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

Plaintiff alleged that two sheriff deputies unlawfully entered his home. The deputies claim Armstrong’s then-wife invited them in. But although they disagree on whether the deputies’ conduct was reasonable, they do not dispute the historical facts as to what happened. Plaintiff filed a claim under 42 U.S.C. Section 1983. The deputies moved for summary judgment on the merits claiming that, even construing the facts in the light most favorable to Plaintiff, their conduct was objectively reasonable. Alternatively, the deputies claimed they should be granted summary judgment based on qualified immunity. The district court agreed with the deputies on the merits, finding the deputies reasonably believed that Roadcap had the authority to consent to the deputies’ entry.   The Fourth Circuit affirmed. The court explained that, construing the evidence in the light most favorable to Plaintiff, the deputies did, as the district court concluded, briefly detain Plaintiff. But the court agreed with the district court that the deputies acted reasonably as a matter of law because they were responding to a domestic situation, there were guns in the house, and Plaintiff was argumentative. Accordingly, the court affirmed the district court’s order granting summary judgment on the seizure of person claim as well. Moreover, the court wrote that, construing the evidence in the light most favorable to Plaintiff, the deputies exercised some care. Thus, the district court properly dismissed the gross negligence claim. Last, as to the conversion claim, the district court properly explained that there is no evidence in the record that the deputies possessed, touched or exercised any authority over Plaintiff’s personal property. View "Adam Armstrong v. Bryan Hutcheson" on Justia Law

The Employee Retirement Income Security Act’s Section 502(a)(1)(B) allows a beneficiary to “recover benefits due to him under the terms of his plan.” And ERISA’s Section 502(a)(3) allows a beneficiary to sue for “other appropriate equitable relief.” This case requires us to answer when—and under what conditions—a plaintiff may seek monetary relief under one of those provisions. Plaintiff’s son had a rare heart condition. He died at the age of twenty-seven, awaiting a heart transplant, which Plaintiff says that Defendants—who administered her son’s employer-based health benefits program—wrongfully denied. So she sued on behalf of his estate, seeking monetary relief under both Section 502(a)(1)(B) and 502(a)(3). The district court dismissed both claims. As to Plaintiff’s (a)(1)(B) claim, the court held that money was not one of the “benefits” that her son was owed “under the terms of his plan.” And, as to her (a)(3) claim, the court held that her requested monetary relief was too similar to money damages and was thus not “equitable.”   The Fourth Circuit affirmed in part and vacated in part. The court explained that the district court correctly held that money was not one of the “benefits” that Plaintiff’s son was “due” “under the terms of his plan.” So it was right to dismiss her (a)(1)(B) claim. However, the court explained that it must vacate its complete dismissal of Plaintiff’s (a)(3) claim. While the district court correctly noted that compensatory, “make-whole” monetary relief is unavailable under Section 502(a)(3), it did not consider whether Plaintiff plausibly alleged facts that would support relief “typically” available in equity. View "Jody Rose v. PSA Airlines, Inc." on Justia Law

\Petitioner, a native and citizen of Mexico, petition for review of a final order of removal entered by the Board of Immigration Appeals. The Board determined that Petitioner was ineligible for cancellation of removal because his prior conviction for receipt of stolen property was a crime involving moral turpitude. The Board also held that the immigration judge (IJ) provided Petitioner with legally adequate notice of the conditions applicable to his voluntary departure.   The Fourth Circuit affirmed the Board’s holding that Petitioner’s conviction for receipt of stolen property rendered him ineligible for cancellation of removal. However, the Board erred in concluding that the IJ was not required to advise Petitioner of the bond requirement before granting voluntary departure. Accordingly, the court denied the petition with respect to the cancellation of removal but remanded for the Board to consider Petitioner’s request for voluntary departure. The court explained that the Board did not address whether an alien must show he was prejudiced by the IJ’s delay in providing the required advisals or whether Petitioner had made such a showing. The court therefore granted the petition in part and remanded for the Board to consider Petitioner’s request for remand to the IJ for a new period of voluntary departure with the required advisal. View "Cesar Solis-Flores v. Merrick Garland" on Justia Law

