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

A group of registered voters in South Carolina, all under the age of sixty-five, challenged a provision of state law that restricts “no excuse” absentee-by-mail voting to voters sixty-five years of age or older. These plaintiffs argued that the statute unconstitutionally discriminates against them on account of age, in violation of the Twenty-Sixth Amendment, and also violates the Equal Protection Clause of the Fourteenth Amendment. The law at issue allows voters sixty-five and older to vote absentee by mail for any reason, while voters under sixty-five can only do so if they meet specific, narrow criteria such as disability, military service, or certain employment conflicts.The case was initially heard in the United States District Court for the District of South Carolina, where the court granted summary judgment in favor of the defendants—the South Carolina State Election Commission and related officials—on both constitutional claims. The district court found that the plaintiffs did not demonstrate a violation of either the Twenty-Sixth Amendment or the Equal Protection Clause. The plaintiffs appealed this decision.The United States Court of Appeals for the Fourth Circuit reviewed the appeal. This court held that the plaintiffs have standing and that South Carolina’s age-based absentee-by-mail voting scheme violates the Twenty-Sixth Amendment because it abridges the right to vote on account of age by providing greater ballot access to older voters. However, the court affirmed the district court’s decision to dismiss the Equal Protection claim, as age is not a suspect classification under the Equal Protection Clause and the plaintiffs did not challenge the law under rational basis or Anderson-Burdick scrutiny. The Fourth Circuit reversed the district court’s judgment on the Twenty-Sixth Amendment claim, affirmed the Equal Protection ruling, and remanded the case for appropriate remedy. View "Grant v. Belangia" on Justia Law

The case concerns a challenge brought by several houses of worship from Quaker, Sikh, and Cooperative Baptist Fellowship religious traditions to a new policy adopted by the Department of Homeland Security (DHS) in January 2025. This policy rescinded longstanding guidelines that limited immigration enforcement actions at or near houses of worship, replacing them with a directive that left the decision to conduct enforcement actions largely to the discretion of immigration officers without specific guidelines or required supervisory approval. The plaintiffs alleged that the new policy has already caused, and will continue to cause, a decline in attendance at their worship services and ministries, thereby impeding their ability to exercise their religion communally and to minister to immigrant communities.Previously, the United States District Court for the District of Maryland granted the plaintiffs’ motion for a preliminary injunction, ordering DHS to follow its prior 2021 guidelines that limited immigration enforcement at or near the plaintiffs’ houses of worship. The district court found that the plaintiffs had standing and were likely to succeed on the merits of their claims under the Religious Freedom Restoration Act (RFRA), and that they would suffer irreparable harm without interim relief.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s decision. The Fourth Circuit held that the plaintiffs had met the requirements for standing, including injury-in-fact, traceability, and redressability, based on evidence of actual and likely future declines in attendance linked to the new policy. The court further concluded that the district court did not abuse its discretion in finding that the plaintiffs were likely to succeed on the merits of their RFRA claim, as the new policy substantially burdened their religious exercise. The government’s arguments under strict scrutiny were found to be waived, as they were not properly raised below. The Fourth Circuit affirmed the district court’s preliminary injunction. View "Yearly Meeting of the Religious Society of Friends v. Department of Homeland Security" on Justia Law

The case involves several married couples, each consisting of a U.S. citizen and a noncitizen spouse who is subject to a final order of removal. The noncitizen spouses are seeking lawful permanent residency through a process that requires them to first file a family-based petition, then seek special permission to reapply for admission, and finally apply for a provisional unlawful presence waiver. The waiver, if granted, would allow the noncitizen to leave the country to complete consular processing without triggering a lengthy inadmissibility bar. Several noncitizen plaintiffs were arrested by ICE at their immigration interviews, causing others to avoid or delay their own interviews out of fear of arrest and removal.The United States District Court for the District of Maryland certified a class of similarly situated couples and granted summary judgment in favor of the plaintiffs. The district court held that the government lacked authority to arrest or remove noncitizens during the provisional waiver process, finding this violated the relevant regulations, the Administrative Procedure Act, and the Due Process Clause. The court issued class-wide declaratory and injunctive relief, barring the government from interfering with plaintiffs’ participation in the waiver process through arrest or removal.Upon review, the United States Court of Appeals for the Fourth Circuit vacated the district court’s judgment and remanded for further proceedings. The Fourth Circuit held that the relevant regulations do not bar the government from arresting or removing noncitizens during the provisional waiver process and that the plaintiffs do not have a protected interest in accessing the process without risk of removal. The court also found the factual record insufficient to support the alternative theory that the government uses the waiver process to target noncitizens for removal. Thus, the award of summary judgment to the plaintiffs was vacated. View "Sanchez v. Mullin" on Justia Law

