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

A flight attendant on a Delta Air Lines flight observed a 13-year-old passenger crying during turbulence and believed the man accompanying her was behaving inappropriately. Concluding that the man was sexually assaulting and trafficking the child, the attendant reported her concerns to the flight captain, who relayed the information to a station manager. The manager contacted local police, who detained and questioned the man, Nicholas Cupp, and his daughter upon landing. After investigation, police determined Cupp was the child’s father and released him without charges. Cupp later filed suit, alleging the report was false and reckless, and claimed significant emotional distress and harm to his relationship with his daughter.The case was initially filed in the Circuit Court of Newport News, Virginia, but was removed to the United States District Court for the Eastern District of Virginia based on diversity jurisdiction. The defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), arguing immunity under Virginia Code § 63.2-1512 for good-faith reports of suspected child abuse. The district court granted the motion, finding the immunity statute applicable even though the report was made to law enforcement rather than directly to social services, and concluded that Cupp had not sufficiently alleged bad faith or malicious intent.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed whether a nonmandatory reporter who makes a good-faith complaint of suspected child abuse to law enforcement, rather than directly to social services, is entitled to immunity under Virginia Code § 63.2-1512. Finding no controlling Virginia precedent, the Fourth Circuit certified this question to the Supreme Court of Virginia, as its answer will determine whether the district court’s dismissal should be affirmed or reversed. View "Cupp v. Delta Air Lines, Inc." on Justia Law

The defendant was charged with one count of wire fraud after orchestrating a scheme in which he falsely presented himself as a wealthy and experienced investor to at least ten individuals, promising guaranteed returns on investments in the stock market and a cannabis store. Instead of investing the funds, he used the money for personal expenses. To maintain the appearance of legitimacy, he provided promissory notes and sent updates to victims about their supposed investments. When victims requested their money, he made excuses and, at times, threatened them.The United States District Court for the Western District of North Carolina accepted the defendant’s guilty plea to wire fraud. At sentencing, the court applied a two-level enhancement for abuse of trust under U.S.S.G. § 3B1.3, based on evidence that the defendant had assumed a position of trust with his victims by posing as a financial advisor and investor. The court also imposed two discretionary conditions of supervised release, requiring participation in substance abuse testing and treatment, and transitional support services. The defendant objected to the abuse-of-trust enhancement but did not object to the supervised release conditions.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s factual findings for clear error and its legal interpretations de novo. The Fourth Circuit held that the abuse-of-trust enhancement was properly applied because the defendant provided sufficient indicia to his victims that he held a position of private trust, even though he was an imposter. The court also held that the challenged supervised release conditions did not constitute an improper delegation of judicial authority to the Probation Officer, relying on its precedent. The judgment of the district court was affirmed. View "United States v. Brewer" on Justia Law

A North Carolina police officer, Clarence Belton, was shot multiple times by fellow officer Heather Loveridge during the execution of a search warrant. The incident, which resulted in serious injuries to Belton and ended his law enforcement career, was captured on video and body camera footage. Belton sued Loveridge and the City of Charlotte, alleging excessive force and other claims. During the litigation, both parties moved to seal the video exhibits related to the shooting, and the district court granted these motions, placing the footage under seal.After the district court denied Loveridge’s motion for summary judgment, which was later vacated and remanded by the United States Court of Appeals for the Fourth Circuit, a local television station, WBTV, sought to intervene in the case to unseal the video footage. Belton supported WBTV’s motion, but Loveridge opposed it, arguing that unsealing would jeopardize her right to a fair trial. The United States District Court for the Western District of North Carolina denied WBTV’s motion to intervene, citing lack of jurisdiction due to the pending appeal, and also denied the motion to unseal, finding no right of access under the common law or the First Amendment and concluding that Loveridge’s fair trial rights outweighed any public interest.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s denial of WBTV’s motion to intervene, agreeing that the district court lacked jurisdiction at that stage. However, the appellate court treated WBTV’s appeal regarding the sealing order as a petition for a writ of mandamus. The Fourth Circuit held that the district court’s order sealing the video exhibits violated the First Amendment right of access to judicial records. The court vacated the sealing order and remanded with instructions to unseal the video footage, finding that Loveridge had not met her burden to justify continued sealing. View "Gray Media Group, Inc. v. Loveridge" on Justia Law

