Justia U.S. 4th Circuit Court of Appeals Opinion Summaries
United States v. Rumley
The Fourth Circuit affirmed defendant's sentence as an armed career criminal subject to a mandatory minimum sentence of 15 years in prison. On appeal, defendant argued that reliance in his 2019 sentencing on a prior conviction that had not been designated as an Armed Career Criminal Act (ACCA) predicate in his 2008 presentence report violated United States v. Hodge, 902 F.3d 420 (4th Cir. 2018). The court held that Hodge was not controlling in this case, because Hodge is grounded on the defendant's lack of notice and opportunity to contest an ACCA predicate identified for the first time during a collateral proceeding. In this case, defendant had both notice and a meaningful opportunity to challenge the designated predicate convictions prior to the resentencing hearing. The court also held that the district court did not clearly err in finding that, taken together, the documents demonstrated that defendant was in fact convicted of unlawful wounding in 1979. Furthermore, a conviction of Virginia Code 18.2-51 is a violent felony for the purpose of applying ACCA's sentencing enhancement, as it involves the use of physical force required by 18 U.S.C. 924(e)(2)(B)(i). View "United States v. Rumley" on Justia Law
Williams v. Dimensions Health Corp.
Plaintiff filed suit against the hospital, alleging that it violated the Emergency Medical Treatment and Active Labor Act (EMTALA) by failing to properly screen him and stabilize his condition. The Fourth Circuit adopted the requirement of a good faith admission and held that a party claiming an admission was not in good faith must present evidence that the hospital admitted the patient solely to satisfy its EMTALA standards with no intent to treat the patient once admitted and then immediately transferred the patient. The court held that plaintiff failed to point to evidence that creates a genuine issue of material fact as to this high standard. Furthermore, plaintiff failed to point to any evidence in support of his theory that the hospital admitted plaintiff to improperly hoard him in order to garner his premium insurance benefits. View "Williams v. Dimensions Health Corp." on Justia Law
Baehr v. The Creig Northrop Team, P.C.
Plaintiffs, as representatives of a putative class of plaintiffs, specified in their operative single-count complaint that the kickback scheme, in which the Lakeview Defendants paid the Northrop Defendants for marketing services that were actually illegal business referrals, deprived them and the other class members of impartial and fair competition between settlement services providers, in violation of the Real Estate Settlement Procedures Act (RESPA). The Fourth Circuit held that plaintiffs lack Article III standing to sue, because plaintiffs did not suffer any real-world harm, much less a concrete injury, from the deprivation of impartial and fair competition between settlement providers. The court also rejected plaintiffs three novel theories of standing. Therefore, the court vacated the summary judgment award and remanded for dismissal. View "Baehr v. The Creig Northrop Team, P.C." on Justia Law
Posted in: Real Estate & Property Law
SAS Institute, Inc. v. World Programming Ltd.
This case stemmed from litigation between SAS and WPL, software developers that compete in the market for statistical analysis software. The Fourth Circuit affirmed the district court's grant of an expansion injunction and an anti-clawback injunction issued pursuant to its All Writs Act authority. Although the court respected the judicial system and judges of the United Kingdom, the court explained that the district court here needed to ensure that a money judgment reached in an American court under American law—based on damages incurred in America—was not rendered meaningless. In this case, the district court chose to enforce its judgment in the most measured terms, concentrating on the litigants' U.S. conduct and collection efforts. The court wrote that failing to take even these modest steps would have encouraged any foreign company and country to undermine the finality of a U.S. judgment. View "SAS Institute, Inc. v. World Programming Ltd." on Justia Law
United States v. Moreno Pena
Defendant appealed his 24-month sentence for illegally reentering the United States subsequent to conviction for an aggravated felony, in violation of 8 U.S.C. 1326(a) and (b)(2). The Fourth Circuit affirmed the district court's finding that defendant's prior conviction for Texas burglary is a burglary offense under 8 U.S.C. 1101(a)(43)(G), and was therefore an aggravated felony under the Immigration and Nationality Act. However, the court held that the district court committed a procedural error in applying the 2016 Guidelines Manual at sentencing and the error was not harmless. Accordingly, the court affirmed in part, vacated and remanded for resentencing. View "United States v. Moreno Pena" on Justia Law
United States v. Jackson
