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

David Ray Gunter, who had a mechanical heart valve and required daily anticoagulant medication (Coumadin), was arrested and detained at two North Carolina county jails. During his detention, Gunter did not consistently receive his prescribed medication, missing doses over several days due to failures by the contracted medical provider and jail staff. After his release, he suffered serious medical complications, including blood clots and subsequent surgeries. Gunter alleged these injuries were the result of inadequate medical care during his incarceration.The United States District Court for the Middle District of North Carolina granted summary judgment for defendants on Gunter’s constitutional claims under 42 U.S.C. § 1983, including deliberate indifference and Monell claims, finding insufficient evidence that jail officials or contracted medical providers acted with deliberate indifference or that county policies caused the deprivation. The district court also granted summary judgment to Southern Health Partners, Inc. (SHP) on the medical malpractice claim, finding that Gunter’s expert testimony did not establish a breach of the standard of care by SHP, and excluded expert evidence it found speculative. However, the district court found genuine disputes of fact regarding medical malpractice claims against two individual medical providers, but ultimately found no proximate cause. The district court denied Gunter’s motion to compel deposition of the defendants’ expert as untimely and granted a motion to strike a post-deposition declaration from Gunter’s expert.The United States Court of Appeals for the Fourth Circuit reversed the district court’s dismissal of Gunter’s deliberate indifference claim against the medical provider defendants, the Monell claim against the counties, and the medical malpractice claims against SHP and two medical providers, holding that genuine disputes of material fact remained. The appellate court also reversed the exclusion of certain expert testimony and the grant of the motion to strike, but affirmed the denial of the motion to compel. The case was remanded for further proceedings. View "Swink v. Southern Health Partners Inc." on Justia Law

A native and citizen of Honduras entered the United States without authorization in 2019, seeking protection from removal based on claims of past persecution and a likelihood of future harm by the MS-13 gang. He described a series of violent incidents involving MS-13, including the murders of two brothers, threats, extortion attempts, and physical assaults. The petitioner asserted that reporting these incidents to Honduran authorities would have been futile or dangerous due to widespread corruption and gang infiltration of law enforcement. He also provided evidence that MS-13 continued to search for him and his family after he fled Honduras.Removal proceedings were initiated in 2023. The Immigration Judge (IJ) found the petitioner credible but denied his applications for withholding of removal and protection under the Convention Against Torture (CAT). The IJ concluded that the petitioner had not shown the Honduran government was unable or unwilling to control MS-13, partly because he had not reported the incidents to police and because police responded to his brothers’ murders. The IJ also determined that the petitioner had not demonstrated he could not reasonably relocate within Honduras to avoid harm, and that he had not established a likelihood of torture with government acquiescence. The Board of Immigration Appeals (BIA) affirmed the IJ’s decision, finding no clear error in the IJ’s analysis and dismissing the appeal.The United States Court of Appeals for the Fourth Circuit reviewed both the IJ’s and BIA’s decisions. The court held that the IJ and BIA abused their discretion by disregarding credible, unrebutted, and legally significant evidence that reporting to authorities would have been futile or dangerous, and by failing to meaningfully engage with country condition evidence of government corruption and gang control. The court vacated the BIA’s decision and remanded for further proceedings, holding that the record compelled the conclusion that the Honduran government was unable or unwilling to control MS-13 and that the petitioner could not reasonably relocate to avoid persecution. The court also found that the agency failed to properly consider evidence relevant to CAT relief. View "Marquez v. Bondi" on Justia Law

