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

A police officer in Columbia, South Carolina, shot and killed a high school senior, J.R., during the COVID-19 curfew. The officer was responding to a report of teenagers looking into cars and saw J.R. walking alone. When the officer approached, J.R. ran away. The officer chased J.R. and, during the pursuit, observed that J.R. was armed. Despite repeatedly commanding J.R. to stop, get on the ground, and show his hands, J.R. did not comply. At one point, J.R. crouched near a fence, picked up his gun, and then ran again. The officer fired multiple shots, ultimately striking J.R. in the forehead and killing him.J.R.’s mother, acting as his personal representative, sued the officer under 42 U.S.C. § 1983, asserting that the use of deadly force violated J.R.’s Fourth Amendment rights. The United States District Court for the District of South Carolina denied the officer’s motion for summary judgment based on qualified immunity, finding that although J.R. was armed, ignored commands, and turned to face the officer, there was no undisputed evidence that J.R. made a threatening movement with his weapon. The court concluded that genuine disputes of material fact remained and that it was clearly established law that deadly force could not be used under these circumstances.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The Fourth Circuit held that, at the time of the shooting, clearly established law prohibited a police officer from using deadly force against a fleeing, armed suspect who did not make a furtive or threatening movement with his weapon. The court concluded that the officer was not entitled to qualified immunity and allowed the case to proceed. View "Ruffin v. Davis" on Justia Law

A debtor filed for Chapter 13 bankruptcy in North Carolina while earning significant income and owning three luxury vehicles acquired in the years leading up to his petition. He had accumulated over $84,000 in unsecured debt, much of it from personal loans taken around the same time as his vehicle purchases. In his proposed bankruptcy plan, he aimed to retain all three vehicles by having the trustee pay off the secured car loans, while paying unsecured creditors less than 8% of what they were owed and discharging the remainder after five years.The United States Bankruptcy Court for the Eastern District of North Carolina rejected his plan. The court found that, despite technical compliance with the disposable income requirements of 11 U.S.C. § 1325(b), the plan failed the good-faith requirement of § 1325(a)(3). The court determined the plan was structured to allow the debtor to keep luxury items at the expense of unsecured creditors and that he was not making an honest effort to repay those creditors. The United States District Court for the Eastern District of North Carolina affirmed this decision, agreeing that the bankruptcy court properly considered good faith as a separate and independent requirement for plan confirmation.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The Fourth Circuit held that compliance with § 1325(b)'s means test does not shield a Chapter 13 plan from review under the good-faith standard of § 1325(a)(3). The court emphasized that technical compliance with the means test does not preclude a finding of bad faith if the plan abuses the purposes or spirit of Chapter 13. The court found no clear error in the bankruptcy court’s factual findings and affirmed the denial of plan confirmation. View "Goddard v. Burnett" on Justia Law

Late at night in downtown Raleigh, police were investigating a stolen vehicle when Milton Allen repeatedly interfered with the officers’ work, ignoring their commands and disrupting the scene while riding his bicycle. Allen’s actions, which included impeding traffic and resisting multiple direct orders to leave, led officers to attempt an arrest. During the arrest, Allen resisted and struggled with officers, who eventually subdued him using handcuffs and ankle restraints. While Allen was restrained but still squirming, officers searched two cross-body bags he had been wearing and found firearms, illegal drugs, cash, and related items. Based on these discoveries, Allen was charged with firearm and drug offenses.The United States District Court for the Eastern District of North Carolina reviewed Allen’s motion to suppress the evidence found in the bags. The district court found that the search of the bags was not a lawful search incident to arrest because Allen was already secured and could not access the bags, relying on United States v. Davis and Arizona v. Gant. The court also rejected the government’s argument that the evidence would inevitably have been discovered under established inventory search policies, concluding that the government had not sufficiently demonstrated that the policies were particular enough to limit officer discretion or that the bags would have inevitably been searched.On appeal, the United States Court of Appeals for the Fourth Circuit addressed whether the evidence should have been suppressed. The Fourth Circuit held that the search of Allen’s bags would inevitably have occurred pursuant to standardized inventory search policies of both the Raleigh Police Department and Wake County Detention Center, which required the search of all arrestees’ personal property and limited officer discretion. The Fourth Circuit concluded that the evidence would have been lawfully discovered and thus should not have been suppressed, reversing the district court’s order. View "United States v. Allen" on Justia Law

