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

The case involves Russell Lucius Laffitte, who was convicted of bank and wire fraud in the United States District Court for the District of South Carolina. The government alleged that between 2006 and 2021, Laffitte, as CEO of Palmetto State Bank, conspired with Alex Murdaugh, a disbarred attorney, to defraud Murdaugh’s clients. Laffitte was accused of using his position to access settlement accounts, collecting fees, and extending unsecured loans to Murdaugh, resulting in nearly two million dollars being stolen from the accounts. Laffitte was charged with conspiracy to commit wire and bank fraud, bank fraud, wire fraud, and misapplication of bank funds.During the trial, the government presented fifteen witnesses, and Laffitte called eight witnesses and testified in his own defense. After the jury began deliberations, the court received notes from jurors indicating issues, including one juror needing medication and another feeling pressured. The district court decided to remove two jurors, Juror No. 88 and Juror No. 93, and replaced them with alternates. The jury then returned a guilty verdict on all counts.Laffitte appealed, arguing that the removal of the jurors violated his Fifth Amendment right to be present and his Sixth Amendment right to an impartial jury. The Fourth Circuit Court of Appeals reviewed the case and found that the removal of Juror No. 88 violated Laffitte’s Sixth Amendment right because there was a reasonable and substantial possibility that her removal was related to her views on the case. The court also found that the removal violated Laffitte’s Fifth Amendment right to be present, as he was not present during the in camera interview when the decision to remove Juror No. 88 was made. The court concluded that these errors were not harmless and vacated Laffitte’s convictions and sentence, remanding the case for a new trial. View "US v. Russell Laffitte" on Justia Law

The plaintiff, Siddhanth Sharma, a convicted felon, challenged North Carolina's felony-disclosure requirement for candidates running for federal office. This state law mandates that candidates disclose any felony convictions and provide additional information about the convictions and the restoration of citizenship rights. Sharma, who announced his candidacy for North Carolina’s Thirteenth Congressional District seat, argued that this requirement violated the Qualifications Clause and the First Amendment.The United States District Court for the Eastern District of North Carolina dismissed Sharma's claims. The court found that Sharma had standing to challenge the felony-disclosure requirement but concluded that it did not constitute an additional qualification for office. The court also held that the requirement did not violate the First Amendment, as it served a substantial interest in promoting an informed electorate and posed only a modest burden. Sharma's challenge to the address-disclosure requirement was dismissed for lack of standing, as the court found his injury insufficiently particularized.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court's decision, holding that the felony-disclosure requirement is constitutional. The court reasoned that the requirement does not exclude candidates from the ballot or disadvantage political viewpoints, and it falls within the state's authority to regulate elections. The court also found that the requirement imposes only a light burden on First Amendment rights and serves the state's interest in fostering an informed electorate. However, the court vacated the judgment on the address-disclosure challenge and remanded it to the district court with instructions to dismiss it as moot, as Sharma's address was already publicly available in the voter-search database. View "Siddhanth Sharma v. Alan Hirsch" on Justia Law

Christopher Ladariss Mitchell was charged with conspiracy to commit Hobbs Act robbery and one substantive count of Hobbs Act robbery. The indictment alleged that Mitchell and his co-defendants conspired to rob employees of two wireless communication retailers, referred to as Company A and Company B, at various locations within the Middle District of North Carolina and elsewhere. Mitchell pleaded guilty to the charges in January 2023.The United States District Court for the Middle District of North Carolina sentenced Mitchell based on a presentence investigation report (PSR) that included four separate robberies in the calculation of his total offense level. Mitchell objected, arguing that only two robberies should be considered. The district court rejected his argument, finding that the evidence supported his involvement in all four robberies beyond a reasonable doubt, and sentenced him to 108 months in prison.On appeal to the United States Court of Appeals for the Fourth Circuit, Mitchell contended that the district court erred in including the four robberies in the offense level calculation. He argued that the conspiracy count should only include two robberies, one for each company. The Fourth Circuit reviewed the case de novo and affirmed the district court's decision. The court held that under U.S.S.G. § 1B1.2(d), a conviction on a count charging a conspiracy to commit more than one offense should be treated as if the defendant had been convicted on a separate count of conspiracy for each offense. The court found that the indictment's broad language encompassed the four robberies and that the district court correctly applied the guideline by including all four robberies in the offense level calculation. View "United States v. Mitchell" on Justia Law

