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

Patrick Sutherland was convicted of three counts of filing false tax returns and one count of obstructing an official proceeding. He managed several insurance businesses and routed his international transactions through a Bermuda company, Stewart Technology Services (STS), which he claimed was owned and controlled by his sister. However, evidence showed that Sutherland managed all its day-to-day affairs. Between 2007 and 2011, STS sent Sutherland, his wife, or companies that he owned more than $2.1 million in wire transfers. Sutherland treated these transfers as loans or capital contributions, which are not taxable income, while STS treated them as expenses paid to Sutherland. Sutherland did not report the $2.1 million as income on his tax returns. In 2015, a federal grand jury indicted Sutherland for filing false returns and for obstructing the 2012 grand jury investigation. The jury found Sutherland guilty on all charges.Sutherland appealed his convictions, but the Court of Appeals affirmed them. He then filed a 28 U.S.C. § 2255 petition to vacate his obstruction conviction and a petition for a writ of error coram nobis to vacate his tax fraud convictions. The district court denied both petitions without holding an evidentiary hearing. Sutherland appealed this decision.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court found that Sutherland failed to show how the proffered testimony from his brother and a tax expert would have undermined his obstruction conviction. The court also found that Sutherland had not demonstrated ineffective assistance of counsel and thus could not show an error of the most fundamental character warranting coram nobis relief. View "United States v. Sutherland" on Justia Law

The case involves Daniel Lamont Mathis, who was convicted of multiple offenses, including Hobbs Act robbery, racketeering, and violent crimes in aid of racketeering activity, all in connection with the carjacking, kidnapping, and execution-style murder of a Virginia police officer. Initially, Mathis was sentenced to four concurrent life sentences and a consecutively imposed term of 132 years’ imprisonment. However, after an appeal and the passage of the First Step Act of 2018, which amended the sentencing structure for second or subsequent convictions under 18 U.S.C. § 924(c), the district court resentenced Mathis to four concurrent life sentences, plus 48 years’ imprisonment.The district court also set forth mandatory and discretionary conditions of supervised release. One of the discretionary conditions was that Mathis would be subject to warrantless search and seizure to ensure compliance with these conditions. However, the written judgment included additional language, stating that Mathis must warn any other occupants that the premises may be subject to searches pursuant to this condition.Mathis appealed, arguing that the additional language in the written judgment constituted error under United States v. Rogers and United States v. Singletary. The United States Court of Appeals for the Fourth Circuit agreed with Mathis, finding that the requirement to warn other occupants was inconsistent with the orally pronounced condition. The court held that this discrepancy constituted reversible error under Rogers and Singletary. As a result, the court vacated Mathis' sentence and remanded the case for a full resentencing. View "US v. Mathis" on Justia Law

The case involves Angel Cartagena, an inmate in the Virginia Department of Corrections (VDOC) prison system, who challenged the conditions of his 18-month confinement at the River North Correctional Center. Cartagena alleged that his confinement was too restrictive and caused him emotional distress and severe mental anguish, in violation of his First, Eighth, and Fourteenth Amendment rights, as well as statutory prohibitions against discrimination. VDOC officials had determined that Cartagena was seriously mentally ill and unable to function in the general prison population, so they assigned him to the VDOC’s Secure Diversionary Treatment Program (SDT Program) at the River North facility. Cartagena refused to comply with the treatment regimen prescribed for him and complained about the consequential restrictions of the Program.The district court granted the prison officials’ motion to dismiss Cartagena’s complaint, concluding that Cartagena had failed to state plausible claims for relief. The court found that Cartagena had not sufficiently alleged a deliberate indifference by prison officials to his condition, the deprivation of a constitutionally protected liberty interest, or discrimination because of his disability.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court found that Cartagena failed to demonstrate the required mens rea for an Eighth Amendment violation, as the prison officials had offered him treatment, which he refused. The court also found that Cartagena failed to adequately allege a cognizable liberty interest in his placement in the SDT Program, and therefore, the Due Process Clause requires no process related to his placement in the Program. Finally, the court concluded that Cartagena failed to plausibly allege that he was “otherwise qualified” for the benefits that he seeks and therefore to state a claim for discrimination under the Americans with Disabilities Act and the Rehabilitation Act. View "Cartagena v. Lovell" on Justia Law

