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

Nathaniel Powell pled guilty in 2016 to conspiracy to manufacture, distribute, and possess with intent to distribute more than 100 grams of heroin. The United States Probation Office recommended a two-level sentence enhancement under the United States Sentencing Guidelines for maintaining a premises for drug distribution, based on information from Powell’s co-defendant, Valerie Wilson. Wilson claimed she bought drugs from Powell at his residence and witnessed heroin processing there. Powell’s attorney, Lawrence Woodward, objected to the enhancement, questioning Wilson’s credibility and the sufficiency of the evidence.The United States District Court for the Eastern District of Virginia overruled the objection and adopted the presentence report, sentencing Powell to 300 months in prison. Powell later filed a pro se motion under 28 U.S.C. § 2255 to vacate his sentence, claiming ineffective assistance of counsel for failing to investigate potentially exculpatory evidence, including a lease agreement showing someone else leased the premises during part of the relevant time. The district court dismissed most claims but held a hearing on this issue. Woodward testified he did not receive the lease and believed attacking Wilson’s credibility was the best strategy. The district court dismissed Powell’s claim, finding Woodward’s performance was not deficient and the lease would not have changed the outcome.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that Woodward’s performance was not constitutionally deficient, as his strategy to attack Wilson’s credibility was reasonable. The court also found no prejudice, as the district court indicated it would have applied the same sentence even without the enhancement. Thus, the Fourth Circuit affirmed the district court’s denial of Powell’s § 2255 motion. View "United States v. Powell" on Justia Law

The appellants, Jose Joya Parada, Oscar Armando Sorto Romero, Milton Portillo Rodriguez, and Juan Carlos Sandoval Rodriguez, were charged in 2018 with various racketeering offenses related to their involvement with the MS-13 gang. During jury selection, the government used peremptory strikes on several Black venirepersons, including Jurors 217 and 138. The appellants raised Batson challenges to these strikes, which the district court rejected. The trial proceeded, and during jury deliberations, Juror 9 tested positive for COVID-19. Over the appellants' objections, the district court decided to proceed with an eleven-member jury. The jury found some appellants guilty on all charges and others guilty on some charges.The United States District Court for the District of Maryland denied the appellants' Batson challenges and decided to proceed with an eleven-member jury after Juror 9 tested positive for COVID-19. The appellants were subsequently found guilty of various charges. The appellants appealed, arguing that the district court erred in rejecting their Batson challenges and in proceeding with an eleven-member jury.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the district court did not clearly err in rejecting the Batson challenges, as the government provided race-neutral reasons for the peremptory strikes, and the district court found these reasons credible. The court also held that the district court did not abuse its discretion in proceeding with an eleven-member jury, as it thoroughly considered all alternatives and found good cause to excuse Juror 9. The Fourth Circuit affirmed the district court's judgment. View "US v. Parada" on Justia Law

IonQ, Inc., a public company developing quantum computers, experienced a significant drop in its stock price from $7.86 on May 2, 2022, to $4.34 on May 12, 2022. A group of investors claimed this decline was due to the Scorpion Report, published on May 3, 2022, which alleged that IonQ had been committing widespread fraud regarding the value of its company. The investors filed a securities fraud lawsuit against IonQ, asserting that the report revealed the truth about IonQ's misrepresentations, causing their financial losses.The United States District Court for the District of Maryland dismissed the investors' first amended complaint for failing to state a claim, particularly for not adequately pleading loss causation. The court found that the Scorpion Report, authored by a short-seller with financial incentives, was not a reliable source of information. The court also noted that the investors failed to show that the report or IonQ's response revealed any new, truthful information to the market. The investors then sought reconsideration and leave to file a second amended complaint, which the district court denied, again citing the failure to plead loss causation.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that the Scorpion Report, given its disclaimers and the financial motivations of its authors, could not plausibly be seen as revealing the truth about IonQ's alleged fraud. Additionally, IonQ's response to the report did not concede any truth to the allegations but rather dismissed them as inaccurate. Therefore, the investors failed to establish the necessary element of loss causation, making their proposed amendments futile. The court affirmed the district court's judgment. View "Defeo v. IonQ, Inc." on Justia Law

