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

After Radiance published an article online entitled “NAACP: National Association for the Abortion of Colored People” that criticized the NAACP’s stance on abortion, the NAACP sent Radiance a cease-and-desist letter. Radiance sought a declaratory judgment that it had not infringed any NAACP trademarks and the NAACP filed counterclaims alleging trademark infringement and dilution. The court concluded that the NAACP does not have actionable claims for trademark infringement in this case; Radiance's use of the NAACP's marks or colorable imitation falls squarely within the exceptions to trademark dilution specifically included in the Lanham Act, 15 U.S.C. 1051 et seq., to avoid encroaching on free speech rights; and therefore, the court reversed the district court's injunction and remanded with directions that defendant's counterclaims be dismissed. View "The Radiance Foundation, Inc. v. NAACP" on Justia Law

Defendant pled guilty to reentering the United States as an illegal alien and the district court imposed a twelve-level sentencing enhancement based on his prior felonious conviction for unlawfully transporting aliens. On appeal, defendant argued that the Court's ruling in United States v. Simmons precludes the enhancement because the Guidelines for his prior conviction under the then-mandatory Sentencing Guidelines was zero to six months' imprisonment. The court affirmed the sentence, concluding that the district court did not err in imposing the enhancement because the judge who sentenced defendant for the prior conviction had discretion to sentence him for up to five years. View "United States v. Bercian-Flores" on Justia Law

In this putative class action, plaintiffs are a class of black steel workers who allege endemic racial discrimination at a South Carolina plant owned by Nucor. At issue was whether the workers have presented a common question of employment discrimination through evidence of racism in the workplace. In light of the Supreme Court's opinion in Wal-Mart Stores, Inc. v. Dukes, the district court on remand refused to certify the class. The court held that the district court has for a second time erred in refusing to certify the workers’ class, where (1) statistics indicate that promotions at Nucor depended in part on whether an individual was black or white; (2) substantial anecdotal evidence suggests discrimination in specific promotions decisions in multiple plant departments; and (3) there is also significant evidence that those promotions decisions were made in the context of a racially hostile work environment. The court concluded that the district court fundamentally misapprehended the reach of Wal-mart and its application to the workers' promotions class. Accordingly, the court vacated in part and remanded for recertification of the class. View "Brown v. Nucor Corp." on Justia Law

Defendant, a board-certified dermatologist, was indicted for executing a "scheme or artifice to defraud" when billing public and private healthcare benefit programs and related offenses. The district court granted plaintiff's motion to strike as unduly prejudicial certain financial details alleged in the indictment, a motion in limine to exclude evidence of post-scheme conduct the government intended to introduce to show defendant's consciousness of guilt; and a motion in limine to exclude all evidence of the scheme that was not directly related to one of the 53 specifically charged executions. The court concluded that the district court abused its discretion in limiting the government’s proof to that which is directly relevant to one or more of the 53 executions charged in the indictment, without taking into account the relevance of uncharged conduct to the alleged overarching scheme; the district court abused its discretion because it misapplied Federal Rule of Evidence 404(b) and 403 in excluding evidence of defendant's post-scheme conduct; and the district court abused its discretion where, because a violation of the healthcare fraud statute requires knowing and willful conduct, the government must establish defendant's intent to defraud. Accordingly, the court reversed and remanded. View "United States v. Bajoghli" on Justia Law

Plaintiff filed suit against Dr. Cohen seeking a declaration that they properly rescinded his disability insurance policies. The magistrate judge held that Dr. Cohen made material misrepresentations on his policy applications and granted summary judgment to plaintiffs. Applying Maryland law, the court concluded that each of the questions to which Dr. Cohen allegedly gave false answers is subject to more than one reasonable interpretation, and so is ambiguous. Because the language of each question at issue in this case is ambiguous, summary judgment was inappropriate. In regard to the magistrate judge's denial of Dr. Cohen's motion in limine, the court held that a Consent Order suspending a Maryland medical license rendered by the Maryland State Board of Physicians is not admissible in a civil or criminal action absent consent, except for in an action brought by a party aggrieved by a Board decision. Accordingly, the court reversed and remanded. View "Certain Underwriters at Lloyd's v. Cohen" on Justia Law

