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

Christopher Arthur was investigated after founding a business that sold military gear and later provided training and manuals on tactics including the use of explosives. The FBI became involved after a customer, Joshua Blessed, died in a shootout and was found to possess pipe bombs and Arthur’s manuals. Subsequently, an undercover informant, “Buckshot,” sought training from Arthur, who instructed him on fortifying his home and making explosive devices, knowing Buckshot claimed he wanted to use such tactics against federal agents. Arthur was arrested in January 2022 and a search of his home revealed illegal firearms and improvised explosives.A grand jury in the United States District Court for the Eastern District of North Carolina indicted Arthur under 18 U.S.C. § 842(p)(2)(B) for teaching explosives use with knowledge of criminal intent, and on additional firearms and explosives charges. Arthur moved to dismiss the primary count, arguing the statute was facially overbroad under the First Amendment. The district court denied the motion, finding the statute’s knowledge requirement limited its scope to conduct integral to criminal acts, not protected speech. After a three-day trial, the jury found Arthur guilty on all counts. At sentencing, the court applied the U.S.S.G. § 3A1.4 terrorism enhancement, increasing his guidelines range, and sentenced Arthur to a total of 300 months’ imprisonment.The United States Court of Appeals for the Fourth Circuit reviewed the case. It held that 18 U.S.C. § 842(p)(2)(B) is not unconstitutionally overbroad, concluding that the statute targets speech integral to criminal conduct and does not criminalize a substantial amount of protected expressive activity. The Fourth Circuit also found no reversible error in applying the terrorism enhancement, and determined any alleged guidelines error was harmless given the district court’s alternative sentencing rationale. The judgment of the district court was affirmed. View "US v. Arthur" on Justia Law

The case centers on Jessie Glass, whose estranged wife, April, reported to law enforcement that she witnessed a significant quantity of child sexual abuse material on Glass’s phone. April provided specific details about the alleged material, the devices Glass owned, and information for accessing his online accounts. Detective Jason Lowrance investigated April’s claims, which included reviewing her prior allegations against Glass as well as Glass’s history of previous investigations for similar offenses. Some of these earlier investigations had been closed without charges or with findings labeled “[u]nfounded.” Lowrance then prepared affidavits for search warrants to search Glass’s home and electronics, securing evidence of child sexual abuse material.The United States District Court for the Western District of North Carolina denied Glass’s motion to suppress, which argued that Lowrance recklessly omitted information in his warrant affidavits that would have undermined April’s credibility and thus probable cause. The district court found that any omissions were not made with intent to mislead or recklessness, and that the omitted facts would not have altered the probable cause determination. A jury later found Glass guilty on all counts, and the district court sentenced him to fifteen years’ imprisonment and imposed financial penalties.The United States Court of Appeals for the Fourth Circuit reviewed the appeal. It held that Lowrance’s affidavits contained sufficient detail to support probable cause, and that the omitted information about April’s credibility would not have defeated probable cause. The appellate court also rejected Glass’s double jeopardy argument, finding the convictions and sentences were based on distinct conduct. Finally, the court affirmed the district court’s imposition of a $5,000 special assessment, concluding the required statutory considerations were adequately addressed. The judgment was affirmed in all respects. View "US v. Glass" on Justia Law

