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

Gilbert Devon Melvin, after serving over 20 years in federal prison for drug and firearm offenses, was released in March 2021 and began a five-year term of supervised release. In August 2023, Melvin's mental health deteriorated, and he was arrested for trespassing. At the revocation hearing, the district court initially agreed to terminate Melvin's supervised release and enter a time-served sentence. However, Melvin had an outburst in court, which led the court to conclude that he posed a danger to the public and his probation officers. As a result, the court withdrew its initial agreement to a time-served sentence and instead decided to maintain Melvin's supervised release with an additional mental health condition.The district court's decision was based on Melvin's behavior during the revocation hearing. The court initially agreed to terminate Melvin's supervised release and enter a time-served sentence. However, after Melvin's outburst, the court concluded that he posed a danger to the public and his probation officers. The court then withdrew its initial agreement and decided to maintain Melvin's supervised release with an additional mental health condition.On appeal to the United States Court of Appeals for the Fourth Circuit, Melvin argued that the district court lacked the authority to withdraw or modify the time-served sentence it had initially agreed to impose. The Fourth Circuit disagreed, affirming the district court's decision. The court held that a sentence is not imposed until it has been unequivocally pronounced during the sentencing hearing, and there has been a formal break in the proceedings from which to logically and reasonably conclude that sentencing had finished. The court found that the district court's initial acceptance of a time-served sentence was tentative and that the court had the authority to modify that sentence when Melvin addressed the bench only moments later, during the course of the same sentencing hearing. View "US v. Melvin" on Justia Law

Jake's Fireworks Inc., a large importer and distributor of consumer fireworks, sought judicial review of several warning notices it received from the U.S. Consumer Product Safety Commission. The notices were issued after the Commission's staff sampled fireworks imported by Jake's Fireworks and found that about one-third of those samples indicated that the fireworks were dangerously overloaded with explosive material, rendering them "banned hazardous substances" under the agency’s regulations. The Commission's Compliance Office accordingly sent Jake's Fireworks several “Notice[s] of Non-Compliance,” requesting that the distribution of the sampled lots not take place and that the existing inventory be destroyed.Jake's Fireworks first sued the Commission in federal court in 2019, seeking injunctive and declaratory relief from the agency’s enforcement of its fireworks regulations via the Notices. The district court dismissed the lawsuit, determining that the Notices did not constitute final agency actions under the Administrative Procedure Act because they did not consummate the Commission’s decisionmaking process. After the dismissal of its first lawsuit, Jake's Fireworks requested an informal hearing with the Compliance Office to contest the Notices. The Compliance Office declined to hold a hearing or to revisit its findings, and Jake's Fireworks filed a second lawsuit, which was also dismissed by the district court on the same grounds as the first lawsuit.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court held that the Notices did not constitute final agency actions under the Administrative Procedure Act. The court reasoned that the Compliance Office’s Notices of Noncompliance did not mark the consummation of the agency’s decisionmaking process, as it is the Commission itself, not its Compliance Office, that makes final determinations on whether goods are banned hazardous substances. The court also found that the language of the Notices confirmed that they conveyed preliminary findings and advice from agency staff rather than a final determination from the Commission itself. View "Jake's Fireworks Inc. v. United States Consumer Product Safety Commission" on Justia Law

The case involves the 68th Street Site Work Group (the "Group"), a collective of entities that had settled their liability for environmental cleanup costs with the Environmental Protection Agency (EPA). The Group sought to recoup some of these costs by filing a contribution action under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) against several non-performing and non-settling entities, alleging that each defendant incurred arranger liability by arranging for the disposal of waste at the Superfund Alternative Site.The District Court for the District of Maryland dismissed the claims against each of these defendants, concluding that the Group failed to allege that the defendants took intentional steps with the specific intent to dispose of hazardous waste and knew that the disposed-of waste was hazardous. The Group then sought to amend its complaint against seven of the defendants, but the district court denied the motion, standing by its prior interpretation of CERCLA’s arranger-liability provision.The United States Court of Appeals for the Fourth Circuit vacated the district court's decision and remanded the case for further proceedings. The appellate court held that under CERCLA’s arranger-liability provision, a defendant is liable whenever they intentionally arrange for the disposal of a substance and the substance is hazardous. The court concluded that the district court erred by requiring the Group to allege that the defendants knew the disposed-of waste was hazardous. View "68th Street Site Work Group v. Alban Tractor Co., Incorporated" on Justia Law

