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

Tim Landholt was arrested in South Carolina after failing to pay child support, pursuant to a bench warrant issued by a family court judge. After Landholt appeared in court, paid a fine, and resolved the matter, the warrant was supposed to be recalled, but the clerk’s office failed to do so. Over five years later, Landholt was arrested again on the same, now-stale warrant and spent three days in jail. He then brought a negligence claim under South Carolina law against Jeanette McBride, in her official capacity as the Richland County Clerk of Court, alleging that the failure to recall the warrant caused his wrongful arrest and detention.Landholt initially filed suit in state court, asserting both federal and state-law claims. After procedural delays and amendments, the case was removed to the United States District Court for the District of South Carolina. The parties filed cross-motions for summary judgment. A magistrate judge recommended granting summary judgment to McBride on the negligence claim, finding her immune under the South Carolina Tort Claims Act, specifically S.C. Code § 15-78-60(2), which provides immunity for administrative actions or inactions of a judicial or quasi-judicial nature. The district court adopted this recommendation, holding that the immunity applied even to non-discretionary (ministerial) acts, and granted summary judgment to McBride.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s summary judgment ruling de novo. The Fourth Circuit held that, under South Carolina precedent, immunity under S.C. Code § 15-78-60(2) applies only to discretionary, not ministerial, acts. Because the record did not establish that the failure to recall the warrant was a discretionary act, the Fourth Circuit vacated the district court’s grant of summary judgment to McBride on this ground and remanded the case for further proceedings. View "Landholt v. Corley" on Justia Law

Three individuals who are lawful gun owners challenged a Fairfax County, Virginia ordinance that prohibits the possession, carrying, or transportation of firearms in certain locations. The two main restrictions at issue are a ban on firearms in county parks and a ban in public spaces where, or near where, a county-permitted event is taking place. The plaintiffs argued that both restrictions violate the Second Amendment, and that the events restriction is unconstitutionally vague under the Fourteenth Amendment.The United States District Court for the Eastern District of Virginia reviewed the case. It denied the plaintiffs’ motion for a preliminary injunction and later granted summary judgment to Fairfax County and its Chief of Police. The district court found that both restrictions were consistent with the Second Amendment’s sensitive places doctrine and that the events restriction was not unconstitutionally vague.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s summary judgment ruling de novo. The Fourth Circuit affirmed the district court’s decision regarding the parks restriction, holding that the ordinance is constitutional in at least some applications, specifically as applied to preschools located within county parks. The court relied on Supreme Court dicta indicating that bans on firearms in schools are presumptively constitutional. However, the Fourth Circuit vacated the district court’s judgment regarding the events restriction, concluding that the plaintiffs lacked Article III standing to challenge it because they did not demonstrate a credible threat of prosecution or a concrete intention to violate the restriction. The case was remanded with instructions to dismiss the claims related to the events restriction without prejudice. View "Lafave v. County of Fairfax" on Justia Law

A professor was hired by a university in 2014 as a tenure-track Assistant Professor with a starting salary at the lowest end of the pay scale for her department. Over the next several years, she was denied promotions, demoted to at-will status, and claims she was paid less than male colleagues. She alleges that these actions were motivated by sex discrimination and retaliation for her complaints, including derogatory statements allegedly made by a department chair about her gender and sexual orientation. She filed charges with the Equal Employment Opportunity Commission (EEOC) and, after leaving the university, brought suit alleging violations of federal and state anti-discrimination laws.The United States District Court for the District of Maryland granted summary judgment to the university and individual defendants on all claims. The court found that her Title VII claims regarding the 2019 and 2020 promotion denials were procedurally barred—one as untimely and the other for failure to exhaust administrative remedies. The court also found that the evidence did not support her claims of sex discrimination, wage discrimination, or retaliation, concluding that the university’s stated reasons for its actions were legitimate and not pretextual.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. It affirmed the district court’s ruling that the Title VII claims related to the 2019 and 2020 promotion denials were procedurally barred. However, it reversed the grant of summary judgment on the remaining claims, holding that genuine disputes of material fact existed regarding sex discrimination in the 2016 promotion denial, retaliation, and wage discrimination. The court also held that the procedural bars of Title VII did not apply to the plaintiff’s claims under Title IX, Section 1983, or Maryland state law for the 2019 and 2020 promotion denials. The case was remanded for further proceedings on those claims. View "Hollis v. Morgan State University" on Justia Law

