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

The case involves Zackary Ellis Sanders, who was convicted of multiple offenses related to the illegal production, receipt, and possession of child pornography. Sanders appealed his conviction, arguing that the court erred in denying motions to suppress evidence seized pursuant to a search warrant for his residence, in admitting statements he made to FBI agents during the search of his residence, in excluding evidence of the victims’ voluntary participation in the production of child pornography, and in giving certain jury instructions.The court rejected each of Sanders’s appellate contentions and affirmed the judgment of the district court. The court found that the search warrant was valid and that Sanders was not entitled to a hearing to probe the truthfulness of an affidavit used to support the search warrant. The court also found that Sanders’s statements to the FBI agents were not in violation of the Fifth Amendment. The court ruled that evidence of the victims’ voluntary participation in the production of child pornography was irrelevant and properly excluded. Finally, the court found no error in the jury instructions given by the district court. View "United States v. Sanders" on Justia Law

The case involves Raymond Sefakor Yao Azumah, a Ghanaian national who was admitted to the United States as a lawful permanent resident in 2010. After a trip to Ghana in 2014, Azumah was deemed inadmissible due to an intervening embezzlement conviction. Despite this, the government paroled Azumah into the country and initiated removal proceedings against him. These proceedings were later dismissed, and Azumah applied for citizenship. However, the United States Citizenship and Immigration Services denied his application, arguing that Azumah was statutorily ineligible because he was not “lawfully admitted for permanent residence” upon his return to the United States in 2014. The district court affirmed this denial.The United States Court of Appeals for the Fourth Circuit disagreed with the lower court's decision. The court noted that Azumah was indeed “lawfully admitted for permanent residence” at all relevant times, including 2010, 2014, and when he sought citizenship, because he had the status of a legal permanent resident of the United States. The court did not interpret the agency regulation to impose upon Azumah the additional burden of showing that he was “lawfully admitted” rather than paroled when he returned to the United States in 2014. Therefore, the court vacated the judgment of the district court and remanded for further proceedings consistent with its opinion. View "Azumah v. United States Citizenship and Immigration Services" on Justia Law

The case involves Johnnie Simmons, Jr., who filed a pro se action against Hampton Roads Regional Jail corrections officers R. Whitaker, Benjamin Hull, and Derrick Brown. Simmons claimed that during an incident on February 8, 2019, Officer Whitaker choked him, which was caught on videotape. The district court granted summary judgment to Officers Hull and Brown, finding that their conduct did not violate the Eighth Amendment. Simmons appealed the decision.The district court had dismissed Officer Whitaker from the case due to lack of service. Officers Hull and Brown filed motions for summary judgment, arguing that the video footage and multiple officer affidavits established that Simmons could not prevail on his § 1983 bystander liability claims. The district court granted summary judgment for the defendants, crediting the video and the officers’ version of the event.The United States Court of Appeals for the Fourth Circuit found that the district court erred in its summary judgment analysis. The court held that the video evidence did not blatantly contradict Simmons's account, and the district court improperly ignored material admissible evidence in Simmons’s affidavit. The court also found that the district court applied the wrong legal standard, using the Eighth Amendment standard instead of the Fourteenth Amendment standard applicable to pre-trial detainees. The court affirmed in part, reversed in part, and remanded in part the district court's decision. View "Simmons v. Whitaker" on Justia Law

The case involves an American citizen and her noncitizen husband who sued two U.S. Citizenship and Immigration Services (USCIS) officials, alleging that USCIS unreasonably delayed adjudicating a waiver application the husband submitted two years prior. The plaintiffs argued that the Administrative Procedure Act (APA) and the Mandamus Act granted subject-matter jurisdiction over their claims. The district court dismissed their claims, concluding that language in the Immigration and Nationality Act (INA) that denies courts jurisdiction over suits based on agency “decisions or actions” also bars suits over agency inaction.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision, but for different reasons. The appellate court found that the district court erred in interpreting the INA's jurisdictional bar to include agency inaction. However, the court concluded that no statute or regulation requires USCIS to adjudicate the husband’s waiver application, and therefore, the district court lacked jurisdiction over the plaintiffs' claims. The court noted that while the delay in adjudication was stressful for the plaintiffs, their complaint should be addressed to the political branches, as the court lacked jurisdiction to order the relief sought. View "Lovo v. Miller" on Justia Law