In December 2021, an individual with a lower leg amputation and a history of medical episodes broke into a car dealership in Chesterfield County, Virginia. After the alarm was triggered, police—including an officer and his police K-9—responded to the scene. The individual hid in a storage room, unarmed and passively waiting to be arrested. When the officer and his leashed K-9 located him lying in a submissive, fetal-like position, the officer allegedly gave no orders or warnings before directing the dog to attack. The K-9 inflicted severe injuries, including to sensitive areas of the individual’s body, resulting in significant blood loss and destruction of his prosthetic leg. Following the incident, the individual was charged with trespassing and vandalism, but no violent offenses.The individual filed suit in the United States District Court for the Eastern District of Virginia, asserting a Fourth Amendment excessive force claim under 42 U.S.C. § 1983, as well as related state law claims. The officer moved to dismiss, arguing that the use of force was objectively reasonable and that qualified immunity applied because the right in question was not clearly established. The district court ruled that the complaint plausibly alleged a Fourth Amendment violation but concluded that the specific right was not clearly established, granting the officer qualified immunity and dismissing the federal claim. The court declined to exercise supplemental jurisdiction over the state law claims.The United States Court of Appeals for the Fourth Circuit reviewed the case and held that, as of 2013, it was clearly established that a non-threatening, unarmed, and passively-resisting suspect had a right to be free from unnecessary, gratuitous, and disproportionate force by deployment of a police K-9. The court vacated the district court’s judgment and remanded for further proceedings. View "Harrold v. Hagen" on Justia Law

Three equestrian trainers, each subjected to sanctions by the United States Center for SafeSport (SafeSport) for past misconduct, sought to challenge those sanctions. Navarro and Giorgio were permanently banned after SafeSport learned of their prior guilty pleas to child sexual abuse, while Shaffer received a suspension and probation following SafeSport’s investigation of complaints against her. Navarro and Giorgio pursued arbitration and internal grievance procedures that ultimately confirmed SafeSport’s sanctions. Shaffer declined to arbitrate, citing the cost. All three alleged that SafeSport’s procedures violated their constitutional rights because they were barred from Olympic sports without a prior hearing, and further argued that SafeSport, a private body, unconstitutionally exercises governmental authority.After their grievances and appeals were rejected by the United States Equestrian Federation (USEF) and the United States Olympic & Paralympic Committee (USOC), the trainers filed suit in the United States District Court for the Western District of Virginia. The district court dismissed their claims, holding that the trainers lacked standing to sue the USOC, that Shaffer failed to exhaust administrative remedies, that Appellees were not state actors and thus not subject to the Fifth Amendment, and that SafeSport’s powers did not violate the private non-delegation doctrine.The United States Court of Appeals for the Fourth Circuit reviewed the case. It affirmed the district court’s rulings that the trainers lacked standing to sue the USOC, that the Appellees were not state actors subject to the Due Process Clause, and that the court lacked jurisdiction over the private non-delegation claim. However, it reversed the district court’s finding on administrative exhaustion, holding that Shaffer was not obligated to arbitrate her constitutional claims before seeking relief in federal court. Thus, the judgment was affirmed in part and reversed in part. View "Navarro v. United States Center for SafeSport" on Justia Law