The defendant was indicted for aiding and abetting possession with intent to distribute 40 grams or more of a mixture containing fentanyl. He entered into a written plea agreement with the government, in which he agreed to plead guilty. In exchange, the government stipulated to certain sentencing factors, including the drug weight used to calculate the base offense level and that the defendant was a manager or supervisor of criminal activity involving five or more participants. The agreement reserved the government’s right to present evidence, make a sentencing recommendation, and clarified that it was not promising to seek a downward departure.The United States District Court for the Eastern District of North Carolina accepted the guilty plea. At sentencing, the government moved for both an upward and a downward departure or variance from the Guidelines range, citing the defendant’s criminal history and role in the offense. The district court applied both departures and sentenced the defendant to 234 months’ imprisonment. The defendant did not object at sentencing but later appealed, arguing that the government breached the plea agreement by failing to request a below-Guidelines sentence and by making arguments inconsistent with the stipulations regarding drug weight and his role.The United States Court of Appeals for the Fourth Circuit reviewed the case for plain error, as the defendant had not raised these arguments below. The court held that the plea agreement did not require the government to seek a below-Guidelines sentence or prohibit it from moving for both upward and downward departures. The court also found that, while some of the government’s arguments at sentencing created tension with the stipulations, the agreement’s language did not clearly prohibit such arguments. Therefore, the court concluded there was no plain error and affirmed the district court’s judgment. View "US v. Wilson" on Justia Law

The plaintiff, after her vehicle was declared a total loss in a collision, received a payment from her insurer based on the “actual cash value” of her car, as determined by a third-party valuation system. This system used comparable vehicle listings and, when actual sales prices were unavailable, applied a “Projected Sold Adjustment” to estimate market value. The plaintiff accepted the insurer’s offer, paid her deductible, and did not contest the valuation or invoke the policy’s appraisal process. Despite this, she filed suit alleging breach of contract, claiming the insurer’s use of the adjustment resulted in underpayment, and sought to represent a class of similarly situated South Carolina policyholders.The United States District Court for the District of South Carolina certified a class of individuals who received total loss payments calculated using the Projected Sold Adjustment. The court found that the plaintiff’s claims were typical of the class and that common questions predominated, thus meeting the requirements for class certification under Federal Rule of Civil Procedure 23.On interlocutory appeal, the United States Court of Appeals for the Fourth Circuit reversed the class certification order. The Fourth Circuit held that the plaintiff lacked standing because she did not suffer a concrete injury—she accepted the insurer’s payment, was not out-of-pocket beyond her deductible, and never demonstrated that her vehicle’s value exceeded the amount paid. The court further held that, even if standing existed, class certification was improper because determining whether the insurer breached its obligation to pay actual cash value would require individualized inquiries into each class member’s vehicle and circumstances. Thus, the requirements of commonality and predominance under Rule 23 were not met. The district court’s order certifying the class was therefore reversed. View "Freeman v. Progressive Direct Insurance Company" on Justia Law

Amir Golestan, founder and CEO of Micfo, LLC, orchestrated a scheme to fraudulently obtain approximately 1.3 million valuable IPv4 Internet Protocol addresses from the American Registry for Internet Numbers (ARIN) by creating fictitious companies and individuals. He then resold some of these addresses for profit. The scheme was uncovered when ARIN blocked a large attempted sale. Golestan and Micfo were indicted by a federal grand jury on 20 counts of wire fraud.The United States District Court for the District of South Carolina denied Golestan and Micfo’s motion to dismiss the indictment, finding that IP addresses constituted “property” under the wire fraud statute. During a bench trial, after the government presented substantial evidence, Golestan and Micfo changed their pleas to guilty. The district court accepted the pleas without advising Golestan of possible immigration consequences. Sentencing was delayed for 17 months, during which Golestan moved to continue sentencing pending the Supreme Court’s decision in United States v. Ciminelli, and later sought to withdraw the guilty pleas, arguing that Ciminelli invalidated the prosecution’s theory and that he was not properly advised of immigration consequences. Micfo also argued Golestan lacked authority to plead on its behalf. The district court denied these motions and sentenced Golestan to 60 months’ incarceration and Micfo to probation.The United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgments. The court held that the government’s theory of wire fraud did not rely on the “right-to-control” doctrine rejected in Ciminelli, but rather on deprivation of traditional property interests. The court found the district court’s failure to advise Golestan of immigration consequences was harmless error, as he was a naturalized citizen. The court also held that the record supported Golestan’s authority to plead for Micfo and declined to address ineffective assistance of counsel on direct appeal. View "US v. Golestan" on Justia Law

Several individuals and an LLC, who own oil and gas interests in West Virginia, leased their mineral rights to EQT, a group of related energy companies. The leases, numbering nearly 3,843, required EQT to pay royalties to the lessors. During the period from January 1, 2012, to February 28, 2021, EQT extracted “wet gas” from the wells, which contains valuable natural gas liquids (NGLs) like propane and butane. EQT sold the wet gas at the wellhead to its own affiliates and paid royalties to the lessors based on the energy content (BTU) of the wet gas, not on the value of the NGLs. EQT then separated and sold the NGLs to third parties but did not pay additional royalties for these sales. In 2021, EQT notified lessors it would begin calculating royalties based on the separate value of NGLs and residue gas.The plaintiffs filed a putative class action in the United States District Court for the Northern District of West Virginia, alleging breach of contract and fraudulent concealment, and sought class certification. The district court granted partial summary judgment, finding EQT’s affiliates were its alter egos, and certified classes for both claims, later dividing the class into three subclasses based on lease language. EQT petitioned for interlocutory appeal of the class certification order.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s certification order. The Fourth Circuit affirmed the certification of the breach of contract claim, holding that the class was ascertainable and that common questions of law and fact predominated, given EQT’s uniform royalty payment method and the immateriality of lease language variations under West Virginia law. However, the Fourth Circuit reversed the certification of the fraudulent concealment claim, holding that individual questions of reliance would predominate, making class treatment inappropriate for that claim. Thus, the district court’s order was affirmed in part and reversed in part. View "Glover v. EQT Corporation" on Justia Law

