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

Brock Beeman was convicted by a federal jury of mailing three threatening letters to a prosecutor and an investigator involved in a previous criminal case against him, violating 18 U.S.C. § 876(c). Beeman appealed his conviction, challenging the district court's decisions on three grounds: the admission of an uncharged threatening letter, the empaneling of an anonymous jury, and the denial of his motion for a mistrial due to the prosecutor's improper statement during closing arguments.The United States District Court for the Eastern District of Virginia admitted the uncharged letter as res gestae evidence and under Federal Rule of Evidence 404(b), finding it provided necessary context for Beeman's animus and intent. The court also empaneled an anonymous jury due to Beeman's history of threatening behavior and potential for lengthy incarceration, while ensuring Beeman's rights were protected by providing his counsel with an unredacted juror list. During closing arguments, the prosecutor improperly suggested jurors consider their personal feelings about the threats, but the court immediately corrected this with a curative instruction.The United States Court of Appeals for the Fourth Circuit reviewed Beeman's challenges for abuse of discretion. The court found no abuse of discretion in admitting the uncharged letter, as it was relevant to proving elements of the crime and not unfairly prejudicial. The court also upheld the empaneling of an anonymous jury, noting the district court's careful consideration of the factors and safeguards to protect Beeman's rights. Finally, the court determined that the prosecutor's improper statement during closing arguments did not prejudice Beeman, given the immediate correction and overwhelming evidence of his guilt.The Fourth Circuit affirmed the district court's judgment, upholding Beeman's conviction. View "US v. Beeman" on Justia Law

Justin Longworth, a federal inmate, alleged that he faced repeated sexual harassment and abuse by Sherry M. Beck, a correctional officer at the Federal Correctional Institution in Butner, North Carolina. Longworth claimed Beck engaged in daily aggressive sexual harassment and abuse, including forced oral sex, fondling, and groping. He did not immediately report Beck's conduct due to fear of retaliation. Other officials at the institution initially did nothing to stop or report Beck's abuse. Eventually, Beck was reported, fired, and Longworth was transferred to another facility, but Beck continued to harass him through letters.Longworth filed two separate lawsuits in the Eastern District of North Carolina. The first lawsuit was a Bivens action against the officials directly involved, alleging violations of his civil rights under the Fourth and Eighth Amendments. The district court dismissed the Bivens claims, finding that they presented new contexts and that special factors counseled hesitation in extending Bivens to this context. Longworth appealed the dismissal of his Bivens claims. The second lawsuit was an FTCA claim against the United States, alleging negligence by the officials. The district court dismissed the FTCA claim for lack of subject matter jurisdiction, finding that Beck was not acting within the scope of her employment during the alleged misconduct. Longworth did not appeal the FTCA judgment.The United States Court of Appeals for the Fourth Circuit reviewed the case and concluded that the district court's FTCA judgment precluded Longworth's Bivens appeal. The FTCA judgment bar provides that an FTCA judgment is a complete bar to any action by the claimant against the employee of the government whose act or omission gave rise to the claim. Since a judgment on the FTCA claim had been entered, Longworth could no longer pursue his Bivens action based on the same conduct. Consequently, the Fourth Circuit dismissed the appeal. View "Longworth v. Mansukhani" on Justia Law

Two former employees sued Zen Nails Studio LLC and its owners for violating the Fair Labor Standards Act (FLSA) and a similar Maryland state law. After a five-day bench trial, the plaintiffs won and were awarded approximately 60% of their requested damages. The plaintiffs then sought $343,189.85 in attorney’s fees, but the district court awarded them $167,115.49, which was less than half of what they requested. The plaintiffs appealed the district court’s decision regarding the hourly rates used to calculate the attorney’s fees.The United States District Court for the District of Maryland, at Greenbelt, initially reviewed the case. The district court set the hourly rates for the plaintiffs’ attorneys, paralegals, and paraprofessionals based on the local rules' guidelines, which it treated as presumptively reasonable. The court then calculated the hours reasonably worked and reduced the total by 35% due to the plaintiffs achieving a moderately successful outcome. The plaintiffs challenged the district court’s reliance on the local rules' guidelines for setting the hourly rates.The United States Court of Appeals for the Fourth Circuit reviewed the case. The appellate court held that the district court erred by treating the hourly rates in the local rules as presumptively correct and requiring special justification for higher rates. The Fourth Circuit emphasized that while fee matrices can be a useful starting point, they should not be treated as setting a baseline that requires special justification to deviate from. The appellate court vacated the fee award and remanded the case for further proceedings, instructing the district court to consider all relevant evidence to determine the prevailing market rates without giving undue weight to the local rules' guidelines. View "De Paredes v. Zen Nails Studio LLC" on Justia Law