M.B., a Pakistani woman, was forced into labor by her in-laws, Zahida Aman and her sons, Nauman and Rehan Chaudhri, after marrying another son, Salman. Upon arriving in Virginia, M.B. was isolated, had her documents confiscated, and was coerced into performing extensive household chores under threats of deportation and physical abuse. The abuse escalated over the years, including physical violence and psychological manipulation, until M.B. was eventually confined to a laundry room and later a garage annex. M.B. managed to escape in 2016 with the help of her brother and law enforcement.The United States District Court for the Eastern District of Virginia convicted the defendants of conspiracy to commit forced labor, forced labor, and document servitude. The defendants appealed, arguing that the forced labor statute did not apply to familial relationships, that the government improperly struck jurors based on race, that prejudicial evidence was admitted, and that the jury was improperly instructed.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the forced labor statute, 18 U.S.C. § 1589, applies broadly and includes familial relationships. The court found no Batson violation in the jury selection process, since the government's peremptory strikes were based on age, marital status, and childlessness, not race. The court also ruled that the evidence of abuse after the forced labor ended was intrinsic to the crime and necessary to complete the story. Finally, the court determined that the jury instructions were adequate, despite the defendants' objections.The Fourth Circuit affirmed the convictions, concluding that the statute applied to the defendants' conduct and that the district court did not err in its rulings during the trial. View "U.S. v. Chaudhri" on Justia Law

In 2011, Winston Sylvester Oliver II and his co-defendant, Warren Brown, were convicted of conspiracy to commit Hobbs Act robbery, attempted Hobbs Act robbery, and use of a firearm during these crimes. Oliver's firearm convictions were later vacated, necessitating resentencing for the remaining convictions. At his resentencing, Oliver argued that his Fifth and Sixth Amendment rights were violated when the court allowed Brown to invoke his Fifth Amendment right against self-incrimination due to his pending appeal. Oliver also contended that his sentence was procedurally and substantively unreasonable.The United States District Court for the Eastern District of Virginia initially sentenced Oliver to 630 months in prison. After his firearm convictions were vacated, the court resentenced him to 610 months. On appeal, the Fourth Circuit vacated his remaining firearm conviction and remanded for resentencing. At the second resentencing, Oliver's motion to recuse the entire bench of the Eastern District of Virginia was denied. The district court allowed Brown to invoke his Fifth Amendment right, excluded unauthenticated letters allegedly written by Brown, and calculated Oliver's Guidelines range, ultimately sentencing him to 480 months in prison.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the district court did not abuse its discretion in allowing Brown to invoke his Fifth Amendment right, as his testimony could have had adverse consequences due to his pending appeal. The court also found that the district court did not err in applying sentencing enhancements for Oliver's leadership role, obstruction of justice, and firearm discharge. The court concluded that the 480-month sentence was substantively reasonable, considering Oliver's extensive criminal history and the impact on the victims. The Fourth Circuit affirmed the district court's judgment. View "United States v. Oliver" on Justia Law

A fire broke out in an apartment building in Surry County, North Carolina, leading to the deaths of four occupants due to smoke inhalation. The 911 dispatcher advised the caller not to open the window, which was believed to fuel the fire. The estates of the deceased sued Surry County and the dispatchers for negligence. The Travelers Indemnity Company, which insured Surry County, settled the claims for $9 million and sought contribution from American Alternative Insurance Corporation (AAIC), which also had issued a policy to Surry County.The United States District Court for the Middle District of North Carolina ruled that AAIC's policy provided primary but not excess coverage for the 911 call center employees, ordering AAIC to pay $1 million to Travelers. Both parties appealed the decision.The United States Court of Appeals for the Fourth Circuit reviewed the case and concluded that AAIC's policy did not cover the 911 call center employees. The court determined that both the primary and excess coverage provisions of AAIC's policy were limited to employees of Surry County Emergency Services and did not extend to the 911 call center. Consequently, the court affirmed the district court's ruling regarding the excess coverage but reversed the ruling on the primary coverage, concluding that AAIC was not liable for any part of the settlement. The case was remanded for the entry of judgment in favor of AAIC. View "The Travelers Indemnity Co. v. American Alternative Insurance Corp." on Justia Law

In September 2020, inmate Garfield Holley, proceeding pro se, sued several officers at Wallens Ridge State Prison under Section 1983. Holley alleged that the officers transported him to a dental appointment in a dog cage and subjected him to subsequent mistreatment. He claimed that this treatment was in retaliation for filing a grievance about a delayed medical procedure. Holley, who has asthma, described being chained in a padlocked dog cage in near-freezing temperatures for over six hours, leading to pneumonia and delayed medical care. He also alleged a pattern of retaliatory treatment against prisoners who complained about their conditions.The United States District Court for the Western District of Virginia dismissed Holley's complaint without prejudice for failing to pay the filing fee, citing the three-strikes rule under the Prison Litigation Reform Act. The court found that Holley had not adequately alleged imminent danger of serious physical injury, as the incidents described occurred approximately two years before the complaint was filed. Holley's motion for reconsideration was denied, and he timely appealed.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The court concluded that Holley had adequately pleaded imminent danger of serious physical injury, noting the specificity of his allegations and the ongoing pattern of retaliatory treatment against prisoners at Wallens Ridge State Prison. The court found that Holley's allegations were sufficient to meet the imminent-danger exception to the three-strikes rule. Consequently, the Fourth Circuit reversed the district court's decision and remanded the case for further proceedings. View "Holley v. Combs" on Justia Law