The case involves Ronald Cox, who was convicted of first-degree murder and three firearm offenses based primarily on the testimony of a jailhouse informant. The informant claimed that Cox and his co-defendant confessed their involvement in the murder. Cox's trial counsel declined to introduce jail records that suggested Cox and the informant were not in the same area of the jail when the alleged conversation took place. Cox sought postconviction relief on the grounds of ineffective assistance of counsel, which was denied by the state postconviction court.The United States District Court for the District of Maryland also denied Cox's petition for habeas relief but issued a certificate of appealability on Cox's ineffective assistance claim. Cox appealed the district court's denial of his petition, and the State cross-appealed the district court's issuance of the certificate of appealability.The United States Court of Appeals for the Fourth Circuit affirmed the district court's denial of Cox's petition. The court found no reason to dismiss the certificate of appealability and, due to the highly deferential standard governing petitions alleging ineffective assistance of counsel, affirmed the district court's denial of Cox's petition. The court concluded that the state postconviction court's denial of Cox's ineffective assistance claim was not objectively unreasonable. View "Cox v. Weber" on Justia Law

The case involves 360 Virtual Drone Services LLC and its owner, Michael Jones, who sought to provide customers with aerial maps and 3D digital models containing measurable data. However, the North Carolina Board of Examiners for Engineers and Surveyors argued that doing so would constitute engaging in the practice of land surveying without a license, in violation of the North Carolina Engineering and Land Surveying Act. Jones and his company sued the Board, arguing that the restriction on their ability to offer these services without first obtaining a surveyor’s license violates their First Amendment rights.The district court granted summary judgment in favor of the Board. The court concluded that Jones had standing to challenge the statute based on his desire to create “two-dimensional and three-dimensional maps with geospatial data.” It also concluded that the Engineering and Land Surveying Act implicated the First Amendment. However, it found that the Act constituted “a generally applicable licensing regime that restricts the practice of surveying to those licensed” and primarily regulated conduct rather than speech, such that intermediate scrutiny applied. Finally, the court concluded that the Act survived intermediate scrutiny.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The appellate court concluded that the Act, as applied to the plaintiffs, was a regulation of professional conduct that only incidentally impacts speech. Therefore, it applied a more relaxed form of intermediate scrutiny that mandates only that the restriction be “sufficiently drawn” to protect a substantial state interest. The court found that the Act met this standard and therefore did not violate the plaintiffs' First Amendment rights. View "360 Virtual Drone Services LLC v. Ritter" on Justia Law

The case revolves around a dispute over a 15,000 square foot vacation home, the Chesapeake, located in Currituck County, North Carolina. The home is owned by Elizabeth LeTendre and has been the subject of litigation for over a decade regarding its compliance with county and state zoning requirements. The home's design includes a central area and two side wings, each structurally independent and less than 5,000 square feet. LeTendre's neighbors, Marie and Michael Long, contested that the Chesapeake violated a county zoning ordinance, which was upheld by the North Carolina Court of Appeals. The County then sued LeTendre to enforce the mandate and hold her in contempt if she refused to comply.LeTendre removed the case to federal court, seeking a declaratory judgment that the Chesapeake now complies with both county and state requirements. She argued that a recent amendment to North Carolina’s state zoning law abrogated the previous ruling. The district court agreed with LeTendre, holding that the County’s interpretation of a single-family detached dwelling, as applied to the Chesapeake, is “inconsistent with the State Building Code’s definition of a dwelling.”The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court held that the Building Code Council’s determination that the Chesapeake is “a building” controls. The court rejected the appellants' arguments that the district court's ruling violated principles of res judicata and the Rooker-Feldman doctrine, stating that the court was not reviewing whether the previous rulings correctly interpreted the Ordinance, but rather that the zoning amendment made the Council decision controlling. View "Currituck County v. LeTendre" on Justia Law

