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

A jury found Defendant guilty of six drug-related offenses, and the district court sentenced him to 40 years in prison. The district court increased Defendant's offense level by two because it found he was “an organizer, leader, manager, or supervisor” within the meaning of Guidelines Section 3B1.1(c). Second, the court increased Defendant’s offense level by four because it concluded Defendant misrepresented fentanyl as heroin. Defendant raised two challenges to the verdict. Defendant also raised two challenges to his sentence.   The Fourth Circuit rejected Defendant’s sufficiency of the evidence challenge and his claim that the district court committed reversible error in instructing the jury. The court vacated Defendant’s sentence and remanded for resentencing. The court held that the government was not required to prove that the victim died from a fentanyl overdose—it was required to show that she died from using a “substance” containing fentanyl for whose distribution Defendant was legally responsible. The government introduced sufficient evidence for the jury to conclude it had met that burden. The jury heard evidence Defendant supplied the drugs the victim consumed on the day of her death and that she died around three hours later from a drug overdose. Here, a jury could conclude a substance distributed by Defendant was the cause of the victim’s death. However, the court concluded that the district court erred in applying a provision that was not part of the Sentencing Guidelines when Defendant committed his offenses and that Defendant is entitled to relief even under the plain-error standard. View "US v. Rodney Coby" on Justia Law

This appeal stems from the district court’s dismissal of Petitioner’s petition for habeas corpus relief. An incarcerated person at Federal Correctional Institution Williamsburg, Petitioner alleged that the Bureau of Prisons had miscalculated his release date by not retroactively applying the First Step Act to his previous sentence and crediting the resulting good conduct time to his release date. After the Warden moved for summary judgment, a magistrate judge issued a report and recommendation (“R&R”) concluding that Petitioner’s petition should be dismissed. Petitioner objected to the recommendation in detail; nonetheless, the district court did not review the R&R de novo because Petitioner had only “reargue[d] his case.” After reviewing for clear errors, the district court adopted the R&R and dismissed Petitioner’s petition. On appeal, Petitioner first submits—and the Warden concedes—that the district court erred by failing to review the R&R de novo. Petitioner further requests that the Fourth Circuit proceed to the merits of his habeas petition and consider the retroactive applicability of the First Step Act. Finally, Petititioner asked this Court to recall its previous mandate dismissing his 2015 appeal of his revocation sentence.   The Fourth Circuit agreed with Petitioner that his grounds for objection were clear and thus should have prompted a de novo review of the magistrate’s R&R. Because the district court only reviewed the R&R for clear error, the court vacated and remanded with directions to review Petitioner’s grounds for objection de novo. The court declined, however, to consider the merits of Petitioner’s petition or recall of the court’s previous mandate. View "Larone Elijah v. Richard Dunbar" on Justia Law

This case involves an appeal by the Charlotte-Mecklenburg County Board of Education (“CMS”) and cross-appeal by Plaintiff, individually and on behalf of his child, A.B. Plaintiff filed an administrative action in North Carolina, alleging that CMS violated the Individuals with Disabilities Act (“IDEA”), by failing to provide A.B. with a free appropriate public education (“FAPE”) through an individualized education plan (“IEP”). The administrative law judge (“ALJ”) dismissed Plaintiff’s action as time-barred by a one-year statute of limitations. CMS filed an original civil action in district court, seeking a judicial determination that the statute of limitations barred Plaintiff’s administrative action. Plaintiff and A.B. filed a counterclaim, asking the district court to decide the merits of the underlying IDEA claim. The district court agreed with the SHRO and held that the statute of limitations did not bar Plaintiff’s IDEA claim, but it held that Plaintiff needed to exhaust his administrative remedies before bringing the merits to federal court. Both parties appealed.   The Fourth Circuit affirmed the district court’s holding as to CMS’s appeal and held that the statute of limitations does not bar Plaintiff’s IDEA claim. But, because Plaintiff’s counterclaim is compulsory, the court concluded that he need not exhaust. Therefore, the court reversed on that issue and remanded to the district court for further proceedings. The court explained that the Plaintiff was prevented from filing a timely administrative petition because CMS withheld information it was required to provide him. Therefore, his IDEA petition was not barred by the statute of limitations. View "Charlotte-Mecklenburg County Board of Education v. Aleah Brady" on Justia Law

