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

Law enforcement officers executed a search warrant at Lee Marvin Harris, Sr.'s home, discovering a significant amount of cocaine in an old Cadillac parked in the yard. Harris, Sr. was arrested for possession with intent to distribute and spent five months in pretrial detention before charges were dismissed. He then sued the Town of Southern Pines and the officers involved, alleging malicious prosecution under the Fourth Amendment and fabrication of evidence under the Fourteenth Amendment, claiming officers omitted material evidence from prosecutors and grand juries.The United States District Court for the Middle District of North Carolina granted summary judgment in favor of the defendants. The court found that probable cause existed for Harris, Sr.'s arrest based on the discovery of cocaine on his property and dismissed the fabrication of evidence claim, reasoning that such claims are not viable if the plaintiff was not convicted. Harris, Sr. appealed the decision.The United States Court of Appeals for the Fourth Circuit reviewed the case and found genuine disputes of material fact regarding whether Harris, Sr. was arrested and charged without probable cause. The court held that the officers were not entitled to qualified immunity for the Fourth Amendment malicious prosecution claim. Additionally, the court determined that a plaintiff who was arrested and detained but not convicted could still state a Fourteenth Amendment fabrication of evidence claim. Consequently, the court reversed the district court's summary judgment on the Fourth Amendment malicious prosecution claim, vacated the summary judgment on the Fourteenth Amendment fabrication of evidence claim, and remanded for further proceedings. The court affirmed the district court's summary judgment on the state law malicious prosecution claim, the failure to intervene claim, and the Monell claim against the Town of Southern Pines and the Chief of Police. View "Harris v. Town of Southern Pines" on Justia Law

The plaintiffs, property owners in West Virginia, filed a lawsuit against the current and former owners of abandoned oil and gas wells on their properties. They sought damages for the defendants' failure to plug the wells, alleging common law nuisance, trespass, and negligence. The defendants argued that the West Virginia Department of Environmental Protection (WVDEP) was responsible for well plugging and that WVDEP had approved transactions between the defendants, which purportedly relaxed their statutory duty to plug the wells. They claimed WVDEP was an indispensable party under Federal Rule of Civil Procedure 19 and, because it could not be joined due to sovereign immunity, sought judgment in their favor under Rule 12(c).The United States District Court for the Northern District of West Virginia denied the defendants' motion, ruling that WVDEP was not a necessary and indispensable party under Rule 19. The court concluded that it could grant the plaintiffs damages on their common law claims without implicating the State’s interests. The defendants then filed an interlocutory appeal, arguing that the district court's order was reviewable under the collateral order doctrine, as it effectively denied WVDEP sovereign immunity.The United States Court of Appeals for the Fourth Circuit reviewed the case and determined that the district court's order did not rule on any immunity issue but only on whether WVDEP was a necessary and indispensable party under Rule 19. The appellate court found that the order did not satisfy the requirements of the collateral order doctrine and was not a final decision. Consequently, the court granted the plaintiffs' motion to dismiss the appeal for lack of jurisdiction. View "McEvoy v. Diversified Energy Company PLC" on Justia Law

A power company based in Florida sued a North Carolina-based power company, alleging that the latter had monopoly power in the wholesale power market in the Carolinas and maintained that power through anticompetitive conduct, violating § 2 of the Sherman Act. The plaintiff presented evidence that the defendant devised a plan to exclude the plaintiff from competing for the business of Fayetteville, North Carolina, the only major customer whose contract was expiring soon enough for the plaintiff to compete.The United States District Court for the Western District of North Carolina granted the defendant's motion for summary judgment. The court found that while there was a question of fact regarding the defendant's monopoly power, the plaintiff failed to show that the defendant engaged in anticompetitive conduct. The court concluded that the defendant's actions constituted legitimate competition to retain Fayetteville’s business.The United States Court of Appeals for the Fourth Circuit reviewed the case and found that the district court erred by compartmentalizing the defendant's conduct rather than considering it as a whole. The appellate court noted that the plaintiff presented sufficient evidence to show that the defendant's conduct, including a blend-and-extend strategy and interference with the plaintiff's interconnection efforts, could be seen as part of a coordinated anticompetitive campaign. The court held that genuine disputes of material fact existed regarding whether the defendant's actions were anticompetitive.The Fourth Circuit vacated the district court's summary judgment and remanded the case for further proceedings. The appellate court also ordered that the case be assigned to a different judge, citing the principle that once a judge recuses himself, he should remain recused from the case. View "Duke Energy Carolinas, LLC v. NTE Carolinas II, LLC" on Justia Law

