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

In 2007, Petitioner, a native and citizen of El Salvador, was convicted of petit larceny. In 2009, the U.S. Department of Homeland Security commenced removal proceedings against Petitioner. Petitioner conceded removability but applied for cancellation of removal under 8 U.S.C. 1229b(b)(1), The immigration judge pretermitted Petitioner’s application and ordered her removed to El Salvador, concluding that her petit-larceny conviction rendered her ineligible for relief because it was a crime involving moral turpitude. The Board of Immigration Appeals (BIA) affirmed. Petitioner appealed, arguing that the BIA’s decision was based on an incorrect interpretation of section 1229b(b)(1)(C).The Fourth Circuit affirmed, holding that the BIA’s reading of section 1229b(b)(1)(C) was a permissible interpretation of the statute, entitling the BIA’s decision to Chevron deference. View "Hernandez v. Holder" on Justia Law

After a jury trial, Appellants, Abukar Osman Beyle and Shani Nurani Shiekh Abrar, were convicted on twenty-six criminal counts arising from the armed abduction and murder of four U.S. citizens off the coast of Somalia. The Fourth Circuit affirmed, holding (1) the district court had jurisdiction over the charges of murder and concomitant use of a firearm because the site of the murders, thirty to forty nautical miles from the Somali coast, lay on the “high seas,” and thus, Appellants were within the reach of the U.S. criminal statutes under which they were convicted; and (2) Abrar was not denied his Fifth Amendment right to due process or his Sixth Amendment right to present witnesses material to his duress defense, and therefore, the district court did not err in denying Abrar’s motion to dismiss the indictment. View "United States v. Beyle" on Justia Law

Appellant-homeowners were victims of one of the largest residential arsons in Maryland history. Appellants sought to hold SSA Security, Inc. responsible for the arsons, which were allegedly committed by one of SSA's security guards. The district court granted summary judgment for SSA. On appeal, the Fourth Circuit certified to the Court of Appeals of Maryland a question of law regarding the Maryland Security Guards Act. The Court of Appeals answered that the Act does not impose liability beyond common law principles of respondeat superior such that an employer may be responsible for off-duty criminal acts while he or she was on duty. Because Appellants thus could not satisfy the common law doctrine of respondeat superior, the First Circuit affirmed in full the district court’s grant of summary judgment in SSA’s favor. View "Antonio v. SSA Security, Inc." on Justia Law

Appellant pled guilty to one count of knowing possession of child pornography and was sentenced to sixty months’ imprisonment followed by a lifetime term of supervised release. The Fourth Circuit affirmed, holding (1) Appellant’s lifetime term of supervised release was procedurally reasonable because the sentencing judge satisfactorily explained the sentence at length; and (2) Appellant’s lifetime term of supervised release was substantively reasonable where it was necessary to deter Defendant, protect the public from additional crimes by him, and provide him with the mental health care and necessary corrective treatment he needed. View "United States v. Helton" on Justia Law

Page Bender Jr. worked as an underground coal miner for twenty-one years and suffered from a totally disabling respiratory condition. Bender filed a claim for black lung benefits. An administrative law judge (ALJ) applied to Bender’s claim the rebuttable presumption of total disability due to pneumoconiosis, under which the burden shifted to the coal mine operator to disprove Bender’s entitlement to benefits. The ALJ awarded black lung benefits to Bender based on the ALJ’s conclusion that the operator had failed to rebut the presumption by showing that Bender’s pneumoconiosis did not in any way contribute to his disability. The Benefits Review Board affirmed. The Fourth Circuit affirmed, holding (1) the Department of Labor acted within its regulatory authority in requiring the coal mine operator to show, where Bender met the statutory criteria for the presumption, that “no part of the miner’s respiratory or pulmonary total disability was caused by pneumoconiosis”; and (2) the ALJ’s decision was supported by substantial evidence. View "W. Va. CWP Fund v. Bender" on Justia Law