A man who had been found not guilty by reason of insanity for sending threats to his former lawyer was committed to a federal medical facility for treatment of his mental illness. After several years, the director of the facility determined that he could be conditionally released under a prescribed regimen of psychiatric care, provided he complied with certain conditions, including a prohibition on possessing weapons. The district court ordered his conditional discharge subject to these terms. Some years later, the man traveled out of state and committed an armed robbery, violating the condition that barred him from possessing weapons.Following the robbery, the U.S. Probation Office sought to revoke his conditional discharge, citing three grounds: committing new criminal conduct, possessing a weapon, and leaving the state without permission. Of these, only the prohibition on weapon possession was actually a condition of his discharge order. The United States District Court for the District of South Carolina agreed with the government’s argument that it could revoke conditional discharge for this violation and subsequently revoked his conditional discharge.On appeal, the United States Court of Appeals for the Fourth Circuit considered whether revocation under 18 U.S.C. § 4243(g) can be based only on violations of the prescribed regimen of medical, psychiatric, or psychological care or treatment, or whether it may also be based on violations of ancillary conditions. The Fourth Circuit held that § 4243(g) permits revocation only for failing to comply with the prescribed regimen. However, the court determined that the no-weapons condition was part of the prescribed regimen, not an ancillary condition, because it was included in the regimen developed and certified by the facility director and approved by the court as necessary for treatment and public safety. Accordingly, the court affirmed the revocation of conditional discharge. View "US v. Roney" on Justia Law

A postal service employee in Fayetteville, North Carolina, was stopped by police for a traffic violation. During the stop, officers discovered drug paraphernalia and, upon searching the vehicle, found 48 United States Treasury checks not made out to him, with 47 checks in the trunk and one, which had been altered, in his backpack. The backpack also contained marijuana, a large amount of cash, and a loaded firearm. A subsequent traffic stop and a search of his home uncovered further evidence of altered and stolen checks. In total, he was linked to 51 stolen checks, with a significant intended loss, and was later indicted on charges of theft of mail matter by a postal service employee and possession of stolen mail. He pleaded guilty to both charges.The United States District Court for the Eastern District of North Carolina, relying on the Presentence Report, calculated his Sentencing Guidelines range and applied a two-level firearm enhancement under USSG § 2B1.1(b)(16)(B), finding that his offense involved possession of a firearm in connection with the offense. The court sentenced him to 48 months’ imprisonment, above the bottom of the applicable range. The defendant did not object to the firearm enhancement at sentencing.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed only the procedural reasonableness of the sentence. The Fourth Circuit held that the district court erred by applying the firearm enhancement without making required factual findings linking the firearm to the theft or possession offenses. The appellate court found that this error was plain, affected the defendant’s substantial rights, and seriously affected the fairness of the proceedings because it could not determine if the district court would have imposed the same sentence absent the error. The Fourth Circuit vacated the sentence and remanded for resentencing with instructions for the district court to make specific factual findings regarding the firearm enhancement. View "US v. Franklin" on Justia Law

Law enforcement officers sought and obtained a no-knock search warrant for a residence in an area known as Kent Bottom, Maryland, based on an affidavit describing the area's reputation for drug activity, criminal histories of individuals associated with the area, and surveillance of suspected drug transactions near the property. The affidavit included descriptions of drug-related incidents from as far back as 2006 involving the residence, as well as more recent but less direct observations of possible drug activity in the general vicinity of the house. The more recent surveillance involved suspected hand-to-hand transactions outside the residence and people entering and leaving the property, but did not directly connect current criminal activity to the interior of the home.After the search, officers recovered drugs and a firearm from a vehicle parked outside the residence. The defendant, who was found inside the house, was charged with several drug and firearm offenses. He moved to suppress the evidence, arguing that the warrant lacked probable cause because the affidavit failed to establish a meaningful connection between the alleged criminal activity and the specific residence. The United States District Court for the District of Maryland denied the motion, reasoning that the history and geography of drug activity in Kent Bottom, along with the observed conduct near the residence, provided a sufficient basis for probable cause.The United States Court of Appeals for the Fourth Circuit reversed. It held that the warrant affidavit did not provide a substantial basis for probable cause to search the residence because the facts were either too old, not specifically tied to the home, or both, and therefore failed to establish a fair probability that evidence of a crime would be found inside the house at the time of the search. The court also determined that the good-faith exception did not apply, as the affidavit was so lacking in indicia of probable cause that no reasonable officer could rely on it. The court reversed the district court’s denial of the motion to suppress, vacated the conviction, and remanded for further proceedings. View "US v. Griffin" on Justia Law

A biopharmaceutical company that develops and sells prescription medications—including a well-known HIV drug—discovered that U.S. patients were receiving versions of its medication intended only for foreign markets, specifically Turkey. This occurred after a Maryland patient received a Turkish-labeled version of the drug. The medication, while chemically identical to the U.S.-approved version, had packaging, labeling, and patient information in Turkish, omitting U.S. regulatory warnings and instructions. The biopharmaceutical company traced the importation to a group of entities and individuals who facilitated the import and sale of these foreign-market drugs to U.S. consumers, working in cooperation with third-party administrators and pharmacy benefit managers serving self-funded employer health plans.The company filed suit in the United States District Court for the District of Maryland against the entities and individuals involved in the importation, alleging direct and contributory trademark infringement under the Lanham Act. The district court granted a preliminary injunction, enjoining the defendants from importing, advertising, or facilitating the importation and sale of the company’s branded medications intended for foreign markets. The court found the imported drugs were materially different from the U.S. versions due to differences in labeling, warnings, and quality control procedures, and that the defendants had knowledge of these differences.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The Fourth Circuit held that the imported medications were not “genuine” under the Lanham Act because they materially differed from the U.S. versions and bypassed the company’s quality-control systems. The court found the company likely to succeed on its direct and contributory infringement claims, concluded that irreparable harm was presumed and not rebutted, and determined that the balance of equities and public interest supported the injunction. The district court’s preliminary injunction order was affirmed. View "Gilead Sciences, Inc. v. Meritain Health, Inc." on Justia Law

