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

Brandon Glen Jackson was indicted in Arizona for a state-law felony related to possessing a short-barreled rifle. While released on bail and with the felony charge still pending, Jackson lawfully acquired a handgun and traveled from Arizona to Maryland, bringing the handgun with him. In Maryland, he was arrested for carrying the gun without a permit. Upon discovering his pending Arizona felony indictment, federal prosecutors charged him under 18 U.S.C. § 922(n), which prohibits individuals under felony indictment from transporting firearms in interstate commerce.The United States District Court for the District of Maryland denied Jackson’s motion to dismiss the indictment on Second Amendment grounds. Jackson then entered a conditional guilty plea, preserving his right to appeal the constitutional issue. He was sentenced to time served, and subsequently appealed the district court’s denial of his motion to dismiss.The United States Court of Appeals for the Fourth Circuit reviewed the case and applied the Supreme Court’s “text-and-history” standard from New York State Rifle & Pistol Association v. Bruen, 597 U.S. 1 (2022). The Fourth Circuit held that Jackson’s conduct—transporting a handgun across state lines while under felony indictment—was presumptively protected by the Second Amendment. However, the court found that the government met its burden to show that § 922(n), as applied to Jackson, was consistent with the nation’s historical tradition of firearm regulation. The court relied on historical surety laws and the tradition of disarming dangerous persons, as well as its own precedent in United States v. Hunt, 123 F.4th 697 (4th Cir. 2024), to conclude that temporary disarmament of those under felony indictment is constitutionally permissible. The Fourth Circuit affirmed the district court’s judgment. View "US v. Jackson" on Justia Law

Two nonprofit organizations challenged the constitutionality of a North Carolina statute that made it a felony for individuals with felony convictions to vote before their rights were restored, regardless of whether those individuals mistakenly believed they were eligible. The statute, originally enacted in the late 19th century, was shown to have been motivated by racial animus and to have a disproportionate impact on Black North Carolinians. In 2023, the North Carolina General Assembly amended the statute to add a requirement that a person must “know” their rights had not been restored to be prosecuted, effective January 1, 2024.The United States District Court for the Middle District of North Carolina considered the plaintiffs’ claims under the Equal Protection and Due Process Clauses. After the statute was amended, a magistrate judge recommended dismissal for lack of standing, but the district court found the case was not moot because prosecutions under the old statute for pre-2024 conduct could still occur, potentially chilling voter participation and requiring the plaintiffs to divert resources. The district court granted summary judgment for the plaintiffs, holding the statute unconstitutional and enjoining its enforcement.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the case was not moot because prosecutions under the prior version of the statute could still proceed, and the plaintiffs retained a concrete interest in the outcome. On the merits, the Fourth Circuit affirmed the district court’s ruling that the challenged statute violated the Equal Protection Clause. The court found that the statute’s original enactment and reenactment were motivated by racial discrimination, and that subsequent legislative changes did not “cleanse” the statute of its discriminatory origins, as the statute itself had not been substantively reenacted or amended in a way that would warrant a presumption of legislative good faith. The court affirmed the district court’s judgment. View "A. Philip Randolph Institute v. North Carolina State Board of Elections" on Justia Law

Two Maryland residents challenged a state law that allows Maryland to take custody of property deemed “abandoned” after a period of owner inactivity, such as unclaimed bank accounts or stocks. Before 2004, owners who reclaimed such property from the state received both the principal and any interest accrued while the property was in state custody. After a 2004 amendment, claimants could only recover the principal, not the interest. The lead plaintiff, who had not yet filed a claim with the state, argued that Maryland’s failure to pay interest constituted an unconstitutional taking under the Fifth Amendment and sought a declaratory judgment and injunction requiring the state to pay just compensation, including interest, when he eventually filed a claim.The United States District Court for the District of Maryland denied the Comptroller’s motion to dismiss, finding that the plaintiff had standing, the claim was ripe, and the complaint stated a facial challenge to the statute. The court also held that the claim was not barred by Eleventh Amendment sovereign immunity, reasoning that the relief sought was prospective and thus fell within the Ex parte Young exception, which allows federal courts to enjoin ongoing violations of federal law by state officials.The United States Court of Appeals for the Fourth Circuit reviewed only the sovereign immunity issue. The Fourth Circuit held that the Eleventh Amendment bars federal courts from ordering Maryland to pay interest that accrued before any federal court judgment, as such relief is retroactive and constitutes a claim for money damages. However, the court held that to the extent the plaintiff seeks prospective relief—specifically, interest that would accrue after a federal court judgment—such a claim may proceed under the Ex parte Young doctrine. The court affirmed in part, reversed in part, and remanded for further proceedings. View "Albert v. Lierman" on Justia Law