A corporation, formed as a captive insurance company in North Carolina, was owned by three shareholders who also served as its directors. The majority shareholder, who was not involved in daily operations, alleged that the two minority shareholders, who managed the company, and a Chief Technology Officer (CTO) hired to develop proprietary software, conspired to create a competing insurance entity. The proprietary software in question was designed to analyze medical records and price insurance contracts more effectively, and was claimed to be confidential and of significant economic value. All employees, including the CTO and the minority shareholders, were required to sign employment contracts containing confidentiality and invention provisions, which specified that inventions and confidential information developed during employment would be the exclusive property of the company.The plaintiffs filed suit in the United States District Court for the Eastern District of North Carolina, alleging, among other claims, that the defendants misappropriated trade secrets in violation of the Defend Trade Secrets Act (DTSA). The defendants moved for judgment on the pleadings. The district court granted the motion as to the DTSA claim, finding that the plaintiffs had not sufficiently alleged that they took reasonable measures to protect the secrecy of the proprietary software. The court declined to exercise supplemental jurisdiction over the remaining state law claims. The plaintiffs appealed the dismissal of the DTSA claim.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s decision de novo. The Fourth Circuit held that the plaintiffs had plausibly alleged ownership of a trade secret, reasonable measures to protect its secrecy through confidentiality agreements, and misappropriation by the defendants. The court concluded that, at the pleading stage, the existence of confidentiality and invention provisions was sufficient to allege reasonable efforts to maintain secrecy. The Fourth Circuit reversed the district court’s dismissal of the DTSA claim and remanded for further proceedings. View "Samuel Sherbrooke Corporate, Ltd v. Mayer" on Justia Law

In this case, the defendant applied for U.S. citizenship in 2011 and, on his application and during an interview, denied ever having committed a crime for which he was not arrested. However, in 2013, he pleaded guilty in North Carolina state court to attempted statutory rape for conduct that occurred in 2008, admitting to engaging in a sexual act with a minor. He did not disclose this conduct on his naturalization application. Years later, a federal grand jury indicted him for naturalization fraud, alleging he knowingly concealed his criminal history to obtain citizenship.The United States District Court for the Western District of North Carolina denied the defendant’s motion to dismiss the indictment for unconstitutional preindictment delay, finding he had not shown actual prejudice from the delay. The court also denied his motion to suppress evidence of his state guilty plea, ruling that he could not collaterally attack the validity of his state conviction in federal court except for a deprivation of counsel, which did not apply here. At trial, the court limited the testimony of the defendant’s expert witness regarding his cognitive abilities, excluding certain opinions about his capacity to understand the application question. The jury convicted the defendant, finding he knowingly made a false statement, and the court sentenced him to six months in prison and revoked his citizenship.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The Fourth Circuit held that the defendant failed to demonstrate substantial actual prejudice from the preindictment delay, that the district court properly refused to suppress the state guilty plea, and that while the limitation of the expert’s testimony was error under recent Supreme Court guidance, the error was harmless given the other evidence presented. The conviction and sentence were therefore affirmed. View "US v. Palmer" on Justia Law

Three individuals, all Cameroonian Americans, participated in a secretive group dedicated to sending firearms and ammunition from Maryland to Anglophone fighters in Cameroon. The group, known as the “Peanut Project,” operated out of a basement in Baltimore County, where they assembled, modified, and packaged weapons and ammunition for overseas shipment. Their concealment methods included obliterating serial numbers from firearms and hiding the items within compressor tanks and other cargo. In 2019, law enforcement intercepted a shipping container en route to Nigeria containing over 35,000 rounds of ammunition and 39 firearms, many with defaced serial numbers. A subsequent search of the group’s base revealed a full-scale operation for manufacturing and preparing firearms for export.A federal grand jury in the United States District Court for the District of Maryland indicted the defendants on five counts, including conspiracy, illegal exportation, transportation of firearms with obliterated serial numbers, and smuggling. After a ten-day jury trial, the defendants were convicted of conspiracy, transporting firearms with obliterated serial numbers, and smuggling, but acquitted on the exportation counts. The district court denied post-trial motions challenging the sufficiency of the evidence and various trial rulings. At sentencing, the court applied enhancements for the number of firearms involved and for trafficking, sentencing each defendant to 63 months’ imprisonment and two years of supervised release.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the convictions and sentences. The court held that the evidence was sufficient to support the jury’s findings, the district court did not abuse its discretion in evidentiary or instructional rulings, and the sentencing enhancements were properly applied. The court also found no error in the oral and written pronouncement of supervised release conditions. The judgments of the district court were affirmed. View "US v. Nji" on Justia Law

