorte, sued Cartograf S.A. de C.V. (Cartograf Mexico) in the Fourth Civil Court of Mexico City in 2021. Banorte alleged that Cartograf Mexico and its sole administrator, José Páramo Riestra, defaulted on loans and concealed assets. Banorte filed an ex parte application in the Eastern District of Virginia to conduct discovery on Cartograf Mexico’s American subsidiary, Cartograf USA, Inc., under 28 U.S.C. § 1782. The district court granted the application, allowing Banorte to serve Cartograf USA with a subpoena. Cartograf USA moved to quash the subpoena, but the district court denied the motion.The United States District Court for the Eastern District of Virginia granted Banorte’s application for discovery under 28 U.S.C. § 1782, finding that the statutory requirements and discretionary factors set out in Intel Corp. v. Advanced Micro Devices, Inc. weighed in Banorte’s favor. The court allowed Banorte to serve subpoenas on Cartograf USA, seeking documents and deposition testimony related to Cartograf USA’s relationship with Cartograf Mexico and Páramo. Cartograf USA argued that the discovery was not for use in a foreign proceeding and that Banorte’s requests were made in bad faith, but the district court rejected these arguments.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court’s decision. The Fourth Circuit held that Banorte satisfied the statutory requirements of § 1782, including the “for use” requirement, as the requested discovery had a reasonable possibility of being useful in the Mexican civil proceedings. The court also found that the district court did not abuse its discretion in analyzing the Intel factors, including the receptivity of the foreign tribunal and whether the request was an attempt to circumvent foreign proof-gathering restrictions. The Fourth Circuit concluded that the district court’s careful consideration of the factors and its decision to grant the application and deny the motion to quash were appropriate. View "Banco Mercantil Del Norte, S.A v. Cartograf USA, Inc." on Justia Law

Curtis Wells parked his car near Arlington Cemetery and was noticed by Officer Armstrong due to his animated gestures while on a phone call. Armstrong approached Wells and discovered that his car had an expired registration. Arlington County police were called, and they found that Wells did not have a driver's license and had weapons in his car. The police decided to tow Wells's car and conducted an inventory search, which revealed various weapons and tactical gear, including a ballistic plate carrier. Wells was sent home, but further investigation suggested that the plate might have been stolen from the Army. Nine days later, Wells was arrested for receiving stolen property.In the United States District Court for the Eastern District of Virginia, Wells brought state and federal claims against various officers and entities, alleging Fourth and Fifth Amendment violations, among other claims. The district court dismissed all his claims, reasoning that the officers were protected by qualified immunity and that Wells had not plausibly alleged the necessary elements for his state tort claims.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's dismissal. The court held that the officers' actions were protected by qualified immunity because Wells did not have a clearly established right against the officers' conduct. The court found that the initial approach by Officer Armstrong was justified under the community-caretaking exception, the inventory search of Wells's car was conducted according to standard procedures, and Wells had consented to the safekeeping of his property. Additionally, the court held that Wells's Second Amendment claims failed because the right to public carry was not clearly established in 2020. The court also dismissed Wells's state law claims, finding that he had not plausibly alleged the necessary elements for false imprisonment or malicious prosecution. View "Wells v. Fuentes" on Justia Law

In September 2018, police officers in Fayetteville, North Carolina, observed a car performing a U-turn and stopping in front of Allen Wendell McNeil's house. After a brief interaction with the car's occupants, the police conducted a traffic stop and found a small bag of marijuana on the passenger. Without a warrant, the officers then went to McNeil's house for a "knock and talk." When McNeil's children answered the door and said he was not home, the officers proceeded to the backyard, where they found McNeil in a shed and detected the smell of marijuana. This led to McNeil's detention and the subsequent search and seizure of marijuana, money, and guns from his property.McNeil was charged with marijuana distribution and firearm possession. He pleaded guilty without a plea agreement, and the district court sentenced him to 114 months in prison. McNeil's direct appeal was affirmed by the United States Court of Appeals for the Fourth Circuit.McNeil filed a pro se petition under 28 U.S.C. § 2255, claiming ineffective assistance of counsel for failing to file a motion to suppress evidence obtained from the warrantless search and for not pursuing a plea agreement despite his requests. The district court dismissed the petition without an evidentiary hearing, ruling that McNeil's Fourth Amendment claim was frivolous and that his statements during the Rule 11 hearing precluded his ineffective assistance claim regarding the plea agreement.The United States Court of Appeals for the Fourth Circuit reviewed the case and concluded that McNeil's ineffective assistance claims could not be resolved on the existing record. The court held that the district court erred in dismissing McNeil's claims without an evidentiary hearing, as the facts surrounding the police officers' entry into the backyard and the plea negotiations required further factual development. The Fourth Circuit vacated the district court's judgment and remanded the case for an evidentiary hearing. View "United States v. McNeil" on Justia Law