Plaintiff filed this diversity action alleging that he owned fractional working interests in four Ritchie County mining partnerships, which owned six oil and gas wells, and demanding an accounting of the four partnerships. Defendant counterclaimed for the cumulative operating expenses attributable to Plaintiff’s asserted working interests in the partnerships. The district court awarded summary judgment to Defendant, concluding that Plaintiff’s assertion of interests in the four mining partnerships failed because he could not produce a writing that evidenced his co-ownership of the subject leases or wells in conformance with the Statute of Frauds. The Supreme Court of West Virginia accepted the Fourth Circuit’s certified question of law and answered (1) if a person contends he owns an interest in a common-law mining partnership, the Statute of Frauds requires the person to prove he is a partner of the mining partnership through a written conveyance; and (2) if the partnership is a general partnership and the partnership owns oil and gas leases, the Statute of Frauds does not require a person to produce a written instrument to prove he is a partner in the general partnership. Having adopted the West Virginia Supreme Court’s opinion answering the Court’s certified question of law, the Fourth Circuit vacated the judgment of the district court and remanded. View "Valentine v. Sugar Rock, Inc." on Justia Law

After a jury trial, Defendant was convicted of three counts relating to marijuana trafficking and was sentenced to 121 months of incarceration. Defendant filed a motion to vacate his conviction and sentence, alleging that his trial and appellate counsel had provided ineffective assistance. The district court denied the motion. The Fourth Circuit affirmed, holding (1) Defendant was not prejudiced by his trial counsel’s failure to request an instruction that the jury find a drug weight based on the amount attributable to or reasonably foreseeable by Defendant; (2) Defendant was not prejudiced by his appellate counsel’s failure to raise the failure to request that instruction as an issue on direct appeal; and (3) Defendant’s trial counsel was not ineffective for failing to challenge the drug weight and advisory guidelines range at sentencing. View "United States v. Rangel" on Justia Law

This case involved a dispute between two clergymen, each of whom believed himself to be the proper leader of The Protestant Episcopal Church in the Diocese of South Carolina. Bishop Charles vonRosenberg brought this action against Bishop Mark Lawrence, alleging Lanham Act violations and seeking declaratory and injunctive relief. Bishop Lawrence asked the district court to abstain and stay this action pending resolution of related state court proceedings. The district court granted the motion to abstain and stayed the action, concluding that it had broad discretion to decline to grant declaratory relief under the abstention doctrine articulated in Brillhart v. Excess Insurance Co. of Am. and Wilton v. Steven Falls Co. The Fourth Circuit vacated the stay order, holding (1) Colorado River Water Conservation Dist. v. United States, which permits a federal court to abstain only in “exceptional” circumstances, properly governed the abstention question in this action; and (2) because the district court did not apply the correct abstention standard, the case is remanded for a determination of whether “exceptional” circumstances are present in this case. View "vonRosenberg v. Lawrence" on Justia Law

Georgia-Pacific Consumer Products LP commenced three separate actions against von Drehle Corporation or its distributors, alleging contributory trademark infringement. In the instant action, a jury found in favor of Georgia-Pacific and awarded Georgia-Pacific $791,431. The district court entered a permanent, nationwide injunction prohibiting von Drehle from infringing Georgia-Pacific’s trademark rights, trebled the jury’s award, awarded attorneys fees, and awarded prejudgment interest and court costs. In the two parallel actions, the district courts ruled against Georgia-Pacific. The Fourth Circuit vacated the district court’s injunction and award of attorneys fees and reversed its award of treble damages and prejudgment interest, holding (1) the Eighth and Sixth Circuits’ rulings against Georgia-Pacific rendered the district court’s injunction unduly broad, and the district court is instructed to narrow it to cover only the geographical area of the Fourth Circuit; and (2) the district court applied the wrong legal standards for trebling the jury award and for awarding attorneys fees and prejudgment interest. View "Georgia-Pacific Consumer Prods. LP v. von Drehle Corp." on Justia Law

Robert Johnson, a prison guard in Bishopville, South Carolina, was shot multiple times in his home in an attack ordered by an inmate at the prison where Johnson worked. The inmate had used a contraband cell phone to communicate with the shooter. Johnson and his wife (together, Plaintiffs) sued several cellular phone service providers and owners of cell phone towers (collectively, Defendants) in state court, seeking to recover under state law negligence and loss of consortium theories. Specifically, Plaintiffs alleged that Defendants were aware that their services facilitated the illegal use of cellphones by prison inmates and that this illegal use created an unreasonable risk of harm to others. Defendants timely removed the case to federal court. The federal district court concluded that it had jurisdiction over the complaint and granted Defendants’ motions to dismiss for failure to state a claim. The Fourth Circuit affirmed, holding that the district court (1) erred in finding the existence of federal question jurisdiction, but the court properly exercised diversity jurisdiction over Plaintiffs’ state law claims; and (2) correctly held that Plaintiffs’ claims failed to state a claim as a matter of law. View "Johnson v. American Towers, LLC" on Justia Law