Two former employees of a large technology company, along with a real estate developer and related individuals and entities, were alleged to have engaged in a kickback scheme involving real estate transactions in Northern Virginia. The employees, responsible for managing real estate deals for the company, allegedly steered contracts to the developer’s firm in exchange for secret payments funneled through a network of trusts and entities. The scheme purportedly inflated the company’s costs for both leasing and purchasing properties, with millions of dollars in kickbacks distributed among the participants. The company discovered the scheme after a whistleblower report, conducted an internal investigation, and reported the matter to federal authorities.The United States District Court for the Eastern District of Virginia granted summary judgment in favor of the defendants on several claims, including those under the Racketeer Influenced and Corrupt Organizations (RICO) Act, fraud, unjust enrichment, and conversion, and partially on a civil conspiracy claim. The district court found that the company failed to establish the existence of a RICO enterprise, did not show injury to its business or property, and that equitable claims were precluded by the availability of legal remedies or the existence of contracts. The court also ruled that an attorney defendant could not be liable for conspiracy with his clients.The United States Court of Appeals for the Fourth Circuit reversed the district court’s summary judgment. The appellate court held that genuine disputes of material fact existed regarding the existence of a RICO enterprise, whether the company suffered financial harm, and the viability of the fraud, unjust enrichment, conversion, and civil conspiracy claims. The court clarified that the company was entitled to pursue legal and equitable remedies in the alternative and that the attorney’s potential liability for conspiracy could not be resolved on summary judgment. The case was remanded for further proceedings. View "Amazon.com, Inc. v. WDC Holdings LLC" on Justia Law

Brandon Glen Jackson was indicted in Arizona for a state-law felony related to possessing a short-barreled rifle. While released on bail and with the felony charge still pending, Jackson lawfully acquired a handgun and traveled from Arizona to Maryland, bringing the handgun with him. In Maryland, he was arrested for carrying the gun without a permit. Upon discovering his pending Arizona felony indictment, federal prosecutors charged him under 18 U.S.C. § 922(n), which prohibits individuals under felony indictment from transporting firearms in interstate commerce.The United States District Court for the District of Maryland denied Jackson’s motion to dismiss the indictment on Second Amendment grounds. Jackson then entered a conditional guilty plea, preserving his right to appeal the constitutional issue. He was sentenced to time served, and subsequently appealed the district court’s denial of his motion to dismiss.The United States Court of Appeals for the Fourth Circuit reviewed the case and applied the Supreme Court’s “text-and-history” standard from New York State Rifle & Pistol Association v. Bruen, 597 U.S. 1 (2022). The Fourth Circuit held that Jackson’s conduct—transporting a handgun across state lines while under felony indictment—was presumptively protected by the Second Amendment. However, the court found that the government met its burden to show that § 922(n), as applied to Jackson, was consistent with the nation’s historical tradition of firearm regulation. The court relied on historical surety laws and the tradition of disarming dangerous persons, as well as its own precedent in United States v. Hunt, 123 F.4th 697 (4th Cir. 2024), to conclude that temporary disarmament of those under felony indictment is constitutionally permissible. The Fourth Circuit affirmed the district court’s judgment. View "US v. Jackson" on Justia Law

