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

The case involves Jamie Christopher Henderson, who was convicted and sentenced following a jury trial for conspiracy to distribute cocaine and cocaine base, possession with intent to distribute cocaine base, and possession of firearms in furtherance of his drug trafficking crimes. Henderson appealed his convictions and sentence, arguing that the evidence was insufficient to support these convictions, and that his sentence is procedurally and substantively unreasonable.The case originated from an incident on April 30, 2019, when law enforcement officers executed a search warrant at Henderson’s residence. They witnessed Henderson toss items underneath a vehicle, including a gun. The officers recovered a loaded handgun, a plastic bag with cocaine and crack cocaine, a cigarette lighter, and a glass crack pipe from underneath the vehicle. Henderson was arrested. Inside the trailer, police found a loaded rifle, a loaded handgun, cocaine powder and crack cocaine in a toilet tank, and a second loaded handgun in a kitchen trash can. They also seized three digital scales and a digital video recorder containing footage from security cameras showing Henderson and other men, armed with multiple handguns and a rifle, standing in the front yard of the residence as cars and people would approach it.Henderson was charged with conspiracy to distribute cocaine and cocaine base, possession of a firearm in furtherance of the drug-distribution conspiracy, possession with intent to distribute cocaine and cocaine base, possession of a firearm in furtherance of the possession-with-intent offense, and possession of a firearm as a felon. He pleaded not guilty. At trial, the Government presented the testimony of the law enforcement officers, Henderson’s videotaped confession, the security footage from the trailer, and a letter Henderson had written to his brother. Henderson presented the testimony of his mother and daughter who claimed that Henderson was a drug user, thief, and liar—but not a drug dealer. The jury convicted Henderson on all counts.The United States Court of Appeals for the Fourth Circuit affirmed the convictions and sentence. The court found that there was substantial evidence to support the conviction and that the sentence was not procedurally or substantively unreasonable. The court noted that Henderson faced a heavy burden in challenging the sufficiency of the evidence and that the court's role was limited to considering whether there was substantial evidence to support the conviction. The court found that there was abundant independent evidence that Henderson was engaged in a large-scale drug trade, which supported the trustworthiness of his confessions. The court also found that the district court did not err in calculating the quantity of drugs attributable to Henderson for sentencing purposes. The court concluded that Henderson's sentence was substantively reasonable and that he failed to overcome the presumption of reasonableness that applies to a below-Guidelines sentence. View "United States v. Henderson" on Justia Law

In 2019, a 13,000-volt electric cable owned by Baltimore Gas & Electric Co. (BG&E) was damaged at the bottom of Eli Cove in Pasadena, Maryland. BG&E alleged that the cable was struck by a barge owned by Coastline Commercial Contracting while performing work for a couple who owned property on the cove. BG&E sued Coastline and the property owners for negligence, invoking federal admiralty jurisdiction over the claim against Coastline and supplemental jurisdiction over the claim against the property owners. The central issue was whether a U.S. court has admiralty jurisdiction to determine the existence and extent of Coastline’s tort liability.The United States District Court for the District of Maryland dismissed the case, ruling that it did not have admiralty jurisdiction. The court found that Eli Cove was not part of the navigable waters because it could not accommodate commercial navigation and was not susceptible of being used as a highway for commerce. The court also found that the incident did not bear a significant relationship to traditional maritime activity because Coastline’s barge was present on Eli Cove solely to extend an existing pier at a private residence.The United States Court of Appeals for the Fourth Circuit reversed the district court's decision. The appellate court held that the case falls within federal admiralty jurisdiction. The court found that the district court applied the incorrect standard when determining whether Eli Cove was navigable and whether the incident bore a significant relationship to traditional maritime activity. The court held that the incident had a potentially disruptive impact on maritime commerce and that the activity giving rise to the incident bore a substantial relationship to traditional maritime activity. The case was remanded for further proceedings. View "Baltimore Gas and Electric Company v. Coastline Commercial Contracting, Inc." on Justia Law

