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

Plaintiff pled guilty to being a felon in possession of a firearm and was sentenced to a mandatory minimum fifteen-year term of imprisonment under the Armed Career Criminal Act (“ACCA”), 18 U.S.C. 924(e). On appeal, defendant argued that the Shepard-approved documents upon which the district court relied for the ACCA enhancement are fatally ambiguous as to whether he committed his predicate armed robbery offenses on different occasions. The court held that the government failed to prove by a preponderance of the evidence that defendant’s prior felonies were separate and distinct criminal episodes for purposes of the ACCA because there are patent internal inconsistencies infecting the underlying state court documents as to the dates when the robberies occurred. Accordingly, the court vacated and remanded for resentencing. The court need not address defendant's alternative argument. View "United States v. Span" on Justia Law

Plaintiffs filed suit under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., seeking disgorgement from an employer who wrongly transferred assets from a pension plan that enjoyed a separate account feature to a pension plan that lacked one. The district court dismissed the complaint, holding that plaintiffs lacked statutory and Article III standing. The court held, however, that a defined contribution plan’s separate account feature constitutes an “accrued benefit” that “may not be decreased by amendment of the plan” under section 204(g)(1). In this case, the transfers at issue resulted in a loss of the separate account feature and thus violated section 204(g)(1). Therefore, plaintiffs have statutory standing. Further, plaintiffs have Article III standing where plaintiffs incurred an injury in fact, and satisfied the causation and redressability requirements. Finally, the court joined the majority of its sister circuits and held that the transferor court’s choice-of-law rules apply when a case has been transferred pursuant to 28 U.S.C. § 1404(a). Here, the court concluded that the statute of limitations cannot serve as a basis for affirming the district court's grant of summary judgment to the Bank. Accordingly, the court reversed and remanded for further proceedings. View "Pender v. Bank of America Corp." on Justia Law

In 1970, the district court determined that the City and the Board were operating racially segregated schools and directed them to submit desegregation plans that would establish a nonracial, unitary school district. This appeal stemmed from the district court's two desegregation orders. Plaintiffs moved to enjoin the implementation of the Board's 2011-2012 student assignment plan because it failed to move the school district toward unitary status. The district court denied relief. The court vacated the district court's ruling, holding that the district court erred when it failed to place the burden on the Board to show that the 2011-12 student assignment plan moved the school district toward unitary status. Subsequently, the district court granted the Board's motion requesting that the district court declare the school district unitary and the district court dismissed plaintiffs' request for an injunction as moot. The court affirmed, concluding that the district court acted within its discretion in choosing to address the Board’s motion for declaration of unitary status before ruling on plaintiffs’ motion for injunctive relief. Further, the district court did not clearly err in determining that the school district is unitary. View "Everett v. Pitt Cnty. Bd. of Educ." on Justia Law

HI petitioned the BRB's decision upholding the ALJ's grant of Ricky Eason's claim for temporary partial disability under the Longshore and Harbor Workers’ Compensation Act (LHWCA), 33 U.S.C. 901-950. The court agreed with the Director that the LHWCA’s statutory framework supports his construction of the LHWCA and nothing in Potomac Electric Power Co. [PEPCO] v. Dir., OWCP precludes reclassification of a scheduled permanent partial disability to a temporary total disability. Accordingly, the court granted the petition for review and remanded to the BRB to enter an order dismissing Eason's claim. View "Huntington Ingalls Indus. v. Eason" on Justia Law

Plaintiff filed suit against the Banks for facilitating collection of loans he obtained from online lenders. On appeal, the Banks challenged the district court's order denying their renewed motions seeking to cure deficiencies the district court relied on in dismissing their claims to enforce arbitration clauses in the loan agreements. The court concluded that the district court erred by treating as motions for reconsideration what were, in both form and substance, renewed motions to compel arbitration and stay further court proceedings. Accordingly, the court vacated the district court's order and remanded for further proceedings. View "Dillon v. BMO Harris Bank, N.A." on Justia Law

Plaintiffs filed suit challenging a state law redrawing the Wake County Board of Education electoral districts, arguing that under the new redistricting plan, some citizen’s votes will get significantly more weight than other’s in violation of the Fourteenth Amendment’s guarantees of one person, one vote and the North Carolina Constitution’s promise of equal protection. The district court granted defendants’ motions to dismiss and denied plaintiffs’ motion to amend as futile. The court concluded that plaintiffs’ allegations in support of their claim that the law violates the one person, one vote principle suffice to survive a motion to dismiss for failure to state a claim. Thus, plaintiffs have stated a claim upon which relief could be granted against the Wake County Board of Elections and the district court therefore erred in dismissing their suit. The court affirmed, however, the denial of the motion to amend because the state officials plaintiffs proposed to add as named defendants are not amenable to suit. View "Wright v. North Carolina" on Justia Law

Plaintiff appealed the district court's summary dismissal of his 42 U.S.C. 1983 claim against defendant on the ground that plaintiff failed to exhaust his administrative remedies pursuant to the Prison Litigation Reform Act (PLRA), 42 U.S.C. 1997e(a). Plaintiff's suit arose from allegations that prison officers used excessive force while transferring him to a different cell. The court reversed and remanded, holding that plaintiff reasonably believed that he had sufficiently exhausted his remedies by complying with an internal investigation. View "Blake v. Ross" on Justia Law

Plaintiff filed suit against the University under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., for discriminatory termination based on gender, retaliatory termination, and the creation of a hostile work environment. At issue was the effect of the Supreme Court’s decision in University of Texas Southwestern Medical Center v.Nassar on what Title VII retaliation plaintiffs must show to survive a motion for summary judgment. The court concluded that the McDonnell Douglas framework, which already incorporates a but for causation analysis, provides the appropriate standard for reviewing plaintiff’s claim. Applying this framework, the court found that summary judgment in favor of the University is not warranted on plaintiff's retaliation claim where a reasonable jury could conclude from plaintiff's evidence that the University's proffered justifications were not its real reasons for firing her and that the University's actual reason for firing her was to retaliate against her complaining about sexual harassment and for her subsequent complaints of ongoing retaliation. Therefore, the court reversed the district court's grant of summary judgment as to plaintiff's retaliation claim. The court affirmed the district court's grant of summary judgment on plaintiff's gender-based discrimination claim and hostile work environment claim. View "Foster v. Univ. of Maryland Eastern" on Justia Law

Defendant appealed his revocation sentence. At issue was whether the district court erred in determining, based on defendant’s status as a recidivist drug offender, that certain drug offenses committed during his supervised release were Grade B violations under the Sentencing Commission’s advisory policy statements for violations of probation and supervised release. The court held that the district court did not err in concluding that defendant's prior drug convictions increased the extent to which his marijuana offenses during supervised release were “punishable” under Section 844(a). Thus, the district court correctly determined that defendant’s multiple acts of possessing marijuana during his supervised release constituted Grade B violations under the Guidelines’ Chapter 7 advisory policy statements. View "United States v. Wynn" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1982, alleging that correctional officers used excessive force when they forcibly extracted him from his prison cell. The officers appealed the district court's denial of their motion for summary judgment on the basis of qualified immunity. The parties agree that the law clearly established at the time of the extraction governs the entitlement to qualified immunity here. In Norman v. Taylor, the court held that absent the most extraordinary circumstances, a plaintiff cannot prevail on an Eighth Amendment excessive force claim if his injury is de minimis. Applying Norman, the court concluded that many of plaintiff's injuries could have an enduring impact on health and well-being and were not de minimis. Accordingly, the court affirmed the judgment of the district court. View "Ussery v. Mansfield" on Justia Law