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

After pleading guilty in 2014 to Hobbs Act robbery and brandishing a firearm during and in relation to the robbery, the defendant was sentenced to consecutive prison terms and concurrent terms of supervised release. Following his release in early 2024, he soon violated several conditions of his supervised release, including testing positive for illicit drugs on multiple occasions, violating location restrictions, and leaving the judicial district without permission. The Probation Officer filed a petition for revocation alleging four violations, including drug testing failures and other conduct, and submitted a supplemental report that incorrectly classified the drug-related violation as a more serious offense.The United States District Court for the Middle District of North Carolina held a revocation hearing at which the defendant admitted the charged conduct. The court dismissed the felony possession allegation but found that the most serious remaining violation was the drug testing violation. Without explanation, the court classified this as a Grade B violation under the Sentencing Guidelines, resulting in a Guidelines range of 8 to 14 months. The court then imposed a sentence of 19 months’ imprisonment with additional terms of supervised release, exceeding the Guidelines range and possibly the statutory maximum.On appeal, the United States Court of Appeals for the Fourth Circuit found that the district court erred in characterizing the drug testing violation as a Grade B violation, rather than the less severe Grade C violation that the record supported. The appellate court held that this misclassification was plain error affecting the defendant’s substantial rights and impacted the fairness of the proceedings. The Fourth Circuit vacated the district court’s judgment and remanded the case for resentencing under the correct Guidelines classification. The court also directed the district court to consider whether the new sentence complies with the statutory limits on supervised release. View "US v. Jones" on Justia Law

A woman named Cynthia Rice died while in custody at a detention center after experiencing opioid withdrawal. Her estate, through the personal representative, sued several detention officers, alleging that they acted with deliberate indifference to her serious medical needs in violation of the Fourteenth Amendment. According to the complaint, Rice informed unidentified officers and medical staff of her heroin addiction and withdrawal symptoms upon booking. Medical staff performed intake and scheduled a detox check, but the complaint alleged that custody staff ignored her pleas for help and failed to provide necessary care. The complaint did not specify what any individual officer did or knew, instead grouping the officers together and making general allegations about their conduct.The United States District Court for the District of Maryland denied the officers’ motion to dismiss, concluding that the plaintiff had stated a viable claim under 42 U.S.C. § 1983 and that the officers were not entitled to qualified immunity at the pleading stage. The officers then appealed the denial of qualified immunity, which is immediately appealable when it involves issues of law.The United States Court of Appeals for the Fourth Circuit reviewed the case and reversed the district court’s decision. The court held that the complaint failed to state a claim against the named officers because it did not make specific, defendant-by-defendant factual allegations connecting any officer to deliberate indifference to Rice’s medical needs. The court emphasized that collective and undifferentiated allegations against a group of officers are insufficient to state a plausible claim under § 1983. As a result, the Fourth Circuit reversed the district court’s denial of the motion to dismiss and remanded the case for further proceedings. View "Rice v. Adams" on Justia Law

A native and citizen of Jamaica entered the United States as a child and overstayed his visa. Years later, he was placed in removal proceedings and sought cancellation of removal. The Department of Homeland Security argued that he was ineligible for cancellation because he had two prior convictions for crimes involving moral turpitude. The dispute centered on whether a 2009 North Carolina misdemeanor larceny charge, which resulted in a “Prayer for Judgment Continued” (PJC) conditioned on completion of community service, counted as a conviction under federal immigration law.The Immigration Judge determined that the 2009 PJC qualified as a conviction for immigration purposes because the state court imposed a requirement to complete community service, which the judge found to be a form of punishment. As a result, the Immigration Judge ruled that the applicant was ineligible for cancellation of removal. The Board of Immigration Appeals affirmed the Immigration Judge’s decision in its own written opinion.The United States Court of Appeals for the Fourth Circuit reviewed both the Immigration Judge’s and the Board’s decisions. The Fourth Circuit held that a North Carolina PJC conditioned on completion of community service constitutes a conviction under 8 U.S.C. § 1101(a)(48)(A) because the community service requirement is a punitive sanction, not merely administrative or compensatory. The court explained that the imposition of discretionary community service is intended to discipline or deter and thus qualifies as punishment. Accordingly, the court denied the petition for review, holding that the petitioner’s 2009 PJC is a conviction for purposes of federal immigration law and renders him ineligible for cancellation of removal. View "Gardner v. Blanche" on Justia Law

