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

After counsel for defendant filed a motion in limine seeking to exclude evidence as a sanction for the government's alleged discovery violation, the district court denied the motion at a hearing that defendant did not attend and in which he did not otherwise participate. Defendant argued on appeal that he should have been present. Because the plain text of Federal Rule of Criminal Procedure 43 did not require a defendant to be present at a hearing on such a motion, the court affirmed defendant's conviction and sentence. View "United States v. Gonzales-Flores" on Justia Law

This dispute related to Employee Retirement Security Act (ERISA), 29 U.S.C. 1001 et seq., contributions made pursuant to a collective bargaining agreement. The district court ordered return of certain allegedly mistaken employer contributions even though the plan administrator determined that the contributions were not made by mistake. Because the court found that the administrator's decision was not an abuse of discretion, the court reversed and remanded for further proceedings. View "U.S. Foodservice, Inc. v. Truck Drivers & Helpers Union" on Justia Law

Plaintiffs appealed from the district court's dismissal of their complaint for declaratory and injunctive relief. Plaintiffs initiated this proceeding against defendants, challenging the use of advanced imaging technology (AIT) scanners and invasive pat-downs at airport screening checkpoints in the United States. On appeal, plaintiffs maintained that the district court erred in dismissing the complaint for lack of subject matter jurisdiction because the TSA's standard operating procedures for checkpoint screenings did not constitute an "order" under 49 U.S.C. 46110. Alternatively, plaintiffs argued, that section 46110's conferral of exclusive jurisdiction in a court of appeals deprived them of due process and contravened the separation of powers rooted in the Constitution. The court held that it had jurisdiction under 28 U.S.C. 1291; on the merits, the district court did not err in ruling that the Checkpoint Screen SOP constituted an order of the TSA Administrator under section 46110; and plaintiffs' remaining contentions lacked merit. Accordingly, the court affirmed the judgment. View "Blitz v. Napolitano" on Justia Law

Defendant filed a motion to suppress evidence of cocaine and subsequently pled guilty to drug charges. Defendant was driving a rental car with a passenger in Virginia when police pulled him over for speeding. Based on the passenger's apparent nervousness and the presence of four cellular phones in the center console, and on defendant's and the passenger's conflicting explanations of their travels, the officer called a drug-detection dog. The dog arrived 13 minutes after the initiation of the traffic stop and a resulting search revealed 830.6 grams of cocaine. The court held that the officer had reasonable suspicion and the delay and search of the vehicle were reasonable. Accordingly, the court affirmed the judgment. View "United States v. Vaughan" on Justia Law

Defendant was convicted of wire fraud, conspiracy to commit wire fraud, conspiracy to commit money laundering, and conspiracy to commit smuggling for his role as the mastermind of a multi-million dollar scheme to defraud the Department of Defense (DOD). The crux of defendant's scheme involved the knowing supply of defective and nonconforming spare parts for use in U.S. military aircraft, vehicles, and weapons systems. Defendant appealed his convictions and sentence on a variety of grounds. The court found his arguments without merit and affirmed the judgment of the district court. View "United States v. Day, Jr." on Justia Law

This case arose when plaintiff filed a putative class action in state court against Santander alleging violations of various Maryland consumer protection laws for undisclosed finance charges and other unfair business practices. Santander subsequently appealed from the district court's order denying its motion to compel arbitration and stay court proceedings of plaintiff's claims against it. While finding that an enforceable arbitration agreement encompassing plaintiff's claims existed, the district court nevertheless concluded that Santander had waived its rights to enforce arbitration by its delay. The court concluded that the record did not support the district court's finding of waiver. Therefore, the court reversed and remanded with directions to defer the claims to arbitration. View "Rota-McLarty v. Santander Consumer USA, Inc." on Justia Law

The MTA applied to the Board to abandon freight transportation use of a right-of-way and to convert it to a recreational trail, as authorized by the National Trails System Act, 16 U.S.C. 1247. The Board rejected the MTA's application, concluding that instead of assuming full responsibility for legal liability or indemnifying the MTA for any potential liability, the proposed sponsors conditioned their undertakings by subjecting them to sovereign immunity and to future state legislative appropriations. The Board explained that instead of assuming full responsibility, the proposed sponsors offered the possibility of no responsibility. The MTA subsequently filed a petition for review. The court found that the MTA's arguments were unpersuasive, especially in light of its burden to demonstrate that the Board acted arbitrarily and capriciously. Accordingly, the court affirmed the decision of the Board and denied the petition for review. View "Maryland Transit v. Surface Transportation Board" on Justia Law

Martin and Lucky Strike appealed the district court's grant of summary judgment in an action to enjoin enforcement of two South Carolina anti-gaming statutes, S.C. Code Ann. 12-21-2710 and 12-21-2712, which prohibited certain devices pertaining to games of chance. Because the statutes have a legitimate application, the court affirmed the district court's vagueness holding. The court further concluded that the statutes did not fall within the scope of Ex Parte Young's holding. Accordingly, the court affirmed the judgment. View "Martin v. Lloyd" on Justia Law

Petitioner, a native and citizen of the Republic of Angola, sought review of an order by the BIA denying his petition to obtain relief from removal under the Immigration and Nationality Act (INA), 8 U.S.C. 1182. The BIA denied petitioner asylum and withholding of removal under the INA because he was a member of, and provided material support to, a terrorist organization. The court held that the BIA did not err in deeming petitioner statutorily ineligible for asylum and withholding of removal under the INA's Material Support Bar. Therefore, the court denied the petition for review. View "de Almeida Viegas v. Holder, Jr." on Justia Law

Defendant was convicted of four charges which were based on intentional misrepresentations he made concerning his service in the United States Marine Corps. After reviewing the parties' arguments on appeal, the court held that there was substantial evidence to support both defendant's false statement conviction and theft conviction. The court further held that the statutes underlying defendant's insignia convictions were constitutional, both on their face and as applied to defendant. Accordingly, the court affirmed the convictions on all counts. View "United States v. Hamilton" on Justia Law