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

The defendant was charged with several offenses arising from a scheme in which he and others conspired to commit wire fraud by deceiving businesses into transferring funds to accounts they controlled. The conspirators, operating from Nigeria and Saudi Arabia, used phishing emails containing malware to access business computers and steal money. The government linked the defendant to the conspiracy using evidence including overlapping social media handles, email accounts, IP addresses, and testimony connecting his online activity to fraud-related accounts. The government also introduced evidence that one company suffered financial losses and response costs due to the crimes.A grand jury indicted the defendant and his co-conspirators, but only the defendant proceeded to trial in the United States District Court for the Eastern District of Virginia. During jury selection, a prospective juror mentioned familiarity with the defendant and the case due to his work in cybersecurity. The court struck this juror for cause and repeatedly instructed the panel on impartiality. The jury convicted the defendant on all counts, including sentencing enhancements. The defendant moved for acquittal and a new trial, arguing that the prospective juror’s comments affected jury impartiality and that the evidence was insufficient to connect him to the scheme or to establish the necessary $5,000 loss for an enhanced sentence. The district court denied these motions and sentenced the defendant to 120 months’ imprisonment.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s denial of a new trial, finding no prejudicial error in the jury selection process and holding that there was sufficient evidence linking the defendant to the fraud. However, the appellate court reversed the sentencing enhancement for intentional damage to a protected computer, concluding that the government failed to prove $5,000 in qualifying losses as required by statute. The case was remanded for resentencing consistent with this opinion. View "United States v. Umeti" on Justia Law

A resident of a retirement community, who has celiac disease and relies on a gluten free diet, experienced multiple episodes of illness after consuming meals labeled as gluten free at the facility. She signed a residential contract based on assurances that her dietary needs would be accommodated. Over several years, she reported incidents of illness to staff, including a crab cake in 2018, a stuffed tomato in 2020, and chicken marsala in 2021, all purportedly gluten free. The facility made various adjustments in response to her complaints, including menu changes, staff training, and kitchen modifications. She continued to use her meal plan but gave away the food. In 2023, she filed suit alleging violations of federal disability rights statutes and several state-law claims.The United States District Court for the District of Maryland granted summary judgment to the retirement community on all claims. The court found her federal claims untimely and denied her request for injunctive relief, concluding she lacked standing. It also rejected her state-law breach of contract and negligence claims, holding they were barred by the statute of limitations and unsupported by evidence.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court’s judgment as to the federal claims, holding that the plaintiff lacked standing for injunctive relief under the Americans with Disabilities Act and that her Fair Housing Act and Rehabilitation Act claims were barred by the applicable statutes of limitations. It also affirmed dismissal of state-law claims related to the 2018 incident. However, the court vacated summary judgment as to her breach of contract and negligence claims arising from the January 2021 chicken marsala incident, finding genuine issues of material fact that should be resolved by a jury. The case was remanded for further proceedings on those claims. View "McGinn v. Broadmead, Inc." on Justia Law

Daqua Ritter was indicted for three federal crimes connected to the murder of Ernest “Dime” Doe, a transgender woman in rural South Carolina. Ritter and Doe had a secretive sexual relationship, and Ritter was sensitive about public knowledge of this relationship, especially since Doe openly referred to Ritter as her boyfriend. Evidence at trial showed Ritter pressured Doe to keep their relationship hidden and reacted angrily when others mentioned it. Doe was found shot dead in a car, and Ritter was last seen with her hours before her death. After the murder, Ritter disposed of his gun and burned his clothes. A federal grand jury indicted Ritter for willfully causing bodily injury based on Doe's gender identity resulting in death, using a gun during a crime of violence, and making false statements to investigators.The United States District Court for the District of South Carolina presided over Ritter’s trial. A jury convicted Ritter on all charges, and the district court sentenced him to life in prison. Ritter moved for a new trial, claiming juror bias and prejudicial hearsay testimony, and challenged the sufficiency of evidence for two counts. The district court held an evidentiary hearing regarding juror bias and denied the motion for a new trial, finding the juror credible and impartial. It also denied the motion for a mistrial based on hearsay, issuing a curative instruction to disregard the testimony.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the district court did not abuse its discretion in finding no juror bias or in denying a mistrial based on hearsay, as the curative instruction was sufficient. The court also found that, viewed in the light most favorable to the government, there was sufficient evidence for the jury to convict Ritter on all counts, including motive based on gender identity and the likelihood that false statements would be communicated to federal law enforcement. The judgment was affirmed. View "United States v. Ritter" on Justia Law