A police operation was planned in Fairfax County, Virginia, based on information from an informant that Jeffery Payne was dealing drugs and often carried a gun. Detectives scheduled a controlled drug buy in a shopping center parking lot, intending to arrest Payne if he appeared. When Payne arrived but sensed something was wrong, he attempted to leave. Detectives in unmarked vehicles pursued him. As Payne neared an exit, Sergeant Moser ordered the detectives to block Payne’s car. Detectives used vehicle maneuvers to stop Payne, including ramming his car, which spun out and was immobilized. Seconds later, Sergeant Moser shot Payne through the back window, believing Payne was reaching for a gun; Payne was later found to be unarmed.The United States District Court for the Eastern District of Virginia granted summary judgment in favor of Sergeant Moser, finding there were no genuine disputes of material fact and that Moser’s actions were objectively reasonable as a matter of law. The district court focused exclusively on the shooting, not addressing Payne’s claims about the vehicle maneuvers.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The Fourth Circuit concluded that the record contained genuine disputes of material fact regarding whether Sergeant Moser used excessive force—both by directing the use of vehicle maneuvers to stop Payne and by shooting him. The court held that, viewing the evidence in the light most favorable to Payne, Sergeant Moser’s conduct was not objectively reasonable as a matter of law. The Fourth Circuit vacated the district court’s grant of summary judgment and remanded the case for further proceedings, including consideration of whether Sergeant Moser is entitled to qualified immunity. View "Payne v. Moser" on Justia Law

The case concerns an individual who filed for Chapter 13 bankruptcy in the Eastern District of Virginia to address approximately $333,000 in personal debt. After his initial proposed repayment plan was denied by the bankruptcy court due to concerns about good faith and failure to meet the statutory “liquidation test,” the debtor submitted additional plans. Each of his second and third proposals was also denied. The bankruptcy court ultimately confirmed his fourth plan, which required significantly larger payments. After the fourth plan was confirmed and payments began, the debtor objected, arguing that the bankruptcy court should have confirmed his first plan.Following confirmation of the fourth plan, the debtor appealed to the United States District Court for the Eastern District of Virginia. He contended that the bankruptcy court erred in denying his first plan. The district court, however, dismissed the appeal as equitably moot, concluding that the requested relief could not be practically or equitably granted after the fourth plan’s confirmation and partial performance.The United States Court of Appeals for the Fourth Circuit reviewed the case. The Fourth Circuit held that the doctrine of equitable mootness—which allows courts to dismiss bankruptcy appeals when practical relief is no longer available—was misapplied in this straightforward, limited-asset Chapter 13 case. The court found that adjusting the debtor’s payments prospectively remained feasible, and the relevant factors weighed against applying equitable mootness. On the merits, the Fourth Circuit affirmed the bankruptcy court’s denial of confirmation of the first proposed plan, concluding there was no clear error in its finding that the plan was not proposed in good faith due to inaccuracies and inconsistencies in the debtor’s submissions and testimony. The Fourth Circuit reversed the district court’s dismissal and affirmed the bankruptcy court’s judgment. View "Cook v. Chapter 13 Trustee" on Justia Law

A group of former employees initiated a mass arbitration against their previous employers, alleging violations of the Virginia Wage Payment Act and, for one claimant, the Fair Labor Standards Act. The employers contended that not all claimants were bound by arbitration agreements and that procedural requirements for arbitration had not been met, leading them to refuse payment of required arbitration initiation fees. In response, the employers filed suit in the Circuit Court of Fairfax County, seeking to enjoin the arbitrations and obtain a declaratory judgment on the arbitration agreements’ scope. The employees removed the case to the United States District Court for the Eastern District of Virginia, where they also filed a petition to compel arbitration and stay the proceedings.The United States District Court for the Eastern District of Virginia denied the employers’ request to enjoin the arbitrations and granted a stay of the court proceedings pending arbitration. The district court did not compel arbitration outright, reasoning that the matters had already been referred to arbitration. When the employers continued to refuse payment of arbitration fees, the employees returned to the district court seeking an order to lift the stay, compel arbitration, and require the employers to pay the fees. The court again declined, maintaining its previous order referring the case to arbitration and keeping the stay in place.The United States Court of Appeals for the Fourth Circuit reviewed the employees’ interlocutory appeal challenging the district court’s denial of their renewed motion. The Fourth Circuit held that it lacked appellate jurisdiction under section 16 of the Federal Arbitration Act because the district court’s order was either an order granting a stay pending arbitration or directing arbitration to proceed—neither of which is appealable at this stage. Accordingly, the appeal was dismissed for lack of appellate jurisdiction. View "Geneva Enterprises, LLC v. Chavez" on Justia Law

The plaintiffs, three organizations representing millions of Americans, challenged the Social Security Administration’s (SSA) decision to grant personnel from the newly created U.S. DOGE Service access to non-anonymized, highly sensitive personal information held by the SSA. This access was authorized following an executive order charging DOGE with improving government technology. Career officials at the SSA resigned in protest, and a new acting administrator approved DOGE’s access. The plaintiffs argued that merely providing this access, regardless of actual misuse or disclosure, was itself unlawful and an intrusion upon the privacy of their members.The United States District Court for the District of Maryland conducted extensive hearings and granted a preliminary injunction blocking DOGE’s access to the data. The Supreme Court subsequently stayed this injunction, pending appellate and possible further Supreme Court review. The case came before the United States Court of Appeals for the Fourth Circuit, which had jurisdiction pursuant to 28 U.S.C. § 1292(a)(1).The United States Court of Appeals for the Fourth Circuit held that the plaintiffs had Article III standing, as the unauthorized access to their sensitive information closely resembled the common law tort of intrusion upon seclusion. However, the Fourth Circuit vacated the preliminary injunction, holding that the plaintiffs had not established that they were likely to suffer irreparable harm in the absence of preliminary relief, as required by the second factor of the Winter test for preliminary injunctions. The court reasoned that monetary damages and reparative permanent injunctions were potentially available remedies, and the record did not show that new or additional irreparable harm would occur during the litigation. The case was remanded to the district court for further proceedings. The main holding is that the preliminary injunction was vacated because the plaintiffs did not show likely irreparable harm. View "American Federation of State, County and Municipal v. Social Security Administration" on Justia Law