Two nonprofit organizations challenged the constitutionality of a North Carolina statute that made it a felony for individuals with felony convictions to vote before their rights were restored, regardless of whether those individuals mistakenly believed they were eligible. The statute, originally enacted in the late 19th century, was shown to have been motivated by racial animus and to have a disproportionate impact on Black North Carolinians. In 2023, the North Carolina General Assembly amended the statute to add a requirement that a person must “know” their rights had not been restored to be prosecuted, effective January 1, 2024.The United States District Court for the Middle District of North Carolina considered the plaintiffs’ claims under the Equal Protection and Due Process Clauses. After the statute was amended, a magistrate judge recommended dismissal for lack of standing, but the district court found the case was not moot because prosecutions under the old statute for pre-2024 conduct could still occur, potentially chilling voter participation and requiring the plaintiffs to divert resources. The district court granted summary judgment for the plaintiffs, holding the statute unconstitutional and enjoining its enforcement.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the case was not moot because prosecutions under the prior version of the statute could still proceed, and the plaintiffs retained a concrete interest in the outcome. On the merits, the Fourth Circuit affirmed the district court’s ruling that the challenged statute violated the Equal Protection Clause. The court found that the statute’s original enactment and reenactment were motivated by racial discrimination, and that subsequent legislative changes did not “cleanse” the statute of its discriminatory origins, as the statute itself had not been substantively reenacted or amended in a way that would warrant a presumption of legislative good faith. The court affirmed the district court’s judgment. View "A. Philip Randolph Institute v. North Carolina State Board of Elections" on Justia Law

Two Maryland residents challenged a state law that allows Maryland to take custody of property deemed “abandoned” after a period of owner inactivity, such as unclaimed bank accounts or stocks. Before 2004, owners who reclaimed such property from the state received both the principal and any interest accrued while the property was in state custody. After a 2004 amendment, claimants could only recover the principal, not the interest. The lead plaintiff, who had not yet filed a claim with the state, argued that Maryland’s failure to pay interest constituted an unconstitutional taking under the Fifth Amendment and sought a declaratory judgment and injunction requiring the state to pay just compensation, including interest, when he eventually filed a claim.The United States District Court for the District of Maryland denied the Comptroller’s motion to dismiss, finding that the plaintiff had standing, the claim was ripe, and the complaint stated a facial challenge to the statute. The court also held that the claim was not barred by Eleventh Amendment sovereign immunity, reasoning that the relief sought was prospective and thus fell within the Ex parte Young exception, which allows federal courts to enjoin ongoing violations of federal law by state officials.The United States Court of Appeals for the Fourth Circuit reviewed only the sovereign immunity issue. The Fourth Circuit held that the Eleventh Amendment bars federal courts from ordering Maryland to pay interest that accrued before any federal court judgment, as such relief is retroactive and constitutes a claim for money damages. However, the court held that to the extent the plaintiff seeks prospective relief—specifically, interest that would accrue after a federal court judgment—such a claim may proceed under the Ex parte Young doctrine. The court affirmed in part, reversed in part, and remanded for further proceedings. View "Albert v. Lierman" on Justia Law

After the 2025 Presidential Inauguration, the federal government initiated mass terminations of thousands of probationary employees across numerous federal agencies. These employees, who were subject to one- or two-year probationary periods, were dismissed without the advance notice typically required for reductions in force (RIFs). The affected states alleged that the lack of notice hindered their ability to provide rapid response services to the terminated employees, resulting in increased unemployment claims and diversion of state resources.Nineteen states and the District of Columbia filed suit in the United States District Court for the District of Maryland, arguing that the terminations violated statutory RIF procedures, including the requirement to provide 60 days’ notice to state governments. The district court granted a temporary restraining order and later a preliminary injunction, ordering the federal government to reinstate the terminated employees and prohibiting further terminations without compliance with all applicable laws and notice requirements. The injunction was later stayed by the United States Court of Appeals for the Fourth Circuit pending appeal.The United States Court of Appeals for the Fourth Circuit reviewed the case and held that the plaintiff states lacked Article III standing to bring the suit. The court found that the states did not suffer a cognizable and redressable injury, as the direct harm was to the terminated employees, not the states. The court also determined that the relief sought by the states—indefinite reinstatement and broad injunctive relief—was not tailored to their alleged informational injury and primarily served to vindicate the rights of non-party employees. As a result, the Fourth Circuit vacated the district court’s judgment and remanded with instructions to dismiss the action. View "State of Maryland v. USDA" on Justia Law

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