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

Defendant, a medical doctor, pleaded guilty to multiple charges under Section 841 for prescribing oxycodone and other controlled substances outside the usual course of professional practice and without a legitimate medical need. After Defendant was sentenced, the Supreme Court issued its decision in Ruan v. United States, 142 S. Ct. 2370 (2022), which held that the statutory knowing-or-intentional mens rea applies not only to the distribution-related elements of the crime but also to the question of authorization. Accordingly, if a defendant charged under Section 841 “produces evidence that he or she was authorized to dispense controlled substances, the Government must prove beyond a reasonable doubt that the defendant knew that he or she was acting in an unauthorized manner, or intended to do so.” Defendant contends his plea was not valid because the district court did not inform him that, if he went to trial, the government would be required to prove beyond a reasonable doubt that Defendant subjectively knew or intended that his conduct was unauthorized, as required by Ruan.   The Fourth Circuit affirmed. The court explained that even if the district court’s explanation of the charges alone did not properly reflect the mens rea required by Ruan, the language of the indictment does reflect Ruan’s holding. The Fourth Circuit has made it clear that when explaining the nature of the charges, a district court may rely on the defendant’s sworn statement that he has read the indictment and discussed it with his attorney. View "US v. Jong Kim" on Justia Law

CSX Transportation, Inc. (“CSXT”) issued furlough notices to employees at its facility in Huntington, West Virginia. Shortly thereafter, over 65 employees submitted forms requesting to take medical leave based on claimed minor soft-tissue injuries sustained while off duty. The forms were similar in content; all were signed by one of two chiropractors; and all called for medical leave of eight weeks or more.Under CSXT’s benefit plans, if an employee were furloughed while on medical leave, the employee would receive health and welfare benefits for up to two years. Otherwise, a furloughed employee would receive such benefits for only four months. Suspecting benefits fraud, CSXT charged the employees with violating its workplace rule against dishonesty and, following hearings, terminated their employment.Plaintiffs, a group of 58 terminated employees, claimed violations of their rights under federal and state law, including violations of the Employee Retirement Income Security Act of 1974 (“ERISA”), the Rehabilitation Act of 1973, the West Virginia Human Rights Act, and the Family and Medical Leave Act of 1993 (“FMLA”). The district court granted summary judgment to CSXT on all claims and Plaintiffs appealed.The Fourth Circuit affirmed, finding that Employer's belief that Plaintiff employees committed benefits fraud was a legitimate and nondiscriminatory reason for terminating Plaintiffs and that Plaintiffs couldn't prove pretext or retaliation. View "Justin Adkins v. CSX Transportation, Inc." on Justia Law

Advantage Veterans Services of Walterboro, LLC (“AVSW”) and United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied Industrial and Service Workers International, Local 7898 (the “Union”) dispute the legitimacy of an arbitration award, which stemmed from the discharge of a union-represented employee. The appeal centers on the provisions of the parties’ collective bargaining agreement (the “CBA”). The CBA contains a number of provisions that govern the relationship between AVSW, the Union and the Union’s members who work at AVSW.   The Fourth Circuit reversed the district court’s order affirming the arbitration award and vacated the underlying award. The court explained that its deferential standard for determining whether an arbitrator erred substantively is rooted in the contractual nature of arbitration. If the parties agree to resolve disputes by arbitration, the court defers to the determinations made in the process the parties agreed to. Here, however, the CBA limits the arbitrator’s power. It requires that the arbitrator make the reasonable basis determination. And it premises the legitimacy of any arbitration award on the arbitrator’s compliance with that directive. It even provides that any award that is contrary to the CBA in any way—which includes that directive—“shall be deemed not to draw its essence from the [CBA] and shall be vacated.” The court explained that given this language, it would be paradoxical to use a highly deferential standard of review, which, once again, is rooted in principles of contract, to look past the arbitrator’s failure to follow contractually agreed-upon procedural rules for the arbitration. View "Advantage Veterans Services of Walterboro LLC v. United Steel Paper and Forestry Rubber" on Justia Law