Three individuals living with well-managed HIV, whose infections are controlled by daily medication and who have undetectable viral loads, sought to join or rejoin the U.S. Army. They were denied enlistment based on Department of Defense and Army policies that list HIV infection as a disqualifying medical condition, alongside numerous other chronic or communicable diseases. A nonprofit organization, Minority Veterans of America, also supported their challenge. The plaintiffs argued that these policies violate their equal protection rights under the Fifth Amendment and are arbitrary and capricious in violation of the Administrative Procedure Act.The United States District Court for the Eastern District of Virginia granted summary judgment to the plaintiffs. The court issued a permanent injunction barring the Military from denying accession to asymptomatic HIV-positive individuals with undetectable viral loads, prohibiting enforcement of HIV-specific policy provisions, and ordering reevaluation of prior decisions made under these policies. The district court concluded that the Military’s justifications—based on medical, cost, and diplomatic concerns—were irrational, arbitrary, and capricious.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the judgment. Applying rational basis review with heightened deference to military judgments, the Fourth Circuit found that the Military’s policies were rationally related to legitimate military purposes, including maintaining deployable, medically fit servicemembers, minimizing complications from chronic conditions, controlling costs, and addressing diplomatic issues with foreign host nations. The court distinguished this case from Roe v. Department of Defense, which concerned policies for current servicemembers rather than initial entry. The Fourth Circuit held that the Military’s HIV accession policy did not violate the Fifth Amendment or the APA and reversed the district court’s judgment, remanding with instructions to enter judgment for the Military. View "Wilkins v. Hegseth" on Justia Law

Advance Auto Parts, Inc., a publicly traded company, announced ambitious financial goals for 2023, which increased its stock price. However, the company subsequently lowered its guidance and identified a series of accounting errors, resulting in significant declines in its stock price. The City of Southfield General Employees’ Retirement System, representing investors who purchased stock during the period between November 2022 and November 2023, filed a class action lawsuit against Advance Auto and several former executives. The plaintiffs alleged violations of SEC Rule 10b-5 and Sections 10(b) and 20(a) of the Securities Exchange Act, asserting that the defendants intentionally or recklessly misrepresented the company’s financial results and forecasts.The United States District Court for the Eastern District of North Carolina consolidated several investor suits and designated Southfield as lead plaintiff. The court found that Southfield adequately alleged material misstatements or omissions and satisfied the basic requirements for a securities fraud claim, except for scienter—the requirement that defendants acted with wrongful intent or recklessness. The court concluded that the more plausible inference was that the defendants acted in good faith and corrected errors as they became known, dismissing the complaint for failure to sufficiently plead scienter.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the dismissal de novo. The Fourth Circuit examined the allegations individually and holistically, finding that none supported a strong inference of scienter as required by the Private Securities Litigation Reform Act. The court held that the facts, even when considered collectively, only plausibly suggested wrongful intent but did not meet the heightened standard for a strong inference. Accordingly, the Fourth Circuit affirmed the district court’s dismissal of the securities fraud claims and the related vicarious liability claim. View "City of Southfield General Employees' Retirement v. Advance Auto Parts, Inc." on Justia Law

While incarcerated in the general population at Central Prison in North Carolina, an individual was violently attacked by a “safekeeper”—a pre-trial detainee designated as requiring strict separation due to risk of violence. On the day in question, prison correctional officers responsible for enforcing separation between safekeepers and the general population failed to keep key security doors closed, contrary to prison policy. This lapse allowed the safekeeper to encounter and assault the plaintiff, resulting in severe facial injuries and lasting pain.The plaintiff brought a lawsuit under 42 U.S.C. § 1983 against three correctional officers, alleging deliberate indifference to his safety in violation of the Eighth Amendment. The United States District Court for the Eastern District of North Carolina granted summary judgment to the officers, finding that the record did not support a jury finding of Eighth Amendment liability and concluding that, even if it did, the officers were entitled to qualified immunity. The district court also allowed the officers, over the plaintiff’s objection, to file a late response to a summary judgment motion without applying the “excusable neglect” standard required under Federal Rule of Civil Procedure 6(b).The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that genuine disputes of material fact remained regarding both the officers’ liability for deliberate indifference and the applicability of qualified immunity. The Fourth Circuit further found that the district court had abused its discretion by failing to consider the correct standard when granting an extension of time for the officers’ late filing. The court vacated the district court’s summary judgment and extension orders, and remanded the case for further proceedings with instructions to apply the proper legal standards. View "Case v. Beasley" on Justia Law

The case concerns an individual who was born in El Salvador in 1981 to unmarried parents. His biological father acknowledged paternity by signing the birth certificate, but the two did not have a relationship. At age 11, he immigrated to the United States as a lawful permanent resident to join his mother. When he was 16, his mother became a naturalized U.S. citizen. As an adult, he was convicted of drug-related offenses. Years later, removal proceedings were initiated against him despite an earlier case memorandum indicating he had derived citizenship through his mother.An immigration judge (IJ) initially denied his motion to terminate removal proceedings, finding that he failed to prove his paternity had not been legitimated under Salvadoran law, and ordered him removed. The Board of Immigration Appeals (Board) affirmed the removal order but remanded for reconsideration of his claim under the Convention Against Torture (CAT). Subsequent IJ and Board orders continued to find him removable and not a U.S. citizen, though relief under CAT was granted and later vacated. Both sides appealed these orders, leading to multiple remands and re-entries of removal orders. Ultimately, the Board reaffirmed its prior rulings, and the petitioner remained in immigration detention.The United States Court of Appeals for the Fourth Circuit reviewed the consolidated petitions. The court held that it had jurisdiction to review both the 2024 and 2025 Board orders. On the merits, the court determined that, under the relevant federal statute in effect when the petitioner’s mother naturalized, his paternity had not been “established by legitimation.” Because all other statutory requirements were met, he automatically became a U.S. citizen upon his mother’s naturalization. The court granted the petitions, vacated the Board’s orders, and remanded with instructions to terminate removal proceedings. View "Lopez v. Bondi" on Justia Law

