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

Defendants in this case were three members of a violent street gang known as the Latin Kings who operated as part of the Greensboro, North Carolina chapter of the gang. After a jury trial, Defendants were convicted of conspiracy to violate the Racketeering Influenced and Corrupt Organizations Act based on their activities in connection with the gang. The Fourth Circuit affirmed, holding (1) the district court did not err in instructing the jury that the Government must prove the enterprise activity affected interstate in any way, “no matter how minimal”; (2) the district court did not err in its jury instruction requiring unanimity as to the types of racketeering acts that members of the conspiracy agreed to commit; (3) the district court did not abuse its discretion issuing two Allen charges; and (4) there was no error in the district court’s evidentiary rulings. View "United States v. Cornell" on Justia Law

Plaintiffs, a class of investors, filed this suit claiming that Chelsea Therapeutics International, LTD. and several of its corporate officers violated the Securities Exchange Act by making misleading statements and material omissions about the development and likelihood of regulatory approval for a new drug. The district court dismissed the claim under Fed. R. Civ. P. 12(b)(6), concluding that Plaintiffs’ securities fraud claims failed because their allegations were insufficient to establish that Defendants acted with the required scienter. The Fourth Circuit vacated the district court’s judgment dismissing Plaintiffs’ complaint, holding that the district court erred in (1) taking judicial notice of three documents filed with the Securities and Exchange Commission because those documents were not explicitly referenced in, or an integral part of, Plaintiffs’ complaint, and the error was not harmless; and (2) concluding that Plaintiffs’ allegations of scienter were insufficient as a matter of law, as, based on Defendants’ failure to disclose critical information about the weaknesses of the new drug application, Plaintiffs’ allegations were sufficient to support the required inference of scienter. Remanded. View "Zak v. Chelsea Therapeutics Int’l" on Justia Law

Plaintiff, who was African American and female, applied for two open positions with the Maryland Department of Transportation’s State Highway Administration (Highway Administration). Plaintiff was not selected for either position. Plaintiff filed this lawsuit, alleging that the Highway Administration refused to her hire her because of her race and her sex in violation of Title VII of the Civil Rights Act. The district court dismissed the complaint for failure to state a claim, concluding that Plaintiff failed to plead adequate facts to give rise to a reasonable inference of discrimination. The Fourth Circuit affirmed, holding (1) the district court improperly applied the evidentiary standard set forth in McDonnell Douglas Corp. v. Green in analyzing the sufficiency of Plaintiff’s complaint; but (2) the court nevertheless reached the correct conclusion because Plaintiff failed to include adequate factual allegations to support a claim that the Highway Administration discriminated against her because she was African American or female. View "McCleary-Evans v. Md. Dep’t of Transp." on Justia Law

As part of a grand jury investigation, the grand jury issued a subpoena to Appellant requiring her to produce certain records. When she failed to produce all of the requested documents, the government moved for an order to show cause as to why Appellant should not be held in contempt for failing to comply with the subpoena. At the show-cause hearing, Appellant testified that she did not produce other materials responsive to the subpoena because of the advice of her attorney. The district court ultimately found Appellant guilty of criminal contempt. Appellant appealed, arguing that the district court violated her due process rights by requiring her to prove her advice-of-counsel defense, a burden she claimed belonged to the government. The Fourth Circuit affirmed the conviction, holding that the district court did not improperly shift the burden of proof to Appellant. View "United States v. Westbrooks" on Justia Law

Plaintiff, a former inmate in the Virginia Department of Corrections facilities, filed numerous complaints about repeated physical and sexual abuse he suffered while imprisoned in the facilities. Plaintiff brought suit against various prison officials alleging violations of his right under the Eighth Amendment to be free from cruel and unusual punishment. The magistrate judge found that Defendants should have been more diligent in handling Plaintiff’s complaints but recommended that because Defendants did not actually know of the substantial risk of harm Plaintiff faced, his claims failed. The district court adopted in its entirety the findings and recommendation of the magistrate judge. The Fourth Circuit vacated the dismissal of Plaintiff’s claims against certain defendants, holding that the magistrate judge and district court failed to appreciate that the subjective “actual knowledge” standard required to find prison officials deliberately indifferent to a substantial risk of serious injury may be proven by circumstantial evidence that a risk was so obvious that it had to have been known. Remanded. View "Makdessi v. Fields" on Justia Law