Both Risk Based Security, Inc. (“RBS”) and Synopsys, Inc., identify vulnerabilities in the source code of software and share information about those vulnerabilities so they can be corrected before nefarious individuals exploit them. After RBS accused Synopsys of engaging in unlawful conduct related to the content of RBS’ vulnerability database, Synopsys filed this declaratory judgment action. In relevant part, Synopsys sought a judicial declaration that it had not misappropriated RBS’ trade secrets. On the merits, the district court granted Synopsys’ motion for summary judgment on that claim after concluding that RBS had not come forward with evidence showing that any of its alleged trade secrets satisfied the statutory definition of that term. RBS appealed by challenging the district court’s merits determination of trade secrets as well as its decisions denying RBS’ motion to dismiss the case as moot, excluding testimony from two of RBS’ expert witnesses, and denying its motion for partial summary judgment as to some of its trade secret claims.   The Fourth Circuit affirmed. The court explained that the district court properly concluded that RBS failed to put forward admissible evidence showing that the seventy-five alleged trade secrets had independent economic value. Absent proof sufficient to satisfy that part of the statutory definition of a “trade secret,” RBS could not prevail in a misappropriation-of-trade-secrets claim, and the district court properly granted summary judgment to Synopsys. Given this holding, the court wrote, it need not consider RBS’ additional argument that the district court erred in denying its motion for partial summary judgment. View "Synopsys, Inc. v. Risk Based Security, Inc." on Justia Law

Not long after getting a new boss at the Priority Automotive Honda dealership, Plaintiffs effectively resigned from their jobs. They then sued, alleging racial discrimination—claiming that the new boss and the company fostered a hostile work environment and demoted them because they are Black—along with various state torts. Plaintiffs lost at summary judgment and appealed.   The Fourth Circuit largely affirmed but remand their state-law conversion claims for further proceedings. First, the court explained that a reasonable person might conclude that the employee’s alleged “white side” was race-based harassment. But the statement, on its own, does not create a severe or pervasive hostile work environment. Next, the court held that, since Plaintiff failed to support a reasonable inference of unlawful intentional discrimination, the magistrate judge rightfully rejected his disparate-treatment claim. Further, the court held that no reasonable jury could find that Defendants’ alleged conduct “rises to the level of ‘outrageous and extreme’ as the term has been interpreted and applied” in North Carolina. The court reasoned that courts do not weigh the evidence when ruling on a motion for summary judgment. So when both parties raise facts sufficient for a reasonable jury to find for them at trial, the claim must survive. But discrimination claims need more than neutral facts, an adverse action, and speculation about discriminatory motives to make it past this stage. As such, on the current record, a reasonable juror could find for Plaintiffs on their conversion claim. View "Kenneth Robinson v. Priority Automotive Huntersville, Inc." on Justia Law

After Defendant pleaded guilty pursuant to a plea agreement to possession of child pornography, in violation of 18 U.S.C. Section 2252A(a)(5)(B) and (b)(2), the district court sentenced him to 120 months imprisonment, the bottom of the advisory guidelines range. That range was determined, in part, by the district court’s conclusion that Defendant was subject to the mandatory minimum sentence of 120 months imprisonment that is required by Section 2252A(b)(2) when a defendant has a prior conviction for a qualifying sex offense. The district court found that Defendant’s prior conviction under Maryland law for a sexual offense in the third degree qualified as a predicate for the Section 2252A(b)(2) enhancement. Defendant then sought a review of the district court’s ruling that his prior Maryland conviction qualified as a predicate conviction under Section 2252A(b)(2), which triggered the 120-month mandatory minimum sentence.   The Fourth Circuit dismissed Defendant’s appeal. The court agreed with the government that Defendant waived his right to appeal that issue in his plea agreement. The court explained the indictment’s allegation that a 120-month minimum sentence applied because of Defendant’s prior Maryland conviction and the limitations that Defendant’s plea agreement placed on his right to challenge that allegation, as well as Defendant’s broad waiver of his right to appeal any determination that the district court made on that issue, preclude the present appeal. And this is confirmed by Defendant’s express waiver of the district court’s determination of the applicable sentencing guidelines range. View "US v. Bruce Sturtz" on Justia Law