The case revolves around the Metropolitan Washington Airports Authority (the Authority), an entity jointly created by Virginia and the District of Columbia to manage the area's two airports. The Authority disputed the Virginia Department of Labor and Industry's (the Department) power to enforce its workplace safety laws against the Authority. The Department had levied a monetary penalty against the Authority following an accident that resulted in an employee's injury. The Authority contested the Department's power to enforce these penalties, arguing that it was not subject to Virginia workplace safety regulations due to its status as an interstate compact entity.The Department's adjudicator found that the Authority was subject to Virginia workplace safety regulations, a decision adopted by the Department's Commissioner. The Authority then sued the Commissioner in federal court seeking injunctive and declaratory relief. The district court ruled in favor of the Authority, reasoning that Virginia had surrendered its ability to exercise unilateral regulatory authority over the Authority's facilities when it created the Authority.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court agreed with the Authority that by jointly creating the Authority with the District, Virginia relinquished its control over the Authority except as otherwise provided in the Compact. The court rejected the Department's argument that the Compact expressly reserves its power to enforce Virginia’s workplace safety regulations against the Authority. The court also dismissed the Department's contention that it can enforce its workplace safety laws against the Authority because nothing in the Compact preempts Virginia law. View "Metropolitan Washington Airports Authority v. Pan" on Justia Law

In this case, the defendant, Guy Bowman, was convicted of distributing methamphetamine and conspiring to do so. Law enforcement officers executed a search warrant on Bowman's property, where they found evidence of drug distribution. Bowman was later located and arrested at a hotel, where he made incriminating statements to officers. He was subsequently indicted on two counts related to drug distribution.Prior to his trial, Bowman filed a motion to suppress his initial statements to the officers, arguing that they were made before he was read his Miranda rights. The district court denied the motion without holding an evidentiary hearing, determining that Bowman had not been interrogated before making the statements in question. Bowman also objected to the jury selection process, arguing that the district court had refused to ask his proposed questions and had provided him with less information about the jurors than was provided to the government.The United States Court of Appeals for the Fourth Circuit affirmed Bowman's convictions. The court found that the district court had not erred in denying Bowman's motion to suppress without an evidentiary hearing, as there were no material factual disputes warranting a hearing. The court also found that the district court had not violated Bowman's Sixth Amendment rights during jury selection, as it had asked sufficient questions to uncover bias and had not denied Bowman his peremptory strikes. Finally, the court found that the district court had not abused its discretion in refusing to play the entirety of Bowman's jail calls with a co-defendant during closing arguments. View "United States v. Bowman" on Justia Law

A group of plaintiffs sued multiple defendants, including white nationalists, white supremacists, and neo-Nazis, for their roles in the violent "Unite the Right" rally in Charlottesville, Virginia, in 2017. The plaintiffs alleged that the defendants conspired to commit racially motivated violence. A jury awarded the plaintiffs over $26 million in damages, including a historic $24 million in punitive damages. However, the district court reduced the punitive damages to $350,000, applying Virginia's punitive damages cap across all plaintiffs.The defendants appealed, challenging the district court's decision to hold them jointly and severally liable for the compensatory damages award. The plaintiffs cross-appealed, challenging the district court's application of Virginia's punitive damages cap.The United States Court of Appeals for the Fourth Circuit affirmed the district court's imposition of joint-and-several liability for the compensatory damages. However, the court held that Virginia's punitive damages cap applies on a per-plaintiff basis, not across all plaintiffs. Therefore, the court vacated the district court's ruling on the punitive damages cap and remanded the case with instructions to apply the cap accordingly. View "Sines v. Hill" on Justia Law

