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

This case involved two common methods employed to blend ethanol with conventional gasoline: inline blending and splash blending. Plaintiffs, API and AFPMA, brought federal preemption-based challenges in the district court seeking to enjoin enforcement of North Carolina's Ethanol Blending Statute, N.C. Gen. Stat. 75-90. Although the court agreed with the district court insofar as it rejected plaintiffs' Petroleum Marketing Practices Act (PMPA), 15 U.S.C. 2801-2841, and federal renewable fuel program preemption challenges, the court held that genuine issues of material fact remained unresolved as to plaintiffs' Lanham Act, 15 U.S.C. 1051-1113, preemption challenge to the Blending Statute. Accordingly, the court affirmed in part, vacated in part, and remanded for further proceedings. View "American Petroleum Institute v. Cooper, III" on Justia Law

Defendant appealed his convictions for various offenses related to the trafficking of contraband cigarettes. The court saw no merit in defendant's argument that the conduct of ATF agents in this case was unlawful, or otherwise "shocking," or "offensive to traditional notions of fundamental fairness." Accordingly, the court affirmed defendant's conviction. The court concluded that defendant's claim that the district court miscalculated the forfeiture amount by calculating the sum based on the gross proceeds was without merit. View "United States v. Hasan" on Justia Law

Westmoreland challenged an ALJ's decision, affirmed by the Benefits Review Board, to award black lung benefits to one of Westmoreland's former employees. The ALJ found that the evidence failed to establish that the employee suffered from clinical pneumoconiosis but did establish that the employee suffered from legal pneumoconiosis. Regarding this legal pneumoconiosis finding, the ALJ chose to credit one medical opinion over others. The ALJ also found that the employee was totally disabled as a result of his pneumoconiosis and thus awarded him benefits under the Black Lung Benefits Act, 30 U.S.C. 901 et seq. The court concluded that the ALJ's decision and order to award benefits was supported by substantial evidence, rational, and consistent with applicable law. Therefore, the Board did not err in affirming the ALJ's decision and order, and the court accordingly denied Westmoreland's petition for review. View "Westmoreland Coal Co. v. Cochran" on Justia Law

Defendant appealed from the district court's order affirming the bankruptcy court's finding of fraud and entry of a nondischargeable judgment for SG Homes. The court concluded that SG Homes justifiably relied on defendant's fraudulent misrepresentations and thereby suffered proven damages. Therefore, the bankruptcy court's finding of fraud on the basis of justifiable reliance was not clearly erroneous. Further, the award of damages for SG Homes was not clearly erroneous and the bankruptcy court did not err in determining that the judgment debt was nondischargeable under 11 U.S.C. 523(a)(2)(A). Accordingly, the court affirmed the judgment. View "SG Homes Associates, LP v. Marinucci" on Justia Law

The Board petitioned for review of the FTC order finding that it violated the Federal Trade Commission Act, 15 U.S.C. 45, by engaging in unfair competition in the market for teeth-whitening services in North Carolina. The court concluded that the Board was not exempt from the antitrust laws under the state action doctrine; the Board engaged in a combination or conspiracy under section 1 of the Sherman Act, 15 U.S.C. 1; and substantial evidence supported the FTC's factual findings regarding the economic effects of the Board's actions and that those findings supported the conclusion that the Board's behavior violated section 1. Accordingly, the court denied the petition. View "The NC State Board of Dental Examiners v. FTC" on Justia Law

Plaintiff appealed the district court's grant of summary judgment to her former employer, Mission, on her hostile work environment claim brought under Title VII of the Civil Rights Act of 1963, 42 U.S.C. 2000e. The court concluded that the district court did not err in finding that plaintiff failed to establish that she had suffered a tangible employment action. The court also concluded that the undisputed facts demonstrated that Mission satisfied both elements of its affirmative defense. Mission could not be held vicariously liable for a supervisor's alleged harassment of plaintiff. Accordingly, the court concluded that the district court did not err in granting summary judgment to Mission. View "Crockett v. Mission Hospital, Inc." on Justia Law

Defendant was convicted of several crimes stemming from his participation in a scheme to arrange fraudulent marriages between Navy sailors and foreign nationals. On appeal, defendant challenged his conviction and sentence. Because the court was satisfied that the statements made by two witnesses on the prison telephone were not testimonial, their admission did not violate the Confrontation clause; because defendant failed to cast doubt on Juror No. 42's assurance that she could set aside any opinion she may have had on the case, the court deferred to the district court's determination that she could serve impartially; the offense underlying the witness tampering counts was the aiding and abetting of false claims and, therefore, the obstruction counts were eligible for grouping only with those counts; and the district court reached a reasonable estimate in its loss calculation. Accordingly, the court affirmed the judgment. View "United States v. Jones" on Justia Law

Defendant conditionally pled guilty to conspiracy to distribute cocaine. On appeal, defendant challenged the district court's denial of his motion to suppress the cocaine. The cocaine was found in the gas tank of a Ford Explorer as the vehicle was being transported on a commercial car carrier. The court affirmed the judgment, agreeing with the government that defendant failed to prove that he had a legitimate expectation of privacy in the vehicle. View "United States v. Castellano" on Justia Law

Plaintiffs filed the underlying action seeking injunctive and declaratory relief pursuant to 42 U.S.C. 1983, alleging that the witness residency requirement on nominating petitions impermissibly burdened their rights to free speech and free association under the First Amendment. The parties filed cross-motions for summary judgment, with the Board's motion premised entirely on its assertion that plaintiffs have not suffered a legally cognizable injury and thus lacked standing. The district court denied the Board's motion as to standing and granted plaintiffs' motion on the merits. The district court declared the witness residency requirement unconstitutional and permanently enjoined its enforcement. Although the Board's witness residency requirement served the Commonwealth's interest in policing fraud potentially permeating the electoral process and therefore meeting the first part of the strict scrutiny standard, the Board produced no concrete evidence of persuasive force explaining why plaintiffs' proposed solution, manifestly less restrictive of their First Amendment rights, would be unworkable or impractical. Accordingly, the court affirmed in all respects the judgment of the district court. View "Libertarian Party of Virginia v. Judd" on Justia Law

HomeAway filed suit in the District Court of Travis County, Texas, against Eye Street and others, asserting, inter alia, state law claims for breach of contract and misappropriation of trade secrets. Eye Street did not attempt to remove HomeAway's Texas suit to federal district court but, instead, filed its own action against HomeAway and others in federal district court. After HomeAway moved to dismiss Eye Street's action for improper venue or, alternatively, to transfer venue to the U.S. District Court for the Western District of Texas, the district court stayed the action pending the resolution of HomeAway's Texas lawsuit. On appeal, Eye Street challenged the propriety of the stay. The court concluded that the district court did not abuse its discretion in staying Eye Street's action. Given the strong case for a stay under the United Capitol Insurance Co. v. Kapiloff factors and Eye Street's deliberate choice to forego removal, the district court's decision would be an appropriate exercise of discretion under either Brillhart v. Excess Insurance Co. of America/Wilton v. Seven Falls Co. or Colorado River Water Conservation District v. United States. Accordingly, the court affirmed the judgment. View "VRCompliance LLC v. HomeAway, Inc." on Justia Law