Courthouse News Service, a news organization, sought remote online access to civil court records from the Circuit Court for Prince William County, Virginia, similar to the access granted to Virginia attorneys. Virginia law prohibits the clerk from providing such access to non-attorneys. Courthouse News sued, claiming this restriction violated its First Amendment and Equal Protection rights.The United States District Court for the Eastern District of Virginia dismissed Courthouse News's Equal Protection claim and granted summary judgment for the defendants on the First Amendment claims. The court found the restrictions to be content-neutral time, place, and manner regulations justified by the state's interests in the orderly administration of justice and protecting sensitive personal information.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court's ruling on the First Amendment and Equal Protection claims, holding that the access restriction was a content-neutral regulation narrowly tailored to serve significant governmental interests. The court found that the restriction did not violate the First Amendment as it provided ample alternative channels for accessing court records and did not burden more access than necessary. The court also concluded that the restriction did not violate the Equal Protection Clause for the same reasons it passed First Amendment scrutiny.However, the court vacated the district court's ruling on the Dissemination Restriction claim, finding that Courthouse News lacked standing to challenge it since the restriction only applied to those with remote access, which Courthouse News did not have. The case was remanded for the district court to dismiss this claim without prejudice. View "Courthouse News Service v. Smith" on Justia Law

Conor Fitzpatrick pleaded guilty to conspiracy to traffic in stolen personally identifying information, fraudulent solicitation of personally identifying information, and possession of child pornography. While released on bond awaiting sentencing, Fitzpatrick violated his conditions of release by secretly downloading a virtual private network and accessing the Internet without his probation officer's knowledge. At sentencing, the district court calculated Fitzpatrick’s advisory Guidelines sentencing range to be 188 to 235 months’ imprisonment but sentenced him to a 17-day time-served term of imprisonment, citing his autism spectrum disorder and youth.The United States District Court for the Eastern District of Virginia initially handled the case. Fitzpatrick was released on bond pending sentencing, subject to several special conditions, which he violated. The district court, considering Fitzpatrick’s autism and youth, imposed a significantly reduced sentence of 17 days, arguing that the Federal Bureau of Prisons would not be able to treat Fitzpatrick’s autism spectrum disorder and that he would be vulnerable in prison.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that the district court abused its discretion by imposing a substantively unreasonable sentence. The Fourth Circuit held that the district court failed to adequately consider the seriousness of Fitzpatrick’s offenses, the need to promote respect for the law, to deter similar wrongdoing, and to protect the public. The court vacated the 17-day sentence and remanded the case for resentencing, emphasizing that a sentence must fulfill the purposes of punishment, deterrence, and incapacitation. View "United States v. Fitzpatrick" on Justia Law

Dr. Anita Jackson, an otolaryngologist, was convicted of various offenses related to her private medical practice in North Carolina. She was the leading Medicare biller for balloon sinuplasty surgery, a procedure treating chronic sinusitis. Jackson reused single-use medical devices, specifically the Entellus XprESS Multi-Sinus Dilation Tool, on multiple patients without proper sterilization, leading to potential contamination. She also incentivized employees to recruit Medicare patients for the procedure, often bypassing proper medical assessments. Additionally, Jackson falsified documents and patient signatures in response to Medicare audits.The United States District Court for the Eastern District of North Carolina convicted Jackson on all counts, including violating the Food, Drug, and Cosmetics Act (FDCA) by holding for resale adulterated medical devices, violating the federal anti-kickback statute, making materially false statements, committing aggravated identity theft, mail fraud, and conspiracy. Jackson was sentenced to twenty-five years in prison and ordered to pay over $5.7 million in restitution. She moved for a judgment of acquittal and a new trial, which the district court denied.The United States Court of Appeals for the Fourth Circuit reviewed the case. Jackson argued that the devices were not "held for sale" under the FDCA, that her actions were protected under 21 U.S.C. § 396, and that the Government relied on a defective theory of per se adulteration. She also challenged the exclusion of certain evidence and jury instructions. The Fourth Circuit found no reversible error in the district court's rulings, holding that the devices were indeed "held for sale," that § 396 did not protect her conduct, and that the Government's theory was valid. The court also upheld the exclusion of evidence and the jury instructions. Consequently, the Fourth Circuit affirmed all of Jackson's convictions. View "United States v. Jackson" on Justia Law

In this case, the plaintiff, a Chapter 11 Trustee for BK Racing, LLC, initiated an adversary proceeding against multiple defendants, including Ronald and Brenda Devine, various family trusts, and corporate entities. The defendants were accused of obstructing the bankruptcy process by failing to comply with discovery obligations, including not producing required financial documents and records, despite multiple court orders.The bankruptcy court found that the defendants willfully disregarded their discovery obligations and engaged in a pattern of obstruction and delay. As a result, the court entered a default judgment against the defendants as a discovery sanction, awarding the plaintiff $31,094,099.89. The district court affirmed this decision, noting the defendants' repeated noncompliance and the necessity of deterrence.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court upheld the lower courts' decisions, finding no abuse of discretion in the entry of default judgment. The court applied the Wilson factors, determining that the defendants acted in bad faith, caused significant prejudice to the plaintiff, necessitated deterrence, and that lesser sanctions would be ineffective. The court also affirmed the decision to pierce the corporate veil, holding the defendants jointly and severally liable, based on evidence that the corporate entities were mere instrumentalities of the Devines, lacking proper corporate formalities and used to siphon funds.The Fourth Circuit concluded that the bankruptcy court's findings were not clearly erroneous and that the default judgment and the amount awarded were appropriate given the defendants' egregious conduct. The decision of the district court was affirmed. View "Smith v. Devine" on Justia Law