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

The petitioner, a Black native and citizen of Guyana, entered the United States as a lawful permanent resident in infancy and lived there since. He suffered from untreated mental illness, including schizophrenia, and physical disabilities requiring a wheelchair. After a psychotic episode, he was convicted of several felonies and served sixteen years in prison. Following his release, the Department of Homeland Security charged him as removable due to his aggravated felony conviction. Fearing torture if deported to Guyana because of his mental health, physical disabilities, criminal-deportee status, and race, he sought deferral of removal under the Convention Against Torture, presenting testimony and evidence of mistreatment faced by similar groups in Guyana.An Immigration Judge found the petitioner and his expert credible but denied relief, concluding that the likelihood of torture in Guyana was insufficient. The judge determined that Guyanese police do not actively seek to harm or torture mentally ill persons and that government acquiescence was not supported by the evidence. The judge also found that discrimination and poor conditions existed but did not rise to the level of torture or government acquiescence. The petitioner appealed to the Board of Immigration Appeals, arguing that the judge failed to consider the cumulative risk of torture based on all asserted grounds and misapplied the definition of torture. The Board affirmed, focusing only on mental illness and finding no clear error in the judge’s conclusions.The United States Court of Appeals for the Fourth Circuit reviewed only the Board’s decision. The court held that the Board abused its discretion by ignoring relevant, unrebutted evidence regarding the petitioner’s risk of torture due to his race, physical disabilities, and criminal-deportee status. The court granted the petition for review, vacated the Board’s decision, and remanded for further proceedings, instructing the agency to consider all evidence and apply the definition of torture to each claim. View "McDougall v. Bondi" on Justia Law

Three plaintiffs alleged they suffered injuries after receiving the Gardasil vaccine, which is designed to prevent certain strains of human papillomavirus. Each plaintiff experienced adverse symptoms following their Gardasil injections, but the onset of these symptoms occurred more than three years before they filed petitions for compensation under the National Vaccine Injury Compensation Program. The plaintiffs acknowledged to the special master that their petitions were untimely and sought equitable tolling of the Vaccine Act’s limitations period.The special master in the United States Court of Federal Claims found the petitions untimely and denied equitable tolling, resulting in dismissal of the claims. The plaintiffs then filed suit against Merck & Co. and Merck Sharp & Dohme LLC in the United States District Court for the Western District of North Carolina, which was handling multi-district litigation related to Gardasil. Merck moved to dismiss, arguing that the plaintiffs had failed to timely pursue their remedies under the Vaccine Act. The district court dismissed the complaints, holding that the proper forum for challenging the special master’s timeliness rulings was the Court of Federal Claims and the Federal Circuit, not the district court. The court also rejected a constitutional challenge to the process by which Gardasil was added to the Vaccine Injury Table.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s rulings. The Fourth Circuit held that the addition of Gardasil to the Vaccine Injury Table did not violate the Constitution. It further held that timely participation in the Vaccine Act compensation program is a prerequisite to bringing a tort suit, and that courts hearing vaccine-related tort suits may not reconsider the timeliness of a Vaccine Act petition once the special master has made a finding. The court affirmed the dismissal of the plaintiffs’ complaints. View "Needham v. Merck & Company Inc." on Justia Law

A tugboat owned by a private company collided with a bridge in Maryland, causing significant property damage. The tugboat owner, seeking to limit its financial liability for the accident, initiated a proceeding under the federal Exoneration and Limitation of Liability Act. This law allows vessel owners to cap their liability at the value of the vessel and its cargo, which in this case was much less than the total damage to the bridge. The State of Maryland, as the party suffering the loss, filed a claim in the limitation proceeding, seeking full compensation for the damage and contesting the applicability of the liability cap.The United States District Court for the Eastern District of Virginia found that the limitation action was not a suit against Maryland and did not seek damages from the state, but rather aimed to determine the tug owner’s liability and distribute the available fund among claimants. The district court denied Maryland’s motion to dismiss, which was based on the argument that sovereign immunity protected it from having its recovery limited by federal law. Maryland appealed this decision before the case proceeded further.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s denial of Maryland’s motion to dismiss. The Fourth Circuit held that sovereign immunity does not shield a state from the operation of the Limitation Act when the state voluntarily files a claim in such a proceeding. The court reasoned that the limitation action did not subject Maryland to coercive judicial process, as Maryland chose to participate as a claimant. The court affirmed the district court’s decision, allowing the limitation action to proceed and holding that Maryland’s sovereign immunity was not implicated under these circumstances. View "Jackson Creek Marine, LLC v. Maryland" on Justia Law