A miner who worked in West Virginia coal mines for nearly four decades applied for benefits under the Black Lung Benefits Act after retiring in 2015. From mid-2012 through December 2014, he worked for Rhino Energy, LLC as a subcontractor in mines owned by Wildcat Energy, LLC. When Rhino’s subcontract ended, he joined Wildcat’s payroll and continued working at Wildcat until his retirement in October 2015. The dispute centers on which employer—Rhino or Wildcat—should be responsible for paying his black lung benefits.After the miner filed his claim, the district director of the Office of Workers’ Compensation Programs designated Rhino as the responsible operator, finding that Wildcat had not employed the miner for the full year required by regulations and thus was not a potentially liable operator. The district director did not address Wildcat’s financial capacity, nor did he issue a Coverage Statement regarding Wildcat’s insurance status. Rhino contested its designation, arguing Wildcat should be responsible, including as a successor operator, but the district director and subsequently the Administrative Law Judge (ALJ) reaffirmed Rhino’s liability, focusing on the duration of Wildcat’s employment. The Benefits Review Board upheld the ALJ’s decision, agreeing that Wildcat had not employed the miner for a year and noting Rhino had not demonstrated Wildcat’s financial capability.The United States Court of Appeals for the Fourth Circuit reviewed the Board’s order. It held that under the correct interpretation of the regulations, Wildcat had employed the miner for the requisite year based on working days, and because the district director did not issue a Coverage Statement, Wildcat was presumed financially capable of paying benefits. The court determined Wildcat should have been designated as the responsible operator, but because regulations prohibit imposing liability on another operator at this stage, it vacated the Board’s order and remanded with instructions for the Black Lung Disability Trust Fund to pay the miner’s benefits. View "Rhino Energy, LLC v. DOWCP" on Justia Law

A federal prisoner was sentenced in December 2020 and, due to pending charges in another jurisdiction, was held at a detention center in Rhode Island rather than being promptly transferred to his designated Bureau of Prisons (BOP) facility in South Carolina. During this period of post-sentencing detention, the prisoner claims to have participated in programs under the First Step Act (FSA), thereby accruing approximately 150 days of time credits, which could reduce his time in custody. However, the BOP did not recognize these credits because he had not undergone a formal risk and needs assessment—the BOP’s prerequisite for awarding such credits—until his eventual arrival at the designated facility in March 2022.After exhausting administrative remedies, the prisoner filed a pro se habeas petition in the United States District Court for the District of South Carolina, seeking recognition of his alleged FSA credits. The magistrate judge, without briefing or discovery, recommended dismissal. The district court adopted this recommendation, concluding that the BOP’s regulation reasonably required an initial assessment before credits could be earned, and applied Chevron deference to uphold the agency's interpretation. The district court also found no evidence the prisoner had “successfully participated” in qualifying programs before arrival at the BOP facility and dismissed the petition without prejudice, refusing to require a government response.On appeal, the United States Court of Appeals for the Fourth Circuit vacated the district court’s judgment and remanded. The Fourth Circuit held that the case was not moot, as the prisoner could still benefit from the FSA credits if his risk status changed or a warden approved his release. The court further held that, in light of the Supreme Court’s decision in Loper Bright Enterprises v. Raimondo, which overturned Chevron deference, the district court must independently determine whether the BOP’s interpretation of “successful participation” aligns with the best reading of the statute. View "Benson v. Warden FCI Edgefield" on Justia Law