A man who was previously convicted of a felony in Virginia sought to have his voting rights restored after his release from prison. Under Virginia’s Constitution, individuals convicted of felonies lose the right to vote, but the Governor has the sole discretion to restore those rights. The restoration process requires applicants to submit a form, after which the Office of the Secretary of the Commonwealth reviews the application and makes a recommendation to the Governor, who then decides whether to grant restoration. The applicant in this case, who had never voted due to his conviction as a minor, submitted at least one application for restoration, but the Governor declined to restore his rights.The United States District Court for the Eastern District of Virginia reviewed the applicant’s claims, which were brought under 42 U.S.C. § 1983. The applicant argued that the Governor’s unfettered discretion in restoring voting rights, and the lack of a definite time limit for the process, violated the First Amendment’s unfettered-discretion doctrine. The district court granted summary judgment in favor of the Governor and Secretary, finding that the doctrine did not apply because the restoration process determines eligibility to reenter the franchise, rather than regulating the exercise of an existing right.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The Fourth Circuit held that Virginia’s discretionary system for restoring voting rights, which is rooted in the executive clemency power, does not facially violate the First Amendment’s unfettered-discretion doctrine. The court reasoned that the clemency power is fundamentally different from a licensing scheme subject to First Amendment prior restraint analysis, and that judicial review of such executive discretion is limited to narrow circumstances not present here. The judgment of the district court was affirmed. View "Hawkins v. Youngkin" on Justia Law

A woman was convicted of first-degree murder in Maryland state court after being tried jointly with her husband. The prosecution’s case was largely circumstantial, focusing on motive and opportunity, and initially argued that she was the shooter. After her conviction, she moved for a new trial, alleging ineffective assistance of counsel. In support of her motion, she disclosed attorney-client privileged materials and testified about her defense strategy and communications with counsel. The trial court granted her a new trial but ordered her to turn over privileged materials to the State and allowed the same prosecution team, now privy to her defense strategy, to retry her case. The court also left open the possibility that her prior testimony could be used to impeach her if she testified at the new trial.On appeal, the Maryland Court of Special Appeals assumed, without deciding, that the trial court erred by allowing the same prosecution team to retry the case and by permitting the State to use information obtained from privileged materials. However, the appellate court found no prejudice, reasoning that the new evidence (including the existence of a second wig) did not harm her defense and that her decision not to testify was not prejudicial absent a proffer of her intended testimony. The Maryland Court of Appeals denied certiorari, and the United States Supreme Court also declined review.The United States Court of Appeals for the Fourth Circuit reviewed the case on habeas corpus. The Fourth Circuit held that the Maryland Court of Special Appeals’ finding of no prejudice was based on an objectively unreasonable determination of the facts, given the record showing the State’s use of privileged evidence and the impact on the defendant’s ability to testify. However, because the state appellate court had not actually decided whether a constitutional violation occurred, the Fourth Circuit vacated the district court’s denial of habeas relief and remanded for the district court to determine that question de novo. View "Kaur v. Warden" on Justia Law

The plaintiff, representing herself and a proposed class, alleged that she was exposed to ethylene oxide (EtO), a carcinogenic gas, due to emissions from a plant in South Charleston, West Virginia, operated by the defendants from 1978 to 2019. She claimed that this exposure increased her risk of developing serious diseases, necessitating ongoing medical monitoring and diagnostic testing, for which she sought compensation under West Virginia common law.The United States District Court for the Southern District of West Virginia recognized that West Virginia law allows for medical monitoring claims but held that the plaintiff lacked Article III standing because she did not have a manifest physical injury. The district court also excluded the plaintiff’s expert, Dr. Sahu, finding his testimony unreliable, and granted summary judgment to the defendants. The court reasoned that the plaintiff’s alleged injury—an increased risk of future illness—was not concrete or ripe, relying on the Supreme Court’s decision in TransUnion LLC v. Ramirez.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. It held that, under West Virginia law, the injury in a medical monitoring claim is the tortious exposure to a hazardous substance and the present need for medical testing, not the manifestation of disease. The court found that this injury is concrete and actual, satisfying Article III standing requirements. The Fourth Circuit also determined that the district court abused its discretion in excluding Dr. Sahu’s expert testimony, as its criticisms went to the weight, not the admissibility, of his opinions. The Fourth Circuit reversed the district court’s grant of summary judgment and exclusion of the expert, and remanded the case for further proceedings. View "Sommerville v. Union Carbide Corp." on Justia Law