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

In 2020 and 2021, Rohan Dhruva and Joshua Stern, residents of California, created accounts and subscribed to CuriosityStream, an online streaming service. They later discovered that CuriosityStream was sharing their event data and other identifiers with Meta, which they claimed violated the federal Video Privacy Protection Act and California state law. Consequently, they filed a putative class action lawsuit in Maryland, where CuriosityStream is headquartered.The United States District Court for the District of Maryland denied CuriosityStream's motion to compel arbitration. The court acknowledged that the website provided adequate notice of the Terms of Use through a conspicuous hyperlink but concluded that users were not given clear notice that clicking the "Sign up now" button constituted agreement to the Terms of Use. CuriosityStream's motion for reconsideration was also denied.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court concluded that Dhruva and Stern had reasonable notice that registering for the streaming service would constitute assent to the website’s Terms of Use, which included an arbitration clause. The court held that the design and content of the website provided sufficient notice of the terms and that Dhruva and Stern manifested their assent by registering with the website. Consequently, the Fourth Circuit reversed the district court's order denying the motion to compel arbitration and remanded the case for further proceedings. View "Dhruva v. CuriosityStream, Inc." on Justia Law

Gerald Wheeler was convicted in 2007 of various drug and firearm offenses and sentenced to 180 months of imprisonment. In 2018, one of his convictions was vacated, and he was resentenced to time served with a four-year term of supervised release starting in March 2019. In January 2023, Wheeler's probation officer filed a petition to modify his supervision conditions due to new charges of felony assault by strangulation and misdemeanor assault on a female. The district court ordered revocation proceedings instead.A United States Magistrate Judge found no probable cause for the felony assault charge but found probable cause for the misdemeanor assault charge. Wheeler remained on bond pending the final revocation hearing. During the hearing, the district court admitted hearsay evidence from the alleged victim, Nyasia Mobley, despite her absence. The court found that the government made sufficient efforts to secure her presence and deemed her statements reliable. The court ultimately found Wheeler violated his supervised release and sentenced him to six months of imprisonment followed by an additional year of supervised release.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the district court abused its discretion by not properly balancing Wheeler's interest in confronting Mobley against the government's reasons for not producing her. The court also found that the government did not provide a satisfactory explanation for Mobley's absence, as the probation officer made only a single attempt to serve her. The Fourth Circuit concluded that the district court's error was not harmless, as the hearsay evidence was essential to the finding of violation. The court vacated the district court's judgment and remanded with instructions to dismiss the Revocation Petition. View "US v. Wheeler" on Justia Law

Tyzeem Kwazhon Nixon pleaded guilty to one count of being a felon in possession of a firearm. While awaiting sentencing, he committed several violent acts, including multiple stabbings. The district court sentenced Nixon to more than double the Sentencing Guidelines range, primarily based on his violent behavior while incarcerated. The court also disregarded a report from a qualified medical expert, which attributed Nixon's violent conduct to his untreated mental health condition and suggested that proper treatment would mitigate his threat to society.The United States District Court for the Eastern District of North Carolina sentenced Nixon to 114 months, significantly above the Guidelines range of 41 to 51 months. The court justified the upward departure by citing Nixon's violent acts while awaiting sentencing and his criminal history. The court rejected the expert's report without counterevidence, stating it did not find the report credible. Nixon appealed the sentence, arguing that the district court's reliance on dissimilar conduct, failure to consider intermediate categories, and rejection of expert testimony rendered the sentence procedurally unreasonable.The United States Court of Appeals for the Fourth Circuit reviewed the case and found the district court's sentence procedurally unreasonable. The appellate court held that the district court improperly relied on dissimilar conduct for the upward departure, failed to consider intermediate criminal history categories, and erroneously rejected the expert testimony without justification. The Fourth Circuit vacated the sentence and remanded the case for resentencing, instructing the district court to recalculate Nixon's criminal history category without improper consideration of dissimilar conduct, to consider intermediate categories, and to properly evaluate the expert testimony. View "US v. Nixon" on Justia Law