After the 2025 Presidential Inauguration, the federal government initiated mass terminations of thousands of probationary employees across numerous federal agencies. These employees, who were subject to one- or two-year probationary periods, were dismissed without the advance notice typically required for reductions in force (RIFs). The affected states alleged that the lack of notice hindered their ability to provide rapid response services to the terminated employees, resulting in increased unemployment claims and diversion of state resources.Nineteen states and the District of Columbia filed suit in the United States District Court for the District of Maryland, arguing that the terminations violated statutory RIF procedures, including the requirement to provide 60 days’ notice to state governments. The district court granted a temporary restraining order and later a preliminary injunction, ordering the federal government to reinstate the terminated employees and prohibiting further terminations without compliance with all applicable laws and notice requirements. The injunction was later stayed by the United States Court of Appeals for the Fourth Circuit pending appeal.The United States Court of Appeals for the Fourth Circuit reviewed the case and held that the plaintiff states lacked Article III standing to bring the suit. The court found that the states did not suffer a cognizable and redressable injury, as the direct harm was to the terminated employees, not the states. The court also determined that the relief sought by the states—indefinite reinstatement and broad injunctive relief—was not tailored to their alleged informational injury and primarily served to vindicate the rights of non-party employees. As a result, the Fourth Circuit vacated the district court’s judgment and remanded with instructions to dismiss the action. View "State of Maryland v. USDA" on Justia Law

The petitioner, a Black native and citizen of Guyana, entered the United States as a lawful permanent resident in infancy and lived there since. He suffered from untreated mental illness, including schizophrenia, and physical disabilities requiring a wheelchair. After a psychotic episode, he was convicted of several felonies and served sixteen years in prison. Following his release, the Department of Homeland Security charged him as removable due to his aggravated felony conviction. Fearing torture if deported to Guyana because of his mental health, physical disabilities, criminal-deportee status, and race, he sought deferral of removal under the Convention Against Torture, presenting testimony and evidence of mistreatment faced by similar groups in Guyana.An Immigration Judge found the petitioner and his expert credible but denied relief, concluding that the likelihood of torture in Guyana was insufficient. The judge determined that Guyanese police do not actively seek to harm or torture mentally ill persons and that government acquiescence was not supported by the evidence. The judge also found that discrimination and poor conditions existed but did not rise to the level of torture or government acquiescence. The petitioner appealed to the Board of Immigration Appeals, arguing that the judge failed to consider the cumulative risk of torture based on all asserted grounds and misapplied the definition of torture. The Board affirmed, focusing only on mental illness and finding no clear error in the judge’s conclusions.The United States Court of Appeals for the Fourth Circuit reviewed only the Board’s decision. The court held that the Board abused its discretion by ignoring relevant, unrebutted evidence regarding the petitioner’s risk of torture due to his race, physical disabilities, and criminal-deportee status. The court granted the petition for review, vacated the Board’s decision, and remanded for further proceedings, instructing the agency to consider all evidence and apply the definition of torture to each claim. View "McDougall v. Bondi" on Justia Law

Three plaintiffs alleged they suffered injuries after receiving the Gardasil vaccine, which is designed to prevent certain strains of human papillomavirus. Each plaintiff experienced adverse symptoms following their Gardasil injections, but the onset of these symptoms occurred more than three years before they filed petitions for compensation under the National Vaccine Injury Compensation Program. The plaintiffs acknowledged to the special master that their petitions were untimely and sought equitable tolling of the Vaccine Act’s limitations period.The special master in the United States Court of Federal Claims found the petitions untimely and denied equitable tolling, resulting in dismissal of the claims. The plaintiffs then filed suit against Merck & Co. and Merck Sharp & Dohme LLC in the United States District Court for the Western District of North Carolina, which was handling multi-district litigation related to Gardasil. Merck moved to dismiss, arguing that the plaintiffs had failed to timely pursue their remedies under the Vaccine Act. The district court dismissed the complaints, holding that the proper forum for challenging the special master’s timeliness rulings was the Court of Federal Claims and the Federal Circuit, not the district court. The court also rejected a constitutional challenge to the process by which Gardasil was added to the Vaccine Injury Table.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s rulings. The Fourth Circuit held that the addition of Gardasil to the Vaccine Injury Table did not violate the Constitution. It further held that timely participation in the Vaccine Act compensation program is a prerequisite to bringing a tort suit, and that courts hearing vaccine-related tort suits may not reconsider the timeliness of a Vaccine Act petition once the special master has made a finding. The court affirmed the dismissal of the plaintiffs’ complaints. View "Needham v. Merck & Company Inc." on Justia Law

A tugboat owned by a private company collided with a bridge in Maryland, causing significant property damage. The tugboat owner, seeking to limit its financial liability for the accident, initiated a proceeding under the federal Exoneration and Limitation of Liability Act. This law allows vessel owners to cap their liability at the value of the vessel and its cargo, which in this case was much less than the total damage to the bridge. The State of Maryland, as the party suffering the loss, filed a claim in the limitation proceeding, seeking full compensation for the damage and contesting the applicability of the liability cap.The United States District Court for the Eastern District of Virginia found that the limitation action was not a suit against Maryland and did not seek damages from the state, but rather aimed to determine the tug owner’s liability and distribute the available fund among claimants. The district court denied Maryland’s motion to dismiss, which was based on the argument that sovereign immunity protected it from having its recovery limited by federal law. Maryland appealed this decision before the case proceeded further.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s denial of Maryland’s motion to dismiss. The Fourth Circuit held that sovereign immunity does not shield a state from the operation of the Limitation Act when the state voluntarily files a claim in such a proceeding. The court reasoned that the limitation action did not subject Maryland to coercive judicial process, as Maryland chose to participate as a claimant. The court affirmed the district court’s decision, allowing the limitation action to proceed and holding that Maryland’s sovereign immunity was not implicated under these circumstances. View "Jackson Creek Marine, LLC v. Maryland" on Justia Law