The case involves an incarcerated individual, Thomas Alexander, who alleged that two correctional officers violated his Fourth and Eighth Amendment rights by forcibly removing a contraband phone from his rectum in a prison shower. The officers, however, claimed that they found the phone in Alexander's pocket and used no more force than necessary. The incident was partially captured on video, but the footage did not conclusively resolve the dispute over where the phone was located.The United States District Court for the Eastern District of North Carolina granted summary judgment in favor of the officers. The court relied on the video footage, concluding that it discredited Alexander's version of events to such an extent that no reasonable jury could have believed him.On appeal, the United States Court of Appeals for the Fourth Circuit vacated the lower court's decision and remanded the case for further proceedings. The appellate court found that the video did not clearly depict what happened in the shower room and did not blatantly contradict Alexander's account. Therefore, the court held that the district court should have credited Alexander's version of events when considering the officers' summary judgment motion. The appellate court also concluded that, viewing the evidence in the light most favorable to Alexander, a reasonable jury could find that the officers violated Alexander's Fourth and Eighth Amendment rights. View "Alexander v. Connor" on Justia Law

The case involves United Therapeutics Corporation (UTC), a biotechnology company, and the Commissioner of Internal Revenue. The dispute centers on the interpretation of a tax provision that coordinates two tax credits: the research credit and the orphan drug credit. The Commissioner claimed that UTC disregarded one of the provision’s two commands, improperly reducing its tax liability by over a million dollars. UTC argued that the relevant half of the coordination provision lost effect in 1989 and has been moribund since.The United States Tax Court disagreed with UTC's argument. The court interpreted the statute’s terms by reference to their ordinary meaning, giving effect to the full coordination provision. The court rejected UTC's argument that changes to the tax law since its enactment rendered part of the coordination provision ineffective. The court also disagreed with UTC's interpretation of two regulations it relied on for support.The United States Court of Appeals for the Fourth Circuit affirmed the tax court's decision. The appellate court agreed with the tax court's interpretation of the coordination provision according to its ordinary meaning. The court also found that the tax court correctly rejected UTC's arguments based on the interpretation of predecessor statutes and regulations. The court concluded that the tax court correctly resolved the case in favor of the Commissioner. View "United Therapeutics Corporation v. Commissioner of Internal Revenue" on Justia Law

The case involves Quentin Lowell Horsley, who was convicted of conspiring to distribute, and possession with intent to distribute, cocaine, methamphetamine, heroin, and cocaine base, as well as three counts of distributing cocaine. The evidence against Horsley included witness testimony, text messages, evidence of controlled buys, and drugs and cash seized during searches. Horsley challenged the admission of several items of evidence, including a cellphone seized without a warrant and the search of a car tied to him. He also challenged the testimony of an officer who interpreted text messages and the handling of the verdict form by the district court.The United States District Court for the Western District of Virginia denied Horsley's motion to suppress the cellphone and the fruits of the car search. The court also allowed the officer's testimony and handled the verdict form in a way that Horsley contested.On appeal, the United States Court of Appeals for the Fourth Circuit held that the district court erred in failing to suppress the evidence from the cellphone seized at the time of Horsley's arrest, but given the weight of the evidence against Horsley, the error was harmless. The court also held that the search of the car and its contents was proper, and that the district court did not plainly err in allowing the officer's testimony. The court found no error in connection with the district court’s handling of the verdict form. Therefore, the court affirmed the conviction. View "US v. Horsley" on Justia Law

The case revolves around the murder of Sallie Copeland Evans by her grandson, Isaiah Evans Ceasar, a lance corporal in the United States Marine Corps. Sallie's son, Mitchell Garnet Evans, acting as the executor of her estate, filed a wrongful death claim against the United States under the Federal Tort Claims Act, alleging that the Marine Corps was negligent in its handling of Ceasar, who had previously expressed suicidal intentions and violent tendencies. The district court dismissed the claim for lack of subject-matter jurisdiction.The United States Court of Appeals for the Fourth Circuit found that the district court had erred in dismissing the claim under Federal Rule of Civil Procedure 12(b)(1) because the jurisdictional question and the merits of the case were inextricably intertwined. However, the court also found that Evans failed to state a wrongful death claim under North Carolina law. The court concluded that even if the Marine Corps had a duty to Sallie, her murder was not foreseeable under the circumstances. Therefore, while the district court's decision was procedurally incorrect, it was substantively proper. The court affirmed the district court's decision on alternative grounds and dismissed the case under Rule 12(b)(6). View "Evans v. US" on Justia Law

