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

Plaintiff collapsed with exertional heatstroke while practicing as a member of the Towson University football team. Plaintiff was in a coma for nine days, almost died, and suffered multi-organ failure, requiring a liver a transplant and numerous additional surgeries. Plaintiff subsequently recovered and pursued his plan to return to playing football. However, the Team Physician, a board-certified sports medicine doctor, concluded that allowing plaintiff to participate in the football program at the University presented an unacceptable risk of serious reinjury or death. Plaintiff filed suit against the University, alleging that its decision to exclude him from the football program amounted to a violation of Title II of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., and Section 504 of the Rehabilitation Act, 29 U.S.C. 701 et seq. The district court entered judgment against the University. The court reversed, concluding that plaintiff was not “otherwise qualified” to participate fully in the University’s football program because the University reasonably applied its Return-to-Play Policy. The court was required to give deference to the University's judgment. The court did not reach the University's challenge to the district court's evidentiary rulings. View "Class v. Towson Univ." on Justia Law

This appeal stemmed from a disagreement between CoreTel and Verizon over interconnection agreements (ICAs) under the Telecommunications Act of 1996, 47 U.S.C. 151 et seq. CoreTel disputes the district court’s determination that it owes Verizon $227,974.22 for the use of Verizon’s telecommunications facilities and $138,724.47 in late-payment fees. The court concluded that the district court did not violate the court's own mandate in CoreTel I by awarding as damages any total element long-run incremental cost (TELRIC)-based facilities charges at all; the district court did not err in calculating the total amount owed; and the district court did not err in calculating the late fees CoreTel owes under the ICAs. Accordingly, the court affirmed the judgment. View "CoreTel Virginia, LLC v. Verizon Virginia, LLC" on Justia Law

Petitioners seek review of the Board's 2014 decision affirming an award of black lung benefits to Arvis R. Toler. Petitioner contends that, by applying the fifteen-year rebuttable presumption to Toler’s second claim for benefits, the ALJ contravened the Black Lung Benefits Act, 30 U.S.C. 901-945, and its regulations, as well as principles of finality and separation of powers. The court concluded that, the text of the statute and regulations, as well as the preamble to the 2000 Final Rule, demonstrate that the fifteen-year presumption applies to subsequent claims and may be used to establish a change in an applicable condition of entitlement. Therefore, the court rejected petitioner's contention that the ALJ contravened either the Act or the applicable regulations by applying the fifteen-year presumption to Toler’s second claim. The court also rejected petitioner's remaining constitutional contention that utilization of the fifteen-year presumption to decide Toler’s second claim contravened constitutional principles of separation of powers. Accordingly, the court denied the petition for review. View "Eastern Associated Coal Corp. v. DOWCP" on Justia Law

Defendant appealed his conviction of knowingly employing, using, persuading, inducing, enticing, or coercing a minor in sexually explicit conduct, for the purpose of producing a visual depiction of that conduct, in violation of 18 U.S.C. 2251(a). The court held that the government adduced insufficient evidence to show that defendant acted for the purpose of producing a visual depiction. In this case, defendant's use of a cell phone to take pictures does not support a finding of purpose. Therefore, the district court erred in denying defendant’s motion for judgment of acquittal. The court reversed and vacated the conviction. View "United States v. Palomino-Coronado" on Justia Law

Defendant plead guilty to possession of a firearm by a convicted felon and was sentenced to 188 months' imprisonment under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e). On appeal, defendant argued that because the predicate offenses were not charged in the indictment in this case, his conviction for simply violating section 922(g)(1) did not support the sentence imposed, violating his Fifth and Sixth Amendment rights. Defendant also argued that his 1998 South Carolina convictions for second-degree burglary did not qualify as “violent felonies” under the ACCA. Although the court concluded that defendant's first argument is foreclosed by Almendarez-Torres v. United States, the court concluded that the evidence that the government offered with respect to at least four of his five burglary convictions did not show that they qualified as “violent felonies” under ACCA because the government was unable to demonstrate that the object of each conviction was necessarily a building or structure, as distinct from a vehicle, boat, or airplane. Accordingly, the court affirmed the conviction but vacated the sentence, remanding for resentencing. View "United States v. McLeod" on Justia Law