Several individuals associated with the Reccless Tigers, a Northern Virginia-based drug gang, were charged with a range of offenses, including drug trafficking, racketeering, kidnapping, and murder. The gang was involved in distributing marijuana and cocaine, and members targeted those who failed to pay drug debts or cooperated with law enforcement. The case centered on the murder of Brandon White, who owed a drug debt and had testified against a gang member. Evidence showed that gang members, including the defendants, orchestrated White’s abduction and murder, with some directly participating in the killing.The United States District Court for the Eastern District of Virginia presided over a joint trial. The court denied several pretrial motions, including requests for continuances, motions to substitute counsel, and a motion to dismiss based on alleged violations of the Speedy Trial Act and the Sixth Amendment. The jury convicted three defendants—Lamborn, Yoo, and Peter—of racketeering conspiracy, murder in aid of racketeering, kidnapping conspiracy, kidnapping resulting in death, drug conspiracy, and killing while engaged in drug trafficking, with Lamborn also convicted of using a firearm resulting in death. Tony was convicted of racketeering and drug conspiracy but acquitted of destructive device charges. The court sentenced Lamborn, Yoo, and Peter to life imprisonment and Tony to 312 months.The United States Court of Appeals for the Fourth Circuit reviewed the case. It affirmed the convictions and most sentences, finding no abuse of discretion in the denial of continuances or substitution of counsel, and sufficient evidence supported the convictions. The court also upheld the district court’s application of sentencing enhancements and rejected the Speedy Trial Act and Sixth Amendment claims. However, it vacated the sentences of Lamborn, Yoo, and Peter due to inconsistencies between the oral pronouncement and written judgments regarding supervised release conditions, remanding for resentencing on that issue. View "US v. Lamborn" on Justia Law

Law enforcement stopped a vehicle in which Michael Henderson was a passenger. During a search, a K-9 alerted to drugs in Henderson’s bag, which contained approximately 1,921.2 grams of pure methamphetamine. Henderson was arrested, and while in jail, he made phone calls instructing associates on drug distribution using coded language. One associate, Bonnie Cagle, revealed to police that Henderson’s references to “puppies” were code for firearms, and “sockets” and “tools” referred to drugs. Police recovered two firearms linked to Henderson from Cagle and her mother’s home.Henderson pleaded guilty in the United States District Court for the Southern District of West Virginia to possessing 500 grams or more of methamphetamine with intent to distribute. The presentence investigation report initially recommended a two-level enhancement for possession of a firearm, but after Henderson’s timely objection and the government’s lack of response, the probation officer removed the enhancement. The revised report also recommended a reduction for acceptance of responsibility. The district court later requested supplemental briefing on Henderson’s eligibility for “safety valve” relief under 18 U.S.C. § 3553(f). The government then argued for sentencing enhancements and against the reduction for acceptance of responsibility, which Henderson claimed were untimely.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the district court acted within its discretion in considering the government’s late arguments for sentencing enhancements, finding that the request for supplemental briefing constituted good cause. The court also found sufficient evidence to support the firearm enhancement, concluding that Henderson constructively possessed firearms in connection with drug trafficking. The court affirmed the district court’s judgment, upholding Henderson’s sentence. View "US v. Henderson" on Justia Law