NCO Financial Systems, Inc. (NCO) entered into a lease agreement with Montgomery Park, LLC (Montgomery Park) for over 100,000 square feet of office space in Baltimore, Maryland. The lease allowed NCO to terminate early after eight years if certain conditions were met. NCO attempted to terminate early, but Montgomery Park claimed the conditions were not satisfied. NCO vacated the premises and stopped paying rent, leading Montgomery Park to send a default notice. NCO then filed a lawsuit seeking a declaratory judgment that it had properly terminated the lease and that the rent was based on misrepresented square footage.The United States District Court for the District of Maryland found in favor of Montgomery Park after a bench trial, awarding it $9,854,566.95 plus ongoing interest. The court also set a schedule for determining Montgomery Park’s claim for costs, fees, and expenses. Montgomery Park filed a motion seeking approximately $3.8 million for these costs, which NCO opposed on several grounds, including the lack of a proper demand for payment and the inclusion of fees for defending against NCO’s initial suit.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court concluded that Montgomery Park made a valid demand for payment when it filed its motion for costs, fees, and expenses on August 24, 2022. The court held that default interest should run only from the date of this demand, not from when the costs were incurred, and remanded the case to recalculate the interest. The court affirmed the district court’s award of costs, fees, and expenses, including those incurred in defending against NCO’s claims and expert witness fees, finding no abuse of discretion or error in the district court’s decisions.The Fourth Circuit affirmed in part, vacated in part, and remanded with instructions to recalculate the default interest. View "NCO Financial Systems, Inc. v. Montgomery Park, LLC" on Justia Law

Luis Avila pleaded guilty to three counts of violating 18 U.S.C. § 2252A(a)(2) and (b)(1) for possessing material involving the sexual exploitation of a minor. The probation officer calculated Avila’s advisory guideline range using Section 2G2.2 of the Federal Sentencing Guidelines, which starts with a base offense level of 22 and includes several enhancements that increased Avila’s offense level to 35. The probation officer then applied a cross-reference under Section 2G2.2(c)(1), which increased the offense level to 38, resulting in a guidelines range of 168 to 210 months after a three-level decrease for acceptance of responsibility.Avila challenged the application of the cross-reference, arguing that his actions did not cause the creation of the sexually explicit material because the victims were already sending the same videos to other people. The government argued that Avila’s actions, including offering and paying money for specific videos, caused the victims to create and send the videos. The United States District Court for the Western District of North Carolina overruled Avila’s objection and applied the cross-reference, sentencing him to 132 months of imprisonment followed by 30 years of supervised release.The United States Court of Appeals for the Fourth Circuit reviewed the case and found that the district court committed procedural error in sentencing Avila. The appellate court held that the district court’s factual findings were legally insufficient to support the application of the cross-reference under Section 2G2.2(c)(1). The court concluded that offering money for specific conduct and causing that conduct to happen are different, and proving the former does not prove the latter. Therefore, the Fourth Circuit vacated the district court’s judgment and remanded the case for resentencing. View "US v. Avila" on Justia Law

In May 2021, the appellant, along with a co-defendant, robbed a gas station in New Bern, North Carolina. The appellant entered the store armed with a revolver, pointed it at the cashier, struck the cashier on the head, and took money and cartons of cigarettes. The robbery was captured on surveillance video, and a witness provided a photo of the getaway vehicle. The next day, law enforcement located the vehicle and arrested the appellant and his co-defendant, recovering stolen items and the revolver used in the robbery.The appellant was indicted for robbery, using/brandishing a firearm during a crime of violence, and possession of a firearm by a convicted felon. He agreed to plead guilty to the first two counts and waived his right to appeal his conviction and sentence, except on grounds of ineffective assistance of counsel or prosecutorial misconduct. The district court conducted a brief plea hearing and sentenced the appellant to 144 months of imprisonment. The appellant argued that his appeal waiver was invalid because the district court failed to properly conduct the plea hearing and did not acknowledge his mitigation arguments or provide an explanation for the sentence.The United States Court of Appeals for the Fourth Circuit reviewed the case and held that the appellant’s appeal waiver was not knowingly and intelligently made. The court found that the district court failed to properly inform the appellant of the terms of the appeal waiver and did not ensure that he understood it. The court also noted that enforcing the appeal waiver would result in a miscarriage of justice due to the district court’s repeated disregard for proper procedure. Consequently, the Fourth Circuit vacated the sentence as procedurally unreasonable and remanded the case for reassignment to a different district court judge for further proceedings. View "US v. Smith" on Justia Law

A nurse at a medical clinic where Dr. George P. Naum, III worked prescribed controlled substances without a doctor's supervision. The government prosecuted Naum for conspiracy and aiding and abetting the distribution of controlled substances outside the usual course of his professional practice, alleging he knew about the nurse’s conduct but did not stop it. A federal jury convicted Naum on these counts.The United States District Court for the Northern District of West Virginia handled the initial trial. Naum was found guilty of one count of conspiracy to distribute controlled substances outside the bounds of professional medical practice and four counts of aiding and abetting in the distribution of controlled substances outside the bounds of professional medical practice. Naum's motion for a new trial was denied, and he appealed. The Fourth Circuit initially affirmed the district court's decision.The United States Supreme Court later clarified in Ruan v. United States that to convict a defendant under 21 U.S.C. § 841(a), the government must prove the defendant knew or intended that their conduct was unauthorized. Naum argued that the district court failed to instruct the jury on this requirement. The Fourth Circuit agreed that the jury instructions misstated the law post-Ruan but applied plain error review. The court concluded that Naum did not meet his burden of showing that the outcome of his trial would have been different with proper instructions. Therefore, the Fourth Circuit affirmed Naum's conviction. View "United States v. Naum" on Justia Law