Plaintiff’s son had a rare heart condition. He died at the age of twenty-seven, awaiting a heart transplant, which Rose says that Defendants—who administered her son’s employer-based health benefits program—wrongfully denied. So she sued on behalf of his estate, seeking monetary relief under both Section 502(a)(1)(B) and Section 502(a)(3). The district court dismissed both claims. As to Plaintiff’s (a)(1)(B) claim, the court held that money was not one of the “benefits” that her son was owed “under the terms of his plan.” And, as to her (a)(3) claim, the court held that her requested monetary relief was too similar to money damages and was thus not “equitable.”   The Fourth Circuit affirmed in part and vacated in part. The court explained that the district court correctly held that money was not one of the “benefits” that Plaintiff’s son was “due” “under the terms of his plan.” So it was right to dismiss her (a)(1)(B) claim. But the court explained that it must vacate its complete dismissal of Plaintiff’s (a)(3) claim. The court explained that while the district court correctly noted that compensatory, “make-whole” monetary relief is unavailable under Section 502(a)(3), it did not consider whether Plaintiff plausibly alleged facts that would support relief “typically” available in equity. The court thus remanded for the district court to decide in the first instance whether Plaintiff can properly allege such a theory based on a Defendant’s unjust enrichment, including whether an unjust gain can be followed to “specifically identified funds that remain in Defendant’s possession” or to “traceable items that the defendant purchased with the funds.” View "Jody Rose v. PSA Airlines, Inc." on Justia Law

Plaintiff, a chiropractic office, filed suit under the Telephone Consumer Protection Act after it received an unsolicited fax offering a free eBook with information about prescription drugs. The district court dismissed its complaint, holding that the plaintiff had not alleged that the fax, which tendered a product for free rather than for sale, was sufficiently commercial to bring it within the statutory prohibition on “unsolicited advertisements.” On appeal, Defendant-PDR Network defends both steps in the district court’s reasoning, arguing that a fax must be “commercial” to qualify as an “advertisement” under the TCPA and that Carlton & Harris has not alleged the requisite commercial character. Carlton & Harris disputes both portions of the court’s reasoning, contending that a prohibited “advertisement” may be entirely non-commercial and that, in any event, it has adequately alleged that the fax it received was commercial in nature. Further, Plaintiff asserts that PDR Network profits when its fax persuades a medical practitioner to accept the proffered eBook.   The Fourth Circuit vacated the district court’s order and remanded. The court concluded that Plaintiff had adequately alleged that the fax offer had the necessary commercial character to make it an “unsolicited advertisement” under the Act. The court explained that for present purposes, we accept as true Plaintiff’s commission allegation and find it adequate, at this preliminary stage, to state a claim that the fax offer of a free eBook is a commercial “advertisement” subject to the TCPA. View "Carlton & Harris Chiropractic, Inc. v. PDR Network, LLC" on Justia Law

Petitioner, a native and citizen of Honduras, petitions for review of an order of the Board of Immigration Appeals (Board) upholding the immigration judge’s (IJ’s) denial of his application for deferral of removal under the United Nations Convention Against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment (CAT) and ordering him removed to Honduras. As a former member of the MS-13 gang, Petitioner fears torture by gangs and police in Honduras. The IJ concluded that Ponce-Flores’s risk of torture was substantial, but he had not shown that a government official would more likely than not inflict or acquiesce in it.   The Fourth Circuit denied the petition. The court explained that Petitioner has failed to show that the IJ arbitrarily ignored relevant evidence or otherwise abused her discretion. The court explained that it requires agency adjudicators to demonstrate that they “reviewed all [the applicant’s] evidence, understood it, and had a cogent, articulable basis for [their] determination that [his] evidence was insufficient.” Here, the court concluded that the IJ surpassed that standard. View "Jesus Ponce-Flores v. Merrick Garland" on Justia Law

A federal grand jury indicted Defendant for possessing a firearm while being an unlawful user of a controlled substance. Defendant moved to suppress the firearm and other physical evidence, arguing that the officers lacked reasonable suspicion for the stop. After the district court denied his motion, Defendant entered a conditional guilty plea that preserved his right to appeal the suppression ruling.   The Fourth Circuit vacated Defendant’s conviction and remanded for further proceedings. The court held that the officers lacked reasonable suspicion of criminal activity when they first detained Defendant. The court explained that in considering the totality of the circumstances known to the officers when they stopped Defendant, it concludes the officers did not have objectively reasonable suspicion that Defendant was, or had been, engaged in theft. The court wrote that when the officers stopped Defendant, they knew he was a man with a weighed-down sweatshirt pocket who had walked through a residential neighborhood past an occasionally unoccupied home next to a commercial area in broad daylight and who had behaved evasively when a neighborhood resident watched and followed him. These circumstances, without more, do not give rise to reasonable suspicion of theft. As such, the court held that at bottom, the totality of the circumstances does not support a reasonable, articulable suspicion that Defendant had engaged, or was about to engage, in theft. View "US v. Daniel Critchfield" on Justia Law