A company developed a specialized vehicle-mounted stairway, with design work primarily performed by the founder’s son, who was promised equity in the business but never received it due to the majority owner’s repeated refusals. The son, with his father’s assistance, eventually obtained a patent for the design, which he used as leverage to seek compensation. Negotiations between the parties failed, leading to the father’s removal as company president and the company filing suit against both the father and son. The company alleged breach of fiduciary duty, misappropriation of trade secrets, business conspiracy, unjust enrichment, fraud, and breach of contract, while the son counterclaimed for patent infringement.The United States District Court for the Eastern District of Virginia granted summary judgment to the father and son on all claims except a breach of contract claim against the father and the son’s patent counterclaim. The court found most claims time-barred or unsupported by evidence, and later, the company voluntarily dismissed its remaining claim. The son’s patent was invalidated by a jury. The district court also awarded attorneys’ fees and costs to the father as the prevailing party under the company’s operating agreement.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo and affirmed the district court’s rulings. The appellate court held that the company’s claims were either time-barred under the applicable statutes of limitations or failed on the merits, as there was no evidence the son benefited from the patent or that he had signed a non-disclosure agreement. The court also affirmed the award of attorneys’ fees and costs to the father, finding no error in the district court’s application of Delaware law or its determination of the prevailing party. View "Mission Integrated Technologies, LLC v. Clemente" on Justia Law

Gregory Bonnie was serving a 144-month federal prison sentence in South Carolina, consisting of 120 months for drug trafficking convictions and a consecutive 24 months for violating supervised release, which included a conviction under 18 U.S.C. § 924(c) for possession of a firearm during a drug trafficking crime. While incarcerated, Bonnie sought to earn time credits under the First Step Act (FSA) for the 120-month portion of his sentence related to drug offenses, acknowledging that the 24-month portion for the § 924(c) conviction was disqualifying under the FSA.The Bureau of Prisons (BOP) denied Bonnie’s request, treating his consecutive sentences as a single, aggregate term of imprisonment pursuant to 18 U.S.C. § 3584(c), and finding him ineligible for FSA time credits because his aggregate sentence included a disqualifying § 924(c) conviction. After exhausting administrative remedies, Bonnie filed a habeas petition under 28 U.S.C. § 2241 in the United States District Court for the District of South Carolina. The district court granted summary judgment for the warden, holding that the plain text and statutory context of the FSA and § 3584(c) required aggregation of sentences, making Bonnie ineligible for FSA time credits for the entire 144-month sentence.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the statutory interpretation de novo. The court held that, under the FSA and § 3584(c), the BOP must treat multiple consecutive or concurrent sentences as a single, aggregate sentence for administrative purposes, including the computation of FSA time credits. Because Bonnie’s aggregate sentence included a conviction under § 924(c), he was ineligible for FSA time credits for any portion of the sentence. The Fourth Circuit affirmed the district court’s judgment denying Bonnie’s habeas petition. View "Bonnie v. Dunbar" on Justia Law

A native and citizen of Mexico was placed in removal proceedings after being charged with a misdemeanor offense in 2014. He conceded removability and applied for cancellation of removal under 8 U.S.C. § 1229b, listing one alias on his application. During his merits hearing, he disclosed additional aliases used for work and border crossing, but did not initially mention another alias, “Juan Sanchez Cabrera,” which the government later introduced through documentary evidence. He explained that he had used a false name during a border crossing but could not recall the specific alias. Throughout his testimony, he stated he did not remember all the aliases he had used.The Immigration Judge of the immigration court denied his application for cancellation of removal, finding him statutorily barred from establishing good moral character under 8 U.S.C. § 1101(f)(6) due to providing false testimony. The judge relied on his failure to disclose the “Juan Sanchez Cabrera” alias on his application and during direct testimony. On appeal, the Board of Immigration Appeals affirmed the denial, finding no clear error in the judge’s determination that he provided false testimony with the intent to deceive for immigration benefits, as evidenced by his incomplete disclosure of aliases until confronted by the Department of Homeland Security.The United States Court of Appeals for the Fourth Circuit reviewed the Board’s decision. The court held that it had jurisdiction over the mixed question of law and fact regarding the application of the false testimony bar, but not over factual determinations of intent. The Fourth Circuit found that the Board applied the incorrect standard of review by reviewing the legal question for clear error rather than de novo. The court granted the petition for review, vacated the Board’s decision, and remanded the case for the Board to apply the correct standard. View "Martinez-Martinez v. Bondi" on Justia Law