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

This dispute concerns the Bonner Bridge, which provides highway access between mainland North Carolina and the Outer Bank's Hatteras Island. Plaintiffs filed suit claiming that defendants violated the National Environmental Policy Act (NEPA), 42 U.S.C. 4321-4370f, and Section 4(f) of the Department of Transportation Act of 1966. Defendants settled on a plan that essentially mirrors what currently exists: replacing the Bonner Bridge and maintaining NC 12 on Hatteras Island. The court affirmed the district court's grant of summary judgment regarding plaintiffs' NEPA challenge where defendants have not engaged in unlawful segmentation with respect to the five studied parallel bridge alternatives. The court reversed the district court's grant of summary judgment regarding plaintiffs' Section 4(f) challenge because a Section 4(f) analysis is irrelevant if the joint planning exception applies. The court remanded for further proceedings. View "Defenders of Wildlife v. NC Dept. of Transp." on Justia Law

Plaintiffs, active and retired Baltimore police officers and firefighters who participate in a public pension plan, challenged the City's decision changing the manner in which annual increases to pension benefits are calculated. Plaintiffs claimed that the substitution of a cost-of-living adjustment for a "variable benefit" violates the members' rights under the Contract Clause and the Takings Clause. The court concluded that the members' rights under the Contract Clause were not impaired because the members retained a state law remedy for breach of contract. Accordingly, the court vacated the district court's judgment with respect to the City's elimination of the variable benefit. The court affirmed the district court's decision upholding the remaining portions of the ordinance at issue, and vacated the district court's order dismissing the Takings Clause claim. The court remanded for further proceedings. View "Cherry, Jr. v. Mayor and City Council of Baltimore City" on Justia Law

Plaintiffs filed a class action suit against defendants, alleging that they violated Section 8 of the Real Estate Settlement Procedures Act (RESPA), 12 U.S.C. 2607, by creating a joint venture (Prosperity) to skirt RESPA's prohibition on kickbacks while failing to disclose this business arrangement to its customers. The court concluded that the district court did not abuse its discretion denying plaintiffs' claims because plaintiffs' failed to move for judgment as a matter of law before the jury reached its verdict and because of the highly deferential lenses through which the court must review the issues before it. Accordingly, the court affirmed the judgment of the district court. View "Minter v. Wells Fargo Bank, N.A." on Justia Law

Freight Bulk appealed the district court's denial of its motion to vacate a writ of maritime attachment previously issued in favor of Flame under Supplemental Rule B of the Federal Rules of Civil Procedure. The court held that the district court did not err in concluding that the Forward Freight Swap Agreements at issue in this case are maritime contracts. Therefore, the district court had subject matter jurisdiction to adjudicate the matter before it. The court affirmed the judgment of the district court. View "Flame S.A. v. Freight Bulk Pte. Ltd." on Justia Law

Plaintiff filed suit on behalf of himself and other participants in RJR's 401(k) retirement savings plan (collectively, "the participants"), alleging that RJR breached its fiduciary duties under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., when it liquidated two funds. The court affirmed the district court's holding that RJR breached its duty of procedural prudence and therefore bore the burden of proof as to causation. The court concluded, however, that the district court failed to apply the correct "would have" instead of "could have" legal standard in assessing RJR's liability. Accordingly, the court reversed and remanded for the district court to determine whether, under the correct legal standard, RJR's imprudence caused that loss. View "Tatum v. RJR Pension Investment Committee" on Justia Law

Petitioner, a Guatemalan national residing in the United States, petitioned for review of the BIA's denial of his application for "special rule" cancellation of removal under the Nicaraguan Adjustment and Central American Relief Act (NACARA), 8 U.S.C. 1229b. The court concluded that petitioner did bear the burden of proving that he entered the United States free from official restraint; but he met that burden by relying on a border patrol agent's written report, which, the BIA expressly found, constituted the only credible and reliable evidence in the record that showed that the agent first saw petitioner at milepost nine, seventeen miles beyond the border; and, applying the principle in United States v. Hicks and numerous other cases, the court concluded that a party may rely on its opponent's evidence to make its own case. The Attorney General offered no reason why this principle does not apply in the immigration context and the court saw none; petitioner came under restraint as soon as the agent spotted him at milepost nine; the BIA failed to provide a reasoned explanation for departing with its own precedent; and every circuit to consider the issue has concluded that an alien first observed by a government agent miles beyond the border has entered free from official restraint - regardless of whether the party bearing the burden of proof has offered evidence of the circumstances of the alien's entry. Accordingly, the court granted the petition for review and remanded to the BIA to consider petitioner's application for NACARA relief in light of the proper legal standard. View "De Leon v. Holder, Jr." on Justia Law

