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

Angelo Jackson was identified as a suspect in a double murder in Montgomery County, Maryland, based on information from law enforcement officers. Detective Michael Carin used this information to obtain an arrest warrant for Jackson. After Jackson's arrest, Carin continued the investigation and found exculpatory evidence, including DNA and cellphone records, which led to the charges being dropped and Jackson's release after 65 days of detention.Jackson filed a lawsuit against Carin, alleging that Carin's affidavit for the arrest warrant and his grand jury testimony were deliberately false or made with reckless disregard for the truth. Jackson claimed that if the commissioner and grand jury had been presented with truthful evidence, they would not have found probable cause for his arrest and indictment.The United States District Court for the District of Maryland granted summary judgment in favor of Carin, finding that even with disputed material removed, the affidavit still provided probable cause for Jackson's arrest. The court also found that Carin was protected by qualified immunity on Jackson's federal claims and dismissed Jackson's gross negligence claim under Maryland law.The United States Court of Appeals for the Fourth Circuit affirmed the district court's judgment. The court concluded that Carin did not violate legal standards in his investigation and was shielded by qualified immunity. The court also found that Carin's actions were reasonable and based on information he received from other officers, and that Jackson failed to meet the burden of proving that Carin's statements were false, made with reckless disregard for the truth, or material to the probable cause determination. View "Jackson v. Carin" on Justia Law

Captain Gardenia Dorado-Ocasio, an Army officer, challenged a decision by the Army Board for Correction of Military Records (ABCMR) regarding an adverse performance evaluation she received. The evaluation was based on her failure to comply with her superior's orders and alleged retaliation against a subordinate. Dorado-Ocasio claimed the evaluation was biased and factually inaccurate. The ABCMR upheld the evaluation, finding no substantive errors or evidence of bias.The United States District Court for the Eastern District of Virginia reviewed the case and granted summary judgment in favor of the defendant, the Acting Secretary of the Army. The district court found that the ABCMR had adequately explained its decision and that the decision was not arbitrary or capricious.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The Fourth Circuit held that the ABCMR's decision was supported by substantial evidence and that the Board had provided a discernible path for its determination. The court emphasized the special deference given to military judgments and found that the ABCMR had met the required standard of review. The court concluded that the ABCMR's decision was not arbitrary, capricious, or contrary to law. View "Dorado-Ocasio v. Averill" on Justia Law

Plaintiffs, purchasers of coupon processing services, alleged that Inmar, Inc. and its subsidiaries engaged in an anticompetitive conspiracy to raise coupon processing fees. They sought class certification for a manufacturer purchaser class. The district court rejected their attempts to certify the class, leading to this appeal.The United States District Court for the Middle District of North Carolina denied plaintiffs' first two motions for class certification. The first was denied due to discovery issues, and the second was rejected as an impermissible fail-safe class. Plaintiffs' third motion proposed three different class definitions: the Fixed List Class, the Limited Payer Class, and the All Payer Class. The district court rejected all three, finding the Fixed List Class to be a fail-safe class, the Limited Payer Class to be unascertainable and excluding too many injured manufacturers, and the All Payer Class to fail the predominance requirement of Rule 23(b)(3) due to a high percentage of uninjured members.The United States Court of Appeals for the Fourth Circuit reviewed the district court's decision and affirmed the denial of class certification. The court found that the Fixed List Class failed to define a class and improperly shifted the burden to the district court. The Limited Payer Class was deemed unascertainable and not superior due to its exclusion of many injured manufacturers. The All Payer Class failed the predominance requirement as the plaintiffs' expert did not show injury for 32% of the class members, raising both predominance and standing issues. The Fourth Circuit concluded that the district court did not abuse its discretion in denying class certification. View "Mr. Dee's Inc. v. Inmar, Inc." on Justia Law

The City of Martinsville, Virginia, sued Express Scripts and OptumRx in state court, alleging public nuisance and harm related to the opioid epidemic. The defendants removed the case to federal court under the Class Action Fairness Act, but the district court remanded it back to state court. In 2024, the defendants again removed the case to federal court under the federal-officer-removal statute. The district court granted Martinsville's motion to remand the case to state court.The defendants appealed the remand order before it was mailed to the state court and requested a stay of the remand order pending appeal, citing the Supreme Court's decision in Coinbase, Inc. v. Bielski. The district court denied the stay, interpreting Coinbase narrowly to apply only to orders compelling arbitration. The defendants then sought a stay from the United States Court of Appeals for the Fourth Circuit.The Fourth Circuit granted the stay, holding that the district court was automatically stayed from mailing the remand order once the defendants filed their notice of appeal. The court applied the "Griggs principle," which divests the district court of control over aspects of the case involved in the appeal. The court found that the district court's interpretation of Coinbase was too narrow and that the automatic stay applied to the remand order. The court concluded that the district court lacked the authority to mail the remand order while the appeal was pending. View "City of Martinsville v. Express Scripts, Inc." on Justia Law