Petitioner, a native and citizen of El Salvador, entered the United States without inspection and without valid entry documents. The Government subsequently initiated deportation proceedings against Petitioner. Petitioner conceded her removability but sought relief from removal in the form of asylum and withholding of removal under the Immigration and Naturalization Act. The immigration judge concluded that Petitioner had not established her eligibility for asylum. The Board of Immigration Appeals (BIA) affirmed. The Fourth Circuit granted Petitioner’s petition for review and vacated the order of the BIA, holding that Petitioner had established her eligibility for asylum. Remanded. View "Hernandez-Avalos v. Lynch" on Justia Law

Plaintiff was injured as the result of a train derailment. Plaintiff filed this negligence action in state court against Norfolk Southern Railway Company seeking both compensatory and punitive damages. Before trial, the district court granted summary judgment for Plaintiff on the issue of whether Norfolk Southern’s negligence cause the derailment and granted summary judgment against Plaintiff on his claim for punitive damages. After a jury trial on the issue of Plaintiff’s compensatory damages, the jury awarded Plaintiff $2,977,383. The Fourth Circuit reversed, holding that the district court (1) erred in granting partial summary judgment to Plaintiff on the issue of Norfolk Southern’s liability for the accident because, while Plaintiff established that Norfolk Southern breached its duty as a matter of law to properly inspect the track, a genuine issue of material fact exists as to whether Norfolk Southern’s breach proximately caused the derailment and Plaintiff’s injuries; and (2) properly granted summary judgment on Plaintiff’s punitive damages claim. View "Harris v. Norfolk Southern Railway Co." on Justia Law

Concerned by Plaintiff’s “increasingly threatening” Facebook posts, two Marine veterans who had served with Plaintiff contacted the FBI. After interviewing Plaintiff, two FBI agents consulted with Michael Campbell, a local mental health evaluator, as to whether they should detain Plaintiff for a mental health evaluation. Campbell recommended that Plaintiff be detained. After interviewing Plaintiff, Campbell petitioned for and received a temporary detention order from a magistrate judge. Plaintiff was taken to a hospital, where he was involuntarily admitted for treatment for seven days. Following his release, Plaintiff filed suit under 42 U.S.C. 1983, seeking damages and injunctive relief against Campbell for violating his Fourth Amendment and First Amendment rights. The district court granted summary judgment to Campbell on the basis of qualified immunity. The Fourth Circuit affirmed, holding (1) Campbell did not violate Plaintiff’s Fourth Amendment rights based on existing precedent; (2) Plaintiff did not make out a First Amendment violation; and (3) injunctive relief was not appropriate on this record. View "Raub v. Campbell" on Justia Law

Defendant was charged with possession with intent to distribute one kilogram or more of heroin. If convicted, Defendant faced a mandatory minimum penalty of twenty years’ imprisonment. For several months, Defendant refused to plead guilty. The morning of his scheduled trial, however, Defendant accepted the government’s plea offer. Defendant subsequently filed a pro se motion to withdraw his guilty plea on the basis of ineffective assistance of counsel, arguing that his plea had been involuntary because he had been pressured to plead guilty by the district court. The Fourth Circuit vacated and remanded for further proceedings, holding that the district court committed plain error by impermissibly participating in the plea discussions. Remanded. View "United States v. Braxton" on Justia Law

Debtor filed a voluntary petition for relief under Chapter 7 of the Bankruptcy Code. Thereafter, the Trustee and the Bankruptcy Administrator (collectively, the Trustee) filed a complaint objecting to Debtor’s discharge in bankruptcy. Debtor responded by asserting that the Trustee’s complaint was barred by the applicable statute of limitations. The bankruptcy court granted the Trustee’s motion for summary judgment and entered an order denying Debtor a discharge. The district court affirmed, concluding that the Trustee’s complaint was timely. The Fourth Circuit reversed, holding that the bankruptcy court erred in finding that Trustee’s complaint was timely filed. Remanded. View "Jenkins v. Ward" on Justia Law