An Indian professor employed at a public university in North Carolina applied for tenure after a probationary period, but his initial application was denied following negative evaluations from colleagues concerning his teaching, mentorship, and administrative performance. Several years later, the same professor reapplied and was granted tenure. After receiving tenure, he sued various university officials, alleging that the original denial was the result of racial discrimination in violation of the Equal Protection Clause and 42 U.S.C. § 1981, as well as retaliation for his non-traditional teaching methods in violation of the First Amendment. His complaint focused on negative statements and actions by two specific colleagues, while also asserting that other officials enabled or failed to remedy alleged bias.The United States District Court for the Eastern District of North Carolina dismissed the complaint for failure to state a claim under Rule 12(b)(6). The court found that the plaintiff’s allegations of racial discrimination were unsupported by facts connecting any defendant’s actions to race, and that his First Amendment retaliation claim failed to identify protected speech or a causal link between such speech and the tenure decision.The United States Court of Appeals for the Fourth Circuit affirmed the district court’s dismissal. The Fourth Circuit held that the plaintiff’s allegations did not plausibly suggest he was treated differently than similarly situated colleagues because of his race, as required for Equal Protection and § 1981 claims. The court also concluded that the complaint failed to plausibly allege protected speech or retaliation under the First Amendment. The Fourth Circuit emphasized the limited judicial role in reviewing academic tenure decisions and declined to address qualified immunity, as no plausible claim was stated. Thus, the district court’s judgment was affirmed. View "Katti v. Arden" on Justia Law

The plaintiff, a community advocate, posted a lengthy video—obtained from internal office security footage of a local police department—on his Facebook page. Only a few department employees had access to this footage. In response, a special agent from the Virginia State Police investigated how the plaintiff obtained the video, suspecting possible computer trespass under Virginia law. The agent sought and obtained warrants to search the plaintiff’s Facebook and Gmail accounts, believing these accounts might contain evidence relevant to the investigation. Although the plaintiff moved to quash both warrants for lack of probable cause, a state court denied the motions, and the Supreme Court of Virginia refused his appeal. Ultimately, the local prosecutor determined there was insufficient evidence to charge anyone with computer trespass.Following these events, the plaintiff filed a federal lawsuit in the United States District Court for the Western District of Virginia, alleging that the searches violated his First and Fourth Amendment rights and were conducted in retaliation for his criticism of local government. After amending his complaint once, the plaintiff sought to amend it a second time. The district court dismissed his claims, concluding that his failure to plead the absence of probable cause was fatal, and denied leave to amend as futile.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court’s decisions. The Fourth Circuit held that, in order to state a First Amendment retaliatory search claim, the plaintiff was required to plead the absence of probable cause or show he qualified for a narrow exception, and he had done neither. The court further held that the same requirement applied to his Fourth Amendment claim. The court also agreed that denying leave to amend was proper, as the proposed amendment would not have stated a valid claim. View "Stanley v. Bocock" on Justia Law

After the death of her husband, who had worked in coal mining for nearly 28 years, a widow applied for survivor benefits under the Black Lung Benefits Act (BLBA). Her husband died in 2014 following a hospitalization, and she filed her claim shortly thereafter. The BLBA provides survivor benefits to eligible dependents if a miner’s death is due to pneumoconiosis (“black lung disease”) arising from coal mine employment. A key question in this case was whether the miner’s terminal arterial blood gas (ABG) studies, taken during his last hospitalization, could be used to establish that he was totally disabled due to a chronic respiratory or pulmonary condition at the time of his death.Initially, the District Director awarded benefits and identified the employer as the responsible operator. The employer requested a hearing before the Office of Administrative Law Judges. The first Administrative Law Judge (ALJ) denied benefits, finding that although the miner worked long enough to invoke a presumption that his death was due to pneumoconiosis, the ABG tests lacked an adequate physician’s report linking the results to a chronic condition, as required by regulation. The widow sought modification, arguing that a mistake of fact had been made. A second ALJ granted modification and awarded benefits, relying on a comprehensive report from one of the physicians that sufficiently connected the ABG results to the miner’s chronic lung disease. The Benefits Review Board (BRB) affirmed, holding that the widow established her entitlement to benefits and that the employer failed to rebut the statutory presumption.The United States Court of Appeals for the Fourth Circuit reviewed the case and denied the employer’s petition. The court held that substantial evidence supported the BRB’s decision affirming the award of benefits. Specifically, the court found the physician’s report was sufficient to link the terminal ABG results to a chronic respiratory condition, thus satisfying regulatory requirements and entitling the widow to the statutory presumption. The court also concluded that the ALJ properly granted modification based on a mistake of fact. View "Clinchfield Coal Company v. Mullins" on Justia Law