Rojay Lawson was involved in a telemarketing sweepstakes scheme based in Jamaica that targeted elderly individuals in the United States. Lawson, operating from South Carolina, collected and laundered the fraudulent proceeds, keeping a portion for himself and sending the rest to his co-conspirators in Jamaica. The scheme defrauded at least 179 victims, most of whom were elderly, out of approximately $720,000. Lawson pleaded guilty to multiple counts, including wire fraud conspiracy, money laundering conspiracy, wire fraud, and mail fraud.The United States District Court for the District of South Carolina sentenced Lawson to 78 months in prison and ordered him to pay $405,401 in restitution. Lawson challenged his sentence, arguing against the application of a vulnerable victim enhancement, the denial of a minor role reduction, and the calculation of the loss amount. The district court overruled his objections, finding that the scheme specifically targeted elderly victims and that Lawson played a significant role in the conspiracy.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the vulnerable victim enhancement was appropriate because the elderly victims were particularly susceptible to the telemarketing fraud, and Lawson knew or should have known about their vulnerability. The court also upheld the denial of a minor role reduction, noting that Lawson's involvement in collecting and laundering the funds was substantial and essential to the scheme. Additionally, the court found no error in the calculation of the loss amount, which was based on actual losses suffered by the victims. The appellate court concluded that Lawson's sentence was both procedurally and substantively reasonable. View "United States v. Lawson" on Justia Law

Gary D. LeClair, a founding member of the now-defunct law firm LeClairRyan PLLC, attempted to withdraw from the firm in July 2019. He announced his immediate withdrawal and resignation effective July 31, 2019. However, on July 29, 2019, the firm's other members voted to dissolve the firm and established a Dissolution Committee. The firm filed for Chapter 11 bankruptcy on September 3, 2019, which was later converted to Chapter 7. The bankruptcy trustee listed LeClair as an equity holder, making him liable for some of the firm's tax obligations. LeClair contested this, arguing that he had effectively withdrawn before the bankruptcy filing.The bankruptcy court ruled that LeClair's withdrawal was ineffective because it occurred after the dissolution vote, interpreting the firm's operating agreement to prohibit member withdrawal after a dissolution event. The district court largely affirmed this decision but reversed on a minor point regarding the date of the equity holders list.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that the bankruptcy and district courts misinterpreted the operating agreement. The agreement did not prohibit members from withdrawing after a dissolution event; it only barred withdrawal while a member held shares and the firm was still operational. Since LeClair's employment ended on July 31, 2019, his shares were automatically transferred back to the firm, and he ceased to be a member.The Fourth Circuit vacated the district court's judgment and remanded the case for further proceedings, instructing the bankruptcy court to determine if any equitable considerations might still warrant denying LeClair's motion to amend the equity holders list. View "LeClair v. Tavenner" on Justia Law

Javier Chavez Dominguez, a Mexican citizen, was arrested in North Carolina in August 2022 on state drug charges. After confirming his identity and criminal history, he was charged with Illegal Reentry after Removal Subsequent to Conviction for Aggravated Felony under 8 U.S.C. §§ 1326(a), (b)(2). Dominguez pleaded guilty and received a 48-month prison sentence followed by three years of supervised release. He appealed the sentence, presenting new arguments not raised in the district court.The United States District Court for the Middle District of North Carolina handled the initial proceedings. Dominguez faced both state and federal charges, first pleading guilty to state charges and receiving a 10 to 21-month sentence. Upon release, he was detained by ICE and later charged federally. He pleaded guilty to the federal charge without filing any motions and did not object to the presentence investigation report (PSR), which calculated his advisory Guidelines range as 30 to 37 months.The United States Court of Appeals for the Fourth Circuit reviewed the case. Dominguez raised four main challenges: the classification of his 2015 Arizona conviction as an aggravated felony, the constitutionality of his prior removal proceedings, the calculation of his Sentencing Guidelines range, and the substantive reasonableness of his upward variant sentence. The court found no reversible error in the district court's decisions. It held that Dominguez's guilty plea waived his right to challenge the constitutionality of his prior removals and that the district court did not plainly err in its Guidelines calculation or in imposing the upward variant sentence. The court affirmed the district court's judgment. View "US v. Dominguez" on Justia Law