The Berkeley County School District filed a lawsuit against several defendants, including HUB International Ltd. and HUB International Midwest Ltd., alleging claims related to insurance policies and services provided. HUB sought to compel arbitration based on brokerage service agreements (BSAs) from 2002, 2003, 2005, 2006, 2009, and 2011. The district court denied the motion, and HUB appealed. The appellate court reversed and remanded for a trial to resolve factual disputes about the agreements. After a bench trial, the district court again denied the motion, finding no meeting of the minds for the 2006, 2009, and 2011 BSAs and precluding consideration of the 2002 and 2003 BSAs. HUB appealed again, and the appellate court vacated the judgment regarding the 2002 and 2003 BSAs.On remand, the district court found the 2002 and 2003 BSAs valid and enforceable but denied HUB's motion to compel arbitration, deciding that the dispute did not fall within the scope of those agreements. HUB appealed this decision.The United States Court of Appeals for the Fourth Circuit reviewed the case and determined that the district court erred by deciding the arbitrability of the dispute itself. The appellate court held that the arbitration provisions in the 2002 and 2003 BSAs, which incorporate the American Arbitration Association (AAA) commercial rules, clearly delegate arbitrability questions to the arbitrator. Therefore, the district court should have compelled arbitration to resolve whether the claims fall within the scope of the arbitration agreements.The Fourth Circuit reversed the district court's judgment and remanded the case with instructions to compel arbitration of the threshold arbitrability question in accordance with the parties' agreement. View "Berkeley County School District v. HUB International Limited" on Justia Law

Maryland and South Carolina filed lawsuits in state courts against 3M Company and other chemical manufacturers, alleging contamination of their waterways with per- and polyfluoroalkyl substances (PFAS). The states filed separate complaints for PFAS contamination from aqueous film-forming foam (AFFF) and non-AFFF products, explicitly disclaiming any connection between the two in their non-AFFF complaints.In the District of Maryland, 3M removed Maryland's non-AFFF complaint to federal court under the federal officer removal statute, arguing that PFAS from its Military AFFF production was indistinguishably commingled with PFAS from its non-AFFF products. The district court remanded the case, giving dispositive effect to Maryland's disclaimer and concluding that 3M's federal work was not implicated. Similarly, in the District of South Carolina, 3M removed South Carolina's non-AFFF complaint, but the district court also remanded, crediting the state's disclaimer and finding no connection to 3M's federal work.The United States Court of Appeals for the Fourth Circuit reviewed the consolidated appeals. The court held that the states' disclaimers were not dispositive in determining the connection between 3M's federal work and the charged conduct. The court concluded that 3M plausibly alleged that PFAS contamination from its Military AFFF production was related to the states' claims, satisfying the nexus requirement for federal officer removal. The court vacated the district courts' decisions and remanded for further consideration of whether 3M met the other elements for federal officer removal, including acting under a federal officer and having a colorable federal defense. View "State of Maryland v. 3M Company" on Justia Law

Christine Sugar filed for Chapter 13 bankruptcy in the Eastern District of North Carolina in September 2019. Her confirmed bankruptcy plan required her to make monthly payments and prohibited the sale of non-exempt property valued over $10,000 without court approval. Despite this, Sugar sold her residence without obtaining prior court authorization, believing it was fully exempt based on her attorney's advice. The sale resulted in proceeds of approximately $94,000.The bankruptcy court found that Sugar's sale of her residence violated the confirmed plan and the local bankruptcy rule. The court dismissed her Chapter 13 case and barred her from filing another bankruptcy application for five years. Additionally, the court imposed monetary sanctions on her attorney, Travis P. Sasser, for advising her incorrectly and for his conduct during the proceedings.The United States District Court for the Eastern District of North Carolina affirmed the bankruptcy court's findings and sanctions. Sugar and Sasser appealed the decision, arguing that the local rule was invalid, the property was exempt, and that paying off the plan balance entitled Sugar to immediate discharge.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the bankruptcy court's determination that Sugar violated the local rule by selling her residence without prior court approval. However, it vacated the judgment dismissing Sugar's Chapter 13 case and the five-year filing bar, remanding the case for the bankruptcy court to consider the effect of Sugar's reliance on her attorney's advice. The court affirmed the monetary sanctions against Sasser, finding that his advice and conduct warranted the penalties imposed. View "Sugar v. Burnett" on Justia Law

A father, Scott Williams, and his son, Taeyan Williams, were convicted by a federal jury of various drug-related offenses, including conspiracy to distribute and possess with intent to distribute marijuana and cocaine. The case stemmed from an investigation into the disappearance of a drug dealer, Noah Smothers, who supplied drugs to Scott and Taeyan. A search of Scott's home revealed large quantities of drugs, firearms, and cash. Both Scott and Taeyan were found guilty of conspiracy and possession with intent to distribute, while Scott was also convicted of additional charges related to methamphetamine and evidence destruction.The United States District Court for the District of Maryland denied Scott's motion to suppress evidence obtained from the search, despite his claim that law enforcement failed to knock and announce before entering. The court held that suppression was not the appropriate remedy. Scott and Taeyan were sentenced to 276 months and 150 months in prison, respectively, followed by five years of supervised release. Both appealed their convictions and sentences.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed Taeyan's conviction, finding sufficient evidence to support his possession with intent to distribute charges, based on his connection to the drugs found in Scott's home. The court also upheld the district court's denial of Scott's motion to suppress, citing exigent circumstances that justified the no-knock entry. Additionally, the court rejected Scott's request for a sentence reduction under the newly promulgated U.S.S.G. § 4C1.1, advising him to seek relief through a motion under 18 U.S.C. § 3582. Finally, the court found no improper delegation of judicial authority in the conditions of Scott's supervised release, affirming the district court's judgments in their entirety. View "United States v. Williams" on Justia Law

