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

In the case, Remy Holdings International, LLC ("Remy") sued Fisher Auto Parts, Inc. ("Fisher") after Fisher terminated their business relationship and sold its inventory to a different manufacturer. Remy claimed that Fisher wrongfully terminated their agreement and that the inventory Fisher sold belonged to Remy. Remy brought claims for breach of contract, unjust enrichment, and conversion. Fisher counterclaimed for breach of contract due to Remy's poor performance.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decisions, which were all in Fisher's favor. The court found that Remy committed the first material breach of the contract by failing to keep Fisher competitive in the marketplace. Furthermore, Fisher did not waive its right to assert the first material breach defense by continuing to order from Remy and occasionally waiving the order-fill penalty. Therefore, Remy was precluded from enforcing the contract and its breach of contract claim related to ownership of the inventory was dismissed.The court also rejected Remy's argument that the district court should have reinstated its unjust enrichment claim after declaring its contractual rights unenforceable. Remy had failed to respond to Fisher's motion for summary judgment seeking the dismissal of the unjust enrichment claim, and as a result, forfeited any opposition to its dismissal.Lastly, the court found no error with the district court's evidentiary rulings, including the admission of expert testimony and the USA Core Policy, and its refusal to instruct the jury on certain defenses. View "Remy Holdings International, LLC v. Fisher Auto Parts, Inc" on Justia Law

In a case before the United States Court of Appeals for the Fourth Circuit, a foreign service officer and a non-citizen were convicted of conspiring to fraudulently obtain U.S. citizenship for the non-citizen and making false statements in the process. The defendants, Laura Anne Gallagher and Andrey Nikolayevich Kalugin, were married in 2015. They were accused of conspiring to achieve naturalization and proof of citizenship for Kalugin by making false statements and submitting fraudulent documents. The jury found them guilty on all counts. On appeal, the court concluded that the evidence was sufficient to support each defendant’s convictions. However, it found that the jury was allowed to consider a legally inadequate theory on one count and an erroneous evidentiary ruling prevented the defendants from offering certain evidence on the remaining two counts. As a result, the court vacated the convictions and remanded the case for further proceedings. View "US v. Gallagher" on Justia Law

In this case, Jordan Jones, a prisoner at North Carolina’s Avery-Mitchell Correctional Institution, sued multiple prison officials under § 1983. The suit challenged the conditions of his confinement and a transfer to another prison that he alleged was retaliatory. The United States Court of Appeals for the Fourth Circuit affirmed in part and reversed in part the district court's grant of summary judgment to the defendants.Jones had been placed in a “dry” cell, with the water turned off, for about 17 hours after he was suspected of having ingested contraband. He was allowed to clean himself only with toilet paper, despite having to defecate three times in a portable toilet. He also had to eat a meal with his hands, which he was unable to wash. The court concluded that while the conditions of Jones's confinement were deplorable, the officials were entitled to qualified immunity on this claim because it was not clearly established in April 2015 that these conditions posed a substantial risk of serious harm in violation of the Eighth Amendment.However, the court reversed the district court's grant of summary judgment to defendant Gregory Taylor on Jones's claim that his transfer to another prison was in retaliation for his filing of grievances. The court concluded that a reasonable jury could find that Taylor ordered the transfer in retaliation for Jones's grievances, and that Taylor was not entitled to qualified immunity on this claim because it was clearly established at the time of the transfer that such retaliation violated the First Amendment. The court remanded for further proceedings on this claim. View "Jones v. Solomon" on Justia Law

In this case from the United States Court of Appeals for the Fourth Circuit, the plaintiff, Frank Morgan, appealed from a decision of the United States District Court for the Southern District of West Virginia. Morgan alleged that a police officer, J.D. Tincher, used excessive force during his arrest and subsequent detention, causing him serious injuries. The case proceeded to a jury trial, and the jury found in favor of Officer Tincher.However, after presenting his case, Morgan discovered another lawsuit against Officer Tincher, involving similar allegations of excessive force, which Tincher had failed to disclose during discovery. Morgan requested sanctions and moved for a new trial under Federal Rule of Civil Procedure 60(b)(3), alleging misconduct by the opposing party. The district court denied the motion, leading to this appeal.In its decision, the Fourth Circuit held that Officer Tincher's failure to disclose the other excessive-force lawsuit constituted misconduct under Rule 60(b)(3). It also found that Morgan had presented a meritorious claim and that the misconduct prevented him from fully presenting his case. The court further concluded that the district court had erred in its analysis of whether the undisclosed evidence would have changed the trial outcome. Lastly, the court ruled that the interest of justice in this case outweighed the interest in the finality of judgments.Therefore, the Fourth Circuit reversed the district court's decision, vacated the final judgment in favor of Officer Tincher, and remanded the case to the district court with instructions to allow for a reasonable period of additional discovery before conducting a new trial. View "Morgan v. Tincher" on Justia Law