The Chapter 11 Litigation Trustee for the estate of Railworks sought to avoid and recover premium payments that Railworks transferred to CPG, which later transferred them to TIG. Railworks made the transfers within ninety days before Railworks filed for bankruptcy protection. The bankruptcy court granted summary judgment in favor of CPG, thus preventing the trustee from avoiding and recovering the premium payment transfers to CPG. The court held that the bankruptcy court's grant of CPG's summary motion was proper. While CPG had physical control over the transfers it received, it did not have the legal right to use them as it pleased. Instead, the General Agency Agreement mandated that CPG, the agent, hold the funds in trust for TIG, the principal. Consequently, the court reversed the district court's decision and remanded with instructions to reinstate the bankruptcy court's judgment. View "Railworks Corp. v. Construction Program Group" on Justia Law

Plaintiffs filed suit challenging Virginia Code sections 20-45.2 and 20-45.3; the Marshall/Newman Amendment, Va. Const. art. I, 15-A; and any other Virginia law that bars same sex-marriage or prohibits the State's recognition of otherwise-lawful same-sex marriages from other jurisdictions (collectively, the Virginia Marriage Laws). Plaintiffs argued that these laws violate the Due Process and Equal Protection Clauses of the Fourteenth Amendment. The district court granted plaintiffs' motion for summary judgment and enjoined Virginia from enforcing the laws. As a preliminary matter, the court concluded that each of the plaintiffs had standing as to at least one defendant, and the court declined to view Baker v. Nelson as binding precedent. The court concluded that strict scrutiny analysis applied in this case where the Virginia Marriage Laws impede the right to marry by preventing same-sex couples from marrying and nullifying the legal import of their out-of-state marriages. Proponents contend that five interests support the laws: federalism-based interests, history and tradition, protecting the institution of marriage, encouraging responsible procreation, and promoting the optimal childrearing environment. The court concluded, however, that these interests are not compelling interests that justify the Virginia Marriage Laws. Therefore, all of the proponents' justifications for the laws fail and the laws cannot survive strict scrutiny. Accordingly, the court concluded that the Virginia Marriage Laws violate the Due Process and Equal Protection Clauses of the Fourteenth Amendment to the extent that they prevent same-sex couples from marrying and prohibit Virginia from recognizing same-sex couples' lawful out-of-state marriages. The court affirmed the judgment of the district court. View "Bostic v. Schaefer" on Justia Law

Defendant appealed his sentence after pleading guilty to unlawfully entering the United States after being deported. The court affirmed the district court's application of a sentencing enhancement under U.S.S.G. 2L1.2(b)(1)(B) because defendant illegally reentered the country after a prior North Carolina conviction for felony drug trafficking, which is a drug offense punishable by more than one year in prison. The court held that North Carolina's legislatively mandated sentencing scheme, not a recommended sentence hashed out in a plea negotiations, determines whether an offender's prior North Carolina conviction was punishable by more than a year in prison. View "United States v. Valdovino" on Justia Law

Plaintiffs filed suit challenging the validity of an IRS final rule implementing the premium tax credit provision of the Patient Protection and Affordable Care Act (ACA), 26 U.S.C. 36B. The final rule interprets the Act as authorizing the IRS to grant tax credits to individuals who purchase health insurance on both state-run insurance "Exchanges" and federally-facilitated "Exchanges" created and operated by HHS. The court found that the applicable statutory language is ambiguous and subject to multiple interpretations. Applying deference to the IRS's determination, the court upheld the rule as a permissible exercise of the agency's discretion. Accordingly, the court affirmed the judgment of the district court. View "King v. Burwell" on Justia Law