Willie Slocum, Jr. appealed the denial of his motion to correct, vacate, or set aside his convictions and sentences based on ineffective assistance of counsel. Slocum was indicted on two counts of drug conspiracy under 21 U.S.C. § 846, but argued that the two charged conspiracies were actually one. He claimed that he was punished twice for the same conspiracy in violation of the Fifth Amendment’s Double Jeopardy Clause, and that his trial counsel rendered ineffective assistance by failing to raise a double jeopardy challenge before the trial court. The district court denied his motion without ordering a response from the government or holding an evidentiary hearing.The United States Court of Appeals for the Fourth Circuit found that the district court erred in its decision. The appellate court determined that Slocum was indeed punished twice for a single conspiracy in violation of the Double Jeopardy Clause. However, the court noted that it was unclear whether trial counsel had a strategic reason for failing to raise a double jeopardy challenge. The court concluded that Slocum was entitled to an evidentiary hearing under 28 U.S.C. § 2255(b) where the performance of his trial counsel could be assessed. Therefore, the court vacated the district court’s denial of Slocum’s § 2255 motion and remanded for an evidentiary hearing on Slocum’s ineffective assistance claim. View "United States v. Slocum" on Justia Law

The case involves a dispute over the award of black lung benefits to the surviving wife of the late Bruce E. Goode, who worked for American Energy as a coal miner and suffered from a severe chronic obstructive pulmonary disability. American Energy disputed the cause of his impairment, arguing that it was due to his long-term cigarette smoking, not his coal mine employment. An administrative law judge (ALJ) found that Mr. Goode’s disability arose from his coal mine employment and awarded black lung benefits. The Benefits Review Board affirmed the award.American Energy appealed, arguing that the ALJ applied an incorrect legal standard. The company contended that the Black Lung Benefits Act and its implementing regulations require a miner to prove that coal dust caused the lung disease or made it worse. American Energy argued that the ALJ reversed the burden of proof by finding that the company had not proven why Mr. Goode’s lung disease was not at least partially due to coal dust exposure.The United States Court of Appeals for the Fourth Circuit agreed that the ALJ applied the wrong legal standard in determining that Mr. Goode had legal pneumoconiosis. However, the court noted that the ALJ also concluded that Mr. Goode’s clinical pneumoconiosis entitled him to benefits. The court granted American Energy’s petition and vacated and remanded the Board’s order for further proceedings. View "American Energy, LLC v. Director, Office of Workers' Compensation Programs" on Justia Law

The case involves Douglas Damon Whitley, who was convicted of Hobbs Act robbery, federal carjacking, and a firearm offense in connection with his theft of a Peloton delivery van and its contents. Whitley was sentenced to concurrent 84-month prison terms for the robbery and carjacking convictions. On appeal, Whitley argued that his convictions and sentences for both offenses violated the Double Jeopardy Clause, as he believed Hobbs Act robbery to be a lesser included offense of carjacking. He also contended that there was insufficient evidence of the specific intent needed to convict him of federal carjacking.The case was first heard in the United States District Court for the Eastern District of Virginia. Whitley and his co-defendant, Kindal Robinson, pleaded not guilty and proceeded to a joint jury trial. The jury found them both guilty of all charges. Whitley then filed a motion for judgment of acquittal, arguing that his convictions for both Hobbs Act robbery and federal carjacking violated the Double Jeopardy Clause. He also argued that the government failed to produce sufficient evidence of his specific intent to cause death or serious bodily harm, an essential element of federal carjacking. The district court denied Whitley’s motion, determining that Hobbs Act robbery is not a lesser included offense of carjacking and that a reasonable jury could have found that Whitley had the specific intent to kill or seriously injure the van driver.The case was then reviewed by the United States Court of Appeals for the Fourth Circuit. The court disagreed with Whitley's arguments and affirmed the district court’s judgment. The court found that the jurisdictional elements of Hobbs Act robbery and federal carjacking differed, meaning that the two offenses were not the same under the Blockburger test. The court also found that there was sufficient evidence to support the jury’s finding that Whitley had the specific intent to cause death or serious bodily harm, thus rejecting Whitley's sufficiency challenge. View "US v. Whitley" on Justia Law