The case involves Gabrielle Barbour, who alleges that she was denied employment as a Special Agent with the Drug Enforcement Administration (DEA) in retaliation for her participation in a class action lawsuit against the Federal Bureau of Investigation (FBI) for workplace discrimination. The district court dismissed Barbour's complaint under Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim upon which relief can be granted.The district court found that Barbour failed to establish a causal link between her protected activity (the lawsuit against the FBI) and the adverse employment action (non-selection by the DEA). The court also found that Barbour's complaint affirmatively pleaded legitimate nondiscriminatory reasons for her non-selection, which were not rebutted by Barbour.On appeal, the United States Court of Appeals for the Fourth Circuit reversed the district court's decision. The appellate court found that the district court erred in its analysis of the complaint's allegations and in requiring Barbour to rebut the DEA's proffered reasons for her non-selection at the motion to dismiss stage. The appellate court concluded that the complaint's allegations were sufficient to support a plausible inference of a causal link between Barbour's lawsuit against the FBI and the DEA's subsequent refusal to hire her. The case was remanded for further proceedings. View "Barbour v. Garland" on Justia Law

Family Health Physical Medicine, LLC, an Ohio-based company, filed a lawsuit against Pulse8, LLC and Pulse8, Inc., Maryland-based companies. The dispute arose when Pulse8 sent a fax to Family Health inviting it to a free webinar on medical coding technology, a product that Pulse8 sells. Family Health claimed that this fax was an unsolicited advertisement and thus violated the federal Telephone Consumer Protection Act (TCPA). Pulse8 argued that the fax did not qualify as an advertisement under the TCPA because the webinar was free.The United States District Court for the District of Maryland granted Pulse8's motion to dismiss the case, agreeing with Pulse8's argument that the fax did not qualify as an advertisement under the TCPA. Family Health appealed this decision to the United States Court of Appeals for the Fourth Circuit.The Fourth Circuit Court disagreed with the lower court's decision. The court found that the fax did have a commercial component, as it was sent by a company that sells a product related to the subject of the webinar. The court concluded that the fax was being used to market Pulse8's product. The court also found that Family Health had plausibly alleged that accepting the invitation to the webinar would trigger future advertising. However, the court rejected Family Health's argument that the fax was an advertisement because it offered a chance to win a gift card in exchange for completing a survey. The court reversed the district court's judgment and remanded the case for further proceedings. View "Family Health Physical Medicine, LLC v. Pulse8, LLC" on Justia Law

Adams Outdoor Advertising Limited Partnership, a company that constructs, manages, designs, and repairs billboards, clashed with Beaufort County over the county's billboard policy. The county sought to phase out billboards within its borders by prohibiting the construction of new billboards and restricting structural repairs of old ones. Adams was issued a criminal citation for performing structural repairs on two old billboards without seeking authorization. Additionally, Adams filed eleven applications requesting permits to construct new commercial billboards with digital displays, each of which was denied. Adams sought to challenge Beaufort County’s local ordinance regulating billboards, along with several other local sign regulations.The district court dismissed all of Adams’s claims with prejudice. The claims related to the criminal citation were dismissed under the Younger abstention doctrine, and those related to the permit denials were dismissed for lack of jurisdiction. Adams appealed the decision.The United States Court of Appeals for the Fourth Circuit agreed with each of the district court’s dismissal determinations. However, it noted that the claims dismissed for lack of jurisdiction should have been dismissed without prejudice. The court remanded those claims with the instruction that their dismissal be amended to dismissal without prejudice. The court also found that Adams did not have standing to challenge certain provisions of the county's sign ordinance, as it had not demonstrated that it had been adversely affected by those provisions. The court concluded that the case belongs in state court due to the state's interest in land-use planning and development, the ongoing state court proceedings, and the jurisdictional hurdles faced by Adams. View "Adams Outdoor Advertising Limited Partnership v. Beaufort County" on Justia Law