In passing the Water Infrastructure Improvements for the Nation Act (“WIIN Act”), Congress directed the U.S. Army Corps of Engineers to design a fish-passage structure for the New Savannah Bluff Lock and Dam. The Corps settled on a design that would lower the pool of water by about three feet. The State of South Carolina and several of its agencies responded by suing the Corps and various federal officials. Their complaint alleged that the Corps’ design violated the WIIN Act, the National Environmental Policy Act, the Administrative Procedure Act, state law, a previous settlement agreement, and certain easements. The district court held that the Corps’ plan didn’t “maintain the pool” since it would lower it from its height on the date of the Act’s enactment. Corps argued that this reading ignores the clause “for water supply and recreational activities” and that a lowered pool that still fulfills these functions would comply with the Act.   The Fourth Circuit vacated the district court’s judgment for Plaintiffs on their WIIN Act claim and the resulting permanent injunction against the Corps. The court left it to the district court to decide whether the Corps’ chosen design can maintain the pool’s then-extant water-supply and recreational purposes. The court explained that it agreed with the Corps that pinning the required pool height to the “arbitrary and unknowable-to-Congress date that the President signed the legislation” leads to “absurd results.” Plaintiffs suggest that the statute only obligates the Corps to maintain the pool at its “normal operating range.” But neither the statute nor the district court’s order makes clear this permissible “range.” View "State of South Carolina v. United States Army Corps of Engineers" on Justia Law

Virginia police responded to a 911 call seeking help to locate Plaintiff, who they were told was potentially armed and suicidal. After failing to find Plaintiff in his house, two officers and a K-9 searched the surrounding woods. The dog quickly caught Plaintiff’s scent, leading officers to find him lying in a shallow ditch. Bodycam footage shows the subsequent heated encounter, with officers demanding Plaintiff turn around and Plaintiff angrily ordering them to leave. After a two-minute impasse, an officer twice released the dog, who bit Plaintiff and caused a severe injury. The officers ultimately discovered Plaintiff didn’t have a gun. Plaintiff sued under state law and 42 U.S.C. Section 1983, alleging, among other things, violations of his Fourth Amendment rights. The district court denied the K-9 officer’s summary-judgment motion asserting qualified immunity, holding that the undisputed facts didn’t establish whether the officer had a reasonable belief that Plaintiff was armed.   The Fourth Circuit reversed the district court’s denial of qualified immunity to the K-9 officer on the excessive-force count and remanded with instructions that the court enters judgment for him on that count. The court explained that while the bodycam video alone may not illuminate whether the officer had a reasonable belief that Plaintiff was armed, the full record clarifies that this assumption was reasonable. Given that, the officer’s use of his dog to seize Plaintiff didn’t violate the Fourth Amendment. View "Dillard Putman v. Quentin Harris" on Justia Law

Plaintiff sued the federal government under the FTCA, alleging one count of battery. A magistrate judge recommended dismissing Plaintiff’s suit for lack of subject matter jurisdiction in a detailed memorandum devoted solely to whether the FTCA waives sovereign immunity for the type of claim Plaintiff brought. The district court adopted the magistrate judge’s recommendation. The district court concluded it need not review the recommendation de novo because Plaintiff failed to object with sufficient specificity and, in any event, “the Magistrate Judge’s proposed conclusions of law are correct and are consistent with current case law.   The Fourth Circuit reversed the district court’s judgment and remanded for further proceedings. The court held that the district court erred in concluding Plaintiff did not adequately preserve her claim for review. The court explained that a party wishing to avail itself of its right to de novo review must be “sufficiently specific to focus the district court’s attention on the factual and legal issues that are truly in dispute.” The court concluded that Plaintiff cleared that bar.   Further, the court concluded that the district court erred in dismissing Plaintiff’s complaint for lack of subject matter jurisdiction. The court held that the FTCA permits people who allege they were assaulted by TSA screeners to sue the federal government. View "Erin Osmon v. US" on Justia Law