Police officers responded to a noise complaint at a house party in Sanford, North Carolina, on September 12, 2021. They heard gunshots and saw the defendant, Chad Marques Jennings, run to a van and speed away. After a chase, officers detained Jennings, who admitted to having a gun in his waistband. Bullet casings found at the scene matched Jennings' gun. Jennings, a convicted felon, was charged with being a felon in possession of a firearm and pled guilty.The United States District Court for the Middle District of North Carolina held a sentencing hearing where Jennings' attorney spoke, and Jennings was invited to address the court. Jennings spoke about his struggles with alcoholism, read a poem, and a prepared speech. The court interrupted Jennings twice with questions and later prevented him from reading a letter to his mother, focusing instead on questioning him about his criminal history. The court sentenced Jennings to the statutory maximum of 120 months, citing the seriousness of the offense and his criminal history. Jennings appealed, arguing that the court denied him the full exercise of his allocution right.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the district court did not err in its handling of Jennings' allocution. The court found that the district court's interruptions were permissible clarifying questions and that the exclusion of the letter to Jennings' mother was within the court's discretion to limit irrelevant or repetitive information. The court concluded that Jennings was given a reasonable opportunity for allocution and affirmed the district court's judgment and sentence. View "United States v. Jennings" on Justia Law

Several property management companies advertised their apartment buildings on Facebook, targeting users who are 50 years old or younger. Neuhtah Opiotennione, who is older than 50, did not see these advertisements and claimed that the companies discriminated against her based on her age. She filed a lawsuit seeking a declaratory judgment, a permanent injunction, and damages.The United States District Court for the District of Maryland dismissed Opiotennione’s complaint, ruling that she lacked standing to sue because she had not suffered a concrete and particularized injury in fact. The court found that Opiotennione had not demonstrated how the alleged discrimination personally affected her.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo and affirmed the district court’s decision. The Fourth Circuit held that Opiotennione failed to allege a concrete and particularized injury in fact. The court noted that merely being a member of the disfavored age group did not constitute a particularized injury. Additionally, the court found that Opiotennione did not allege that she was personally denied information or housing opportunities by the defendants, as she had not actively sought information from them. The court also rejected her claims of informational and stigmatic injuries, concluding that she had not demonstrated a personal denial of information or a concrete stigmatic injury. Thus, the Fourth Circuit affirmed the district court’s dismissal of the case for lack of standing. View "Opiotennione v. Bozzuto Management Co." on Justia Law

Jason Wayne Gowen, a pretrial detainee at the Lynchburg Adult Detention Center, was placed in solitary confinement for 125 days after complaining about hot conditions in his cell and encouraging other inmates to do the same. Gowen filed a lawsuit against several correctional officers, alleging violations of his First Amendment rights due to retaliation for his grievances and his Fourteenth Amendment rights for being placed in solitary confinement without due process.The United States District Court for the Western District of Virginia dismissed Gowen’s First Amendment retaliation claim, stating that he failed to show a causal connection between his grievances and the adverse actions taken against him. The court later granted summary judgment to the officers on Gowen’s Fourteenth Amendment due process claim, concluding that he failed to exhaust his administrative remedies as required by the Prison Litigation Reform Act.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that Gowen adequately alleged a First Amendment retaliation claim by showing that he engaged in protected activity, faced adverse action, and established a causal connection through temporal proximity and the officers' awareness of his grievances. The court also determined that Gowen did not forfeit his argument regarding the exhaustion of administrative remedies, as his verified complaint contained sufficient evidence of his attempts to use the grievance process and the officers' failure to respond.The Fourth Circuit reversed the district court’s dismissal of Gowen’s First Amendment retaliation claim and vacated the summary judgment on his Fourteenth Amendment due process claim. The case was remanded for further proceedings consistent with the appellate court’s findings. View "Gowen v. Winfield" on Justia Law