Eugenia Bautista Chavez, a native and citizen of Mexico, challenged the Board of Immigration Appeals’ order of removal based on her 2011 conviction for petit larceny under section 18.2-96 of the Virginia Code. The Board held that petit larceny categorically qualified as a crime involving moral turpitude, rendering Chavez ineligible for cancellation of removal. Chavez argued that a defendant in Virginia could be convicted of larceny for taking property that he or she sincerely but unreasonably believed was abandoned, which falls short of the requisite mental state for a crime involving moral turpitude. She also contended that petit larceny for taking property of de minimis value does not constitute sufficiently reprehensible conduct to make out a crime involving moral turpitude.The Immigration Judge ruled for the government, reasoning that he was required to find that petit larceny was a crime involving moral turpitude under the Fourth Circuit’s decision in Hernandez v. Holder. Chavez appealed to the Board, arguing that Virginia petit larceny did not require a culpable mental state and did not involve reprehensible conduct. The Board dismissed Chavez’s appeal, concluding that the offense required a culpable mental state and involved reprehensible conduct. Chavez then moved the Board to reconsider its decision, but a temporary Board member denied her motion.The United States Court of Appeals for the Fourth Circuit reviewed the case and denied Chavez’s petition. The court held that Virginia petit larceny is a crime involving moral turpitude because it requires an intent to permanently deprive the owner of property, which satisfies the culpable mental state requirement. The court also found that the offense involves reprehensible conduct, regardless of the value of the property taken. Additionally, the court rejected Chavez’s challenge to the authority of the temporary Board member who decided her reconsideration motion, citing its previous decision in Salomon-Guillen v. Garland. View "Chavez v. Bondi" on Justia Law

Nathaniel Powell pled guilty in 2016 to conspiracy to manufacture, distribute, and possess with intent to distribute more than 100 grams of heroin. The United States Probation Office recommended a two-level sentence enhancement under the United States Sentencing Guidelines for maintaining a premises for drug distribution, based on information from Powell’s co-defendant, Valerie Wilson. Wilson claimed she bought drugs from Powell at his residence and witnessed heroin processing there. Powell’s attorney, Lawrence Woodward, objected to the enhancement, questioning Wilson’s credibility and the sufficiency of the evidence.The United States District Court for the Eastern District of Virginia overruled the objection and adopted the presentence report, sentencing Powell to 300 months in prison. Powell later filed a pro se motion under 28 U.S.C. § 2255 to vacate his sentence, claiming ineffective assistance of counsel for failing to investigate potentially exculpatory evidence, including a lease agreement showing someone else leased the premises during part of the relevant time. The district court dismissed most claims but held a hearing on this issue. Woodward testified he did not receive the lease and believed attacking Wilson’s credibility was the best strategy. The district court dismissed Powell’s claim, finding Woodward’s performance was not deficient and the lease would not have changed the outcome.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that Woodward’s performance was not constitutionally deficient, as his strategy to attack Wilson’s credibility was reasonable. The court also found no prejudice, as the district court indicated it would have applied the same sentence even without the enhancement. Thus, the Fourth Circuit affirmed the district court’s denial of Powell’s § 2255 motion. View "United States v. Powell" on Justia Law

The appellants, Jose Joya Parada, Oscar Armando Sorto Romero, Milton Portillo Rodriguez, and Juan Carlos Sandoval Rodriguez, were charged in 2018 with various racketeering offenses related to their involvement with the MS-13 gang. During jury selection, the government used peremptory strikes on several Black venirepersons, including Jurors 217 and 138. The appellants raised Batson challenges to these strikes, which the district court rejected. The trial proceeded, and during jury deliberations, Juror 9 tested positive for COVID-19. Over the appellants' objections, the district court decided to proceed with an eleven-member jury. The jury found some appellants guilty on all charges and others guilty on some charges.The United States District Court for the District of Maryland denied the appellants' Batson challenges and decided to proceed with an eleven-member jury after Juror 9 tested positive for COVID-19. The appellants were subsequently found guilty of various charges. The appellants appealed, arguing that the district court erred in rejecting their Batson challenges and in proceeding with an eleven-member jury.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the district court did not clearly err in rejecting the Batson challenges, as the government provided race-neutral reasons for the peremptory strikes, and the district court found these reasons credible. The court also held that the district court did not abuse its discretion in proceeding with an eleven-member jury, as it thoroughly considered all alternatives and found good cause to excuse Juror 9. The Fourth Circuit affirmed the district court's judgment. View "US v. Parada" on Justia Law