In the case before the United States Court of Appeals for the Fourth Circuit, Gregory Kelly, the former Town Manager of Abingdon, Virginia, sued the Town for discrimination, retaliation, interference, and failure to accommodate under the Americans with Disabilities Act (ADA). Kelly alleged that he suffers from anxiety, depression, and high blood pressure, and these conditions worsened due to a hostile work environment created by the elected Mayor and Town Council. He further alleged that, despite his efforts to seek accommodations for his disabilities, the Town failed to engage in a meaningful dialogue to determine appropriate accommodations, and instead escalated its pattern of harassment.The Court of Appeals affirmed the lower court's dismissal of Kelly's discrimination and interference claims, along with its ruling that a letter Kelly sent to the Town in January 2018 was not an ADA accommodation request. The court reasoned that although Kelly had informed the Town of his disabilities and it was aware of them, the January 2018 letter, despite being titled "Accommodations Requests," did not make it clear that Kelly was seeking accommodations for his disabilities. The requests in the letter were not connected to Kelly's disabilities and were more related to general workplace issues. Therefore, the letter did not trigger the Town's duty to engage in an interactive process to determine appropriate accommodations under the ADA.The Court also found that Kelly failed to state a claim for ADA discrimination. He did not provide any facts suggesting that the Town had a discriminatory motive or that his disability was a "but-for" cause of his constructive discharge. The Court further held that Kelly failed to state a claim for ADA interference, as he did not allege that the Town engaged in behavior to prevent him from exercising his ADA rights or that the Town had a discriminatory motive. View "Kelly v. Town of Abingdon" on Justia Law

In the case before the United States Court of Appeals for the Fourth Circuit, the defendant, Keyon Paylor, appealed from the decision of the United States District Court for the District of Maryland, which denied his petition to vacate his conviction for being a felon in possession of a firearm. Paylor had entered a guilty plea, which he later sought to vacate, asserting that his plea was not knowing and voluntary. He claimed that law enforcement officers involved in his arrest planted the firearm and stole thousands of dollars from him, and that his plea was induced as a result of egregious law enforcement misconduct. The district court denied his petition, concluding that Paylor did not produce enough evidence to establish that information regarding former Detective Daniel Hersl’s misconduct materially influenced his decision to plead guilty. The Court of Appeals disagreed with the district court's decision and vacated it, concluding that Paylor is entitled to discovery and an evidentiary hearing in order to attempt to gather evidence to support his claim. The case was remanded back to the district court for further proceedings. View "US v. Paylor" on Justia Law

In this case, Eric Henderson, a convicted felon, was charged with one count of possession of a firearm, violating 18 U.S.C. § 922(g)(1). Henderson pleaded guilty to the charge, but objected to the sentencing enhancements applied by the district court. The United States Court of Appeals for the Fourth Circuit reversed the district court's decision and remanded the case for resentencing.The court held that the district court erred in applying a four-level sentencing enhancement under § 2K2.1(b)(6)(B) of the United States Sentencing Guidelines. This enhancement was based on Henderson's possession of a firearm "in connection with another felony offense," namely, possession of a firearm while under a domestic violence protective order. The court noted that a person cannot be punished more severely for violating multiple provisions of § 922(g) with the same act of possession.The court also ruled that the district court made a mistake in applying a two-level enhancement under § 3C1.2 of the Sentencing Guidelines for reckless endangerment during flight. The court found that Henderson's conduct did not meet the definition of recklessness as established by prior court decisions, which require "flight-plus-something more" for the enhancement to apply. In Henderson's case, there was insufficient evidence to demonstrate reckless behavior or substantial risk of death or serious bodily injury during his flight. View "US v. Henderson" on Justia Law