Plaintiff, a deputy clerk at a courthouse in New Hanover County, North Carolina, was assigned to provide customer service at the courthouse front counter. Plaintiff requested to be assigned to a role with less direct interpersonal interaction, believing that her alleged social anxiety disorder hindered her ability to perform her job. Three weeks later, Plaintiff’s employer terminated her. Plaintiff sued her employer, alleging violations of the Americans with Disabilities Act. The district court granted summary judgment in favor of the employer. The Fourth Circuit reversed, holding that the district court erred by resolving disputed facts in favor of the movant and improperly resolved factual issues at the summary judgment stage in contravention of well-settled law. Remanded for trial. View "Jacobs v. N.C. Admin. Office of the Courts" on Justia Law

After a jury trial, Appellants, four individuals, were convicted of multiple offenses arising from a string of robberies they committed in December 2012. The Fourth Circuit affirmed the convictions, holding (1) the trial judge did not abuse his discretion or violate the Federal Rules of Evidence by admitting certain evidence; (2) assuming the admission of evidence recovered from one appellant’s cell phone violated the Sixth Amendment where not everyone in the phone’s chain of custody testified at trial, the error was harmless beyond a reasonable doubt; and (3) there was sufficient evidence to convict Appellants on every charged offense. View "United States v. Reed" on Justia Law

The Washington Metropolitan Area Transit Authority (WMATA) operates the Metrorail and Metrobus systems in Washington, D.C., Maryland, and Virginia and employs a police force, the Metro Transit Police Department (MTPD). The Fraternal Order of Police (FOP) is the bargaining agent for MTPD officers. WMATA fired two MTPD officers, but the Board of Arbitration overturned both discharges and ordered WMATA to reinstate the officers. WMATA reinstated the officers, but as a result of their initial terminations, the officers lost the certifications to serve as police officers in Maryland. Consequently, WMATA discharged the officers for a second time. The FOP filed this action in federal court on behalf of each officer, alleging that WMATA failed to comply with the arbitration awards. The district court granted summary judgment for the FOP. The Fourth Circuit reversed, holding (1) WMATA’s decision to terminate the officers for a second time did not violate the earlier arbitration awards; and (2) the officers’ grievances belonged before the Board of Arbitration, not a federal court. View "Fraternal Order of Police v. Washington Metro. Area Transit Auth." on Justia Law

A written state policy mandates that all persons sentenced to death in Virginia be confined on “death row” while awaiting execution. Inmates on death row live in separate single cells, with minimal visitation and recreational opportunities. After incarceration on Virginia’s death row for almost six years, Plaintiff brought this 42 U.S.C. 1983 action alleging that his confinement on death row violated his procedural Due Process rights and seeking injunctive relief. The district court granted summary judgment for Plaintiff and issued an injunction ordering Virginia prison officials to either alter the policy or to improve the conditions. The Fourth Circuit reversed, holding (1) contrary to Plaintiff’s contention, harsh and atypical confinement conditions in and of themselves do not give rise to a liberty interest in their avoidance; and (2) Plaintiff failed to point to a Virginia law or policy providing him with an expectation of avoiding the conditions of his confinement and failed to establish that those conditions imposed an atypical and significant hardship in relation to the ordinary incidents of prison life. View "Prieto v. Clarke" on Justia Law

Despite having only a few hundred dollars in her checking account at SunTrust Bank, Appellant cut herself a check for nearly $10,000, resulting in a sizable overdraft. SunTrust hired a Maryland law firm, Mitchell Rubenstein & Associates (MR&A) to bring a debt collection suit. MR&A filed suit on SunTrust’s behalf in a general district court in Virginia. The general district court entered judgment in favor of MR&A. Appellant subsequently filed a complaint against SunTrust and MR&A (collectively, Appellees), alleging that Appellees violated Maryland consumer protection laws and that MR&A violated the Fair Debt Collection Practices Act. The federal district court dismissed Appellant’s suit for failure to state a claim. The Fourth Circuit affirmed, holding that the district court did not err in finding that the counts alleged in Appellant’s complaint failed to state a claim for relief. View "Elyazidi v. SunTrust Bank" on Justia Law