Malcolm Wiener purchased $16 million in permanent life insurance from AXA Equitable Life Insurance in the 1980s. In 2013, his policy lapsed after he failed to pay premiums on time. When Wiener sought reinstatement, AXA erroneously determined he had four serious medical conditions and reported these to the Medical Information Bureau (MIB), a consortium used by insurers to assess applicants. As a result, Wiener was unable to obtain comparable life insurance from other companies at standard rates; most rejected him outright, and two offered only limited coverage at much higher premiums. Wiener then brought a negligence claim against AXA, alleging that the false MIB report rendered him uninsurable.The case was tried in the United States District Court for the Western District of North Carolina. The jury found AXA liable for negligence and awarded Wiener $16 million in damages, reduced to $8 million for failure to mitigate. AXA moved for judgment as a matter of law under Rule 50(b), arguing that Wiener had not provided sufficient evidence to support the damages award. The district court initially dismissed the case for lack of subject matter jurisdiction, but the United States Court of Appeals for the Fourth Circuit reversed and remanded, instructing the district court to address the sufficiency of the evidence for damages. On remand, the district court found the evidence insufficient to support the jury’s damages calculation and reduced the award to $1 in nominal damages.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The court held that, although there was sufficient evidence that AXA’s negligence caused Wiener to become uninsurable at a reasonable cost, there was not enough evidence for the jury to calculate the amount of damages with reasonable certainty, particularly because Wiener failed to provide evidence of his expected remaining lifespan. As a result, only nominal damages were appropriate. View "Wiener v. AXA Equitable Life Insurance Co." on Justia Law

A Nigerian citizen, after returning to his home country from Venezuela, was recruited under false pretenses to work as a cook at a rural camp. Upon arrival, he discovered the camp was operated by a group known as the Unknown Gunmen, which the Nigerian government considers a terrorist organization. He was not allowed to leave, was forced to cook for the group’s leaders, and was eventually held without pay. After several months, he managed to escape and, fearing for his life due to repeated threats and attacks by the group, fled Nigeria. He traveled to Venezuela and then to the United States, where he sought asylum and withholding of removal, claiming a well-founded fear of persecution.An Immigration Judge found him removable for entering the United States without valid documents. The judge denied his applications for asylum and withholding of removal, concluding that by cooking for the Unknown Gunmen, he had provided “material support” to a terrorist organization, which barred him from relief. The judge also denied his claim for protection under the Convention Against Torture, finding insufficient evidence that he would likely be tortured with the acquiescence of a public official if returned to Nigeria. The Board of Immigration Appeals affirmed the Immigration Judge’s decision, agreeing that the material-support bar applied and that there was no de minimis or duress exception.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the petitioner’s forced cooking for the group did not constitute “material support” under the relevant statute, as his actions were not sufficiently substantial to help the organization accomplish its terrorist activities. The court granted the petition for review, vacated the Board’s order of removal, and remanded the case for further proceedings. View "Ozurumba v. Bondi" on Justia Law

A California resident sought to participate in Maryland’s cannabis business licensing process, which included a “social equity applicant” program designed to address historical inequities in the cannabis industry. To qualify as a social equity applicant, an individual needed to meet one of several criteria, such as having lived in a disproportionately impacted area, attending a public school in such an area, or attending for at least two years a Maryland institution of higher education where at least 40% of students are Pell Grant eligible. The plaintiff, who had never lived in Maryland, claimed eligibility based on her attendance at California State University, Long Beach, but was unable to meet the Maryland-specific higher education criterion. She was ultimately found ineligible for the first round of licensing.The plaintiff filed suit in the United States District Court for the District of Maryland, alleging that the Maryland licensing scheme discriminated against nonresidents in violation of the Dormant Commerce Clause and seeking declaratory and injunctive relief. She moved for a temporary restraining order and preliminary injunction to halt the licensing process. The district court denied her motion, finding she had not demonstrated a likelihood of success on the merits, and denied her request for an injunction pending appeal.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s denial of a preliminary injunction for abuse of discretion. The Fourth Circuit held that the challenged higher education criterion did not discriminate against non-Maryland residents, as it did not require Maryland residency and was equally available to out-of-state applicants who attended qualifying Maryland institutions. The court affirmed the district court’s denial of injunctive relief, concluding that the plaintiff failed to show a likelihood of success on the merits of her Dormant Commerce Clause claim. View "Jensen v. Maryland Cannabis Administration" on Justia Law

Tim Landholt was arrested in South Carolina after failing to pay child support, pursuant to a bench warrant issued by a family court judge. After Landholt appeared in court, paid a fine, and resolved the matter, the warrant was supposed to be recalled, but the clerk’s office failed to do so. Over five years later, Landholt was arrested again on the same, now-stale warrant and spent three days in jail. He then brought a negligence claim under South Carolina law against Jeanette McBride, in her official capacity as the Richland County Clerk of Court, alleging that the failure to recall the warrant caused his wrongful arrest and detention.Landholt initially filed suit in state court, asserting both federal and state-law claims. After procedural delays and amendments, the case was removed to the United States District Court for the District of South Carolina. The parties filed cross-motions for summary judgment. A magistrate judge recommended granting summary judgment to McBride on the negligence claim, finding her immune under the South Carolina Tort Claims Act, specifically S.C. Code § 15-78-60(2), which provides immunity for administrative actions or inactions of a judicial or quasi-judicial nature. The district court adopted this recommendation, holding that the immunity applied even to non-discretionary (ministerial) acts, and granted summary judgment to McBride.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s summary judgment ruling de novo. The Fourth Circuit held that, under South Carolina precedent, immunity under S.C. Code § 15-78-60(2) applies only to discretionary, not ministerial, acts. Because the record did not establish that the failure to recall the warrant was a discretionary act, the Fourth Circuit vacated the district court’s grant of summary judgment to McBride on this ground and remanded the case for further proceedings. View "Landholt v. Corley" on Justia Law

