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

The United States Court of Appeals for the Fourth Circuit examined a dispute between the plaintiffs, John and Dawn Harrell, and the defendant, Douglas DeLuca. The Harrells sued DeLuca, a general contractor from whom they purchased a home, for fraudulent inducement, constructive fraud, breach of contract, and violations of the Virginia Consumer Protection Act. The district court granted summary judgment in favor of DeLuca regarding the Harrells’ fraud claims based on one category of misrepresentations. The case otherwise proceeded to a bench trial where the court found DeLuca liable for breaching the contract, but not for the remaining claims. The Harrells appealed, arguing that summary judgment was inappropriate and that the district court should have made explicit findings related to their constructive fraud and breach-of-contract claims.The Court of Appeals upheld parts of the lower court's decision but also vacated parts of it. It agreed with the Harrells that the summary judgment was inappropriate, vacated it, and remanded the case for additional proceedings. It also agreed that the district court should have made explicit findings related to one of each of their constructive fraud and breach-of-contract claims. However, it affirmed the resolutions of the remaining claims which were not challenged by the Harrells on appeal. The court remanded the case back to the district court for further proceedings consistent with its opinion. View "Harrell v. Deluca" on Justia Law

The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision that the Federal Bureau of Investigation (FBI) could withhold records relating to a criminal investigation based on Exemption 7(A) of the Freedom of Information Act (FOIA). This exemption allows federal agencies to withhold records if their release could reasonably be expected to interfere with law enforcement proceedings.In the case, Mark Zaid, an attorney, requested records related to the FBI's criminal investigation into one of his clients, Zackary Sanders, who had been charged with production and possession of child pornography. The FBI refused to release the requested records, citing Exemption 7(A) of FOIA. Zaid then sued the FBI to release the records, but the district court found the records were exempt from disclosure.The appeals court agreed with the district court's decision, stating that the disclosure of these records could reasonably be expected to interfere with ongoing or future investigations and prosecutions of child pornography cases. The court also noted that forcing the FBI to disclose information exchanged between law enforcement agencies could make those agencies hesitant to share information in the future, which would harm FBI investigations. The court also dismissed Zaid's arguments that cited two decisions from the Middle District of Florida, stating those decisions were not binding on the district court or the appeals court. View "Zaid v. Department of Justice" on Justia Law

In this case, the plaintiff, Ricky Pendleton, is an inmate in the West Virginia prison system who follows the "Sufi Original Traditions" of Islam. His religious beliefs require a diet that promotes "compassion and harmlessness to living creatures," which he interprets to mean a diet of "vegetables, fruits and certain fish." In 2014, prison officials introduced a new diet program for those with religious dietary restrictions. However, the program only offered one "religious special diet" designed to meet the needs of all faiths by following the rules of the most diet-restrictive ones. This diet used soy as its primary protein source, which Pendleton's body had problems digesting. Pendleton requested a religious accommodation, but this request was denied. He filed two grievances, which were also denied. Pendleton then filed a pro se complaint against three prison officials. The district court dismissed Pendleton’s complaint, concluding he had not adequately alleged he was being forced to consume any foods forbidden by his religion.The United States Court of Appeals for the Fourth Circuit vacated and remanded the district court's judgment. The court held that Pendleton had plausibly alleged that prison officials imposed a substantial burden on his religious practice by forcing him to choose between a government-provided benefit (the diet) and his religious convictions. The court also rejected the argument that Pendleton could obtain a meat-free and soy-free diet by obtaining test results showing he has a medically significant allergy to soy. The court concluded that Pendleton need not produce documentation of his alleged soy allergy to survive a motion to dismiss. Instead, it was enough that he had plausibly alleged that he cannot digest soy and that he suffered gastrointestinal distress after switching to the religious special diet. The court also held that Pendleton’s Free Exercise Clause claim and his motion to be severed from the prison’s diet program should be reconsidered by the district court. View "Pendleton v. Jividen" on Justia Law

