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

In a trademark infringement dispute between Georgia-Pacific and von Drehle involving paper towels and "touchless" paper towel dispensers, the court vacated the district court's award of summary judgment in von Drehle's favor, and remanded the case for a jury determination of whether von Drehle was liable for contributory trademark infringement. Over three months later, von Drehle sought for the first time to amend its answer to include affirmative defenses of claim preclusion and issue preclusion. The court subsequently held that the district court erred in vacating the jury verdict and in awarding judgment in von Drehle's favor because: (1) von Drehle waived the preclusion defenses by failing to assert them in a timely manner; and (2) the district court erred in alternatively considering the preclusion defense sua sponte. Accordingly, the court vacated the district court's award of judgment in von Drehle's favor, and remanded the case to the district court with instructions to reinstate the jury's verdict in favor of Georgia-Pacific. View "Georgia Pacific Consumer Products, LP v. von Drehle Corp." on Justia Law

Petitioner was convicted of two offenses: the misdemeanor offense of contributing to the delinquency of a minor, in contravention of Virginia Code section 18.2-371; and the felony offense of violating the Commonwealth's criminal solicitation statute, found in section 18.2-29. The predicate felony for petitioner's criminal solicitation offense was Virginia Code section 18.2-361(A) ("the anti-sodomy provision"). The court subsequently granted a certificate of appealability on the issue of whether the anti-sodomy provision was unconstitutional either facially or as applied in petitioner's case, in light of the Supreme Court's decision in Lawrence v. Texas. The court held that the anti-sodomy provision did facially violate the Due Process Clause and therefore, reversed the judgment of the district court and remanded for an award of habeas corpus relief. View "MacDonald v. Moose" on Justia Law

Defendants, individual investors, sought to arbitrate claims against plaintiff that arose when the investors purchased allegedly fraudulent securities directly from Inofin. Defendants contended that they were plaintiff's customers because they purchased Inofin securities on the advice of an attorney who, though lacking any formal affiliation with plaintiff, was a business and personal acquaintance of a registered representative of plaintiff. The court held that defendants were not "customers" of plaintiff within the meaning of the Financial Industry Regulatory Authority (FINRA) arbitration provisions. To compel arbitration here would be to expand the scope of the arbitration agreement beyond what the text permitted and the parties intended. Therefore, the court affirmed the judgment of the district court. View "Raymond James Financial Services v. Cary" on Justia Law

Defendant appealed the district court's holding that his Tennessee statutory rape conviction qualified as a generic "statutory rape" offense and thus constituted a "crime of violence" under the sentencing enhancement established in U.S.S.G. 2L1.2(b)(1)(A)(ii). Because Tennessee's statutory rape provision set the age of consent at eighteen and was therefore significantly broader than the generic offense, the court held that a conviction thereunder did not categorically qualify for the crime-of-violence enhancement. Accordingly, the court reversed and remanded. View "United States v. Rangel-Castaneda" on Justia Law

Plaintiffs brought this action in Maryland state court seeking a declaration as to Allstate's duty under a renters insurance policy to defend and indemnify plaintiffs in a tort suit brought against them, and others. On appeal, defendant challenged the district court's grant of summary judgment to Allstate, concluding that Allstate did not have a duty to defend. The court held that Maryland law applied to the issue of whether Allstate had a duty to defend plaintiffs if Maryland law would apply without the choice-of-law provision in the policy; according to Maryland's lex loci contractus rule for choice-of-law decisions, California law governed the analysis of whether Allstate had a duty to defend plaintiffs in the underlying action; and the court rejected plaintiffs' argument that Allstate nonetheless owed them a duty to defend under the policy. Accordingly, the court affirmed the judgment. View "Francis v. Allstate Ins. Co." on Justia Law

Plaintiff brought this action under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., against AT&T after her claim to recoup her lost benefits was denied. The district court found that AT&T unreasonably denied plaintiff's claim and failed to adequately notify her of a material change to its pension plan that allowed her to collect full benefits earlier than she had originally understood. The court held that the district court properly considered limited evidence outside of the administrative record but known to AT&T when it rendered plaintiff's benefits determination; correctly determined that AT&T breached its statutory and fiduciary duties to plaintiff; and did not err in awarding plaintiff her lost benefits. Accordingly, the court affirmed the judgment. View "Helton v. AT&T Inc." on Justia Law

Plaintiffs, thirteenth North Carolina residents who lost access to in-home personal care services (PCS) due to a statutory change, brought suit challenging the new PCS program. The district court granted plaintiffs' motions for a preliminary injunction and class certification. Defendants appealed, raising several points of error. The court agreed with the district court's conclusion that a preliminary injunction was appropriate in this case. The court held, however, that the district court's order failed to comply with Federal Rule of Civil Procedure 65 because it lacked specificity and because the district court neglected to address the issue of security. Accordingly, the court remanded the case. View "Pashby v. Delia" on Justia Law

Defendant was convicted of intent to distribute crack cocaine and distribution of powder cocaine. Following Amendment 750 to the Sentencing Guidelines, which lowered sentences for certain crack cocaine offenses, the district court granted defendant's motion to reduce his sentence. The court held that the district court did not clearly err in holding that it had not originally made a finding that rendered defendant ineligible for the reduction, or otherwise abused its discretion. Therefore, the court affirmed the district court's judgment. View "United States v. Mann" on Justia Law

Plaintiff brought this declaratory judgment action, asserting that the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., preempted a state court order requiring him to turn over benefits received under ERISA retirement and life insurance plans owned by his deceased ex-wife. At issue was whether ERISA prohibited a state court from ordering plaintiff, who had previously waived his right to those benefits, to relinquish them to the administrators of the ex-wife's estate. The court held that ERISA did not preempt post-distribution suits against ERISA beneficiaries because the court detected no conflict with either ERISA's objectives or relevant Supreme Court precedent. Accordingly, the court affirmed the judgment. View "Andochick v. Byrd" on Justia Law

Defendant was convicted of carjacking, using a firearm in furtherance of carjacking, and conspiracy. Defendant appealed the district court's denial of his motion for a new trial, arguing that the discovery of the actual dates of the Short Hair Picture - a photo of a second suspect with short hair - and the Dreadlocks Picture - a photo of the second suspect with dreadlocks - constituted newly discovered evidence and, alternatively, that the government's failure to disclose this fact violated Brady v. Maryland. The court concluded that defendant was entitled to a new trial because the court found that the district court erred in rejecting defendant's newly-discovered-evidence argument. View "United States v. Moore" on Justia Law