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

Plaintiff filed suit against Cava, alleging a Title VII retaliation claim for reporting alleged sexual harassment between employees. Plaintiff's supervisor concluded, after an investigation, that plaintiff made up the allegations. The Fourth Circuit affirmed the district court's grant of summary judgment against plaintiff, holding that neither plaintiff nor amici have cited any case holding that the opposition clause protects employees' pretending to oppose Title VII violations by intentionally fabricating allegations, and the court was not aware of any; while the case law plaintiff and amici presented favor liberally interpreting the statute to further the goal of encouraging employees to come forward, they did not favor rewriting a statute that conditions liability on the existence of a retaliatory motive; and there was no genuine dispute of fact regarding the reasonableness of Cava's investigation into whether plaintiff fabricated her conversation with an employee. View "Villa v. Cavamezze Grill, LLC" on Justia Law

Defendant was convicted of bank robbery and conspiracy to commit bank robbery following a jury trial. The Fourth Circuit held that the statements defendant gave to police during the investigation of the crime was coerced, and that he did not voluntarily waive his Fifth Amendment rights. Furthermore, the error in introducing those statements was not harmless. The court need not address the additional issues raised by defendant and thus reversed the conviction. View "United States v. Giddins" on Justia Law

Plaintiff appealed the denial of her application for disability insurance benefits and supplemental security income. The Fourth Circuit held that the ALJ did not give appropriate weight to the opinions of plaintiff's treating physicians and failed to adequately explain his decision to deny her benefits. Accordingly, the court vacated and remanded for further proceedings. View "Lewis v. Berryhill" on Justia Law

Plaintiff pro se filed suit against defendant, a prison official, alleging that plaintiff's placement in segregation violated his constitutional rights to freedom from retaliation for filing a grievance, equal protection, and due process. The Fourth Circuit agreed with the district court that plaintiff failed to state a claim under the Equal Protection and Due Process clauses. The court held, however, that plaintiff pleaded sufficient facts to state a claim that defendant violated plaintiff's First Amendment rights by placing him in segregation as retaliation for filing a grievance. Furthermore, it was clearly established at the time that defendant placed plaintiff in segregation that retaliating against an inmate for filing a grievance violates the inmate's rights under the First Amendment. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Martin v. Duffy" on Justia Law

Movant sought authorization to file a successive 28 U.S.C. 2255 motion, arguing that under Johnson v. United States, 135 S.Ct. 2551 (2015), he should be allowed to challenge his 18 U.S.C. 924(c) conviction. Section 924(c) is a penalty provision that mandates an enhanced sentence for a defendant who uses or carries a firearm during, as relevant here, a "crime of violence." Movant was also convicted of 18 U.S.C. 924(j), causing the death of a person through the use of a firearm in the course of committing a section 924(c) offense. The Fourth Circuit held that second-degree retaliatory murder is a crime of violence under the force clause of section 924(c); Johnson's holding, which is limited to the residual clause, was inapplicable to movant's section 924(c) conviction; and thus the court denied the request for authorization. View "In re: James Allen Irby, III" on Justia Law

In 2012, defendant pleaded guilty in the Eastern District of Virginia to conspiracy to possess with intent to distribute cocaine from July 2012 to August 22, 2012. In 2014, defendant was indicted in the Western District of Virginia for, among other offenses, conspiracy to possess with intent to distribute cocaine. The Government alleged that defendant operated a vast drug trafficking organization in the same area from 1998 through 2012. The Fourth Circuit held that double jeopardy barred defendant's follow-up prosecution in the Western District of Virginia for conspiracy to possess with intent to distribute cocaine in violation of 21 U.S.C. 846. The court explained that there was substantial, if not complete, overlap on each element of the double jeopardy analysis. Accordingly, the court reversed and remanded. View "United States v. Jones" on Justia Law