Trina Cunningham, an employee of the Baltimore Department of Public Works, was responsible for monitoring water flow at the Patapsco Wastewater Treatment Plant. On June 3, 2019, while inspecting the plant's Grit Facility, Cunningham fell through a metal, grated catwalk that collapsed under her feet, causing her to drown in the wastewater chamber below. Her estate and family members filed a lawsuit against multiple defendants, including the City of Baltimore, various city officials, and several crane servicing companies, alleging negligence and other claims related to her death.The United States District Court for the District of Maryland granted motions to dismiss filed by most of the defendants, including Freeland Hoist & Crane, Inc., but did not address the claims against Crane 1 Services, Inc., and Overhead Crane Service, Inc., who had not filed motions to dismiss. The district court dismissed the entire complaint, despite the unresolved claims against these two defendants.The United States Court of Appeals for the Fourth Circuit reviewed the case and determined that the district court's order was not a final decision because it did not resolve all claims against all parties. The appellate court noted that the district court failed to address the claims against Crane 1 Services and Overhead Crane Services, and thus, the order was not appealable. Consequently, the Fourth Circuit dismissed the appeal for lack of jurisdiction and remanded the case to the district court to adjudicate the remaining claims. View "Estate of Cunningham v. Mayor and City Council of Baltimore" on Justia Law

Nia Lucas, an African American woman with military service-related disabilities, including PTSD, depression, anxiety, panic attacks, and a traumatic brain injury, sought care at VHC for her pregnancy. Despite her complaints of pre-term contractions and pain, the Labor and Delivery Unit staff did not treat her as prescribed by her doctor. Lucas alleged that she was told her pain was not real and was only in her head. After complaining to VHC staff about racial and disability discrimination, she received a letter terminating her care, and she was subsequently dismissed from a scheduled appointment. Lucas gave birth prematurely and experienced ongoing physical and mental suffering.The United States District Court for the Eastern District of Virginia dismissed Lucas' claims of racial discrimination, disability discrimination, and retaliation under the Affordable Care Act (ACA). The court found that Lucas did not plausibly plead that she was denied treatment because of her disabilities and that her racial discrimination claim was based on a single, isolated statement. The court also concluded that the ACA did not support an independent cause of action for retaliation.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the dismissal of Lucas' disability discrimination claim, finding that she did not allege facts connecting her disabilities to the denial of treatment or her termination. However, the court reversed the dismissal of her racial discrimination claim, holding that Lucas plausibly alleged that VHC acted with deliberate indifference to her complaints of racial discrimination. The court also held that the ACA permits retaliation claims, and Lucas plausibly pled a retaliation claim based on the temporal proximity between her complaints and her termination. The case was remanded for further proceedings consistent with this opinion. View "Lucas v. VHC Health" on Justia Law

Plaintiffs, a Maryland LLC and a Missouri nonprofit corporation, alleged that the Maryland State Board of Elections mismanaged state electoral operations in violation of state and federal laws during the 2020 and 2022 general elections. They claimed inaccuracies in voter registration records, excessive error rates in voting systems, improper certification of voting machines, use of uncertified machines, and failure to provide requested audit logs and configuration reports. They sought declaratory and injunctive relief, including the appointment of a Special Master to supervise changes before the November 2024 election.The United States District Court for the District of Maryland dismissed the complaint without prejudice for lack of subject-matter jurisdiction, concluding that the plaintiffs had not alleged injuries sufficiently concrete and particularized to support Article III standing. The court found that the plaintiffs did not satisfy the requirements for organizational standing, as they failed to allege any injury to their organizational activities or to their members that was concrete and particularized. The court also held that the alleged violations of the Maryland Public Information Act did not constitute a redressable injury in fact.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that the plaintiffs lacked representational standing to assert claims on behalf of their individual members. The court found that the alleged vote dilution and the possibility that members' ballots were cast blank were generalized grievances that did not constitute concrete, particularized injuries. Additionally, the court held that the plaintiffs did not demonstrate that any of their members made the public records requests, thus failing to establish standing for the alleged violations of the Maryland Public Information Act. Consequently, the appellate court affirmed the dismissal of the complaint and the denial of the motion for injunctive relief as moot. View "Maryland Election Integrity, LLC v. Maryland State Board of Elections" on Justia Law