Plaintiff signed a one-year contract to teach criminal justice courses at Spartanburg Methodist College (SMC). Less than a year later, SMC decided not to renew Plaintiff’s contract and terminated her shortly thereafter. Plaintiff brought a mix of state and federal law claims against SMC, essentially arguing that her contract nonrenewal and termination were unlawful. The district court granted summary judgment in favor of SMC on all federal claims and declined to exercise supplemental jurisdiction over the state law claims. Plaintiff appealed. Under the Americans with Disabilities Act (ADA), Plaintiff accused SMC of discrimination, retaliation, and engaging in an unlawful health inquiry. Under Title IX of the Education Amendments Act of 1972 (Title IX), she accused SMC of retaliation.   The Fourth Circuit affirmed. The court explained that in analyzing the case, it becomes clear that Plaintiff’s retaliation claims cannot succeed. SMC offers nonretaliatory reasons for not renewing Plaintiff’s contract and terminating her employment, and she is unable to demonstrate that SMC’s reasons are pretextual. Further, the court explained that Plaintiff’s claim of pretext is undermined by the fact that the primary decision-makers at SMC were not aware of Plaintiff’s ADA or Title IX-protected activity. Second, any notion of pretext is further dispelled by the fact that SMC’s explanations have been consistent throughout. Moreover, the court explained that Plaintiff cannot show that SMC refused to make an accommodation because she cannot show that she ever properly requested one. Her failure-to-accommodate claim fails for this reason. View "Summer Lashley v. Spartanburg Methodist College" on Justia Law

The appeal is another installment in a series of disputes involving an enforcement action by the Federal Trade Commission (FTC) against a group of fraudulent real estate developers (the Sanctuary Belize enforcement action). Appellants, a group of 14 individual investors and a family-owned corporation moved to intervene in an action brought by others and sought relief from the district court’s judgment. Appellants did not do so until after the district court had entered final judgment and that judgment had been appealed to the Fourth Circuit. Because the Sanctuary Belize enforcement action was already on appeal when Appellants filed their motions, the district court concluded that it lacked jurisdiction to entertain those motions. It held alternatively that the motions should be denied as meritless.   The Fourth Circuit affirmed. The court held that a district court lacks jurisdiction over a motion to intervene while an appeal is pending, regardless of who noted the appeal. Further, the court explained that because the district court correctly determined it lacked jurisdiction on a matter that had been appealed to the Fourth Circuit, the court held that it only has jurisdiction to review that decision, not to entertain the underlying merits. View "Federal Trade Commission v. Yu Lin" on Justia Law

Law firm Halscott Megaro, P.A. (“Halscott Megaro” or “the firm”) sued former clients and their guardians (collectively “former clients”), seeking to recover unpaid legal fees and expenses. A district court dismissed the action under Federal Rule of Civil Procedure 12(b)(6). The district court took judicial notice of a North Carolina State Bar Disciplinary Hearing Commission (“Commission”) decision that found the firm’s lead partner misled the former clients and engaged in other unethical conduct. The court then held the firm was precluded from relitigating issues decided by the Commission. It held that Halscott Megaro failed to plausibly plead claims for which relief could be granted. Halscott Megaro appealed, arguing the district court improperly considered matters outside the pleadings and failed to accept its allegations and all reasonable inferences from them as true in concluding that the Commission’s decision as to its lead partner bound the law firm.   The Fourth Circuit affirmed and held that the district court committed no reversible error in granting the former clients’ motion to dismiss or in denying the law firm’s motion for recusal. The court wrote that it agreed with the district court’s conclusion that the Commission was acting in a judicial capacity when it entered its discipline order against Megaro. The court also agreed that Megaro received a full and fair opportunity to litigate the issues and due process protections. Further, the court held that the firm’s allegations of impartiality were not related to any particular facts, sources or statements. A presiding judge is not required to recuse himself simply because of unsupported or highly tenuous speculation. View "Halscott Megaro, P.A. v. Henry McCollum" on Justia Law

Plaintiff brought a wrongful-termination action against her former employer—the North Carolina Department of Justice—and two former supervisors in their official and individual capacities. The district court dismissed some claims as barred by sovereign immunity and dismissed the entirety of the complaint as time-barred.   The Fourth Circuit affirmed the uncontested dismissal of the North Carolina Department of Justice and the uncontested dismissal of the official-capacity claims against the individual Defendants for money damages. But because the statute of limitations for the remaining claims is four years and not three years as the district court found, the court explained it must otherwise vacate the district court’s grant of Defendants’ motion to dismiss the individual Defendants from the action.   The court explained that here, Plaintiff brought a Section 1983 action for wrongful termination in violation of Section 1981. A wrongful termination claim is based on post-contract-formation conduct. The court reasoned that as Defendants correctly recognized at oral argument, it would not have been possible for Plaintiff to bring this action prior to December 1, 1990, because, before that date, Section 1981 was limited to discrimination in contract formation and enforcement. In 1991, Congress expanded Section 1981 to include discrimination post-contract formation. Therefore, the 1991 amendment to Section 1981 “made possible” this Section 1983 action, and the four-year catchall statute of limitations provided by Section 1658 applies. View "Margaret Chambers v. North Carolina Department of Justice" on Justia Law