Appellees filed a voluntary petition under Chapter 13 of the Bankruptcy Code. Appellees calculated their disposable income using Official Form 122C-2. As the form instructs, Appellees entered the relevant “National and Local Standards” for their monthly costs for food, clothing, utilities, out-of-pocket healthcare, and vehicles. The bankruptcy trustee objected to Appellees’ proposed Chapter 13 plan. The trustee acknowledged the Cooks followed the instructions on Official Form 122C-2. The trustee maintained, however, that the form was wrong because the Bankruptcy Code only allowed Appellees to claim the relevant Local Standards amount for their “Mortgage/Rent” deduction ($1,098) rather than their actual monthly payment ($2,233.34). The trustee asked the bankruptcy court to certify an appeal directly to the Fourth Circuit under 28 U.S.C. Section 158(d)(2)(A).   The Fourth Circuit affirmed. The court explained disposable income, in turn, means “current monthly income received by the debtor” minus “amounts reasonably necessary to be expended.” Clause Three says the Appellees’ “average monthly payments on account of ” that mortgage “shall be calculated” based on the amounts “contractually due to secured creditors,” that is, what Appellees owe under their mortgage agreement. Performing that calculation, the Appellees reached an average monthly payment of $2,233.34. Then, Clause One tells Appellees to “reduce” their “current monthly income” “by the amount determined under” Clause Three. Thus, Appellees subtracted $2,233.34 (and other uncontested amounts) from their current monthly income to reach a disposable income of $253.27. Accordingly, the court concluded Appellees were entitled to use their average monthly mortgage payments when calculating their disposable income. View "Joseph Bledsoe, III v. Cheryl Cook" on Justia Law

Defendant appealed the district court’s denial of his habeas petition under 28 U.S.C. Section 2254. He claimed that his guilty plea wasn’t voluntary because he didn’t know that Maryland’s sentencing guidelines were merely advisory. But a Maryland court denied his request for postconviction relief, finding that he understood the terms of his plea agreement, including his maximum sentencing exposure. The district court held that the Maryland court’s decision denying Defendant postconviction relief was reasonable.   The Fourth Circuit affirmed. The court explained that AEDPA forecloses habeas relief unless the PCR court’s decision was “based on” an erroneous finding, 28 U.S.C. Section 2254(d)(2), and Defendant doesn’t make that showing. Further subsection (d)(1) corrects only the most “extreme malfunctions.” Here, the PCR court’s decision wasn’t “contrary to” or an “unreasonable application of” Supreme Court precedent because it didn’t “arrive at a result different from” a Supreme Court case with “materially indistinguishable” facts. Nor was the PCR court’s decision an “unreasonable application” of principles announced by the Supreme Court. Here, the PCR court concluded that Defendant couldn’t reasonably believe that the guidelines were mandatory or that he was entitled to a sentence between 30 and 51 years. That’s because the plea court correctly advised him that each of his charges carried a possible sentence of 30 years. So this isn’t a case in which Defendant was clueless about the endpoints of his sentencing exposure. View "Calvin Currica v. Richard Miller" on Justia Law

Appellant, a Maryland Capitol Police officer, appealed the district court’s denial of qualified immunity on several First and Fourth Amendment claims brought by picketers whom he arrested on the sidewalk outside the Maryland State House. Appellant arrested the picketers after they disobeyed his orders to back up off the sidewalk and protest instead from an adjoining square.   The Fourth Circuit reversed and remanded. The court held a reasonable officer in Appellant’s position could have believed that the orders constituted lawful time, place, or manner restrictions on the picketers’ First Amendment rights. Therefore, Appellant is entitled to qualified immunity. The court explained no law, clearly established or otherwise, required Appellant to wait for an imminent traffic accident. Preventive measures to promote public safety are a basic contribution of government. Appellant’s assessment of safety risks and attempts to mitigate them were informed by common sense and the facts on the ground, not animus or conjecture. It was at least reasonable for him to believe that his orders promoted a substantial governmental interest. View "Clayton Hulbert v. Brian Pope" on Justia Law

Defendant was convicted of illegally reentering the United States after an aggravated felony conviction. He challenged his conviction on numerous fronts, claiming vindictive prosecution and violations of his constitutional rights to a speedy trial, due process, and freedom from unreasonable searches and seizures.   The Fourth Circuit affirmed. The court held that Defendant failed to demonstrate that the presumption of vindictiveness applies. The presumption of regularity that attends a prosecutor’s pretrial charging decision, therefore, remains in place. Further, the court wrote that Defendant’s constitutional right to a speedy trial on the aggravated reentry charge attached when the government obtained the indictment charging him with that offense, the second indictment in this case. Because Defendant does not argue that the time between the second indictment and his trial—just short of 6 months—is presumptively prejudicial, he has not met the threshold requirement for evaluating the remaining Barker factors. Finally, the court held that Defendant has not shown that officers arrested and fingerprinted him for an investigative purpose; therefore, the court affirmed the district court’s denial of his second suppression motion. View "US v. Francisco Villa" on Justia Law