In this case, Daniel N. Kemp, Sr. was charged with nine counts of sexually abusing his adopted children. Kemp pleaded guilty to one count of aggravated sexual abuse under a plea agreement and the remaining charges were dismissed. The United States District Court for the Eastern District of North Carolina sentenced Kemp to life imprisonment and a lifetime term of supervised release. Kemp appealed his conviction and sentence. On appeal, the United States Court of Appeals for the Fourth Circuit affirmed Kemp's conviction. The court found that the district court's plea colloquy did not comply with Rule 11 of the Federal Rules of Criminal Procedure in multiple respects, but Kemp failed to demonstrate a reasonable probability that, but for the error, he would not have entered the plea. As for Kemp's sentence, the Court of Appeals found that the district court improperly failed to orally pronounce multiple discretionary conditions of supervised release that it subsequently imposed in Kemp's written judgment. This constituted error under United States v. Rogers, 961 F.3d 291 (4th Cir. 2020), violating Kemp's right to be present at sentencing. Therefore, the Court of Appeals vacated Kemp's sentence and remanded for the district court to resentence the defendant. View "US v. Kemp" on Justia Law

In this appeal to the United States Court of Appeals for the Fourth Circuit, James Dow Vandivere challenged a district court decision denying his motion for release from civil commitment under the Adam Walsh Act. Vandivere, who had been convicted of multiple crimes involving the sexual exploitation of minors and sentenced to almost twenty years in prison, was nearing the end of his sentence when the government moved to civilly commit him. The government argued, and the district court agreed, that Vandivere remained sexually dangerous. Vandivere filed a motion for discharge and, following a hearing, the district court found he remained sexually dangerous and denied his motion. Vandivere appealed, arguing that he was wrongly forced to bear the burden of proof at the hearing and that the district court erred in determining that he remained sexually dangerous.The Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The appellate court found that under the Adam Walsh Act, the burden of proof at an Adam Walsh Act discharge hearing is on the detainee to show his recovery by a preponderance of the evidence. The court also found this allocation of burden does not violate the detainee’s due process rights. Further, the appellate court found no error in the district court's conclusion that Vandivere remained sexually dangerous, stating that the district court had appropriately considered Vandivere's behavior while in custody, his persistent cognitive distortions about sexual abuse, his refusal to participate in sex offender therapy, and his proposed release plan. View "US v. Vandivere" on Justia Law

In the United States Court of Appeals for the Fourth Circuit, the case involved defendant Glenda Taylor-Sanders, a licensed insurance agent, who pleaded guilty to one count of wire fraud. Taylor-Sanders had used her position to defraud several trucking companies and an insurance finance company, BankDirect Capital Finance, by misappropriating funds meant for insurance premiums and obtaining loans under the guise of non-existent insurance policies. She used the funds for personal expenditures, leading to the lapse of some of the trucking companies' insurance policies.In her plea agreement, Taylor-Sanders agreed to pay full restitution to all victims harmed by her relevant conduct, and she waived all rights to contest the conviction and sentence in any appeal, unless it was due to ineffective assistance of counsel or prosecutorial misconduct. However, she later attempted to withdraw her guilty plea, arguing that she didn't fully understand the implications of her plea and that she never acted with the requisite intent to defraud. The district court denied her motion to withdraw the plea, concluding that her claim was not credible and that she had not provided a fair and just reason to withdraw her guilty plea.After being sentenced to 66 months' imprisonment and ordered to pay over $700,000 in restitution, Taylor-Sanders appealed her conviction, sentence, and the restitution order. She argued that her guilty plea wasn’t knowing and voluntary, that the district court miscalculated her offense level, and that the district court made several errors when awarding restitution.The Court of Appeals found that Taylor-Sanders's guilty plea and plea waiver were valid and the issues she raised on appeal fell within the scope of her appeal waiver. The court distinguished between claims that a sentence is "illegal" because the district court lacked the authority to issue the sentence (which remain reviewable despite an appeal waiver) and claims that a sentence was "imposed in violation of law" because it has otherwise merely "been touched by a legal error" (in which case the court will enforce the appeal waiver). The court dismissed Taylor-Sanders's appeal in its entirety. View "US v. Taylor-Sanders" on Justia Law