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

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The Fourth Circuit affirmed the district court's denial of defendant's motion to suppress after he conditionally pleaded guilty to possession of a firearm in furtherance of a drug crime. The court held that the district court did not err by admitting evidence of the firearm where the district court admitted the derivative evidence not because it was the fruit of voluntary statements, but because it found that the inevitable discovery exception to the exclusionary rule rendered the derivative evidence admissible; defendant's first statements were voluntary and the statements admitting possession of the gun were involuntary; and defendant's admission to the first bag of marijuana gave the officer the reasonable suspicion to justify detaining defendant and investigating further. In this case, before defendant made any involuntary admissions, the officer believed that he possessed a gun, had the probable cause necessary to search the car, and intended to find the gun. View "United States v. Alston" on Justia Law

Posted in: Criminal Law
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The Fourth Circuit affirmed the denial of social security disability benefits to plaintiff, holding that there was no conflict between the language describing her residual functioning capacity (RFC) and the DOT's definition of Level 2 reasoning. In this case, the ALJ found that plaintiff could perform jobs limited to simple, routine repetitive tasks of unskilled work. Furthermore, there was no comparable inconsistency between plaintiff's RFC and Level 2's notions of detailed but uninvolved instructions and tasks with a few variables. View "Lawrence v. Saul" on Justia Law

Posted in: Public Benefits
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The Fourth Circuit affirmed the district court's grant of summary judgment in favor of petitioners, a class of noncitizens subject to reinstated removal orders, holding that they were detained under 8 U.S.C. 1226 because a decision on removal remains "pending" until their withholding-only proceedings are complete. The court read the plain text of the provisions at issue to ensure that they fit together to form a workable statutory framework, holding that section 1226 applies when there is still "pending" a legal determination that must be made before a noncitizen may be removed; and once there are no remaining legal impediments to removal, section 1231's 90-day removal period begins. The court explained that the government lacks the authority to actually execute orders of removal while withholding-only proceedings are ongoing and thus petitioners were detained under section 1226. Therefore, the court agreed with the district court that the relevant provisions of section 1226, rather than section 1231, govern petitioners' detention, entitling petitioners to individualized bond hearings. View "Guzman Chavez v. Hott" on Justia Law

Posted in: Immigration Law
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The Fourth Circuit reversed defendant's conviction for being a felon in possession of a firearm in violation of 18 U.S.C. 922(g). The court held that the North Carolina Supreme Court would hold that a conditional-discharge plea is not a conviction for purposes of section 921 and 922. Therefore, defendant was not a felon and his federal felon-in-possession conviction could not stand. View "United States v. Smith" on Justia Law

Posted in: Criminal Law
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The Fourth Circuit reversed the district court's denial of habeas relief, holding that a juror's external communication with her pastor regarding the death penalty was not harmless. Given how Federal Rule of Evidence 606 limits the presentation of evidence in these circumstances, the court held that it was especially important for it to view the record practically and holistically when considering the effect that a juror's misconduct reasonably may be taken to have had upon the jury's decision. In this case, the juror shared the pastor's counsel with the other jurors in an apparent effort to convince someone it was okay to vote for the death penalty. The court remanded for further proceedings. View "Barnes v. Thomas" on Justia Law

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The Government appealed the district court's grant of defendant's motion to suppress a revolver found on his person. The district court reasoned that the initial stop and flashlight illumination of the men leaving the site of the shooting violated the Fourth Amendment, which rendered the later pat down illegal. The Fourth Circuit reversed and held that the officers here reacted to a perilous active-shooter situation, arriving on scene within 35 seconds of hearing multiple gunshots in a densely populated area; these exigent circumstances implicated vital governmental interests—citizen and police safety—beyond the ordinary need for law enforcement; and the officers' initial response was tailored to address these needs with minimal intrusion and thus reasonable. The court remanded for the district court to consider whether the officers had reasonable suspicion to search defendant after he disregarded their orders. View "United States v. Curry" on Justia Law