The case involves Zackary Sanders, who was convicted for violating federal child pornography laws. Sanders had engaged in communications with underage boys, some as young as 13 years old, through various social media and communication applications. He had the minors send him explicit videos and pictures of themselves, some of which he later used as blackmail. Sanders stored these videos and photos, as well as other depictions of child pornography downloaded from the Internet, on the same electronic devices that he used to communicate with the minors. Sanders was indicted in 12 counts for the production, receipt, and possession of child pornography.The district court ordered the forfeiture of nine electronic devices on which Sanders stored child pornography and with which he committed the crimes. Sanders objected to the forfeiture, contending that the forfeiture statute did not reach so broadly as to require the forfeiture of non-contraband items that were also stored on the electronic devices. He requested that the district court order the government to allow his forensic expert to segregate and make digital copies of non-contraband items. The district court refused his request.On appeal, Sanders challenged the district court’s reading of the forfeiture statute. He also claimed, for the first time on appeal, that the forfeiture order’s inclusion of his non-contraband items was “plainly excessive under the Eighth Amendment.” The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court held that the forfeiture statute required the forfeiture of electronic devices that contain visual depictions of child pornography. The court also concluded that the forfeiture of the nine electronic devices, with the data contained on them at the time of forfeiture, was not grossly disproportional to the gravity of the offenses for which Sanders was convicted. View "U.S. v. Sanders" on Justia Law

The case revolves around the tragic death of sixteen-year-old Peyton Alexander Ham. His mother, Kristee Ann Boyle, acting as the representative of his estate, filed a lawsuit against State Trooper Joseph Charles Azzari Jr. for excessive force under 42 U.S.C. § 1983, and for assault, battery, and intentional infliction of emotional distress under Maryland state law. The incident occurred when Azzari responded to a dispatch reporting a suspicious man with a gun. Upon arrival, Azzari encountered Ham, who he believed was holding a gun. Azzari fired at Ham, who was actually holding a replica of a Sig Sauer. Azzari then noticed Ham had a knife and fired additional shots, resulting in Ham's death.The district court denied Boyle's request for additional time for discovery and granted Azzari's pre-discovery motion for summary judgment. The court determined that the evidence Boyle sought could not create a triable issue of fact regarding her claims and held that Azzari was entitled to summary judgment because his actions were reasonable even under Boyle’s proffered account of the relevant events.The United States Court of Appeals for the Fourth Circuit disagreed with the lower court's decision. The appellate court concluded that discoverable evidence could create a material dispute of fact and thus the district court abused its discretion in denying Boyle an opportunity to conduct discovery. The court did not assess the lower court's determination on the merits, but reversed its denial of Boyle’s motion for discovery, vacated its grant of summary judgment to Azzari as premature, and remanded the case for additional proceedings. View "Boyle v. Azzari" on Justia Law

The case involves Okello Chatrie, who was convicted for robbing a credit union in Virginia. The police, unable to identify the suspect from security footage and witness interviews, obtained a geofence warrant to access Google's Location History data. This data revealed that Chatrie's phone was in the vicinity of the bank during the robbery. Chatrie was subsequently indicted and pleaded not guilty, moving to suppress the evidence obtained via the geofence warrant.The district court denied Chatrie's motion to suppress, citing the good-faith exception to the exclusionary rule. Chatrie entered a conditional guilty plea and was sentenced to 141 months' imprisonment and 3 years' supervised release. He appealed, arguing that the geofence warrant violated his Fourth Amendment rights and that the fruits of the warrant should be suppressed.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court held that Chatrie did not have a reasonable expectation of privacy in the two hours’ worth of Location History data voluntarily exposed to Google. Therefore, the government did not conduct a Fourth Amendment search when it obtained this information from Google. The court rejected Chatrie's argument that the geofence warrant violated his Fourth Amendment rights, stating that he voluntarily exposed his location information to Google by opting into Location History. The court also noted that the information obtained was far less revealing than that obtained in previous cases involving long-term surveillance. View "United States v. Chatrie" on Justia Law

The case involves Hysen Sherifi, who was convicted of five federal offenses related to his participation in a terrorism conspiracy. Sherifi was initially sentenced to 540 months' imprisonment. However, the Supreme Court later ruled that certain applications of a statute under which Sherifi was twice convicted were unconstitutional. Consequently, Sherifi's convictions under this statute were set aside, and he was resentenced to 516 months' imprisonment for the remaining three counts.The district court in the Eastern District of North Carolina initially sentenced Sherifi. The court applied the Sentencing Guidelines, finding a total offense level of 43 and a criminal history category of VI. Sherifi appealed his convictions and sentences, but the Fourth Circuit Court of Appeals affirmed the district court's decision.In the United States Court of Appeals for the Fourth Circuit, Sherifi argued that his resentencing was procedurally flawed and that he was sentenced based on facts not found by the jury. However, the court found no reversible error and affirmed the lower court's judgment. The court held that the district court adequately explained its sentence, applied the relevant factors, and granted Sherifi's request for a downward variance based on his individual circumstances. The court also rejected Sherifi's argument that his Sixth Amendment right to a jury trial was violated, as well as his contention that the district court erred by applying a hate-crime enhancement. View "United States v. Sherifi" on Justia Law

