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

In this case, Nagla Abdelhalim, an Egyptian immigrant and a Muslim woman, filed suit against her neighbors Aaron and Dinara Lewis and Andrew and Roxana McDevitt, alleging that they violated the Fair Housing Act by engaging in a year-long campaign of harassment against her in an attempt to drive her out of the neighborhood because of her race, national origin, and religion. The dispute began when Abdelhalim started a short-term rental business, renting out her basement on platforms such as Airbnb, which violated a local ordinance at the time and was disapproved by her neighbors. The United States District Court for the Eastern District of Virginia granted summary judgment to the defendants, concluding that Abdelhalim had not produced evidence of intentional discrimination based on a protected ground.On appeal, the United States Court of Appeals for the Fourth Circuit considered only whether the district court erred in granting the defendants' motions for attorneys’ fees. The Fourth Circuit ruled that the district court had applied the wrong legal standard and thus abused its discretion in granting attorneys’ fees to the defendants. The court noted that while a plaintiff’s failure to prevail is a factor to consider, it alone cannot be the basis for concluding that a claim was without foundation. The court found that Abdelhalim had provided sufficient evidence to support her belief that the defendants intended to discriminate against her based on her race, religion, or national origin. Thus, her claims were not without foundation, and the award of attorneys' fees to the defendants was vacated. View "Abdelhalim v. Lewis" on Justia Law

In this case, plaintiffs Kewon English and Earl Powell were arrested for sexual assault and burglary and detained for over a year before their cases were nolle prossed and they were released. They sued Senior Investigator Joseph Clarke of the Richland County Sheriff’s Department, alleging that he had coerced them into signing false confessions. They also sued Sheriff Leon Lott and the Richland County Sheriff's Department for damages under § 1983, claiming their constitutional rights under the First, Fourth, Fifth, Sixth, and Fourteenth Amendments were violated. The United States Court of Appeals for the Fourth Circuit affirmed the grant of summary judgment on English’s claims and dismissed Clarke’s cross-appeal. The court determined that there was probable cause to arrest English based on the victim’s identifications. Regarding English's malicious prosecution claim, the court held that even assuming probable cause was negated, Clarke cannot be held responsible for English’s continued detention. The court found no evidence that the Richland County Sheriff's Department had any unconstitutional policy or custom, and that Clarke could not be held liable for the continued detention of English. Furthermore, the court dismissed Clarke's cross-appeal, ruling that the appeal turned on a question of fact and was therefore not suitable for interlocutory treatment. View "English v. Clarke" on Justia Law

In this case, the defendant, Jahsir Claybrooks, pleaded guilty to possession of a stolen firearm. The probation office determined that at the time of the offense, Claybrooks was an unlawful user of controlled substances and under indictment for a felony, making him a "prohibited person" not allowed to possess a firearm. As a result, his sentence was calculated based on this status. Claybrooks challenged this designation, arguing that he was not an unlawful drug user and that the statute was unconstitutionally vague. He also asserted that the district court erred in determining he was under indictment at the time of his offense and in imposing a sentence above the recommended guidelines. Finally, Claybrooks argued that the district court should have conducted an analysis of the firearms statutes at issue in accordance with a recent Supreme Court case. The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision, concluding that the district court did not commit reversible error. The court found that the district court correctly determined that Claybrooks was an unlawful user of controlled substances at the time of the offense, the relevant statute was not unconstitutionally vague, and the district court did not err in imposing an above-guidelines sentence. The court also dismissed Claybrooks' argument regarding the need for an analysis of the firearms statutes, as he raised this issue for the first time on appeal. View "US v. Claybrooks" on Justia Law