In early 2022, FBI and IRS agents investigated John Doe and his businesses for suspected wire fraud, money laundering, and tax fraud. They obtained three search warrants to search Doe’s apartment, office, and vehicle. The warrants included a filter protocol to protect potentially privileged materials. During the searches, agents seized various paper materials and electronic devices. The government later contacted Doe to assist in segregating potentially privileged material, but Doe’s counsel did not respond. Negotiations between Doe and the government failed, leading Doe to file a motion to establish a filter protocol to protect his legal privileges.The magistrate judge granted Doe’s motion to intervene but denied his substantive motion for a new filter protocol, finding that Doe did not meet the requirements for a preliminary injunction. The district court reviewed the magistrate judge’s decision and also denied Doe’s motion, agreeing that Doe was not entitled to an injunction. Doe then appealed to the United States Court of Appeals for the Fourth Circuit.The Fourth Circuit dismissed Doe’s appeal, holding that it lacked appellate jurisdiction. The court explained that under 28 U.S.C. § 1291, it generally only has jurisdiction over final decisions of district courts. The court applied the DiBella test, which states that orders resolving pre-indictment suppression motions are not immediately appealable unless the motion is solely for the return of property and not tied to a criminal prosecution in esse. The court found that Doe’s motion was not solely for the return of property and was tied to an ongoing grand jury investigation. Therefore, the court concluded that it lacked jurisdiction under both § 1291 and § 1292(a)(1) and dismissed the appeal. View "United State of America v. Doe" on Justia Law

Ahmad Hashimi was indicted on four counts in the Eastern District of Virginia, including drug-related charges and charges involving violence against his ex-girlfriend. Hashimi and his court-appointed lawyer, Bruce Johnson, had a contentious relationship, with Hashimi repeatedly complaining about poor communication and the lack of a plea deal. Despite these issues, the district court did not replace Johnson. During the trial, Johnson attempted to negotiate a plea deal for the violence charges, but the court rejected it, and the case proceeded to the jury. In his closing argument, Johnson conceded Hashimi's guilt on the violence charges without Hashimi's explicit consent, focusing his defense on the drug charges. The jury found Hashimi guilty on all counts, and he was sentenced to 300 months in prison.Hashimi appealed his conviction, arguing that Johnson's concession of guilt without his consent violated his Sixth Amendment rights. The Fourth Circuit initially affirmed the conviction but reconsidered after the Supreme Court's decision in McCoy v. Louisiana, which established a defendant's right to maintain innocence. On remand, the Fourth Circuit again affirmed but allowed Hashimi to raise his claim in a 28 U.S.C. § 2255 motion. Hashimi filed the motion, presenting evidence that he did not consent to the concession and highlighting his poor communication with Johnson.The United States District Court for the Eastern District of Virginia denied Hashimi's § 2255 motion without an evidentiary hearing, reasoning that Hashimi did not explicitly object to the concession. The Fourth Circuit Court of Appeals reviewed the case and found that the district court erred in denying the motion without a hearing. The appellate court held that the record did not conclusively show that Hashimi was informed of and consented to the concession, as required by McCoy. Therefore, the Fourth Circuit vacated the district court's decision and remanded the case for further factual development. View "US v. Hashimi" on Justia Law

Kenneth Watkins, an Atlanta-based rap musician, was convicted of conspiracy to possess a controlled substance with intent to distribute. Investigators, suspecting drug activities linked to a Charlotte-based record label operated by Steven “Ziggy” Cloud, obtained a wiretap on Cloud’s phone. Evidence showed that Watkins was involved in drug transactions with Cloud, including three trips where couriers transported pills from Atlanta to Charlotte. The couriers, Jonquilla Sanders and Latisha Anderson, testified about their trips, with intercepted calls and other evidence linking Watkins to the drug deliveries.The United States District Court for the Western District of North Carolina tried the case. Watkins was convicted by a jury and sentenced to ten years in prison, three years of supervised release, and a $100 fine. Watkins appealed, challenging the sufficiency of the evidence, the admission of his song lyrics as evidence, the jury instructions, the calculation of drug quantity, and the denial of a downward departure in sentencing.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that the evidence was sufficient to support Watkins’s conviction, as a rational jury could infer his knowledge and participation in the conspiracy. The court also held that the district court did not err in allowing the prosecution to question Watkins’s wife about his song lyrics, as Watkins had introduced character evidence. The court affirmed the district court’s jury instructions, finding no abuse of discretion. The court upheld the drug quantity calculation and the use of the 1-to-380-gram conversion ratio for eutylone. Finally, the court ruled that the district court’s discretionary denial of a downward departure was not reviewable. The Fourth Circuit affirmed the district court’s decision. View "US v. Watkins" on Justia Law