The case involves Zackary Ellis Sanders, who was convicted of multiple offenses related to the illegal production, receipt, and possession of child pornography. Sanders appealed his conviction, arguing that the court erred in denying motions to suppress evidence seized pursuant to a search warrant for his residence, in admitting statements he made to FBI agents during the search of his residence, in excluding evidence of the victims’ voluntary participation in the production of child pornography, and in giving certain jury instructions.The court rejected each of Sanders’s appellate contentions and affirmed the judgment of the district court. The court found that the search warrant was valid and that Sanders was not entitled to a hearing to probe the truthfulness of an affidavit used to support the search warrant. The court also found that Sanders’s statements to the FBI agents were not in violation of the Fifth Amendment. The court ruled that evidence of the victims’ voluntary participation in the production of child pornography was irrelevant and properly excluded. Finally, the court found no error in the jury instructions given by the district court. View "United States v. Sanders" on Justia Law

The case involves Raymond Sefakor Yao Azumah, a Ghanaian national who was admitted to the United States as a lawful permanent resident in 2010. After a trip to Ghana in 2014, Azumah was deemed inadmissible due to an intervening embezzlement conviction. Despite this, the government paroled Azumah into the country and initiated removal proceedings against him. These proceedings were later dismissed, and Azumah applied for citizenship. However, the United States Citizenship and Immigration Services denied his application, arguing that Azumah was statutorily ineligible because he was not “lawfully admitted for permanent residence” upon his return to the United States in 2014. The district court affirmed this denial.The United States Court of Appeals for the Fourth Circuit disagreed with the lower court's decision. The court noted that Azumah was indeed “lawfully admitted for permanent residence” at all relevant times, including 2010, 2014, and when he sought citizenship, because he had the status of a legal permanent resident of the United States. The court did not interpret the agency regulation to impose upon Azumah the additional burden of showing that he was “lawfully admitted” rather than paroled when he returned to the United States in 2014. Therefore, the court vacated the judgment of the district court and remanded for further proceedings consistent with its opinion. View "Azumah v. United States Citizenship and Immigration Services" on Justia Law

The case involves Johnnie Simmons, Jr., who filed a pro se action against Hampton Roads Regional Jail corrections officers R. Whitaker, Benjamin Hull, and Derrick Brown. Simmons claimed that during an incident on February 8, 2019, Officer Whitaker choked him, which was caught on videotape. The district court granted summary judgment to Officers Hull and Brown, finding that their conduct did not violate the Eighth Amendment. Simmons appealed the decision.The district court had dismissed Officer Whitaker from the case due to lack of service. Officers Hull and Brown filed motions for summary judgment, arguing that the video footage and multiple officer affidavits established that Simmons could not prevail on his § 1983 bystander liability claims. The district court granted summary judgment for the defendants, crediting the video and the officers’ version of the event.The United States Court of Appeals for the Fourth Circuit found that the district court erred in its summary judgment analysis. The court held that the video evidence did not blatantly contradict Simmons's account, and the district court improperly ignored material admissible evidence in Simmons’s affidavit. The court also found that the district court applied the wrong legal standard, using the Eighth Amendment standard instead of the Fourteenth Amendment standard applicable to pre-trial detainees. The court affirmed in part, reversed in part, and remanded in part the district court's decision. View "Simmons v. Whitaker" on Justia Law

The case involves an American citizen and her noncitizen husband who sued two U.S. Citizenship and Immigration Services (USCIS) officials, alleging that USCIS unreasonably delayed adjudicating a waiver application the husband submitted two years prior. The plaintiffs argued that the Administrative Procedure Act (APA) and the Mandamus Act granted subject-matter jurisdiction over their claims. The district court dismissed their claims, concluding that language in the Immigration and Nationality Act (INA) that denies courts jurisdiction over suits based on agency “decisions or actions” also bars suits over agency inaction.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision, but for different reasons. The appellate court found that the district court erred in interpreting the INA's jurisdictional bar to include agency inaction. However, the court concluded that no statute or regulation requires USCIS to adjudicate the husband’s waiver application, and therefore, the district court lacked jurisdiction over the plaintiffs' claims. The court noted that while the delay in adjudication was stressful for the plaintiffs, their complaint should be addressed to the political branches, as the court lacked jurisdiction to order the relief sought. View "Lovo v. Miller" on Justia Law