Three individuals who are lawful gun owners challenged a Fairfax County, Virginia ordinance that prohibits the possession, carrying, or transportation of firearms in certain locations. The two main restrictions at issue are a ban on firearms in county parks and a ban in public spaces where, or near where, a county-permitted event is taking place. The plaintiffs argued that both restrictions violate the Second Amendment, and that the events restriction is unconstitutionally vague under the Fourteenth Amendment.The United States District Court for the Eastern District of Virginia reviewed the case. It denied the plaintiffs’ motion for a preliminary injunction and later granted summary judgment to Fairfax County and its Chief of Police. The district court found that both restrictions were consistent with the Second Amendment’s sensitive places doctrine and that the events restriction was not unconstitutionally vague.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s summary judgment ruling de novo. The Fourth Circuit affirmed the district court’s decision regarding the parks restriction, holding that the ordinance is constitutional in at least some applications, specifically as applied to preschools located within county parks. The court relied on Supreme Court dicta indicating that bans on firearms in schools are presumptively constitutional. However, the Fourth Circuit vacated the district court’s judgment regarding the events restriction, concluding that the plaintiffs lacked Article III standing to challenge it because they did not demonstrate a credible threat of prosecution or a concrete intention to violate the restriction. The case was remanded with instructions to dismiss the claims related to the events restriction without prejudice. View "Lafave v. County of Fairfax" on Justia Law

A professor was hired by a university in 2014 as a tenure-track Assistant Professor with a starting salary at the lowest end of the pay scale for her department. Over the next several years, she was denied promotions, demoted to at-will status, and claims she was paid less than male colleagues. She alleges that these actions were motivated by sex discrimination and retaliation for her complaints, including derogatory statements allegedly made by a department chair about her gender and sexual orientation. She filed charges with the Equal Employment Opportunity Commission (EEOC) and, after leaving the university, brought suit alleging violations of federal and state anti-discrimination laws.The United States District Court for the District of Maryland granted summary judgment to the university and individual defendants on all claims. The court found that her Title VII claims regarding the 2019 and 2020 promotion denials were procedurally barred—one as untimely and the other for failure to exhaust administrative remedies. The court also found that the evidence did not support her claims of sex discrimination, wage discrimination, or retaliation, concluding that the university’s stated reasons for its actions were legitimate and not pretextual.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. It affirmed the district court’s ruling that the Title VII claims related to the 2019 and 2020 promotion denials were procedurally barred. However, it reversed the grant of summary judgment on the remaining claims, holding that genuine disputes of material fact existed regarding sex discrimination in the 2016 promotion denial, retaliation, and wage discrimination. The court also held that the procedural bars of Title VII did not apply to the plaintiff’s claims under Title IX, Section 1983, or Maryland state law for the 2019 and 2020 promotion denials. The case was remanded for further proceedings on those claims. View "Hollis v. Morgan State University" on Justia Law

The defendant was indicted for aiding and abetting possession with intent to distribute 40 grams or more of a mixture containing fentanyl. He entered into a written plea agreement with the government, in which he agreed to plead guilty. In exchange, the government stipulated to certain sentencing factors, including the drug weight used to calculate the base offense level and that the defendant was a manager or supervisor of criminal activity involving five or more participants. The agreement reserved the government’s right to present evidence, make a sentencing recommendation, and clarified that it was not promising to seek a downward departure.The United States District Court for the Eastern District of North Carolina accepted the guilty plea. At sentencing, the government moved for both an upward and a downward departure or variance from the Guidelines range, citing the defendant’s criminal history and role in the offense. The district court applied both departures and sentenced the defendant to 234 months’ imprisonment. The defendant did not object at sentencing but later appealed, arguing that the government breached the plea agreement by failing to request a below-Guidelines sentence and by making arguments inconsistent with the stipulations regarding drug weight and his role.The United States Court of Appeals for the Fourth Circuit reviewed the case for plain error, as the defendant had not raised these arguments below. The court held that the plea agreement did not require the government to seek a below-Guidelines sentence or prohibit it from moving for both upward and downward departures. The court also found that, while some of the government’s arguments at sentencing created tension with the stipulations, the agreement’s language did not clearly prohibit such arguments. Therefore, the court concluded there was no plain error and affirmed the district court’s judgment. View "US v. Wilson" on Justia Law