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

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

Plaintiff filed suit under 42 U.S.C. 1983 and North Carolina law against police officers, alleging, inter alia, that they fabricated evidence that led to plaintiff's arrest, convictions, and nearly-twelve-year incarceration. The district court granted the officers' motion for judgment on the pleadings under Rule 12(c). The court concluded that plaintiff waived his right to appeal the judgment in Officer Ledford's favor. The court also concluded that plaintiff has failed to state a claim on which relief can be granted in regards to Officers Ojaniit and Esposito. Further, plaintiff failed to plead any colorable state law claim as to these two officers. Accordingly, the court dismissed the appeal as to Officer Ledford and affirmed the judgment as to Officers Ojaniit and Esposito. View "Massey v. Ojaniit" on Justia Law

Petitioner, a native and citizen of El Salvador, sought review of the BIA's order affirming the IJ's denial of asylum and withholding of removal because petitioner was not a member of a cognizable social group and, alternatively, because petitioner failed to establish a nexus between a social group and the death threats he received from MS-13. The court granted the petition for review and remanded for further proceedings, concluding that petitioner demonstrated a cognizable family-based social group because of his kinship ties to his cousin and uncle, both of whom MS-13 murdered on account of their membership in a rival gang. Further, the BIA's nexus analysis failed to build a rational bridge between the record and the agency's legal conclusion. View "Cordova v. Holder" on Justia Law

Plaintiff filed suit under the Alien Tort Claims Act, 28 U.S.C. 1350, against former Secretary of Defense Robert Gates and other federal officials allegedly involved in his detention as a suspected terrorist. Plaintiff was determined to be an "enemy combatant" but was eventually released to his native country of Algeria. The court affirmed the district court's dismissal of the complaint for lack of subject matter jurisdiction under the Military Commissions Act of 2006, 28 U.S.C. 2241(e)(2). View " Ameur v. Gates" on Justia Law

Petitioner sought discretionary relief from removal by way of a special rule cancellation under the Nicaraguan Adjustment and Central American Relief Act of 1997 (NACARA), 8 U.S.C. 1231 (b)(3)(i). Determining that petitioner's challenge was timely and that the court had jurisdiction under 8 U.S.C. 1252, the court concluded that the BIA did not err in concluding that the persecutor bar rendered him ineligible for special rule cancellation of removal where petitioner oversaw the investigation and capture of twenty to fifty civilians and guerrillas, and where petitioner most likely understood that the individuals investigated or arrested would be tortured or killed. The court rejected petitioner's remaining contentions and denied the petition for review. View "Quitanilla v. Holder, Jr." on Justia Law