In 2016, a suicide bombing occurred at the U.S. military base in Bagram Airfield, Afghanistan. The bomber, an Afghan national employed by a subcontractor of Fluor Corporation, detonated an explosive vest, injuring Specialist Winston Tyler Hencely, among others. Hencely sued Fluor, alleging negligence in supervision, entrustment, and retention of the bomber, and breach of contract with the U.S. Government.The U.S. District Court for the District of South Carolina granted judgment to Fluor on all claims. The court found that federal law preempted Hencely’s tort claims and that he was not a third-party beneficiary entitled to enforce the Government’s contract with Fluor. Hencely appealed these decisions.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court’s judgment, holding that the Federal Tort Claims Act’s combatant activities exception preempted Hencely’s state-law tort claims. The court concluded that Fluor was integrated into combatant activities and that the military retained command authority over Fluor’s supervision of Local Nationals at Bagram Airfield. The court also held that Hencely was not an intended third-party beneficiary of the contract between Fluor and the U.S. Government, as the contract did not express an intent to benefit individual soldiers or confer upon them the right to enforce its provisions.Thus, the Fourth Circuit affirmed the district court’s judgment, precluding Hencely’s tort claims and denying his breach of contract claim. View "Hencely v. Fluor Corporation" on Justia Law

The case involves the Republican National Committee (RNC) and the North Carolina Republican Party (NCGOP) filing two state law claims against the North Carolina State Board of Elections (State Board) and its members. The claims, one statutory and one constitutional, allege that the State Board failed to comply with the Help America Vote Act of 2002 (HAVA), which mandates certain voter registration and maintenance procedures. The Democratic National Committee (DNC) intervened as a defendant. The plaintiffs argue that the State Board's noncompliance with HAVA led to improper voter registrations, potentially affecting 225,000 voters.The United States District Court for the Eastern District of North Carolina initially reviewed the case. The district court found it had original jurisdiction over the state statutory claim but not the state constitutional claim. It dismissed the statutory claim, ruling that the relevant statutory provision did not provide a private right of action. Consequently, the district court declined to exercise supplemental jurisdiction over the state constitutional claim and remanded it to state court, also holding that Section 1443 did not provide a valid basis for removal.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the district court's remand order was improper. It found that the district court possessed original jurisdiction over the state constitutional claim under Section 1331 because the claim contained an embedded federal question. The court also determined that removal was permissible under Section 1441. Additionally, the court held that the defendants validly removed the constitutional claim pursuant to Section 1443(2), which allows for removal in cases involving the refusal to perform an act on the grounds that it would be inconsistent with laws providing for equal rights. The court reversed the district court’s remand order and remanded the case for further proceedings consistent with its opinion. View "RNC v. North Carolina State Board of Elections" on Justia Law

Four plaintiffs were injured when a railing collapsed at FedExField during a professional football game. They sued the owner of the football team, the owner of the stadium, the security services provider, and unidentified maintenance persons for negligence. The defendants moved to compel arbitration based on an arbitration clause in the terms and conditions of the tickets, which were purchased online by a friend of the plaintiffs, Brandon Gordon.The United States District Court for the District of Maryland denied the motion to compel arbitration. The court found factual disputes regarding whether Gordon agreed to the arbitration clause. Additionally, the court held that even if Gordon had agreed to the arbitration clause, the defendants did not demonstrate that Gordon was an agent of the plaintiffs who could bind them to the arbitration clause.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court reversed the district court's decision regarding the plaintiffs being bound by any contract Gordon may have entered into, finding that Gordon had apparent authority to bind the plaintiffs to the arbitration clause. The court held that the Washington Football Team's reliance on Gordon's apparent authority was reasonable and traceable to the plaintiffs' actions of using the tickets to enter the stadium. The court vacated the district court's order denying arbitration and remanded the case to resolve the factual disputes about whether Gordon entered into a contract that included the arbitration clause. View "Naimoli v. Pro-Football, Inc." on Justia Law

In 2002, Chadrick Fulks and Brandon Basham engaged in a violent crime spree across several states, including carjacking, kidnapping, and murdering Alice Donovan. They were convicted in the District of South Carolina on multiple counts, including carjacking and kidnapping resulting in death, and were sentenced to death by a jury.Fulks and Basham later filed a successive motion under 28 U.S.C. § 2255, arguing that their firearms convictions under 18 U.S.C. § 924 were invalid. They contended that their carjacking convictions under 18 U.S.C. § 2119 no longer qualified as predicate “crimes of violence” under § 924, citing the Supreme Court’s decision in United States v. Taylor, which held that attempted Hobbs Act robbery was not a crime of violence. They argued that if attempted carjacking was not a crime of violence, then completed carjacking should not be considered a predicate crime of violence either. The district court denied their motion and granted a certificate of appealability.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court’s decision. The court held that the federal carjacking statute is divisible into completed and attempted carjacking. It concluded that completed carjacking is categorically a crime of violence under § 924(c)(3)’s force clause, relying on its previous decisions in United States v. Evans and United States v. Runyon. The court found that the Supreme Court’s decision in Taylor did not undermine these precedents. Additionally, the court determined that Fulks’s and Basham’s § 924 convictions were validly predicated on their carjacking convictions, as the carjacking and kidnapping were inextricably intertwined. Therefore, the Fourth Circuit affirmed the district court’s denial of the § 2255 motion. View "US v. Fulks" on Justia Law

