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

Defendant appealed his conviction of five felony counts relating to the sale of counterfeit prescription drugs. Defendant sought to introduce evidence establishing a gray market for prescription pills to argue that some of the pills that police seized from him could be genuine. The court concluded that the district court did not err in barring cross-examination regarding gray market evidence where there was no connection to the knowledge element and consequently no relevance; defendant cannot use the privilege against self-incrimination as a means to free himself from the basic rules of relevancy; if the evidence were relevant, the district court did not commit reversible error by directing the evidence to defendant's case-in-chief; and, in the alternative, the gray market evidence should be excluded under Federal Rule of Evidence 403. The court also held that, viewed in the light most favorable to the Government, the evidence sufficiently established defendant's knowledge and, therefore, defendant's sufficiency argument failed. Accordingly, the court affirmed the judgment of the district court. View "United States v. Shauaib Zayyad" on Justia Law

NCUC challenged incentives granted by FERC to VEPCO to encourage investment in transmission infrastructure projects. The court held that FERC properly exercised its broad discretion in declining to apply the 2010 policy change in its Rehearing Order and in evaluating VEPCO's application for incentives. Accordingly, the court granted FERC's grant of incentives to VEPCO under section 219 of the Federal Power Act (FPA), 16 U.S.C. 824s(c). View "North Carolina Utilities Comm'n v. FERC" on Justia Law

Defendant appealed his conviction of a firearm offense, contending that the evidence discovered during a traffic stop should have been suppressed at trial because the traffic offense for which he was cited - leaving a vehicle standing such that it obstructs traffic - did not apply to the road on which he had stopped his car. The court rejected this argument, concluding that closely related traffic law barred the conduct for which defendant was cited. The court rejected defendant's argument challenging the exclusion of prior police misconduct where the district court's decision to exclude the evidence was neither arbitrary nor irrational. Accordingly, the court affirmed the judgment of the district court. View "United States v. Williams, IV" on Justia Law

Defendant was convicted of three counts of filing false income tax returns. Defendant was subsequently denied habeas relief but the district court granted him a certificate of appealability (COA) on his Sixth Amendment challenge. The court concluded that the district court did not err in finding that defendant failed to establish that his trial counsel's representation was anything other than objectively reasonable where counsel's decision not to call certain witnesses was a reasonable strategic decision. Accordingly, the court affirmed the judgment of the district court. View "United States v. Dehlinger" on Justia Law

Petitioner, a citizen of El Salvador, requested that the Attorney General withhold removal under 8 U.S.C. 1231(b)(3). Petitioner claimed that as a former member of the violent Mara Salvatrucha gang (MS-13), he is a member of a particular social group and that he would be killed if sent back to El Salvador because he renounced his membership in MS-13. The court concluded that petitioner's proposed particular social group of former MS-13 members from El Salvador was immutable for withholding of removal purposes in that the only way that petitioner could change his membership in the group would be to rejoin MS-13. Accordingly, the court held that the BIA erred in its ruling on immutability and reversed and remanded. The court affirmed the district court's denial of relief under the Convention Against Torture because it was not supported by sufficient evidence. View "Martinez v. Holder, Jr." on Justia Law

Plaintiff filed suit against Altarum, alleging that Altarum discriminated against him by wrongfully discharging him on account of disability and that Altarum failed to accommodate his disability. Plaintiff was terminated after he injured his legs on a subway platform and was on short-term disability benefits. On appeal, plaintiff challenged the district court's dismissal of his wrongful-discharge claim. The court concluded that, under the Americans with Disabilities Act Amendments Act of 2008, Pub. L. No. 110-325, 122 Stat. 3553, and its implementing regulations, an impairment is not categorically excluded from being a disability simply because it is temporary. In this instance, the impairment alleged by plaintiff fell comfortably within the amended Acts' expanded definition of disability. Therefore, the court reversed and remanded for further proceedings. View "Summers v. Altarum Institute, Corp." on Justia Law

Plaintiffs filed a putative class action suit challenging the legality of the toll charged by the MWAA for use of the Dules Toll Road. The district court dismissed the complaint on numerous grounds. The court concluded that plaintiffs' claims were barred neither by the standing requirement of Article III nor the prudential restrictions the court has recognized on its own judicial power; under the Elizabeth River Crossings OpCo, LLC v. Meeks framework, the tolls charged for passage on the Dules Toll Road are user fees, not taxes, under Virginia law; and therefore, their collection by the MWAA did not run afoul of the Virginia Constitution and did not violate the due process rights of motorists. Accordingly, the court affirmed the district court's dismissal of plaintiffs' complaint. View "Corr v. Metropolitan Washington" on Justia Law

Defendant appealed his conviction of two counts of bank robbery. The court concluded that the district court's refusal to allow defendant to testify in narrative form was not arbitrary or disproportionate to its purpose; the court also rejected defendant's claim that the district court impermissibly forced him to choose between his right to represent himself and to choose between testifying pro se in question-answer form and testifying in response to questions from standby counsel who would then control the case; and, therefore, the court affirmed the judgment of the district court. View "United States v. Beckton" on Justia Law

Defendant, who is deaf and communicates through sign language, appealed the district court's order of civil commitment following an evidentiary hearing under 18 U.S.C. 4248. The court affirmed the judgment of the district court in denying defendant's request for consecutive interpretation; the district court did not clearly err in finding that defendant is a "sexually dangerous person;" and the district court did not err in rejecting defendant's equal protection and due process claims in light of United States v. Timms. Accordingly, the court affirmed the judgment of the district court. View "United States v. Heyer" on Justia Law

Defendant appealed the district court's order of restitution as part of his sentence for obstructing federal bankruptcy proceedings. Defendant contended that the purported victims suffered losses when he caused them to take out significant loans for the benefit of his church - conduct with which he was not charged or convicted. At issue was whether the purported victims were victims "of the offense" for the purpose of 18 U.S.C. 3563(b). The court concluded that the statute required the purported victims to be victims only of the offense of conviction; the Government failed to demonstrate that the purported victims' losses were "caused by the specific conduct that is the basis of" defendant's offense of conviction - obstruction of federal bankruptcy proceedings; and therefore, the district court abused its discretion in awarding restitution to the purported victims, as the award was contrary to the legal principles set out in the court's precedent. Accordingly, the court reversed and remanded. View "United States v. Freeman" on Justia Law