This case involves Jeremy Schulman, a former shareholder at the Maryland law firm Shulman, Rogers, Gandal, Pordy & Ecker. Schulman sued insurance companies AXIS Surplus Insurance Company, Endurance American Specialty Insurance Company, and Prosight Syndicate 1110 at Lloyd’s, for breach of contract, detrimental reliance, and lack of good faith, claiming that they wrongfully denied his claim for coverage under his law firm's professional liability insurance policy. The dispute hinges on whether Schulman's indictment in a criminal case qualifies as a "claim" under his professional liability insurance policy, and whether a letter from the insurance companies promising to cover certain costs relating to a subpoena also covered costs related to the later indictment. Schulman also alleges that the insurers acted in bad faith.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision, granting summary judgment to the defendants. The court held that Schulman's indictment in the criminal case did not constitute a "claim" under his professional liability insurance policy, and that the insurers' letter did not promise to cover costs related to the indictment. The court also held that Schulman's claim of bad faith could not succeed because he was not entitled to coverage under the policy and the insurers did not breach any tort duty by denying coverage. View "Schulman v. Axis Surplus Ins. Co., Inc." on Justia Law

In the case, Remy Holdings International, LLC ("Remy") sued Fisher Auto Parts, Inc. ("Fisher") after Fisher terminated their business relationship and sold its inventory to a different manufacturer. Remy claimed that Fisher wrongfully terminated their agreement and that the inventory Fisher sold belonged to Remy. Remy brought claims for breach of contract, unjust enrichment, and conversion. Fisher counterclaimed for breach of contract due to Remy's poor performance.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decisions, which were all in Fisher's favor. The court found that Remy committed the first material breach of the contract by failing to keep Fisher competitive in the marketplace. Furthermore, Fisher did not waive its right to assert the first material breach defense by continuing to order from Remy and occasionally waiving the order-fill penalty. Therefore, Remy was precluded from enforcing the contract and its breach of contract claim related to ownership of the inventory was dismissed.The court also rejected Remy's argument that the district court should have reinstated its unjust enrichment claim after declaring its contractual rights unenforceable. Remy had failed to respond to Fisher's motion for summary judgment seeking the dismissal of the unjust enrichment claim, and as a result, forfeited any opposition to its dismissal.Lastly, the court found no error with the district court's evidentiary rulings, including the admission of expert testimony and the USA Core Policy, and its refusal to instruct the jury on certain defenses. View "Remy Holdings International, LLC v. Fisher Auto Parts, Inc" on Justia Law

In a case before the United States Court of Appeals for the Fourth Circuit, a foreign service officer and a non-citizen were convicted of conspiring to fraudulently obtain U.S. citizenship for the non-citizen and making false statements in the process. The defendants, Laura Anne Gallagher and Andrey Nikolayevich Kalugin, were married in 2015. They were accused of conspiring to achieve naturalization and proof of citizenship for Kalugin by making false statements and submitting fraudulent documents. The jury found them guilty on all counts. On appeal, the court concluded that the evidence was sufficient to support each defendant’s convictions. However, it found that the jury was allowed to consider a legally inadequate theory on one count and an erroneous evidentiary ruling prevented the defendants from offering certain evidence on the remaining two counts. As a result, the court vacated the convictions and remanded the case for further proceedings. View "US v. Gallagher" on Justia Law

In this case, Jordan Jones, a prisoner at North Carolina’s Avery-Mitchell Correctional Institution, sued multiple prison officials under § 1983. The suit challenged the conditions of his confinement and a transfer to another prison that he alleged was retaliatory. The United States Court of Appeals for the Fourth Circuit affirmed in part and reversed in part the district court's grant of summary judgment to the defendants.Jones had been placed in a “dry” cell, with the water turned off, for about 17 hours after he was suspected of having ingested contraband. He was allowed to clean himself only with toilet paper, despite having to defecate three times in a portable toilet. He also had to eat a meal with his hands, which he was unable to wash. The court concluded that while the conditions of Jones's confinement were deplorable, the officials were entitled to qualified immunity on this claim because it was not clearly established in April 2015 that these conditions posed a substantial risk of serious harm in violation of the Eighth Amendment.However, the court reversed the district court's grant of summary judgment to defendant Gregory Taylor on Jones's claim that his transfer to another prison was in retaliation for his filing of grievances. The court concluded that a reasonable jury could find that Taylor ordered the transfer in retaliation for Jones's grievances, and that Taylor was not entitled to qualified immunity on this claim because it was clearly established at the time of the transfer that such retaliation violated the First Amendment. The court remanded for further proceedings on this claim. View "Jones v. Solomon" on Justia Law

