Every decision we've summarized from United States Court of Appeals for the Fourth Circuit.
The Fourth Circuit affirmed Keionta Shawn Hagens's conviction and sentence, ruling that any potential error in calculating his Sentencing Guidelines range was harmless. The court held that the district court would have imposed the same 156-month sentence regardless of the error and that the sentence remained substantively reasonable under 18 U.S.C. § 3553(a).
The Fourth Circuit affirmed the district court's dismissal of a pro se borrower's complaint but modified the order to dismiss without prejudice. The court held that dismissals based on the Rooker-Feldman doctrine, which addresses subject matter jurisdiction defects, must be without prejudice because a court lacking jurisdiction cannot adjudicate claims on the merits.
The Fourth Circuit affirmed the dismissal of a pro se civil action but modified the ruling to reflect that the dismissal for lack of subject matter jurisdiction must be without prejudice. The court held that a court lacking jurisdiction has no power to adjudicate a claim on the merits, requiring the dismissal to allow for potential refiling if jurisdiction can be established.
The Fourth Circuit affirmed the denial of Joseph Bourabah's motions to substitute counsel and withdraw his guilty plea, finding no abuse of discretion in the district court's handling of the requests. The court upheld a 100-month sentence for a severe cyberstalking campaign, ruling that the district court properly applied upward departures for the extreme psychological injury inflicted on the victims.
The Fourth Circuit affirmed the denial of qualified immunity for a police officer who shot and killed a fleeing, unarmed teenager who made no threatening movements with a weapon. The court held that under clearly established law, an officer cannot use deadly force against a suspect who is armed but poses no immediate threat to safety.
The Fourth Circuit affirmed the dismissal of a Title VII claim because the plaintiff failed to file a formal EEO complaint within the mandatory 15-day window. The court held that this statutory deadline is a non-waivable claim-processing rule that bars federal litigation when missed.
The Fourth Circuit affirmed the dismissal of a former employee's claims for unpaid profit-sharing, ruling that oral agreements contradicting a written contract's 'Entire Agreement' clause are unenforceable. The court held that the written contract's explicit statement of 'full compensation' barred quasi-contractual theories like promissory estoppel and unjust enrichment.
The Fourth Circuit affirmed the district court's denial of a pro se litigant's motion for sanctions, ruling that the motion failed to satisfy the mandatory safe harbor provision and was untimely. The court also upheld the rejection of a motion for reconsideration because the appellant failed to identify errors or present new evidence.
The Fourth Circuit dismissed Robert Allen McClinton's appeal from his denied § 2255 motion because his notice of appeal was filed well past the 60-day deadline. The court rejected McClinton's claim that the prison mailbox rule applied, finding he failed to deliver the notice to prison officials within the statutory period.
The Fourth Circuit denied Michael R. White's petition for a writ of mandamus, ruling the case moot because the district court had already issued a final order on his motion. The court found no live controversy remained to justify an appellate directive forcing the district court to act.