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

Rhonda and Robert Notgrass fraudulently obtained benefits from the Pandemic Unemployment Assistance program by falsely claiming unemployment due to the COVID-19 pandemic. Robert, a minister, and Rhonda, his wife, were ineligible for these benefits as Robert was fired for reasons unrelated to the pandemic, and Rhonda had not lost her job. They both pleaded guilty to misdemeanors and were sentenced to probation by the district court.The United States District Court for the Southern District of West Virginia sentenced the Notgrasses to five years of probation, including several conditions. The Notgrasses appealed four of these conditions: obtaining permission before leaving their judicial district, prohibition on possessing dangerous weapons, registering with an unemployment agency, and Robert's participation in a supervised mental-health treatment program. They argued that these conditions were both procedurally and substantively unreasonable.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court first determined that the Notgrasses' appellate waiver did not cover challenges to probation conditions, allowing the appeal to proceed. On the merits, the court found that the district court had adequately explained the conditions in light of the Notgrasses' objections. The travel-permission and weapons prohibition conditions were standard and self-evident, while the unemployment registration and mental-health treatment conditions were tailored to the Notgrasses' specific circumstances. The court held that all four conditions were reasonably related to the § 3553(a) sentencing factors and were not an abuse of discretion.The Fourth Circuit affirmed the district court's sentences, finding the probation conditions both procedurally and substantively reasonable. View "US v. Notgrass" on Justia Law

William Davis Jr. was arrested for reckless driving after police observed him using a handheld device while driving. During the arrest, officers discovered a firearm hidden in his waistband. Davis, a convicted felon, pleaded guilty to being a felon in possession of a firearm. At sentencing, the district court varied upward from the Sentencing Guidelines range of 21 to 27 months and imposed a sentence of 72 months. Davis appealed, arguing that the sentence was procedurally and substantively unreasonable.The United States District Court for the Eastern District of Virginia initially calculated Davis's Sentencing Guidelines range as 57 to 71 months, based on a base offense level of 24 due to his prior felony convictions for controlled substance offenses. However, the court later applied the categorical approach from United States v. Campbell, which led to a recalculated base offense level of 14 and a revised Guidelines range of 21 to 27 months. Despite this, the district court granted the government's motion for an upward variance, citing Davis's extensive criminal history and the seriousness of his offense.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The appellate court found that the district court had conducted an individualized assessment of the facts and arguments, adequately explained its reasoning, and properly considered the § 3553(a) factors. The court emphasized that the district court's findings regarding the seriousness of Davis's offense and his extensive criminal history justified the upward variance. The appellate court concluded that the 72-month sentence was both procedurally and substantively reasonable. View "US v. Davis" on Justia Law

Plaintiffs, business entities owning recovery rights assigned by health insurers and other third-party Medicare payors, alleged that Defendants, including a drug manufacturer, a specialty pharmacy, and healthcare nonprofits, colluded to inflate the price and quantity of the drug Xenazine. This alleged scheme purportedly violated the Racketeer Influenced and Corrupt Organizations Act (RICO) and various state laws, causing the Assignors to reimburse inflated Xenazine prescriptions at supra-competitive prices.The United States District Court for the Eastern District of Virginia dismissed the class-action complaint with prejudice, concluding that Plaintiffs failed to adequately allege that Defendants’ conduct proximately caused their injuries. The court emphasized that RICO’s proximate-causation requirement focuses on the directness of the harm, not its foreseeability. The court found the alleged causal chain too attenuated, involving numerous independent actors like physicians and pharmacists, and dismissed the state-law claims for similar reasons.The United States Court of Appeals for the Fourth Circuit affirmed the district court’s dismissal of the federal RICO claims, agreeing that Plaintiffs failed to establish proximate causation. The court noted that the alleged scheme had more direct victims, such as distributors and wholesalers, and that the volume of Xenazine prescriptions depended on the independent decisions of doctors. The court also affirmed the dismissal of the state-law consumer-protection and unjust-enrichment claims, finding them insufficiently pleaded.The Fourth Circuit reversed the district court’s conclusion that Plaintiffs had standing to bring claims on behalf of unidentified assignors, remanding those claims for dismissal without prejudice. The court upheld the district court’s denial of post-judgment relief and leave to amend the complaint, concluding that further amendment would be futile. View "MSP Recovery Claims, Series LLC v. Lundbeck LLC" on Justia Law

