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

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

The Professional Massage Training Center (PMTC) filed suit against the Accreditation Alliance of Career Schools and Colleges (ACCSC) after ACCSC denied PMTC’s application for re-accreditation. The district court entered judgment in favor of PMTC, finding that ACCSC had violated the school’s due process rights. The court awarded the school more than $400,000 in damages and ordered ACCSC to fully reinstate its accreditation. The Supreme Court reversed in part and affirmed in part, holding (1) the district court erred in conducting a de novo approach to the accreditation process; (2) judged by the correct standard of review, the accreditation decision was well supported and not arbitrary or capricious; and (3) the district court correctly dismissed PMTC’s state law claims for breach of contract, negligence, and tortious interference. Remanded. View "Prof’l Massage Training v. Accreditation Alliance of Career Schs." on Justia Law

After a jury trial, Appellant was convicted of first degree murder. The conviction was upheld on direct appeal. After unsuccessfully seeking habeas corpus relief in state court, Appellant filed a federal habeas petition alleging that he received ineffective assistance of counsel due to his trial counsel’s failure to request a jury instruction defining heat of passion. The district court denied the petition. The Fourth Circuit reversed, holding (1) the state habeas court’s denial of Appellant’s ineffective assistance claim was based on an unreasonable application of clearly established federal law set forth in Strickland v. Washington; and (2) Appellant’s counsel erred in failing to request the heat of passion jury instruction, and Appellant suffered prejudice as a result of this error. Remanded. View "Lee v. Clarke" on Justia Law

In the early 1980s, Georgia Power Company sold a number of its used electrical transformers to Ward Transformer Company (Ward). Because the electrical transformers contained toxic compounds that have been banned since 1979, Ward repaired and rebuilt the transformers for resale to meet third-party customers’ specifications. In the process, one of Ward’s facilities in Raleigh, North Carolina (the Ward Site) became contaminated. In the 2000s, the EPA initiated a costly removal action at the Ward Site. Consolidated Coal Company and PCS Phosphate Company, Inc. each paid more than $17 million in cleanup costs related to the Ward Site. In 2008 and 2009, they filed complaints under the Comprehensive Environmental Response, Compensation, and Liability Act against Georgia Power alleging that, as supplier of some of the transformers to Ward, Georgia Power should be liable for a contribution to those costs. The district court granted summary judgment for Georgia Power. The Fourth Circuit affirmed, holding that the circumstances of the transformer sales did not indicate Georgia Power’s intent to dispose of the toxic compounds and therefore did not support arranger liability. View "Consolidation Coal Co. v. Georgia Power Co." on Justia Law

This appeal arose from a convenience store robbery spree that occurred in Fayetteville, North Carolina over a four-day period in 2011. Appellants, three individuals, each plead guilty to Hobbs Act conspiracy and using and carrying a firearm during and in relation to a crime of violence. The district court sentenced all three Appellants to a combined sentence of 200 months. Appellants appealed, challenging both the procedural and substantive reasonableness of their sentences. The Fourth Circuit vacated and remanded for resentencing, holding that the sentences were procedurally unreasonable because the district court failed to explain its rejection of the Guidelines sentences and also failed to sufficiently explain the sentences imposed. View "United States v. Lymas" on Justia Law

Bonnilyn Mascio filed an application with the Social Security Administration for supplemental security income benefits, alleging that she was disabled from degenerative disc disease, carpal tunnel syndrome, and adjustment disorder. An administrative law judge (ALJ) found that Mascio was not disabled. The district court reversed. On remand, a second ALJ found that Mascio was not disabled and denied her application. The district court upheld the denial of benefits. The Fourth Circuit reversed, holding that the ALJ erred (1) in assessing Mascio’s residual functional capacity because he did not conduct a function-by-function analysis; (2) by not considering Mascio’s moderate limitation in her ability to maintain her concentration, persistence, or pace; and (3) by determining Mascio’s residual functional capacity before assessing her credibility. Remanded. View "Mascio v. Colvin" on Justia Law

Plaintiff filed suit against Officer R.R. Ray, alleging a violation of 42 U.S.C. 1983 claim for excessive force and a state-law claim for assault and battery. Ray filed a motion for summary judgment on the basis of qualified immunity. The district court denied the motion, concluding that a reasonable jury could find that Ray employed excessive force in detaining Plaintiff. Plaintiff appealed, arguing that the district court erred in denying his motion for summary judgment concerning the excessive-force claim. The Fourth Circuit affirmed, holding that the district court properly denied Ray’s summary judgment motion because Ray was not entitled to qualified immunity at this stage in the litigation. View "Smith v. Ray" on Justia Law

Oteria Moses borrowed $1,000 under a loan agreement that was illegal under North Carolina law. When Moses filed for Chapter 13 bankruptcy protection, CashCall, Inc., the loan servicer, filed a proof of claim. Moses subsequently filed an adversary proceeding against CashCall seeking a declaration that the loan was illegal and also seeking money damages for CashCall’s allegedly illegal debt collection activities. CashCall filed a motion to compel arbitration. The bankruptcy court denied CashCall’s motion to compel arbitration and retained jurisdiction over both Moses’ first claim for declaratory relief and second claim for damages. On appeal, the district court affirmed. The Fourth Circuit affirmed in part and reversed in part, holding that the district court (1) did not err in affirming the bankruptcy court’s exercise of jurisdiction to retain in bankruptcy Moses’ first claim; but (2) erred in retaining in bankruptcy Moses’ claim for damages and denying CashCall’s motion to compel arbitration of that claim, as this claim was not constitutionally core. Remanded with instruction to grant CashCall’s motion to compel arbitration on Moses’ second claim for damages. View "Moses v. CashCall, Inc." on Justia Law