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

Defendant was convicted of murder and various drug and firearm offenses in connection with a drug distribution conspiracy. On appeal, defendant argued that the forfeiture-by-wrongdoing exception to the Confrontation Clause, upon which the district court relied in admitting the victim's statement, did not apply unless a criminal defendant's sole motivation in making a witness unavailable was to prevent that witness's testimony. The court held however, that so long as a defendant intended to prevent a witness from testifying, the forfeiture-by-wrongdoing exception applied even if the defendant also had other motivations for harming the witness. Accordingly, the court affirmed the judgment. View "United States v. Jackson" on Justia Law

Defendant was convicted of being a felon in possession of a firearm. On appeal, defendant challenged the district court's denial of his motion to suppress the firearm that was the basis of the conviction. The court held that the district court did not err in concluding that the officer possessed a reasonable suspicion that defendant was trespassing at the time of the Terry stop. The court rejected defendant's argument that the officer's decision to stop him for investigatory purposes was unreasonable because other less intrusive investigatory techniques could have been used because the issue had already been considered and rejected by the Supreme Court. Accordingly, the court affirmed the judgment. View "United States v. Bumper" on Justia Law

Plaintiffs, D.L. and his parents, appealed the district court's grant of summary judgment to the BCBSC and Baltimore City Public Schools, contending that Section 504 of the Rehabilitation Act of 1973, 29 U.S.C. 794, compelled BCBSC to provide D.L. education services related to certain disorders even though D.L. was enrolled exclusively in a private religious school. Because plaintiffs retained full discretion over school enrollment and because BCBSC has taken reasonable measures to fulfill its mission, the court found that BCBSC's policies placed no undue burden on plaintiffs' constitutional rights. Because the court did not read Section 504 to apply an affirmative obligation on school districts to provide services to private school students and because plaintiffs retained full educational discretion, the court affirmed the district court's ruling. View "D. L. v. Baltimore City Bd. of Sch. Comm." on Justia Law

The Trustee for debtor TRM appealed the dismissal of his adversary action against real estate development companies, alleging that TRM and the development companies engaged in a scheme to sell properties at inflated prices in recently developed subdivisions in North Carolina and South Carolina. The court held that the development companies were potentially independently liable to TRM's purchasers because it participated in TRM's sales and marketing efforts. But, because TRM was not entitled to statutory contribution, the Trustee's action failed as a matter of law. Accordingly, the court affirmed the district court's judgment. View "Total Realty Mgmt. LLC v. R. A. North Development, Inc." on Justia Law

Plaintiffs brought this civil enforcement action under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., alleging that defendants, the Bank, and individual members of the Bank's Corporate Benefits Committee, engaged in prohibited transactions and breached their fiduciary duties by selecting and maintaining Bank-affiliated mutual funds in the investment menu for the Bank's 401(k) Plan and the Bank's separate but related Pension Plan (collectively, the Plans). The court affirmed the district court's dismissal of the Pension Plan claims in the Second Amended Complaint on the basis that plaintiffs lacked Article III standing. The district court correctly determined that plaintiffs' remaining claims were time-barred under the limitations period in 29 U.S.C. 1113(1)(A). Finally, the district court's dismissal of the Third Amended Complaint with prejudice did not constitute an abuse of discretion where plaintiffs failed to file a motion to amend and had already amended their original complaint three times. Accordingly, the court affirmed the judgment of the district court. View "David v. Alphin" on Justia Law

Relator, a sales manager for Takeda, brought a qui tam action against his employer under the False Claims Act, 31 U.S.C. 3729-3733, alleging that Takeda violated the Act by causing false claims to be presented to the government for payment under Medicare and other federal health insurance programs. The district court dismissed relator's claims under Rule 12(b)(6). The court held that the district court did not err in dismissing the third amended complaint because relator failed to plausibly allege that any false claims had been presented to the government for payment. The court also held that the district court did not abuse its discretion in denying relator leave to file a fourth amended complaint. Accordingly, the court affirmed the judgment. View "US ex rel. Noah Nathan v. Takeda Pharmaceuticals" on Justia Law

Plaintiff appealed the district court's grant of summary judgment for her employer, the UPS, pursuant to the Pregnancy Discrimination Act (PDA), 42 U.S.C. 2000e(k), and the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq. The court held that plaintiff presented no direct evidence of pregnancy discrimination where the UPS policy at issue, that did not provide light duty work to pregnant workers but did for certain other employees, treated pregnant and nonpregnant workers alike and therefore complied with the PDA. Plaintiff also failed to offer sufficient evidence to make out a prima facie case of discrimination under the McDonnell Douglas framework. Accordingly, the court affirmed the judgment. View "Young v. UPS" on Justia Law

Plaintiff claimed that FedEx violated the Family Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq., by terminating her employment in retaliation for her decision to take medical leave and by failing to restore her to an equivalent position upon her return from leave. Plaintiff worked for FedEx as a mail courier and FedEx claimed that she was terminated for falsifying her delivery records. Because plaintiff failed to point to any evidence that FedEx treated similarly situated employees who had not taken FMLA leave more favorably, and because the record showed that FedEx would have suspended and terminated her employment regardless of her decision to take leave, the court affirmed the district court's grant of summary judgment in favor of FedEx. View "Laing v. Federal Express Corp." on Justia Law

Pinnacle claimed that the Army unlawfully withheld many communications between Clark and the Army, in violation of the Freedom of Information Act, 5 U.S.C. 552. The district court granted summary judgment to the Army and Pinnacle appealed. The court concluded that public disclosure of the Category C documents would impair the government's ability to get this necessary information in the future and that the documents were, therefore, confidential and fell within Exemption 4 of the Act. The court found that Category B documents were protected by the common interest doctrine and qualified as intra-agency communications pursuant to Exemption 5 of the Act. The court disposed of Pinnacle's remaining arguments and affirmed the judgment of the district court. View "American Mgmt. Svcs. v. Dept. of the Army" on Justia Law

Defendant was convicted of being a felon in possession of a firearm. The court reversed his conviction because of a post-trial change in law effected by United States v. Simmons and remanded the case for further proceedings. Defendant was again convicted and appealed on double jeopardy grounds. The court held that defendant's argument failed in light of United States v. Ellyson, where the court had concluded that where a reviewing court determined that the evidence presented at trial had been rendered insufficient only by a post-trial change in law, double jeopardy concerns did not preclude the government from retrying the defendant. Accordingly, the court found no error and affirmed the judgment. View "United States v. Ford" on Justia Law