In the early morning of November 1, 2019, a group of law enforcement officers, including Task Force Officer (TFO) Clarence Belton and Charlotte-Mecklenburg Police Officer Heather Loveridge, attempted to execute a search warrant at the house of a suspect, Larry McConneyhead, in Charlotte, North Carolina. During the operation, McConneyhead fled into his house, and a confrontation ensued. TFO Belton was accidentally shot by Officer Loveridge, who mistook him for the suspect. Belton suffered severe injuries, leading to multiple surgeries and permanent disability.The case was initially filed in North Carolina state court and then removed to the United States District Court for the Western District of North Carolina. Belton alleged excessive force under 42 U.S.C. § 1983 and several state law claims against Officer Loveridge and the City of Charlotte. Officer Loveridge moved for summary judgment, asserting qualified immunity for the federal claim and public officers’ immunity for the state claims. The district court denied her motion, citing genuine disputes of material fact regarding the circumstances of the shooting.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that the district court failed to conduct the proper analysis for determining qualified immunity, which requires identifying the specific constitutional right violated and whether that right was clearly established at the time of the incident. The Fourth Circuit vacated the district court’s order and remanded the case for further proceedings, instructing the lower court to apply the correct legal standards for qualified immunity and public officers’ immunity. View "Belton v. Loveridge" on Justia Law

In early 2021, Jarohn Parham was stopped by Newport News, Virginia police for driving with an expired registration. During the stop, officers observed Parham reaching towards the center console and subsequently found a .25 caliber semi-automatic pistol in the vehicle. Parham, a convicted felon, was arrested and later indicted by a federal grand jury for being a felon in possession of a firearm in violation of 18 U.S.C. § 922(g)(1). He pled guilty to the charge without a plea agreement but with a stipulated statement of facts.The United States District Court for the Eastern District of Virginia calculated Parham’s Sentencing Guidelines range, determining his base offense level to be 20 under U.S.S.G. § 2K2.1(a)(4)(A), based on a prior conviction for Virginia common law robbery, which the court deemed a crime of violence. Parham objected, arguing that his prior conviction did not qualify as a crime of violence under the Guidelines. The district court overruled his objections, finding that Virginia robbery met the generic definition of robbery and imposed an 84-month sentence.The United States Court of Appeals for the Fourth Circuit reviewed the case and agreed with Parham, finding that Virginia robbery does not qualify as a crime of violence under the Sentencing Guidelines. The court noted that Virginia robbery can be committed by threatening to accuse the victim of sodomy, which does not involve the use, attempted use, or threatened use of physical force. Consequently, the court reversed the district court’s judgment, vacated Parham’s sentence, and remanded the case for resentencing. The appellate court also instructed the district court to consider whether Parham’s conviction for use of a firearm during a robbery qualifies as a crime of violence. View "United States v. Parham" on Justia Law

David Levine, former CEO of Geostellar Inc., was accused of defrauding and bankrupting the company. Geostellar had a directors and officers insurance policy from Philadelphia Indemnity Company, which began providing Levine's defense. The policy had a $3 million coverage limit. Levine and his wife later filed for personal bankruptcy, which stayed the Geostellar adversary action. The Geostellar Trustee moved to lift the stay to proceed against Levine to the extent of the insurance coverage, admitting that Levine's debt to Geostellar was uncollectable beyond the insurance coverage.The bankruptcy court granted the motion to lift the stay. The Trustees then filed an adversary action for declaratory judgment, seeking to establish that the right to settlement under the policy was an asset of the Levine Bankruptcy Estate, for which the Levine Trustee was the exclusive representative. The bankruptcy court dismissed the action, and the district court affirmed, finding that neither Trustee had standing to sue the insurer.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The court held that the Geostellar Trustee had no standing because West Virginia law did not permit a direct action against the insurer under the circumstances, and the policy only provided coverage to Levine, not Geostellar. The Levine Trustee also lacked standing because any judgment in the Geostellar adversary action would not impact the Levine Bankruptcy Estate, as Levine's debt to Geostellar was discharged and uncollectable beyond the insurance coverage. The court concluded that the right to consent to settlement under the policy was not the property of either Trustee. View "Fluharty v. Philadelphia Indemnity Insurance Co." on Justia Law

Robert Valladares, who struggled with drug addiction, distributed fentanyl to a friend who subsequently overdosed and died. Valladares was initially charged with distribution resulting in death but ultimately pleaded guilty to lesser charges without the death-resulting enhancement. He was sentenced to 144 months in prison. Valladares sought to earn time credits under the First Step Act, which allows incarcerated individuals to earn credits for participating in recidivism reduction programs, except for those convicted of certain offenses, including drug offenses resulting in death.The Bureau of Prisons (BOP) deemed Valladares ineligible for time credits, citing his conviction under 21 U.S.C. § 841(b)(1)(C) and the resulting death. Valladares challenged this decision through BOP’s administrative process and then filed a habeas corpus petition in the United States District Court for the Northern District of West Virginia. The district court denied his petition, agreeing with BOP that Valladares was ineligible due to the death associated with his crime.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the First Step Act’s ineligibility provision, 18 U.S.C. § 3632(d)(4)(D)(lviii), applies only to those convicted of the death-resulting enhancement element. Since Valladares was not convicted of this enhancement, he is eligible to earn time credits. The Fourth Circuit reversed the district court’s decision and remanded the case, allowing Valladares to earn time credits under the First Step Act. View "Valladares v. Ray" on Justia Law