Carlos Gomez-Ruotolo, a native citizen of Venezuela, was brought to the United States in 2001 and became a lawful permanent resident. He was convicted twice in Virginia for crimes involving minors: once for attempted sexual battery and another for electronic solicitation of a minor. Based on these convictions, he was found removable as a noncitizen convicted of two or more crimes involving moral turpitude and was denied relief by the Board of Immigration Appeals. Gomez-Ruotolo appealed to the United States Court of Appeals for the Fourth Circuit, arguing that his crimes were not morally turpitudinous and that he should receive protection against removal under the Convention Against Torture.The court disagreed. It held that attempted sexual battery and electronic solicitation of a minor both involved moral turpitude, thus making Gomez-Ruotolo deportable under immigration law. The court also affirmed the agency's decision to deny Gomez-Ruotolo protection under the Convention Against Torture, agreeing that he had not shown he was more likely than not to face torture in Venezuela. Therefore, the court denied Gomez-Ruotolo's petition for review. View "Gomez-Ruotolo v. Garland" on Justia Law

In this case, the United States Court of Appeals for the Fourth Circuit considered whether a district court can reduce a sentence for both covered and noncovered offenses under the First Step Act if they were sentenced as a package. The defendant, Nathaniel Richardson, was originally sentenced to two concurrent terms of life imprisonment for conspiracy to distribute crack cocaine and heroin and for engaging in a continuing criminal enterprise. After the passage of the First Step Act, Richardson sought a sentence reduction. The district court reduced the sentence for the crack cocaine distribution offense but left the sentence for the continuing criminal enterprise offense undisturbed.The Fourth Circuit vacated the district court's ruling and remanded the case for further proceedings. The appellate court held that the district court has the discretion to reduce both covered and noncovered offenses under the First Step Act if they function as a package. The court reasoned that since district judges often sentence on multiple counts as an interconnected process, they should be given the discretion to reconfigure the sentencing plan to ensure it remains adequate to satisfy the statutory sentencing factors. The court further noted that the sentencing package doctrine is applicable here because when one count of a package is remanded, the district judge must be given the discretion to review the efficacy of what remains in light of the original plan. The case was remanded for the district court to decide whether the counts functioned as a package, and if so, to resentence accordingly. View "United States v. Richardson" on Justia Law

This case was heard in the United States Court of Appeals for the Fourth Circuit and involved the Estate of Arturo Giron Alvarez and 773 other plaintiffs, who brought claims against The Rockefeller Foundation (TRF), alleging the foundation's involvement in nonconsensual human medical experiments in Guatemala from 1946 to 1948. The experiments involved exposing people to sexually transmitted diseases (STDs) to study the diseases and potential treatments. The defendants had previously filed a motion for summary judgment, which was granted by the district court. The plaintiffs appealed this decision, specifically challenging the decision relating to TRF.The appeal hinged on the question of whether Dr. Soper, an Associate Director of TRF who was assigned to the Pan-American Sanitary Bureau (PASB) in Guatemala during the time of the experiments, was acting as an agent of TRF, thus making TRF liable for his actions. The court found that despite TRF paying Dr. Soper's salary during his time at the PASB, there was no indication that TRF was directing or controlling Dr. Soper’s work. Furthermore, the evidence showed that Dr. Soper considered himself no longer with TRF, and the PASB's constitution prohibited him from taking outside direction.The court concluded that TRF's connection to the experiments was too tenuous to be held liable for them. It affirmed the district court's grant of summary judgment in favor of TRF, stating that Dr. Soper was not an agent of TRF during the time of the experiments. View "In re Estate of Alvarez v. Rockefeller Foundation" on Justia Law