A 13-year-old male student at a Virginia Beach middle school received a sexually explicit photo from a female classmate and, several months later, showed the image to other students during the school day. After teachers reported the incident, the assistant principal removed the student from class, questioned him, and searched his phone’s photo gallery. The school resource police officer was notified and began a criminal investigation. The student ultimately showed the explicit photo to the officer, was read his Miranda rights, arrested, and charged in juvenile court with possession of child pornography. The juvenile court found sufficient evidence for guilt but deferred disposition; the charge was dismissed after the student completed court-imposed conditions.The student, through his mother and later counsel, sued the assistant principal, the school resource officer, the Virginia Beach School Board, and the City of Virginia Beach in the United States District Court for the Eastern District of Virginia. He alleged violations of his Fourth, Fifth, and Fourteenth Amendment rights, as well as conspiracy and Monell claims. The district court granted summary judgment to all defendants, finding the phone search reasonable under New Jersey v. T.L.O., the confession voluntary, no evidence of unlawful conspiracy, and no underlying constitutional violations to support Monell liability.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The court affirmed the district court’s judgment, holding that the assistant principal’s search of the student’s phone was justified at its inception and reasonable in scope under T.L.O., and that Riley v. California did not displace this standard in the school context. The court also held the student’s confession was voluntary under the Fifth and Fourteenth Amendments, found no evidence of a conspiracy to violate constitutional rights, and determined Monell liability could not attach absent an underlying constitutional violation. The court therefore affirmed summary judgment for all defendants. View "O.W. v. Carr" on Justia Law

A married couple, acting on behalf of their minor child, challenged West Virginia’s compulsory vaccination law after their daughter was disenrolled from a public virtual school because she was not fully vaccinated. The parents sought a religious exemption from the vaccination requirement, but were informed that only medical exemptions—based on specific medical contraindications or precautions certified by a physician—are permitted under state law. After being denied a religious exemption, the parents filed suit, claiming that the absence of a religious exemption violated their First Amendment right to freely exercise their Christian faith. They requested a preliminary injunction to allow their daughter’s re-enrollment in the virtual academy during the litigation.The United States District Court for the Northern District of West Virginia granted the preliminary injunction, finding that the parents were likely to succeed on their free exercise claim. The district court applied the test from Employment Division, Department of Human Resources of Oregon v. Smith, concluding that the vaccination law was not generally applicable, and thus subject to strict scrutiny, which it found the law did not survive.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s grant of preliminary relief. The Fourth Circuit held that West Virginia’s compulsory vaccination law is a neutral and generally applicable measure enacted under the state’s police power to protect public health, as recognized in longstanding Supreme Court precedent including Jacobson v. Massachusetts and Prince v. Massachusetts. The court found that the medical exemption process does not constitute a “mechanism for individualized exemptions” that would undermine general applicability under cases such as Fulton v. City of Philadelphia. The Fourth Circuit concluded that the law is subject to rational basis review, which it easily satisfies, and that the Free Exercise Clause does not require religious exemptions simply because medical exemptions exist. The court reversed the district court’s preliminary injunction and remanded the case. View "Perry v. Marteney" on Justia Law

A miner filed a claim for benefits under the Black Lung Benefits Act, asserting total disability due to lung disease following over two decades of coal mine employment. The miner had a significant history of cigarette smoking, but no evidence of clinical pneumoconiosis was present. The dispute centered on whether his disabling pulmonary impairment—despite his smoking history—was legally attributable to his coal mine dust exposure.An Administrative Law Judge (ALJ) first reviewed the claim and found that the miner had worked in coal mines for 27 years and suffered from a totally disabling pulmonary impairment. These facts entitled the miner to a statutory presumption that his disability was caused by pneumoconiosis. The ALJ determined that the mining company, as the responsible employer, failed to rebut this presumption. The ALJ discredited the employer’s medical experts, who attributed the impairment solely to smoking, because their opinions did not properly consider the additive effects of smoking and coal dust, as recognized by the Department of Labor’s Preamble to its Black Lung regulations. The Benefits Review Board affirmed the ALJ’s decision.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the ALJ correctly applied the law by requiring the employer to rebut the presumption, and properly evaluated the medical evidence in light of the regulatory guidance. The court found that the ALJ’s decision was supported by substantial evidence and that there was no legal error in the treatment of expert opinions or the regulatory preamble. The Fourth Circuit denied the mining company’s petition for review, leaving the award of benefits to the miner in place. View "Wolf Run Mining Company v. DOWCP" on Justia Law