Petitioner, a citizen of the Republic of Lithuania, challenged the district court’s denial of his request for a preliminary injunction (the “Injunction Denial”). Petitioner sought— in connection with his petition for habeas corpus relief under 28 U.S.C. Section 2241 — to prevent the defendant government officials from carrying out his extradition to Lithuania. The district court denied Petitioner’s request for injunctive relief, deeming him unlikely to succeed on the merits of his claim that his extradition to Lithuania would contravene the extradition treaty between that country and the United States. More specifically, Petitioner maintained that Lithuania’s 2015 extradition request fails to comply with the treaty’s mandate that Lithuania produce what is called “the charging document” (the “charging document contention”). The Injunction Denial ruled, however, that the documents produced by Lithuania comply with the extradition treaty, and that Petitioner is therefore not entitled to preliminary injunctive relief.   The Fourth Circuit reversed. The court explained that it is satisfied that Petitioner is likely to succeed on the merits of his claim that Lithuania’s 2015 extradition request does not satisfy the charging document mandate of the extradition treaty. The court wrote that Petitioner has demonstrated that Lithuania’s 2015 extradition request to return him to that country does not satisfy the Treaty’s requirements. And the public’s interest in the Secretary of State recognizing and fulfilling Treaty obligations outweighs any detrimental impact that the denial of an improper extradition request could have. View "Darius Vitkus v. Antony Blinken" on Justia Law

Plaintiff was brutally beaten by three Maryland corrections officers because they believed he had taken part in an assault on another officer. He sued their warden along with the officers who attacked him and their direct supervisors. A federal jury awarded Plaintiff $700,000. The warden appealed. He argued that this case should never have proceeded to trial because Plaintiff failed to exhaust his administrative remedies before suing. He also believes the district court should have found that the evidence failed to support the jury’s verdict and that he was entitled to qualified immunity.
The Fourth Circuit affirmed the district court. The court held that Plaintiff was not required to exhaust because no administrative remedies were available, the evidence supports the jury’s verdict, and the warden was not entitled to qualified immunity based on the facts found by the jury. The court explained that this case was properly tried before a jury because inmates cannot receive any relief through Maryland’s administrative grievance proceedings when the Intelligence and Investigative Division is investigating the subject matter of the grievance. And the jury’s role in trials is enshrined in the Seventh Amendment for good reason. Resolving factual disputes, weighing the evidence, and determining whom to believe is within its province. When a jury performs these functions, the court will not disturb its conclusions based on a cold record unless those conclusions lack evidentiary support. Here, the evidence was sufficient to support the jury’s conclusions. And based on how the jury resolved these issues, the warden’s conduct violated clearly established law. View "Kevin Younger v. Tyrone Crowder" on Justia Law

A South Carolina jury convicted Petitioner of voluntary manslaughter concerning the death of his girlfriend. Almost 20 years later—following three rounds of collateral litigation in state court and one 28 U.S.C. Section 2254 habeas petition in federal court—Petitioner sought permission to file a second Section 2254 petition. In that application, Petitioner claims he now remembers that his girlfriend died by suicide. According to Petitioner, his memory was repressed at the time of his trial and his regained memory satisfies the rigorous newly discovered evidence requirements of 28 U.S.C. Section 2244(b)(2)(B), allowing him to file a second habeas petition.     The Fourth Circuit denied the petition. The court explained that one of those requirements is that Petitioner demonstrate, by clear and convincing evidence, that no reasonable factfinder, considering his alleged regained memory with the rest of the evidence, would find Petitioner guilty of manslaughter. Because Petitioner failed to meet this burden, the court denied his application to file a successive Section 2254 habeas petition View "In re: Weldon Stewart, Jr." on Justia Law