In August 2019, Eric Toon led Lieutenant Christopher Zerkle on a high-speed chase before returning to his home, where his girlfriend, Taylor Quinn, was sleeping. Zerkle and other officers, including Sergeants Paxton Lively and Rick Keglor, and Deputies Brandon Kay and Jamie Miller, arrived at Toon’s residence. The officers knocked on the door, which eventually opened outward, leading them to enter the home. Toon then broke a window, jumped out with an AR-15, and was fatally shot by Zerkle and another officer. Quinn, who followed Toon out of the window, was also injured.The United States District Court for the Southern District of West Virginia dismissed some claims and granted summary judgment in favor of the officers on the remaining claims. The court found that the officers reasonably believed they had consent to enter the home when the door opened and that Zerkle’s use of deadly force against Toon was justified. The court also concluded that Quinn’s injuries were accidental and not the result of intentional excessive force.The United States Court of Appeals for the Fourth Circuit reviewed the case and found that factual disputes precluded summary judgment on the warrantless entry claims and Quinn’s excessive force, battery, and trespass claims. The court held that the officers could not assume consent to enter the home merely because the door opened. The court also determined that there was sufficient evidence for a jury to find that Zerkle intentionally shot Quinn. The court affirmed the district court’s decision on the remaining claims, including the excessive force claim related to Toon and the failure to intervene claim against Zerkle. The case was reversed in part, affirmed in part, and remanded for further proceedings. View "Quinn v. Zerkle" on Justia Law

Donna Ard applied for disability benefits, claiming she was disabled due to various health issues, including anemia, chronic pain, depression, PTSD, and OCD. She was 49 years old at the time of her application, six months and seventeen days shy of her 50th birthday. Ard's application was denied by the Social Security Administration, and she subsequently requested a hearing before an administrative law judge (ALJ). The ALJ also denied her application, finding that she was not disabled under the Social Security Act.Ard appealed the ALJ's decision to the Social Security Appeals Council, which denied her request for review. She then filed a complaint in the United States District Court for the District of South Carolina. The magistrate judge affirmed the ALJ's decision, holding that the ALJ was not required to consider whether Ard should be treated as a person closely approaching advanced age under the borderline age rule, as she was more than six months away from her 50th birthday.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the magistrate judge's decision. The court held that the borderline age rule, which allows for consideration of a higher age category if an applicant is within a few days to a few months of reaching that category, did not apply to Ard because she was more than six months away from turning 50. The court found that the ALJ had correctly applied the legal standards and that the factual findings were supported by substantial evidence. Therefore, the court concluded that the ALJ was not required to consider treating Ard as a person closely approaching advanced age. The decision of the district court was affirmed. View "Ard v. O'Malley" on Justia Law

Michael Shipton, a middle-aged man with Type 2 diabetes, worked as an underground gas mechanic for Baltimore Gas & Electric (BGE). Due to his diabetes, he periodically missed work and was granted intermittent Family Medical Leave Act (FMLA) leave in August 2017 and January 2018 for hypoglycemia. In April 2018, Shipton took two days off for severe foot pain caused by neuropathy, but BGE informed him that his FMLA certification only covered hypoglycemia. After submitting a new medical certification for neuropathy, BGE approved his request. However, in June 2018, BGE terminated Shipton, citing conflicting medical documentation.Shipton filed a complaint in the United States District Court for the District of Maryland in June 2020, alleging FMLA interference and retaliation against BGE, Exelon Corporation, Exelon Business Services Company (EBSC), and several individual defendants. The defendants argued that Shipton was terminated based on an honest belief that he misused FMLA leave and that his claims were time-barred. The district court granted summary judgment in favor of the defendants, finding no evidence of willful FMLA violations to extend the statute of limitations and concluding that BGE had a legitimate reason for termination.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo and affirmed the district court's decision. The court held that Shipton failed to demonstrate a genuine dispute of material fact regarding his FMLA interference and retaliation claims. The court found that BGE had a legitimate, nondiscriminatory reason for termination based on conflicting medical documentation and that Shipton did not provide sufficient evidence to show pretext. Additionally, the court upheld the summary judgment in favor of Exelon, EBSC, and the individual defendants, concluding they were not Shipton’s "employer" under the FMLA. View "Shipton v. Baltimore Gas and Electric Company" on Justia Law

Nasanto Antonio Crenshaw, a 17-year-old, was shot and killed by Officer Matthew Sletten of the Greensboro, North Carolina police department while driving an allegedly stolen car. Crenshaw's mother, Wakita Doriety, filed a lawsuit against Officer Sletten for excessive force under 42 U.S.C. § 1983 and various state law claims. The City of Greensboro was also named as a defendant for the state law claims. The City moved to dismiss the claims, asserting governmental immunity, and the district court agreed, dismissing all claims against the City. Officer Sletten also moved to dismiss the claims against him, arguing that the video evidence contradicted the plaintiff's allegations.The United States District Court for the Middle District of North Carolina dismissed the claims against the City based on governmental immunity, ruling under Rule 12(b)(2). The court also dismissed the claims against Officer Sletten under Rule 12(b)(6), finding that the video evidence showed Crenshaw driving directly towards the officer, justifying the use of deadly force. The court concluded that the officer's actions were reasonable and dismissed the excessive force claim and the state law claims against him.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the dismissal of the claims against the City but reversed the dismissal of the claims against Officer Sletten. The appellate court held that the district court erred in dismissing the excessive force claim because the video did not blatantly contradict the plaintiff's allegations. The court found that the plaintiff's allegations, when properly construed, were sufficient to state a claim of excessive force under § 1983. The case was remanded for further proceedings on the claims against Officer Sletten. View "Doriety v. Sletten" on Justia Law