In this case, the plaintiff, Anila Daulatzai, was removed from a Southwest Airlines flight after the captain received information about her dog allergy and the presence of two dogs on board. Daulatzai insisted on remaining in her seat despite the captain’s decision, leading to her physical removal by Maryland Transportation Authority police officers. She was later charged with various offenses, including disorderly conduct and resisting arrest.Daulatzai filed an action against Southwest Airlines and the State of Maryland, alleging various grounds to challenge her removal from the plane and her arrest. The district court dismissed Daulatzai’s complaint for failure to state a plausible claim upon which relief could be granted. Daulatzai appealed that judgment and, while her appeal was pending, she also filed a motion in the district court under Federal Rule of Civil Procedure 60(b), seeking to file a fourth version of her complaint with the district court.The court denied her request, finding that her efforts were pursued in bad faith, that her repeated failures to cure defects in her pleadings had been prejudicial to the defendants, and that the fourth complaint would, in any event, be futile. Daulatzai appealed that ruling as well.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision, finding that Daulatzai had failed to establish any of the grounds for relief under Rule 60(b) and that the district court did not abuse its discretion in denying Daulatzai leave to file her proposed third amended complaint. The court also found that Daulatzai had waived her challenge to the district court’s dismissal of her second amended complaint by failing to preserve it below. View "Daulatzai v. Maryland" on Justia Law

The plaintiff, Peter Massaro, a police officer with the Fairfax County Police Department, alleged that his employer retaliated against him by transferring him to an inferior position after he filed a complaint about discrimination in promotion practices within the department. He sought relief under Title VII of the Civil Rights Act, the Age Discrimination in Employment Act, and 42 U.S.C. § 1983. The district court granted summary judgment to Fairfax County, dismissing all of Massaro's claims. The court held that Massaro failed to establish a causal connection between his initial discrimination complaint and his subsequent job transfer.Upon appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court ruled that the time gap between Massaro's complaint and his transfer was too long to support a causal inference. It found no evidence that the transfer was a result of a scheme to punish Massaro for his complaint. Instead, the court concluded that Massaro's transfer was a result of his own subsequent behavior that led to a violation of departmental policy.The court also dismissed Massaro's First Amendment claim, ruling that his promotion complaint made via an internal grievance process did not reflect a matter of public concern, and thus did not meet the threshold for First Amendment protection. View "Massaro v. Fairfax County" on Justia Law

The United States Court of Appeals for the Fourth Circuit addressed a case where an inmate with celiac disease sued a doctor for depriving him of a gluten-free diet. The district court had granted summary judgment to the doctor because the plaintiff did not have an expert witness to testify about the standard treatment for celiac disease or the causal link between the doctor’s conduct and the plaintiff’s alleged harm. The appeals court held that no expert testimony was needed to avoid summary judgment in this case. The court found that the plaintiff had presented sufficient evidence to create a genuine dispute of material fact about the doctor's knowledge of his celiac disease and the excessive risk it posed by failing to respond reasonably, even without an expert.The court also clarified that expert testimony is not necessary to establish an Eighth Amendment claim of deliberate indifference. The court held that while determining whether medical professionals responded reasonably to a particular risk can involve an examination of the relevant standard of care, the fact that expert testimony may be necessary in some cases does not mean it was in this one. The court vacated the district court’s judgment and remanded the case for further proceedings. View "Phoenix v. Amonette" on Justia Law

This consolidated opinion, delivered by the United States Court of Appeals for the Fourth Circuit, pertains to the appeals of defendants Richard Tipton and James Roane, Jr. Both were convicted in 1993 and sentenced to death and multiple years in prison for involvement in a drug-related enterprise that also included firearms, murders, and other racketeering activity. They have consistently sought post-conviction relief, and in light of recent Supreme Court decisions, they contested their sentences related to their firearm-related 18 U.S.C. § 924(c) convictions in 1993.The court affirmed the district court's decisions, rejecting the defendants' challenges to their § 924(c) sentences. The court concluded that Violent Crimes in Aid of Racketeering Activity (VICAR) murder constitutes a "crime of violence" under § 924(c). The defendants failed to demonstrate that there was more than a reasonable possibility that the jury did not rely on the valid VICAR murder predicate for any of their § 924(c) convictions. Therefore, the validity of any other alleged § 924(c) predicate did not need to be decided. The court held that the defendants' § 924(c) convictions and sentences were legally sound. View "United States v. Tipton" on Justia Law