Petitioner, convicted of crimes related to his armed robbery of a Domino's Pizza, challenged the district court's application of a sentencing enhancement for obstructing the administration of justice under U.S.S.G. 3C1.1. The court concluded that the district court did not erroneously find that defendant knowingly presented false testimony at his trial. In this case, the district court found that the alibi testimony from defendant's girlfriend and her mother, placing him in a different location than the crime scene, could only have been patently false. Accordingly, the court affirmed the district court's application of the sentencing enhancement. View "United States v. Andrews" on Justia Law

Plaintiff filed suit against the police department and three of its former detectives for damages under 42 U.S.C. 1983, alleging that the police and prosecution withheld evidence in violation of Brady v. Maryland during plaintiff's 1982 murder trial. The district court dismissed the case under Heck v. Humphrey. The court affirmed the judgment, concluding that this case involves section 1983 claims that are predicated on alleged Brady violations which would, if proven, necessarily imply the invalidity of plaintiff's convictions. Those convictions have not been reversed on direct appeal, expunged by executive order, declared invalid by a state tribunal, or called into question by a federal court's issuance of a writ of habeas corpus. Therefore, under Heck, they may not be collaterally attacked through section 1983 now. The court concluded that the fact that plaintiff is no longer in custody does not change this result. Finally, plaintiff has identified no impediment to habeas access warranting an expansion of the Heck exception. View "Griffin v. Baltimore Police Dept." on Justia Law

The Government appealed the district court's grant of defendant's motion to suppress evidence stemming from a warrantless search of defendant's vehicle. The court concluded that the absence of probable cause to arrest defendant for any offense at the moment the trooper decided to continue the search without defendant's consent renders the search incident to arrest exception inapplicable in this case. The court also concluded that the automobile exception is inapplicable in this case because the exception requires that the police have probable cause, not just reasonable articulable suspicion. Finally, the same credibility determination by the district court that precludes application of the search incident to arrest exception also thwarts the Government’s collective-knowledge argument. Accordingly, the court affirmed the judgment. View "United States v. Patiutka" on Justia Law

After defendant plead guilty to a three-count indictment for drug-related offenses, defendant appealed the district court's denial of his motion to suppress evidence. The court concluded that, viewed in their totality, the factors cited by the district court do not amount to reasonable suspicion to justify defendant’s seizure. In this case, the officer did not articulate why defendant's explanation for his presence in the parking lot and the activity accompanying it - both seemingly innocent acts - were likely to be indicative of some more sinister activity. Ultimately, this seizure had no connection with the individual seized, the activity he was involved in, his mannerisms, or his suspiciousness; rather the seizure was a mere happenstance of geography. Therefore, the district court erred in denying the motion to suppress and the court reversed the judgment, vacated the conviction and sentence, and remanded for further proceedings. View "United States v. Slocumb" on Justia Law

Relator filed suit against PHEAA and other private and state-created student-loan entities under the False Claims Act (FCA), 31 U.S.C. 3729-33, alleging that defendants fraudulently claimed hundreds of millions of dollars in federal student-loan interest-subsidy payments to which they were not entitled. At issue on appeal is whether PHEAA qualifies as an “arm of the state” or “alter ego” of Pennsylvania such that it cannot be sued under the FCA. The court concluded that PHEAA is an independent political subdivision, not an arm of Pennsylvania, and therefore PHEAA is a "person" subject to liability under the FCA. Accordingly, the court reversed the district court’s order granting summary judgment in favor of PHEAA and remanded for further proceedings on the merits of relator’s FCA claims against PHEAA. View "US ex rel. Oberg v. PHEAA" on Justia Law