In this case from the United States Court of Appeals for the Fourth Circuit, the plaintiff, Frank Morgan, appealed from a decision of the United States District Court for the Southern District of West Virginia. Morgan alleged that a police officer, J.D. Tincher, used excessive force during his arrest and subsequent detention, causing him serious injuries. The case proceeded to a jury trial, and the jury found in favor of Officer Tincher.However, after presenting his case, Morgan discovered another lawsuit against Officer Tincher, involving similar allegations of excessive force, which Tincher had failed to disclose during discovery. Morgan requested sanctions and moved for a new trial under Federal Rule of Civil Procedure 60(b)(3), alleging misconduct by the opposing party. The district court denied the motion, leading to this appeal.In its decision, the Fourth Circuit held that Officer Tincher's failure to disclose the other excessive-force lawsuit constituted misconduct under Rule 60(b)(3). It also found that Morgan had presented a meritorious claim and that the misconduct prevented him from fully presenting his case. The court further concluded that the district court had erred in its analysis of whether the undisclosed evidence would have changed the trial outcome. Lastly, the court ruled that the interest of justice in this case outweighed the interest in the finality of judgments.Therefore, the Fourth Circuit reversed the district court's decision, vacated the final judgment in favor of Officer Tincher, and remanded the case to the district court with instructions to allow for a reasonable period of additional discovery before conducting a new trial. View "Morgan v. Tincher" on Justia Law

In the case before the United States Court of Appeals for the Fourth Circuit, Gregory Kelly, the former Town Manager of Abingdon, Virginia, sued the Town for discrimination, retaliation, interference, and failure to accommodate under the Americans with Disabilities Act (ADA). Kelly alleged that he suffers from anxiety, depression, and high blood pressure, and these conditions worsened due to a hostile work environment created by the elected Mayor and Town Council. He further alleged that, despite his efforts to seek accommodations for his disabilities, the Town failed to engage in a meaningful dialogue to determine appropriate accommodations, and instead escalated its pattern of harassment.The Court of Appeals affirmed the lower court's dismissal of Kelly's discrimination and interference claims, along with its ruling that a letter Kelly sent to the Town in January 2018 was not an ADA accommodation request. The court reasoned that although Kelly had informed the Town of his disabilities and it was aware of them, the January 2018 letter, despite being titled "Accommodations Requests," did not make it clear that Kelly was seeking accommodations for his disabilities. The requests in the letter were not connected to Kelly's disabilities and were more related to general workplace issues. Therefore, the letter did not trigger the Town's duty to engage in an interactive process to determine appropriate accommodations under the ADA.The Court also found that Kelly failed to state a claim for ADA discrimination. He did not provide any facts suggesting that the Town had a discriminatory motive or that his disability was a "but-for" cause of his constructive discharge. The Court further held that Kelly failed to state a claim for ADA interference, as he did not allege that the Town engaged in behavior to prevent him from exercising his ADA rights or that the Town had a discriminatory motive. View "Kelly v. Town of Abingdon" on Justia Law

In the case before the United States Court of Appeals for the Fourth Circuit, the defendant, Keyon Paylor, appealed from the decision of the United States District Court for the District of Maryland, which denied his petition to vacate his conviction for being a felon in possession of a firearm. Paylor had entered a guilty plea, which he later sought to vacate, asserting that his plea was not knowing and voluntary. He claimed that law enforcement officers involved in his arrest planted the firearm and stole thousands of dollars from him, and that his plea was induced as a result of egregious law enforcement misconduct. The district court denied his petition, concluding that Paylor did not produce enough evidence to establish that information regarding former Detective Daniel Hersl’s misconduct materially influenced his decision to plead guilty. The Court of Appeals disagreed with the district court's decision and vacated it, concluding that Paylor is entitled to discovery and an evidentiary hearing in order to attempt to gather evidence to support his claim. The case was remanded back to the district court for further proceedings. View "US v. Paylor" on Justia Law