A defendant was convicted for his role in the kidnapping and killing of an individual, resulting in a mandatory life sentence on the kidnapping charge, in addition to other related convictions. The defendant, along with his co-defendants, faced overwhelming evidence of guilt. Although the government did not seek the death penalty against this defendant, it required any plea agreement to include a truthful proffer and cooperation, specifically testifying against his co-conspirators.After his convictions were affirmed on direct appeal, the defendant filed a motion under 28 U.S.C. § 2255 in the United States District Court for the District of Maryland, arguing that his trial counsel rendered ineffective assistance by failing to pursue a plea agreement that could have resulted in a lesser sentence. The district court sought additional briefing and held a non-evidentiary hearing, but ultimately denied the motion without an evidentiary hearing. The court found that the record conclusively showed the defendant was not entitled to relief, as there was no evidence he would have agreed to the government’s required terms for a plea.On appeal, the United States Court of Appeals for the Fourth Circuit considered whether the district court abused its discretion in denying the § 2255 motion without an evidentiary hearing on the ineffective assistance claim. The Fourth Circuit held that the record, even when viewed in the light most favorable to the defendant, conclusively established he could not prevail. The defendant failed to identify any specific act or omission by counsel constituting deficient performance and did not demonstrate a reasonable probability that he would have accepted a plea requiring cooperation. As a result, the Fourth Circuit affirmed the district court’s denial of the motion without an evidentiary hearing. View "US v. Flood" on Justia Law

An African American employee worked as a driver for a metal recycling company in South Carolina for several months in 2017. During his employment, he experienced repeated racial harassment from white coworkers and supervisors, including the frequent use of racial slurs, exposure to racist cartoons, and derogatory comments both in person and on social media. The employee also believed he was denied training and promotional opportunities due to his race. He refrained from making complaints initially out of fear of retaliation, as a manager had previously warned him against associating with African American coworkers who had complained about discrimination. On June 13, 2017, after a racially offensive incident involving his manager, the employee complained directly to the manager about racial harassment and discrimination. He was immediately suspended and, after providing a written statement, was terminated a week later.After his termination, the employee filed suit in the United States District Court for the District of South Carolina, alleging a racially hostile work environment, race discrimination in training and promotion, and retaliatory discharge under 42 U.S.C. § 1981. The district court, adopting the magistrate judge’s recommendation in part, held that the hostile work environment and race discrimination claims were time-barred. The court also granted summary judgment to the employer on the retaliatory discharge claim, concluding that the employee’s termination was due to “belligerent and insubordinate conduct” rather than retaliation and that no reasonable jury could find otherwise.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s summary judgment ruling de novo. The Fourth Circuit held that genuine disputes of material fact existed as to whether the employer’s stated reason for termination was pretext for retaliation and whether retaliation was a but-for cause of the discharge. The appellate court therefore vacated the summary judgment on the retaliatory discharge claim and remanded the case for further proceedings. View "Stewart v. GES Recycling South Carolina LLC" on Justia Law

A licensed physician assistant accepted a remote, part-time position with a telehealth company. His role was to review files sent by the company and sign orders for genetic tests for Medicare beneficiaries. Over approximately ten months, he signed orders for more than 600 beneficiaries, despite having spoken with only about 20 of them. For each file, regardless of test approval, he was compensated. These signed orders led laboratories to bill Medicare for over 14,600 tests, totaling more than $10 million. The physician assistant did not personally bill Medicare and resigned after raising concerns about the company’s practices.A grand jury indicted him on healthcare fraud and making false statements related to healthcare matters. In the United States District Court for the Western District of North Carolina, a jury convicted him on all counts. The court sentenced him to 72 months in prison. On appeal, the defendant argued that the district court erred by excluding documents about the company’s internal compliance, quashing subpoenas for witnesses who invoked the Fifth Amendment, allowing a prosecutorial rebuttal he claimed was improper, giving flawed jury instructions, and miscalculating the sentencing guidelines.The United States Court of Appeals for the Fourth Circuit reviewed and rejected all of the defendant’s challenges. The court held that the exclusion of compliance documents was not an abuse of discretion under Rule 403, that the district court properly quashed subpoenas after a sufficient inquiry into the witnesses’ privilege against self-incrimination, and that any arguably improper prosecution remarks did not deprive the defendant of a fair trial. Additionally, the court found no reversible error in the jury instructions, determined that the evidence sufficiently supported the convictions, and affirmed the sentencing methodology. The appellate court affirmed the judgment of the district court. View "US v. Joyner" on Justia Law