In 2019, the FBI and DEA, along with local law enforcement, investigated a Mexican drug trafficking organization operating in Mexico, California, Georgia, and North Carolina. Oscar Pliego-Pineda, based in Atlanta, Georgia, was identified as a key figure in coordinating methamphetamine deliveries and managing drug proceeds. He arranged multiple drug transactions and coordinated logistics for methamphetamine shipments, including converting liquid methamphetamine to crystal form.The United States District Court for the Middle District of North Carolina sentenced Pliego-Pineda to 120 months in prison after he pled guilty to conspiracy to distribute methamphetamine and conspiracy to commit money laundering. The court applied a three-level managerial role enhancement under the United States Sentencing Guidelines, which Pliego-Pineda contested, arguing that the district court erred in applying the enhancement and that his sentence was substantively unreasonable.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court upheld the district court's application of the managerial role enhancement, finding that Pliego-Pineda exercised significant decision-making authority, participated extensively in the conspiracy, and managed the logistics of drug transactions. The court noted that the conspiracy involved at least ten individuals and large quantities of methamphetamine. Despite an error in considering Pliego-Pineda's supervision of an undercover officer, the court found sufficient evidence to support the enhancement.The Fourth Circuit also found Pliego-Pineda's sentence substantively reasonable, affirming the district court's decision. The court emphasized that the sentence was within the properly calculated Guidelines range and thus presumptively reasonable. The court concluded that the district court did not abuse its discretion in sentencing Pliego-Pineda. View "United States v. Pliego-Pineda" on Justia Law

Scott Rendelman was convicted in 2008 for mailing threatening communications under 18 U.S.C. § 876(c). The district court instructed the jury that the government only needed to prove that a “reasonable person” would find Rendelman’s communications threatening. In 2023, the Supreme Court held in Counterman v. Colorado that the First Amendment requires the government to prove that the defendant was subjectively aware of the threatening nature of his statements. Rendelman now seeks authorization to file a successive 28 U.S.C. § 2255 motion to vacate his conviction based on this new ruling.Previously, the district court denied Rendelman’s first § 2255 motion, and the United States Court of Appeals for the Fourth Circuit declined to authorize a second § 2255 motion. Rendelman’s conviction was affirmed on direct appeal.The United States Court of Appeals for the Fourth Circuit reviewed Rendelman’s motion for authorization to file a successive § 2255 motion. The court concluded that Rendelman satisfied the gatekeeping requirements of 28 U.S.C. § 2255(h), as the Supreme Court’s decision in Counterman announced a new rule of constitutional law that applies retroactively and was previously unavailable to Rendelman. The court rejected the government’s argument that Rendelman must also show a plausible claim for relief, adhering to the standard that a prima facie showing of possible merit is sufficient. Consequently, the Fourth Circuit granted Rendelman’s motion for authorization to file a successive § 2255 motion. View "In re Rendelman" on Justia Law

John Sigley applied for a Material Handler position with ND Fairmont LLC (NDF) and was offered the job contingent on passing a physical exam. During the physical, conducted by Industrial Therapy Solutions (ITS), Sigley denied having any back issues or seeing a chiropractor, despite having undergone three back surgeries and having a metal rod in his back. He passed the physical and began working on September 13, 2021. On October 28, 2021, Sigley called out of work due to back spasms and later disclosed his back condition to NDF's HR Manager, Joyce Hardway, and Environmental Health & Safety Manager, Justin Darrah. NDF confirmed Sigley's omission of his back condition during the physical and terminated him for dishonesty on November 2, 2021.Sigley filed a lawsuit against NDF, alleging disability discrimination under the Americans with Disabilities Act (ADA). The United States District Court for the Northern District of West Virginia granted summary judgment in favor of NDF, finding that Sigley was terminated for dishonesty, not because of his disability. The court also dismissed Sigley's claims of breach of confidentiality and failure to accommodate, as they were not properly pled in his complaint.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The Fourth Circuit held that Sigley failed to establish a prima facie case of discriminatory discharge, as he could not demonstrate that his termination raised a reasonable inference of unlawful discrimination. The court found that NDF had a legitimate, non-discriminatory reason for terminating Sigley—his dishonesty during the physical exam. The court also noted that Sigley's claims of breach of confidentiality and failure to accommodate were untimely and meritless, as he did not properly plead them and admitted he did not require an accommodation. View "Sigley v. ND Fairmont LLC" on Justia Law