The case involves Warren Balogh, who participated in the "Unite the Right" rally in Charlottesville, Virginia. The rally, organized to protest the removal of a Robert E. Lee statue, quickly turned violent between protesters and counterprotesters. Balogh alleged that the Charlottesville Police, under Chief Al Thomas, and the Virginia State Police, under Lieutenant Becky Crannis-Curl, failed to protect his First and Fourteenth Amendment rights by not intervening in the violence and declaring an unlawful assembly, which he claimed amounted to a heckler's veto.The United States District Court for the Western District of Virginia dismissed Balogh's complaint under Federal Rule of Civil Procedure 12(b)(6). The court found that the defendants were entitled to qualified immunity because there was no clearly established right to police intervention to protect First Amendment rights from third-party violence. The court also held that Balogh failed to state a plausible claim for relief under the First and Fourteenth Amendments, noting that the police did not selectively enforce the unlawful assembly order and that Balogh's allegations of intentional discrimination were conclusory.The United States Court of Appeals for the Fourth Circuit affirmed the district court's dismissal. The Fourth Circuit held that the First Amendment does not obligate police to protect protesters' constitutional rights amid violence, explicitly stating that the First Amendment is a shield against invasive speech regulations, not a sword to wield against violent disruptions. The court also found that Balogh's equal protection claim under the Fourteenth Amendment failed because he did not provide sufficient facts to show intentional or purposeful discrimination. Additionally, the court rejected Balogh's Monell claim against the City of Charlottesville, as he did not demonstrate that the City Manager, the final policymaker, had ratified or delegated authority to Chief Thomas. View "Balogh v. Virginia" on Justia Law

In 2000, Antonio Lamont Lightfoot was convicted by a jury in the District of Maryland for bank robbery and using a firearm during a crime of violence. The government identified two prior convictions for serious violent felonies: a 1985 armed bank robbery in Virginia and a 1990 armed bank robbery in Michigan. Consequently, Lightfoot was sentenced to mandatory life imprisonment under the federal "three-strikes" law, 18 U.S.C. § 3559(c), and an additional seven years for the firearm charge. His convictions and sentence were affirmed on appeal, and subsequent collateral challenges were unsuccessful.Following the Supreme Court's 2015 decision in Johnson v. United States, which invalidated the residual clause of the Armed Career Criminal Act (ACCA) as unconstitutionally vague, Lightfoot sought to vacate his sentence under 28 U.S.C. § 2255. He argued that the residual clause of the "serious violent felony" definition in 18 U.S.C. § 3559(c) was similarly void for vagueness. The district court denied his motion, holding that Michigan bank robbery is a divisible offense and that Lightfoot was convicted of the assaultive version, which qualifies as a serious violent felony under the enumerated offenses clause.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The court affirmed the district court's decision, concluding that Michigan's bank robbery statute is divisible into assaultive and non-assaultive offenses. Lightfoot was convicted of the assaultive version, which involves taking from another by force or intimidation. The court held that this offense qualifies as a serious violent felony under the enumerated offenses clause of the federal three-strikes law, 18 U.S.C. § 3559(c)(2)(F)(i). Therefore, Lightfoot's life sentence was upheld. View "United States v. Lightfoot" on Justia Law

Alvin Johnson pled guilty to possession with intent to distribute cocaine under a plea agreement. The agreement included a stipulation regarding the drug quantity and its base offense level but allowed the Government to make a sentencing recommendation. Johnson was initially sentenced to 128 months in prison, classified as a career offender based on prior convictions. He later successfully challenged one of these convictions, leading to a recalculated Guidelines range of 57-71 months.The United States District Court for the Eastern District of North Carolina initially sentenced Johnson to 128 months. Upon remand, after Johnson's successful challenge to his career offender status, the Probation Office recalculated his Guidelines range to 57-71 months. The Government then moved for an upward departure or variance, arguing that Johnson's criminal history warranted a higher sentence. The district court agreed and sentenced Johnson to 120 months.The United States Court of Appeals for the Fourth Circuit reviewed the case. Johnson argued that the Government breached the plea agreement by seeking a sentence above the recalculated Guidelines range. The court found that the plea agreement did not restrict the Government from recommending a higher sentence and that the Government had reserved the right to make a sentencing recommendation. The court held that the Government did not breach the plea agreement and affirmed the 120-month sentence. View "United States v. Johnson" on Justia Law