Anthony Williams was convicted of two drug offenses in 1999 and has been on supervised release since 2020. In March 2023, a woman Williams had been living with contacted the police, alleging that Williams had assaulted her by strangling and slapping her. The complainant provided photos of her injuries and reported symptoms consistent with strangulation. A police officer and a probation officer corroborated her account through interviews and evidence collection. The district court held a revocation hearing more than eight months later, during which the complainant was not present. The government introduced her out-of-court statements and other evidence, which Williams objected to as hearsay.The United States District Court for the Western District of North Carolina admitted the statements, finding that the government showed good cause for the complainant's absence and that the statements were reliable. The court found Williams had committed the violations and sentenced him to 24 months of imprisonment followed by 12 months of supervised release. Williams appealed, arguing that the district court erred in admitting the hearsay evidence.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the district court did not abuse its discretion in admitting the complainant's statements. The court found that the government made sufficient efforts to contact the complainant, establishing good cause for her absence. Additionally, the court determined that the complainant's statements were reliable, supported by corroborating evidence and consistent recounting. The balancing test weighed in favor of admissibility, and the district court's judgment was affirmed. View "United States v. Williams" on Justia Law

Jacob Doe, a student at the University of North Carolina at Chapel Hill (UNC-CH), was found responsible for two allegations of sexual misconduct and subsequently expelled from the university system. Doe sued the university and several employees, claiming violations of his Fourteenth Amendment due process rights, Title IX, and various state laws. The district court largely denied the defendants' motions to dismiss, allowing Doe’s federal and most state law claims to proceed.The defendants appealed to the United States Court of Appeals for the Fourth Circuit. The appellate court found that the district court erred in rejecting the defendants' claims of sovereign and qualified immunity. The court held that the UNC institutions were entitled to sovereign immunity, reversing the district court’s decision to allow Doe’s claims against them. Additionally, the court determined that the individual university employees were entitled to qualified immunity regarding Doe’s due process claims for damages, as the right to cross-examination in university disciplinary proceedings was not clearly established at the time.However, the appellate court affirmed the district court’s decision to allow Doe to seek prospective injunctive relief for the alleged due process violations. The court recognized that Doe had adequately alleged a liberty interest due to the permanent expulsion and the ongoing harm from the erroneous disciplinary record. The court declined to exercise pendent appellate jurisdiction over the district court’s denial of the motion to dismiss Doe’s Title IX claim against UNC-CH, dismissing that portion of the appeal for lack of jurisdiction.In conclusion, the Fourth Circuit affirmed in part, reversed in part, and dismissed in part the district court’s rulings, allowing Doe’s claims for prospective injunctive relief to proceed while dismissing his claims for damages against the UNC institutions and individual employees. View "Doe v. The University of North Carolina System" on Justia Law

John Koontz received two letters from SN Servicing Corporation (SNSC) regarding his residential mortgage loan. Koontz had previously filed for Chapter 7 bankruptcy, and his debts were discharged. The letters from SNSC stated that they were attempting to collect a debt and mentioned late fees assessed to Koontz's loan account. Koontz filed a lawsuit claiming that SNSC's actions violated the Fair Debt Collection Practices Act (FDCPA) and a similar West Virginia law.The United States District Court for the Northern District of West Virginia dismissed Koontz's complaint. The court concluded that Koontz was no longer a "consumer" with a "debt" under the FDCPA due to his Chapter 7 bankruptcy discharge. The court also found that the letters did not constitute attempts to collect a consumer debt and that Koontz failed to adequately plead a "false, deceptive, or misleading representation" under the FDCPA. Consequently, the court dismissed both the federal and state claims.The United States Court of Appeals for the Fourth Circuit reviewed the case and reversed the district court's decision in part. The appellate court held that Koontz remained a "consumer" with a "debt" under the FDCPA despite his Chapter 7 discharge, as the mortgage lien remained an enforceable obligation. The court also determined that the letters from SNSC constituted attempts to collect a debt. However, the court agreed with the district court that Koontz failed to state a claim under 15 U.S.C. § 1692e but found that he adequately stated a claim under 15 U.S.C. § 1692f. The appellate court reversed the dismissal of the state-law claim for the same reasons. The case was remanded for further proceedings. View "Koontz v. SN Servicing Corporation" on Justia Law