After the district court reduced defendant's sentence under the First Step Act, the district court denied defendant's request for a sentence of 120 months' imprisonment, which would have allowed defendant to bank approximately 57 months toward a future sentence of incarceration if he violated his supervised release. The Fourth Circuit affirmed and held that the district court did not abuse its discretion in reducing defendant's sentence to time served and ordering his immediate release, but denying his request to bank time for credit against future supervised release violations. In this case, the district court considered defendant's ability to bank time against future supervised release revocations in its analysis of the need to protect the public and the need for deterrence, two factors a court considers under 18 U.S.C. 3553(a) in imposing a sentence. View "United States v. Jackson" on Justia Law
Biggs v. North Carolina Department of Public Safety
Plaintiff filed suit against defendants under 42 U.S.C. 1983, alleging claims related to the demotion he suffered in 2012. Plaintiff alleged that defendants racially discriminated against him and seeks reinstatement of his prior position, the removal of negative materials from his personnel file, and reimbursement for his legal expenses. The district court granted summary judgment for defendants. The Fourth Circuit denied defendants' motion to dismiss plaintiff's appeal as moot based on plaintiff's retirement, because plaintiff has sworn that he would promptly return to work if reinstated to his prior position. The court affirmed the district court's grant of summary judgment to the Department, because its removal of this case did not constitute a waiver of sovereign immunity. Finally, the court vacated the district court's award of summary judgment to Defendant Hooks and remanded for further proceedings. In this case, plaintiff is seeking prospective, not retrospective, relief and thus his claim against Hooks falls under the sovereign-immunity exception articulated in Ex Parte Young, 209 U.S. 123 (1908). View "Biggs v. North Carolina Department of Public Safety" on Justia Law
Cantu-Guerrero v. Lumber Liquidators, Inc.
Objectors filed consolidated appeals from the district court's order approving a class action settlement and order awarding attorney's fees to class counsel. The settlement approval order arose from two MDL proceedings related to Lumber Liquidator's sale of allegedly dangerous and defective laminate flooring. The Fourth Circuit affirmed the settlement approval order, holding that the district court did not abuse its discretion in approving the settlement. In this case, the district court did not abuse its discretion in determining that the settlement was fair and adequate and, at bottom, the order thoughtfully assessed what the class members would give up in the proposed settlement and then explained why the tradeoff embodied in the settlement was fair, reasonable, and adequate. However, the court vacated the attorney's fee order, because the district court erred by failing to apply to the store vouchers the "coupon" settlement provisions of the Class Action Fairness Act of 2005. Accordingly, the court remanded with instructions. View "Cantu-Guerrero v. Lumber Liquidators, Inc." on Justia Law
Posted in: Class Action
Mayor and City Council of Baltimore v. BP P.L.C.
The Fourth Circuit affirmed the district court's remand order and held that the federal officer removal statute, 28 U.S.C. 1442, does not provide a proper basis for removal in a climate-change lawsuit against oil and gas companies. The court first held that Noel v. McCain, 538 F.2d 633 (4th Cir. 1976), remains binding precedent in this circuit and dismissed this appeal for lack of jurisdiction, insofar as it seeks to challenge the district court's determination with respect to the propriety of removal based on federal-question, Outer Continental Shelf Lands Act, admiralty, and bankruptcy jurisdiction. Although the court had jurisdiction to review the federal officer removal statute claim, the court agreed with Baltimore that none of the three contractual relationships defendants pointed to were sufficient to justify removal under the federal officer removal statute in this case, either because they failed to satisfy the acting-under prong or because they were insufficiently related to Baltimore's claims for purposes of the nexus prong. View "Mayor and City Council of Baltimore v. BP P.L.C." on Justia Law
Campbell v. McCarthy
Plaintiff, a civilian employee of the Army Corps of Engineers, filed suit challenging the Army's decision to suspend him from his employment pending review of his security clearance. The district court awarded summary judgment to the Army on claims under Title VII of the Civil Rights Act and Age Discrimination in Employment Act. The Fourth Circuit vacated the district court's judgment and dismissed the action in light of the Supreme Court's decision in Department of the Navy v. Egan, 484 U.S. 518 (1988). The court held that review of any of plaintiff's claims requires review of the suspension of his security clearance — a review that necessarily goes to the very heart of the protection of classified information — and thus Egan deprived the district court of subject matter jurisdiction to review each of the claims. Therefore, the district court erred by failing to dismiss these claims outright for lack of subject matter jurisdiction. View "Campbell v. McCarthy" on Justia Law