Posted in: Criminal Law
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At issue in this appeal was a tortious interference claim brought by Sprint against Wireless Buybacks, an arbitrager of upgraded phones from customers that then resells them at higher prices. Sprint alleged that its written contract with customers categorically prohibits them from reselling their phones, and Wireless Buybacks has wrongfully induced customers to do so. The district court found that the contract unambiguously barred resale and granted partial summary judgment for Sprint. The Fourth Circuit held that Sprint's terms and conditions did not unambiguously prohibit customers from reselling their phones, and thus Sprint was not entitled to judgment as a matter of law. In this case, the court rejected Sprint's two theories in support of why "Services" unambiguously included all upgraded phones, and Sprint failed to show that Wireless Buybacks bought phones from Sprint customers who agreed to activate their upgraded phones on Sprint's network. Therefore, the court vacated the district court's summary judgment order insofar as it found Wireless Buybacks liable for tortious interference and remanded for further proceedings. View "Sprint Nextel Corp. v. Wireless Buybacks Holdings, LLC" on Justia Law

Posted in: Business Law, Contracts
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Plaintiff, a Virginia inmate, filed a 42 U.S.C. 1983 action against two Virginia Department of Corrections (VDOC) officials, alleging that defendants violated his Eighth Amendment rights by denying him treatment for his Hepatitis C virus (HCV). The Fourth Circuit vacated the district court's grant of summary judgment for defendants, holding that genuine disputes of material fact exist as to plaintiff's deliberate indifference claim against Defendant Schilling, the Health Services Director. In this case, there was sufficient evidence to establish a genuine issue of material fact as to Schilling's personal involvement in the denial of treatment for plaintiff's HCV. The court also held that genuine disputes of material fact exist as to plaintiff's deliberate indifference claim to Defendant Amonette, the Chief Physician, because a factfinder could determine that Amonette knew that HCV is a serious disease that affects a large percentage of those incarcerated in VDOC facilities. Furthermore, plaintiff presented evidence that Amonette knew that a lack of treatment for someone diagnosed with HCV, like plaintiff, creates a substantial risk of harm to that person. The court rejected defendants' alternative argument, which was based on a misreading of the opinion, and remanded for further proceedings. View "Gordon v. Schilling" on Justia Law

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Plaintiffs filed suit seeking to hold the United States liable for negligently performing a background check on Dylann Roof, the person who entered a church in Charleston, South Carolina and opened fire, killing nine worshippers. No one disputes that if the background check had been performed properly, it would have prevented Roof from purchasing the firearm he used. The district court dismissed plaintiffs' claims for lack of subject matter jurisdiction. The Fourth Circuit reversed and held that neither the discretionary function exception of the Federal Tort Claims Act nor the Brady Act's immunity provision in 18 U.S.C. 922(t)(6) affords the Government immunity in this case. In regard to the FTCA, the court held that this case turns on the NICS Examiner's alleged negligence in failing to follow a clear directive and the government could not claim immunity under these circumstances. The court held that the district court did not err by concluding that the government could not be held liable under the FTCA for declining to give Examiners access to the N-DEx, and the court rejected plaintiffs' claim that the government contravened a mandatory directive by failing to maintain data integrity during the NICS background check. In regard to the Brady Act, the court held that the district court erred in construing 18 U.S.C. 992(t)(6) to bar plaintiffs' claims where plaintiffs sued the government rather than any federal employee, and the federal employees whose conduct forms the basis of this suit were not responsible for providing information to the NICS system. View "Sanders v. United States" on Justia Law

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A putative class of former shareholders in Towers, Watson & Co. filed suit alleging that several defendants violated the Securities Exchange Act by omitting material facts in proxy documents, rendering statements in those documents false or misleading. The district court dismissed the complaint. The Fourth Circuit vacated and held that the statute of limitations begins to run for a claim governed by 15 U.S.C. 78i(f) when the plaintiff has discovery notice. Applying this standard, the court held that the putative class filed suit within one year of discovering the facts constituting the violation. Therefore, the district court erred in dismissing plaintiffs' suit as time-barred. The court also held that plaintiffs have sufficiently alleged that the omitted facts were material and the district court erred in dismissing the Section 14(a) claim. Finally, the court held that none of the three alternative grounds presented by defendants supported the district court's dismissal order. View "In re: Willis Towers Watson" on Justia Law

Posted in: Securities Law