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

Defendants appealed their convictions related to their participation in a conspiracy to traffic in khat, a plant containing the controlled substance cathinone. The court concluded that the district court did not err in instructing the jury on scienter; the district court did not abuse its discretion by giving a willful blindness instruction; the evidence was sufficient to convict defendants of conspiring to traffic in the controlled substance of cathinone; the court affirmed the district court's two procedural rulings at issue; and because the court concluded that Count 2 adequately informed defendants of the money laundering charges against them and provided sufficient detail to enable them to plead an acquittal or conviction in bar of future prosecution for the same offense, the court rejected defendants' challenge. Accordingly, the court affirmed the judgment of the district court. View "United States v. Ali" on Justia Law

Defendant appealed from his sentence for being a felon in possession of a firearm, arguing that the district court erred in sentencing him as an armed career criminal based on violent felonies he committed. Defendant relied on Miller v. Alabama, which held that the Eighth Amendment forbids a sentencing scheme that mandated life in prison without possibility of parole for juvenile offenders. The court found Miller inapplicable in this instance where defendant's sentence punished him for an offense he committed at the age of thirty-three. Accordingly, the court affirmed the sentence. View "United States v. Hunter" on Justia Law

Plaintiff filed suit against Prudential, the plan administrator, and BioMerieux, her employer, after Prudential denied her long-term disability and short-term disability benefits. The district court entered summary judgment in favor of Prudential and BioMerieux. Plaintiff appealed. The court concluded that the language at issue in both plans was ambiguous and did not clearly confer discretionary decision-making authority on the plan administrator. Therefore, the administrator's eligibility determinations denying benefits to a covered employee were subject to de novo judicial review, and the district court erred in reaching a contrary conclusion. The court further held that the district court erred in concluding that the employer's group insurance plan required objective proof of disability in order for an employee to qualify for plan benefits. Accordingly, the court vacated and remanded for further proceedings. View "Cosey v. The Prudential Ins. Co." on Justia Law

Plaintiff filed suit against officers under 42 U.S.C. 1983, as well as state law claims, after plaintiff was shot by the officers. Plaintiff, after hearing sounds of unknown persons outside his home, opened the front door carrying a shotgun and was shot by the officers. The court concluded that it had jurisdiction under the collateral order doctrine. The district court did not err in denying the officers qualified immunity from plaintiff's excessive force claims under section 1983 where a reasonable officer would not have had probable cause to feel threatened by plaintiff's actions and the constitutional right at issue - the right to be free from deadly force when posing no threat - was clearly established at the time the officers shot plaintiff. Accordingly, the court affirmed the district court's judgment as to the section 1983 claims. The court also affirmed the district court's denial of public officers' immunity with respect to plaintiff's state law tort claims. View "Cooper, Sr. v. Sheehan" on Justia Law

DynCorp contracted with the U.S. Department of State to assist in the development of a civilian police force in Iraq and subcontracted with PMC for operations and maintenance support. PMC filed suit against DynCorp alleging that DynCorp breached its contract with PMC by making payments to one account instead of another. The court affirmed the district court's dismissal of PMC's case against DynCorp as a sanction for its discovery malfeasance. The court rejected PMC's arguments on appeal because they did not support reversal of the district court's orders. View "Projects Mgmt. Co. v. DynCorp Int'l LLC" on Justia Law

Plaintiff filed suit against the government, seeking a refund of payments on a federal withholding tax penalty assessed against her under 26 U.S.C. 6672. The government counterclaimed against plaintiff and her husband to reduce to judgment the remaining balance of the trust fund recovery penalties assessed against them. The district court granted summary judgment to the government. The court affirmed the district court's grant of summary judgment against the husband individually where he did not provide a basis of law for his contention that the assessment of the 100% penalty against him was not made within the limitation period set forth in section 6672; affirmed the district court's grant of summary judgment against plaintiff because the undisputed record showed that she was properly liable for the 100% penalty where she was a "responsible person" under section 6672 during the relevant tax periods and where she "willfully" failed to see that the withholding taxes were paid; and affirmed the district court's determination of the amounts of the respective tax liabilities under section 6672. View "Johnson v. United States" on Justia Law

Defendant convicted of distributing crack cocaine, appealed his sentence. The court concluded that the district court did not err in relying on multiple hearsay information to determine defendant's drug quantity for sentencing purposes and did not abuse its discretion in calculating defendant's drug quantity for sentencing purposes. Defendant's remaining claim lacked merit. Accordingly, the court affirmed the sentence. View "United States v. Crawford" on Justia Law

Plaintiff, a state prisoner, filed suit challenging the constitutionality of 42 U.S.C. 1997e(d)(2), a part of the Prison Litigation Reform Act of 1995 (PLRA), as violating his right to equal protection of the laws under the Fifth Amendment's Due Process Clause. Plaintiff challenged a provision that caps the attorneys' fee award that a successful prisoner litigant could recover from the government in a civil rights action at 150 percent of the value of the prisoner's monetary judgment. The court declined to apply heightened equal protection scrutiny in this case and joined its sister circuits in concluding that section 1997e(d)(2) was constitutional. Congress's goals in enacting section 1997e(d)(2) included reducing marginal or frivolous prisoner civil rights lawsuits and protecting the public fisc. Such goals were legitimate and Congress acted rationally in adopting the provision. Accordingly, the court affirmed the judgment of the district court. View "Wilkins v. Gaddy" on Justia Law

Defendant pleaded guilty to being a felon in possession of a firearm and ammunition and was sentenced under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e). On appeal, defendant argued that the district court erred in relying on his 2002 South Carolina conviction for the common law crime of assault and battery of a high and aggravated nature (ABHAN) to impose a mandatory fifteen-year minimum. The court concluded that ABHAN was not categorically a violent felony and that the modified categorical approach played no part in this matter. Accordingly, the court vacated and remanded for resentencing. View "United States v. Hemingway" on Justia Law

Defendant appealed his sentence after pleading guilty to one count of Possession of Child Pornography. The court concluded that the district court improperly applied the five-level sentencing enhancement under U.S.S.G. 2G2.(b)(3)(B), which resulted in improper calculation of defendant's sentencing range. The court declined to adopt the Government's proposed reciprocity rule by applying the enhancement to every Gigatribe distribution offense absent any evidence of the particular defendant's state of mind. The district court's reliance on an improperly calculated sentencing range constituted significant procedural error and the error was not harmless. Accordingly, the court vacated and remanded for resentencing. View "United States v. McManus" on Justia Law