Valentino Darosa was convicted of Hobbs Act robbery and related offenses. The case revolved around a robbery at Atlantic Metals Xchange, a store that buys and sells metals, coins, jewels, and currency notes. The robber, wearing a mask and gloves, handcuffed and duct-taped the store owner, Matthew Schipani, and stole several items. The robber also took Schipani’s backpack, which contained his firearm and wallet. A notebook and roll of duct tape left at the scene were found to have Darosa's fingerprint and DNA respectively.Darosa was indicted on one count of Hobbs Act robbery, one count of brandishing a firearm during a crime of violence, and one count of being a felon in possession of a firearm. He moved to suppress the evidence seized during the search of his vehicle and home, arguing that the search warrant affidavit failed to establish probable cause. The district court denied the motion, finding that Darosa’s fingerprint on the notebook was sufficient to suspect him as the robber.At trial, the government presented evidence connecting Darosa to the crime, including his fingerprint on the notebook, his DNA on the roll of duct tape, and items found in Darosa’s home and vehicle that were stolen from the store. The jury returned a guilty verdict on all counts.On appeal to the United States Court of Appeals for the Fourth Circuit, Darosa challenged the district court’s denial of his motion to suppress, failure to give his proposed jury instruction, and admission of certain testimony. He also challenged the sufficiency of the evidence. The appellate court affirmed the district court's decision, finding no reversible error. View "US v. Darosa" on Justia Law

The case involves Terrance Henderson, an inmate in the Virginia Department of Corrections, who filed a lawsuit seeking to prevent prison officials from deducting money from his prison trust account as restitution for an assault he committed on a fellow inmate in 2015. He also sought to compel the return of money already taken. Henderson claimed that the nearly six-year gap between the guilt-finding phase of his disciplinary hearing and his reconvened restitution hearing violated principles of due process.The United States District Court for the Eastern District of Virginia granted summary judgment to the defendants on Henderson's 42 U.S.C. § 1983 claim and dismissed his Virginia state-law claim without prejudice. Henderson appealed this decision.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court agreed that Henderson had a protected property interest in his prison trust account. However, the court found that even if the nearly six-year delay between the guilt-finding phase and the restitution hearing violated due process, the error was harmless because no evidence that could have aided Henderson's ability to contest the amount of restitution was lost due to the delay. The court also affirmed the district court's decision to decline to exercise supplemental jurisdiction over the remaining state-law claim. View "Henderson v. Harmon" on Justia Law

The case revolves around Lokheim Jeralle Campbell, who was sentenced to 28 months in prison for violating his supervised release. Campbell had previously served a term for Hobbs Act robbery and using a firearm during a crime of violence. After his release, he attempted to rob Cyril Lowery during a drug deal, which led to a revocation motion filed by his probation officer. Campbell admitted to attempted armed robbery but objected to its classification as a crime of violence under the Sentencing Guidelines Chapter 7 policy statement.The district court overruled Campbell's objection and sentenced him to 28 months' imprisonment, to be served consecutively to the 120-month sentence he had already received for the new criminal charges. Campbell appealed his revocation sentence, arguing that the district court incorrectly determined that his attempted armed robbery violation qualified as a crime of violence.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court held that South Carolina attempted armed robbery qualifies as a crime of violence under the residual clause in the Sentencing Guidelines. The court reasoned that since the completed crime of armed robbery is categorically a crime of violence, attempts to commit such a crime similarly qualify. The court also noted that the Guidelines' commentary, which includes inchoate crimes in the definition of a crime of violence, is consistent with the language of the guideline. Therefore, the district court did not err in determining that Campbell's conduct constituted a Grade A violation of his supervised release. View "US v. Campbell" on Justia Law

A group of parents in Montgomery County, Maryland, challenged the local school board's decision to include LGBTQ-inclusive books in the English Language Arts curriculum without providing parents notice or the option to opt their children out of exposure to these books. The parents, who held various religious beliefs, argued that the board's decision violated their rights under the Free Exercise and Due Process Clauses of the U.S. Constitution.The United States District Court for the District of Maryland denied the parents' motion for a preliminary injunction, which would have required the board to provide notice and an opt-out option. The parents appealed this decision to the United States Court of Appeals for the Fourth Circuit.The Fourth Circuit affirmed the district court's decision. The court found that the parents had not shown a likelihood of success on the merits of their claims, a necessary requirement for a preliminary injunction. Specifically, the court found that the parents had not provided sufficient evidence to show that the board's decision coerced them or their children to act or believe contrary to their religious faith. The court also found that the parents had not shown that their due process rights were likely to be violated. The court noted that the parents still had the right to instruct their children on their religious beliefs and to discuss the topics raised in the books with their children. View "Mahmoud v. McKnight" on Justia Law