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

In these consolidated appeals, Chevron sought documents from two Maryland-based attorneys who assisted the lead attorney representing Ecuadorian plaintiffs in a multi-billion dollar judgment rendered in Ecuador against Chevron. The district court ordered production of the requested documents and the attorneys appealed. The court dismissed appeal number 13-1382 based on lack of subject matter jurisdiction to hear the appeal from the district court's order on Chevron's Rule 45 subpoenas because the finality rule prohibits such an interlocutory appeal, and affirmed the lower court's judgment in appeal number 13-2028 under 28 U.S.C. 1872 based on the lead attorney's waiver and two other independent bases to permit discovery of the documents at issue. View "Chevron Corp. v. Page" on Justia Law

The EEOC filed suit alleging that an employee retirement benefit plan maintained by the County discriminated against employees in the protected age group of 40 years of age and older, in violation of the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621-634, by requiring them to pay high contribution rates than those paid by younger employees. In this interlocutory appeal, the court held that the district court correctly determined that the County's plan violated the ADEA, because the plan's employee contribution rates were determined by age, rather than by a permissible factor. The court also concluded that the ADEA's "safe harbor provision" applicable to early retirement benefit plans did not shield the County from liability for the alleged discrimination. Accordingly, the court affirmed the district court's award of summary judgment on the issue of liability and remanded for consideration of damages.View "EEOC v. Baltimore County, Maryland" on Justia Law

Debtors filed a voluntary petition for relief under Chapter 13 of the Bankruptcy Code. At issue was whether above-median-income debtors with negative disposable income were obligated to maintain Chapter 13 bankruptcy plans that last for five years when their unsecured creditors have not been paid in full. The court held that a plain reading of the Bankruptcy Code, and Section 1325 in particular, mandates that an above-median-income debtor maintain a bankruptcy plan for five years unless all unsecured creditor claims are paid in full and irrespective of projected disposable income. Debtors, as above-median-income debtors, were obligated to maintain a five-year plan. The bankruptcy court therefore did not err in deeming the early termination language in debtors' proposed plan void as a matter of law and in extending the duration of debtors' proposed plan. The court affirmed the bankruptcy court's order but remanded in order for debtors to have an opportunity to present evidence regarding the feasibility of their monthly payments. View "Pliler v. Browning" on Justia Law

Dickenson Coal contested a citation by the Secretary of Labor for violating the Federal Mine Safety and Health Act of 1977, Pub. L. No. 95-164, 91 Stat. 1290, by failing to report an injury at one of its mines within ten days of its occurrence. The ALJ awarded summary judgment in the Secretary's favor and the Commission declined to exercise discretionary review of the ALJ's decision. Dickenson Coal petitioned for review. The court concluded that the unambiguous language of 30 C.F.R. 50.20(a) imposed an unconditional duty upon Dickenson Coal to report the injury within ten days. Dickenson Coal was not relieved of this duty when the injured person's employer timely reported the incident. Accordingly, the court denied the petition for review.View "Dickenson-Russell Coal Co. v. Secretary of Labor" on Justia Law

Defendants McLaurin and Lowery appealed their convictions and sentences for conspiracy and firearms charges related to their involvement in a plan to rob a drug "stash house." The court concluded that the district court did not err in giving the jury supplemental instructions clarifying the term "inducement" on defendants' entrapment defense; the district court did not abuse its discretion in admitting evidence of prior bad acts under Rule 404(b); the district court did not err in determining that the conspiracy and felon-in-possession offenses were properly joined; even if the counts were improperly joined, the misjoinder caused no actual prejudice to McLaurin; and the court exercised its discretion to correct the plain error in calculating McLaurin's Guidelines' range by vacating his sentence and remanding for resentencing. Accordingly, the court affirmed the convictions but vacated McLaurin's sentence and remanded for resentencing. View "United States v. McLaurin" on Justia Law

Defendant, convicted of illegal firearm possession, appealed the district court's denial of his pretrial motion to suppress evidence. A law enforcement officer, acting without a warrant, had installed a battery-powered GPS device under the rear bumper of defendant's vehicle. While defendant's case was pending, the Supreme Court held in United States v. Jones that the government's installation of a GPS on a target vehicle, and its use of that device to monitor the vehicle's movements, constituted a "search" within the meaning of the Fourth Amendment. The district court concluded that, in light of Jones, the officer's warrantless use of the GPS on defendant's vehicle was an unconstitutional search that led to the seizure of the challenged evidence. However, the district court held that the exlcusionary rule did not apply because the officer acted in good faith. The court concluded that, under the facts of this case, the rule announced in Davis v. United States directly controls: the officer's use of the GPS was objectively reasonable at the time because of the binding appellate precedent of United States v. Knotts. Accordingly, the court concluded that the exclusionary rule does not apply and the court affirmed defendant's conviction. View "United States v. Stephens" on Justia Law

This appeal arose from the district court's decision to certify five related class action suits where plaintiffs in each case generally alleged that EQT and CNX have unlawfully deprived the class members of royalty payments from the production of coalbed methane gas (CBM) in Virginia. The court granted defendants' petition to appeal the five orders granting class certification and concluded that the district court abused its discretion when it certified the five classes. The court held that the district court's analysis lacked the requisite rigor to ensure that the requirements of Rule 23 were satisfied by any of the certified classes. Accordingly, the court vacated and remanded for further proceedings. View "EQT Production Co. v. Adair" on Justia Law

Crane, one of the many defendants in this asbestos litigation, removed this case to federal court, asserting a federal defense to plaintiff's state tort claims. Plaintiff amended his complaint, eliminating the claims underlying that federal defense, and the district court remanded to state court. Crane appealed. The court concluded that it had jurisdiction over the appeal because this case was originally removed under the federal officer removal statute. The court affirmed the district court's decision to remand where Crane complained that it should have been given the opportunity to assert a new basis for federal jurisdiction but it had declined to do so in a timely fashion. View "Wood v. Crane Co." on Justia Law

Plaintiff filed suit against Absolute Collection, alleging that the collection agency's conduct violated the Fair Debt Collection Practices Act (FDCPA), 15 U.S.C. 1692-1692p, and the North Carolina Collection Agency Act, N.C. Gen. Stat. 58-70-1 et seq. Plaintiff alleged that Absolute Collection falsely reported the status of a 2008 debt to credit bureaus as "past due." The district court granted plaintiff's motion for judgment as a matter of law with respect to certain claims under the FDCPA and allowed the state claims to go to the jury, which found in favor of plaintiff. Absolute Collection appealed. The court concluded that the district court did not err in denying Absolute Collection's motion for judgment as a matter of law and held that a debtor is not required to dispute his or her debt under section 1692g as a condition to filing suit under section 1692e. The court rejected Absolute Collection's remaining arguments and affirmed the judgment of the district court. View "Russell v. Absolute Collection Services" on Justia Law

Twenty days after his trial had begun, before the prosecution had finished presenting its evidence, defendant filed a notice of appeal of the district court's written order denying his motion to dismiss one of the eleven charges against him as barred by collateral estoppel. Sixteen days later, on the eve of jury deliberations, defendant filed a second notice of appeal challenging the district court's denial of his motion to sever that same charge from the remainder of the trial. The court dismissed because neither notice was effective to confer appellate jurisdiction over the merits of the underlying rulings. View "United States v. Modanlo" on Justia Law