A group of nine professional models brought suit against a nightclub in Greenville, South Carolina, alleging that the club took images from the models’ social media pages and used them in its promotional materials without their knowledge, consent, or compensation. The models claimed the advertising falsely implied their association, employment, or endorsement of the club. They asserted two claims under the Lanham Act as well as seven state law claims, including misappropriation of likeness.The defendant responded with a motion to dismiss all counts for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6), but did not challenge the sufficiency of the misappropriation of likeness claim. The plaintiffs did not respond to the motion within the time set by the District of South Carolina’s local rules. The United States District Court for the District of South Carolina granted the motion to dismiss as unopposed, dismissing the federal and most state law claims with prejudice and dismissing the misappropriation of likeness claim without prejudice, declining to exercise supplemental jurisdiction. The plaintiffs’ postjudgment motions for relief were denied by the district court.On appeal, the United States Court of Appeals for the Fourth Circuit held that a court may not grant a Rule 12(b)(6) motion solely because it is unopposed. The court emphasized that Rule 12(b)(6) requires an independent determination of whether the complaint states a plausible claim for relief, regardless of the parties’ failure to respond. Finding that the district court had not made such a determination, the Fourth Circuit vacated the judgment and remanded the case for further proceedings. The court did not reach the merits of the parties’ other arguments or the postjudgment orders. View "Guzman v. Acuarius Night Club LLC" on Justia Law

This case involves individuals who filed asbestos-related tort claims against DBMP LLC. The claims arise from injuries allegedly caused by asbestos-containing products manufactured by CertainTeed Corporation over several decades. Facing a growing number of lawsuits and significant financial exposure, CertainTeed underwent a "divisional merger" under Texas law, splitting into two entities: New CertainTeed, which received most assets and non-asbestos liabilities, and DBMP, which received all asbestos-related liabilities and certain assets. An uncapped funding agreement obligated New CertainTeed to cover DBMP’s asbestos liabilities. DBMP then filed for Chapter 11 bankruptcy, invoking 11 U.S.C. § 524(g) to manage current and future asbestos claims through a trust. As a result, pending tort actions were automatically stayed.The United States Bankruptcy Court for the Western District of North Carolina denied motions from the plaintiffs to lift the automatic stay and to stay a preliminary injunction that extended the stay to CertainTeed affiliates. Applying the standards from In re Robbins, the bankruptcy court found that lifting the stay would prejudice the debtor’s estate, harm judicial economy by returning a large volume of cases to the tort system, and undermine consistent treatment of claimants under a § 524(g) plan. The bankruptcy court also found insufficient evidence of bad faith by DBMP in filing for bankruptcy. The United States District Court for the Western District of North Carolina affirmed, holding that the bankruptcy court’s findings and application of the Robbins factors were not an abuse of discretion.On further appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The Fourth Circuit held that the bankruptcy court did not abuse its discretion in refusing to lift the automatic stay. It found that DBMP sought bankruptcy protection for legitimate purposes under § 524(g), was not shown to have acted in bad faith, and that the statutory framework does not require insolvency. View "Herlihy v. DBMP, LLC" on Justia Law

The case concerns the non-reappointment of a local general registrar of elections in Lynchburg, Virginia. The plaintiff, previously appointed unanimously by a bipartisan electoral board, reapplied for her position after her term expired in 2023. By that time, the board’s partisan makeup had shifted to include two Republicans and one Democrat, reflecting state law. The board interviewed four candidates, including the plaintiff, but ultimately appointed a different candidate who was a registered Republican. The plaintiff, describing herself as an independent, alleged her non-reappointment was due to partisan bias rather than job performance.Following the board’s decision, the plaintiff sued the board and its two Republican members, alleging First Amendment violations tied to political animus. The United States District Court for the Western District of Virginia dismissed the claim against the board itself on sovereign immunity grounds, but allowed the suit against the individual members to proceed. After a jury trial, the verdict favored the defendants. The plaintiff then appealed, raising concerns about jury selection procedures and the exclusion of certain evidence.The United States Court of Appeals for the Fourth Circuit reviewed the appeal. It held that the district court did not abuse its discretion in managing voir dire, including its refusal to allow more pointed questioning about potential jurors’ political affiliations and beliefs. The Fourth Circuit also determined that the plaintiff had not preserved most evidentiary challenges for appellate review, as she failed to make sufficient proffers or obtain definitive rulings on excluded evidence. For the limited evidentiary exclusions properly preserved, the appellate court found no abuse of discretion. Thus, the Fourth Circuit affirmed the judgment in favor of the defendants. View "Gibbons v. Gibbs" on Justia Law