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

Plaintiffs appealed the dismissal with prejudice of their Maryland quiet title claim. Where, as here, a property is encumbered by a deed of trust and its release is conditioned on a party's performance under a note, determining who holds title to the property necessarily involves determining whether the party has performed under the note. Therefore, the court could not decouple the questions of plaintiffs' personal liability and the security interest in the property. In this case, plaintiffs are not entitled to the benefits of a quiet title action because they are not authorized by statute to resolve clouds on a legal title which they do not own. Therefore, the court affirmed the district court's dismissal of the complaint with prejudice. The court also held that the district court acted within its discretion in denying plaintiffs leave to amend the complaint. Accordingly, the court affirmed the judgment of the district court.View "Anand v. Ocwen Loan Servicing, LLC" on Justia Law

GEICO appealed the district court's order granting partial summary judgment against them on the issue of liability in an action asserting denial of overtime pay under the Fair Labor Standards Act (FLSA), 29 U.S.C. 201 et seq. Plaintiffs cross-appealed an order granting partial summary judgment against them on several issues relating to the remedy to be awarded. With no final decision to review, the court concluded that it lacked jurisdiction to consider the appeals before it. Accordingly, the court dismissed the appeals.View "Calderon v. GEICO General Ins. Co." on Justia Law

Defendant appealed his sentence after pleading guilty to unlawful possession of a firearm by a convicted felon. The court concluded that the district court erred by increasing defendant's sentence after determining that his prior conviction for fourth-degree burglary constituted a crime of violence under U.S.S.G. 2K2.1(a)(2). Therefore, the court vacated defendant's 77-month sentence and remanded for resentencing.View "United States v. Martin" on Justia Law

Defendant appealed his sentence after pleading guilty to being a felon in possession of ammunition. The court agreed with the district court's decision to use defendant's general court-martial convictions to classify him as an armed career criminal and rejected defendant's argument which primarily relied on the Supreme Court's decision in Small v. United States. Accordingly, the court affirmed the judgment of the district court.View "United States v. Grant" on Justia Law

Petitioner, a death row inmate, appealed the district court's denial of his petition for a writ of habeas corpus under 28 U.S.C. 2254. Petitioner claimed that an eyewitness's in-court identification violated his due process rights under the Fourteenth Amendment. The court affirmed the district court's denial of habeas relief because the North Carolina state court's rejection of petitioner's claim was not contrary to, or an unreasonable application of, clearly established law, as determined by the Supreme Court. The court held that the procedures leading up to the eyewitness's in-court identification were not unnecessarily suggestive and that, even if they were, they did not create a substantial likelihood of irreparable misidentification. The court also denied petitioner's motion for appointment of qualified and independent counsel under Martinez v. Ryan and Juniper v. Davis.View "Fowler v. Lassiter" on Justia Law

Plaintiffs filed suit challenging a Maryland program subsidizing the participation of a new power plant in the federal wholesale energy market. Maryland's plan was ultimately formalized in the Generation Order. The district court agreed with plaintiffs' contention that the Maryland scheme was preempted under the Federal Power Act's (FPA), 16 U.S.C. 824(b)(1), authorizing provisions, which grant exclusive authority over interstate rates to FERC. The court concluded that the Generation Order is field preempted because it seeks to regulate a field that the FPA has occupied. The court also concluded that the Generation Order is conflict preempted because it conflicts with the auction rates approved by FERC and conflicts with PJM's new entry price adjustment (NEPA). Accordingly, the court held that the Generation Order was preempted under federal law and affirmed the judgment of the district court.View "PPL EnergyPlus, LLC v. Nazarian" on Justia Law

CSS, the debtor, filed a Chapter 11 bankruptcy petition in 2012. Acting as general contractor or as a first tier subcontractor, CSS placed orders with Subcontractors, the creditor. The court held that construction subcontractors entitled to a lien on funds under North Carolina law had an interest in property when the debtor contractor filed for bankruptcy, by which time the subcontractors had not yet served notice of, and thereby perfected, their liens. Because there is no dispute that the other criteria of the applicable bankruptcy stay exception have been met, the court held that the bankruptcy court and district court correctly allowed Subcontractors to serve notice of, and thereby perfect, their liens post-petition.View "Construction Supervision Svcs v. Branch Banking & Trust" on Justia Law

Defendant was convicted of charges stemming from his distribution of substances ("bath salts") that the government alleged were prohibited by the Controlled Substance Analogue Enforcement Act of 1986, 21 U.S.C. 802(32)(A), 813. The court rejected defendant's argument that the Act is unconstitutional because he lacked notice that the distribution of controlled substance analogues is prohibited under federal law; rejected defendant's challenges to the district court's rulings made during trial; and concluded that the evidence was sufficient to convict defendant. Accordingly, the court affirmed the judgment of the district court.View "United States v. McFadden" on Justia Law

Defendant appealed the district court's revocation of his supervised release. The district court found that defendant had violated his supervised release by, among other things, possessing marijuana. The district court's finding relied in part on a laboratory report prepared by a forensic examiner who did not testify at the hearing. The court vacated the sentence and remanded, holding that the district court erred by denying defendant a chance to cross-examine the forensic examiner.View "United States v. Ferguson" on Justia Law

Respondent appealed the district court's order concluding that he was a sexually dangerous person under the Adam Walsh Child Protection and Safety Act of 2006, Pub. L. No. 109-248, 120 Stat. 587, and committing him to the custody of the Attorney General. The court concluded that the procedure set forth in 18 U.S.C. 4248(a) for initiating proceedings for the civil commitment of a sexually dangerous person supplants the summons requirement set forth in Rule 4 of the Federal Rules of Civil Procedure. That the government has physical custody over the respondent in section 4248 civil commitment proceedings obviates the need for a summons. The court concluded that the government easily presented sufficient evidence to support the conclusion that, by clear and convincing evidence, respondent, as a result of his pedophilia, would have serious difficulty in refraining from child molestation if released. The court rejected respondent's remaining arguments. Accordingly, the court affirmed the judgment of the district court.View "United States v. De La Luz Perez" on Justia Law