Defendant was convicted of various drug and firearm offenses. The Fourth Circuit held that the district court abused its discretion by admitting evidence of prior convictions under FRE 404(b) where the government proffered no evidence of any connection between defendant's prior possession conviction and the instant charge; that possession conviction was not relevant to whether defendant intended to distribute the marijuana found inside the locked bedroom; and there was a lack of factual similarity and temporal proximity between defendant's prior convictions and his present convictions. Furthermore, the minimal probative value of admitting the convictions was substantially outweighed by the likelihood of unfair prejudice. Accordingly, the court reversed, vacated, and remanded. View "United States v. Hall, Jr." on Justia Law

Defendant appealed the district court's order of restitution that was imposed after defendant was convicted of making a false statement in a matter within the jurisdiction of the executive branch of the federal government in violation of 18 U.S.C. 1001(a)(2). The Fourth Circuit affirmed and held that it was evident in this case that the district court ordered restitution pursuant to the Mandatory Victims Rights Act (MVRA), 18 U.S.C. 3663; the categorical approach has no role to play in determining whether a Title 18 offense is "an offense against property" that triggers mandatory restitution under the MVRA; given the specific circumstances of defendant's section 1001 conviction, the court had little trouble finding that his false statement on the HUD-1 form was an "offense against property" under the MVRA; and the district court did not err when it determined that defendant's false statement directly and proximately caused harm to Bank of America and thus the Bank was the "victim" within the meaning of the MVRA. The court also held that the district court did not err in awarding restitution to the Bank in the amount of $1,385,444.83. View "United States v. Ritchie" on Justia Law

The Fourth Circuit affirmed in substantial part the district court's issuance of a nationwide injunction as to Section 2(c) of the challenged Second Executive Order (EO-2), holding that the reasonable observer would likely conclude EO-2's primary purpose was to exclude persons from the United States on the basis of their religious beliefs. Section 2(c) reinstated the ninety-day suspension of entry for nationals from six countries, eliminating Iraq from the list, but retaining Iran, Libya, Somalia, Sudan, Syria, and Yemen.Determining that the case was justiciable, the Fourth Circuit held that plaintiffs have more than plausibly alleged that EO-2's stated national security interest was provided in bad faith, as a pretext for its religious purpose. Because the facially legitimate reason offered by the government was not bona fide, the court no longer deferred to that reason and instead may look behind the challenged action. Applying the test in Lemon v. Kurtzman, the court held that the evidence in the record, viewed from the standpoint of the reasonable observer, created a compelling case that EO-2's primary purpose was religious. Then-candidate Trump's campaign statements revealed that on numerous occasions, he expressed anti-Muslim sentiment, as well as his intent, if elected, to ban Muslims from the United States. President Trump and his aides have made statements that suggest EO-2's purpose was to effectuate the promised Muslim ban, and that its changes from the first executive order reflect an effort to help it survive judicial scrutiny, rather than to avoid targeting Muslims for exclusion from the United States. These statements, taken together, provide direct, specific evidence of what motivated both executive orders: President Trump's desire to exclude Muslims from the United States and his intent to effectuate the ban by targeting majority-Muslim nations instead of Muslims explicitly. Because EO-2 likely fails Lemon's purpose prong in violation of the Establishment Clause, the district court did not err in concluding that plaintiffs are likely to succeed on the merits of their Establishment Clause claim. The court also held that plaintiffs will likely suffer irreparable harm; the Government's asserted national security interests do not outweigh the harm to plaintiffs; and the public interest counsels in favor of upholding the preliminary injunction. Finally, the district court did not abuse its discretion in concluding that a nationwide injunction was necessary to provide complete relief, but erred in issuing an injunction against the President himself. View "International Refugee Assistance Project v. Trump" on Justia Law

Defendant appealed the district court's application of a sixteen-level sentencing enhancement after pleading guilty to illegal reentry after being convicted of an aggravated felony. The Fourth Circuit affirmed, holding that defendant's prior conviction under Ohio Rev. Code Ann. 2925.03(A)(2) categorically qualifies as a "drug trafficking offense" as defined in U.S.S.G. 2L1.2, cmt. n.1(B)(iv) (2015). Because the Ohio statute in this case requires that defendant have knowledge that the controlled substance is intended for sale, the statute does not apply to simple possession. View "United States v. Walker" on Justia Law