Malcolm Wiener purchased $16 million in permanent life insurance from AXA Equitable Life Insurance in the 1980s. In 2013, his policy lapsed after he failed to pay premiums on time. When Wiener sought reinstatement, AXA erroneously determined he had four serious medical conditions and reported these to the Medical Information Bureau (MIB), a consortium used by insurers to assess applicants. As a result, Wiener was unable to obtain comparable life insurance from other companies at standard rates; most rejected him outright, and two offered only limited coverage at much higher premiums. Wiener then brought a negligence claim against AXA, alleging that the false MIB report rendered him uninsurable.The case was tried in the United States District Court for the Western District of North Carolina. The jury found AXA liable for negligence and awarded Wiener $16 million in damages, reduced to $8 million for failure to mitigate. AXA moved for judgment as a matter of law under Rule 50(b), arguing that Wiener had not provided sufficient evidence to support the damages award. The district court initially dismissed the case for lack of subject matter jurisdiction, but the United States Court of Appeals for the Fourth Circuit reversed and remanded, instructing the district court to address the sufficiency of the evidence for damages. On remand, the district court found the evidence insufficient to support the jury’s damages calculation and reduced the award to $1 in nominal damages.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The court held that, although there was sufficient evidence that AXA’s negligence caused Wiener to become uninsurable at a reasonable cost, there was not enough evidence for the jury to calculate the amount of damages with reasonable certainty, particularly because Wiener failed to provide evidence of his expected remaining lifespan. As a result, only nominal damages were appropriate. View "Wiener v. AXA Equitable Life Insurance Co." on Justia Law

A Nigerian citizen, after returning to his home country from Venezuela, was recruited under false pretenses to work as a cook at a rural camp. Upon arrival, he discovered the camp was operated by a group known as the Unknown Gunmen, which the Nigerian government considers a terrorist organization. He was not allowed to leave, was forced to cook for the group’s leaders, and was eventually held without pay. After several months, he managed to escape and, fearing for his life due to repeated threats and attacks by the group, fled Nigeria. He traveled to Venezuela and then to the United States, where he sought asylum and withholding of removal, claiming a well-founded fear of persecution.An Immigration Judge found him removable for entering the United States without valid documents. The judge denied his applications for asylum and withholding of removal, concluding that by cooking for the Unknown Gunmen, he had provided “material support” to a terrorist organization, which barred him from relief. The judge also denied his claim for protection under the Convention Against Torture, finding insufficient evidence that he would likely be tortured with the acquiescence of a public official if returned to Nigeria. The Board of Immigration Appeals affirmed the Immigration Judge’s decision, agreeing that the material-support bar applied and that there was no de minimis or duress exception.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the petitioner’s forced cooking for the group did not constitute “material support” under the relevant statute, as his actions were not sufficiently substantial to help the organization accomplish its terrorist activities. The court granted the petition for review, vacated the Board’s order of removal, and remanded the case for further proceedings. View "Ozurumba v. Bondi" on Justia Law

A California resident sought to participate in Maryland’s cannabis business licensing process, which included a “social equity applicant” program designed to address historical inequities in the cannabis industry. To qualify as a social equity applicant, an individual needed to meet one of several criteria, such as having lived in a disproportionately impacted area, attending a public school in such an area, or attending for at least two years a Maryland institution of higher education where at least 40% of students are Pell Grant eligible. The plaintiff, who had never lived in Maryland, claimed eligibility based on her attendance at California State University, Long Beach, but was unable to meet the Maryland-specific higher education criterion. She was ultimately found ineligible for the first round of licensing.The plaintiff filed suit in the United States District Court for the District of Maryland, alleging that the Maryland licensing scheme discriminated against nonresidents in violation of the Dormant Commerce Clause and seeking declaratory and injunctive relief. She moved for a temporary restraining order and preliminary injunction to halt the licensing process. The district court denied her motion, finding she had not demonstrated a likelihood of success on the merits, and denied her request for an injunction pending appeal.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s denial of a preliminary injunction for abuse of discretion. The Fourth Circuit held that the challenged higher education criterion did not discriminate against non-Maryland residents, as it did not require Maryland residency and was equally available to out-of-state applicants who attended qualifying Maryland institutions. The court affirmed the district court’s denial of injunctive relief, concluding that the plaintiff failed to show a likelihood of success on the merits of her Dormant Commerce Clause claim. View "Jensen v. Maryland Cannabis Administration" on Justia Law