An employee of a company specializing in training security officers raised concerns to management about unsafe working conditions, including the handling of weapons and a hazardous firing range where bullet ricochets had resulted in injuries. The employee, along with other instructors, formally complained to supervisors about these dangers, especially during the onset of the COVID-19 pandemic, when he also questioned restrictions on personal protective equipment. After voicing these safety concerns, the employee was suspended and later terminated, allegedly for insubordination.The employee filed a charge with the Regional Director of the National Labor Relations Board (NLRB), asserting that his termination was unlawful retaliation for engaging in protected concerted activity under the National Labor Relations Act (NLRA). After investigation, an NLRB administrative law judge (ALJ) held a hearing and determined that the employee was not a managerial employee and was therefore protected by the NLRA. The ALJ found that the primary reason for the suspension and termination was the employee’s repeated advocacy regarding workplace safety, not insubordination. The ALJ concluded that the employer had committed unfair labor practices. The employer appealed, and the NLRB affirmed the ALJ’s decision with minor modifications.The United States Court of Appeals for the Fourth Circuit reviewed the NLRB’s order. Applying the substantial evidence standard, the court held that the Board’s conclusion—that the employee was not a managerial employee—was supported by the record. The court found that the employee lacked authority to formulate or implement management policy and did not possess the discretion characteristic of managerial status. Therefore, the employee was entitled to the NLRA’s protections. The court granted the NLRB’s application for enforcement of its order and denied the employer’s cross-petition for review. View "National Labor Relations Board v. Constellis, LLC" on Justia Law

A member of the Kuwaiti royal family was defrauded by a Baltimore restaurateur, who convinced her to send nearly $7.8 million under the guise of investing in real estate and restaurant ventures in the United States. The restaurateur used the funds to acquire multiple properties, including a condominium in New York City and a home in Pikesville, Maryland, but secretly held ownership in his own name and for his personal use. After the fraud was uncovered, the investor sued the restaurateur for fraud and sought to impose a constructive trust over the properties purchased with her funds. Around the same time, she attempted to file a notice of lis pendens to protect her interest in the Pikesville property, but the notice was recorded against the wrong property and was thus ineffective.During discovery, the investor learned that World Business Lenders, LLC (WBL) had issued three loans to the restaurateur, each secured by properties acquired with her funds. She then filed suit against WBL in the United States District Court for the District of Maryland, alleging that WBL aided and abetted the restaurateur’s fraud by encumbering the properties with liens, thereby hindering her ability to recover on any judgment. Following a bench trial, the district court found for WBL on two of the loans, but found WBL liable for aiding and abetting fraud in relation to the loan secured by the Pikesville home, awarding compensatory and punitive damages.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s factual findings for clear error and legal conclusions de novo. The appellate court affirmed the district court’s judgment for WBL on the first two loans but reversed as to the Pikesville loan. The Fourth Circuit held that WBL was not willfully blind to the restaurateur’s fraud in any of the loans as a matter of law and remanded with instructions to enter final judgment for WBL on all claims. View "Al-Sabah v. World Business Lenders, LLC" on Justia Law