Patrick Nichols, while being arrested by two police officers in Bethesda, Maryland on outstanding warrants for theft, forgery, and burglary, alleges that he was subjected to excessive force. According to Nichols, one officer slammed him to the ground, breaking his left forearm in two places, while the other placed a knee on his throat, causing him to fear for his life and temporarily lose the ability to breathe. Nichols claims he did nothing to threaten the officers and that their use of force was unprovoked. Following his arrest, he required medical treatment for his injuries and continues to experience pain and stress.Nichols, proceeding pro se and incarcerated, initially filed a complaint naming only Officer Bumgarner in the caption, though he described the involvement of a second officer, Schmidt, in the body of his complaint. The United States District Court for the District of Maryland dismissed Nichols’s complaint without prejudice, finding it lacked sufficient factual detail. Nichols then filed an amended complaint, again naming only Bumgarner in the caption but specifically describing Schmidt’s actions in the body. The district court dismissed the amended complaint as well, again for lack of specificity and treated the action as brought solely against Bumgarner, never acknowledging Schmidt as a defendant.The United States Court of Appeals for the Fourth Circuit reviewed the case. It found that the district court erred in treating the complaint as only against Bumgarner rather than both officers, given the content of the complaints and the pro se status of Nichols. The Fourth Circuit also held that Nichols’s amended complaint stated a plausible excessive force claim under the Fourth Amendment, given the serious injuries alleged and the facts construed in Nichols’s favor. The appellate court vacated the district court’s dismissal and remanded the case for further proceedings. View "Nichols v. Bumgarner" on Justia Law

An Afghan infant was orphaned and injured during a joint U.S.-Afghan military operation and received emergency care at a U.S. military hospital. A U.S. Marine Corps Judge Advocate, Major Joshua Mast, and his wife, Stephanie Mast, initiated custody proceedings and ultimately obtained a Virginia adoption order for the child. Separately, the U.S. Embassy gave custody to a man claiming to be the child's uncle, and the infant was subsequently cared for by John and Jane Doe, who later evacuated from Afghanistan to the United States with the child during Operation Allies Refuge. After arriving in the U.S., the Masts took custody of the child. The Does then challenged the adoption in Virginia state court, but the Supreme Court of Virginia rejected their challenge.Following the state proceedings, the Does filed a federal lawsuit in the U.S. District Court for the Western District of Virginia, seeking, among other things, a protective order to prevent the defendants from disclosing their identities. The district court granted the protective order, concluding that disclosing the Does’ identities would pose a substantial risk to their safety and that of their family in Afghanistan. The order prohibited the defendants and their representatives from revealing any information that could directly or indirectly identify the Does or their family members unless a non-disclosure agreement was executed. After the Does engaged with the media while maintaining anonymity, the Masts moved to vacate or modify the protective order, arguing it was an unconstitutional restraint on speech. The district court denied the motion and held Joshua Mast in contempt for violating the order.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s order. The Fourth Circuit held that the protective order, while a content-based prior restraint, fit within a narrow exception because it was narrowly tailored to serve the government’s compelling interest in national security—specifically, the protection of individuals perceived as U.S. collaborators. The court found the order survived strict scrutiny and was not unconstitutionally vague. View "Doe v. Mast" on Justia Law

A federal inmate brought an action for damages against several officials at a federal prison, claiming they provided delayed or inadequate medical treatment and used excessive force against him during his incarceration. His allegations included delayed dental care, insufficient response to rectal bleeding, denial of participation in a mental health class, and the use of restraints and physical force during an incident involving his cellmate. He asserted that these actions violated his constitutional rights under the Eighth, Fourth, and Fifth Amendments.The United States District Court for the Western District of Virginia dismissed his complaint, holding that a damages remedy under Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics was not available for his claims. The court reasoned that his claims, both for inadequate medical care and excessive force, presented new contexts beyond those recognized in previous Supreme Court cases and that special factors counseled against extending a judicially implied damages remedy. The inmate appealed from the district court’s judgment.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the inmate’s inadequate medical treatment claims presented a new context distinct from Carlson v. Green, as the facts involved less severe circumstances and implicated broader, systemic prison management issues rather than deliberate malfeasance. The court further found that special factors, including Congress’s silence and provision of alternative remedies, counseled against extending Bivens. Regarding the excessive force claims, the Fourth Circuit found that the Supreme Court’s intervening decision in Goldey v. Fields expressly foreclosed recognizing a Bivens remedy in this context. Thus, the Fourth Circuit affirmed the district court’s dismissal, holding that a Bivens remedy was unavailable for the plaintiff’s claims. View "Spivey v. Breckon" on Justia Law