A decorated Army sergeant was convicted in Virginia after pleading guilty to two counts of malicious wounding and other charges stemming from separate incidents occurring on a single day in March 2011. At the time, he had recently returned home from combat in Afghanistan, where he had suffered multiple serious injuries, including two traumatic brain injuries. His crimes included shooting a woman during an altercation and, later that day, assaulting a man in a bar. He received a sentence of 46 years, well above the state’s discretionary sentencing guidelines.On direct appeal, the Court of Appeals of Virginia and the Supreme Court of Virginia both affirmed his convictions and sentence, finding no error in the sentencing court’s weighing of mitigating evidence. The defendant then pursued state habeas relief in the Circuit Courts for the City and County of Roanoke, arguing ineffective assistance of counsel under the Sixth Amendment. He contended his lawyer failed to present readily available mitigating evidence, including details of his military service, combat injuries, mental health struggles (especially PTSD), and failed to object to the use of his expunged juvenile criminal record. The state court denied relief, concluding there was no prejudice, and the Supreme Court of Virginia summarily refused further appeal.In subsequent federal habeas proceedings under 28 U.S.C. § 2254, the United States District Court for the Western District of Virginia denied relief, holding that the state decision was not contrary to or an unreasonable application of federal law.The United States Court of Appeals for the Fourth Circuit reversed. The court held that the state court applied the wrong legal standard for prejudice under Strickland v. Washington, failed to consider the totality of available mitigating evidence, and that there was a reasonable probability of a different sentence had counsel performed adequately. The case was remanded with instructions to grant a writ of habeas corpus unless the Commonwealth provides plenary resentencing within a reasonable time. View "Coleman v. Dotson" on Justia Law

During the COVID-19 pandemic, an employer instituted a company-wide vaccine mandate that applied to all employees, including those working remotely. Two remote employees requested religious exemptions from the vaccine requirement. One objected on the basis of her Christian beliefs regarding the use of fetal cell lines in vaccine development, while the other cited her conscience and faith, referencing Catholic teachings. Both exemption requests were denied, and the employees were subsequently terminated.After their terminations, the two employees initiated a lawsuit in the United States District Court for the District of Maryland. Their claims included religious discrimination under Title VII of the Civil Rights Act and two disability discrimination claims under the Americans with Disabilities Act (ADA): one for unlawful medical inquiry and one for being “regarded as” disabled due to their unvaccinated status. The district court dismissed all claims, concluding that the plaintiffs had not sufficiently pleaded that their objections were based on religious beliefs and finding that neither ADA theory was viable because vaccination status is not equivalent to a disability.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s decision de novo. The Fourth Circuit held that the plaintiffs’ complaints plausibly alleged that their opposition to the vaccine mandate was an essential part of their religious faith and that their refusal to be vaccinated was connected to those beliefs. Therefore, the court found that the district court erred in dismissing the Title VII religious discrimination claims at the pleading stage. However, the Fourth Circuit affirmed the dismissal of both ADA claims, holding that an inquiry into vaccination status is not a disability-related inquiry and that being unvaccinated does not constitute a physical or mental impairment under the ADA. The case was affirmed in part, vacated in part, and remanded for further proceedings on the Title VII claims. View "Finn v. Humane Society of the United States" on Justia Law

The defendant was convicted by a jury in 2002 on multiple federal drug and firearm charges, receiving a lengthy sentence. He unsuccessfully challenged his convictions and sentence through direct appeals and several motions for habeas relief under 28 U.S.C. § 2255, including claims of ineffective assistance, vindictive prosecution, and arguments based on later Supreme Court rulings. After a First Step Act sentence reduction in 2019, which resulted in an amended judgment and a reduced sentence, the defendant filed another pro se § 2255 motion in 2022, arguing that he was actually innocent of one of his firearm convictions because both firearm offenses occurred as part of the same drug conspiracy.The United States District Court for the District of South Carolina dismissed the defendant’s 2022 habeas motion on two alternative grounds: first, that it was an unauthorized “second or successive” motion because a First Step Act sentence reduction does not create a “new judgment” for purposes of AEDPA; and second, that it was untimely under the one-year limitations period, with no basis for equitable tolling. The district court found that even if the motion was not successive, it was still time-barred, and the merits of his claim did not justify tolling.The United States Court of Appeals for the Fourth Circuit reviewed only the question of whether a First Step Act sentence reduction results in a “new judgment” under AEDPA, having denied the defendant’s request to expand the appeal to include the timeliness issue. The Fourth Circuit held that, because the district court’s alternative ruling of untimeliness was not appealable and would remain unaffected regardless of the outcome on the “new judgment” issue, the court had no ability to redress the defendant’s injury. As a result, the appeal was dismissed as moot. View "United States v. Robinson" on Justia Law