4th Cir.

United States Court of Appeals for the Fourth Circuit

Every decision we've summarized from United States Court of Appeals for the Fourth Circuit.

Apr 20 2026
24-4171 Per Curiam

UNITED STATES OF AMERICA v. ARMAND SAQUAN SUFYAN LEWIS-LANGSTON

The Fourth Circuit affirmed a 200-month sentence for a firearms conviction, ruling that while the district court erred by determining the 'different occasions' of prior felonies without a jury, the mistake was harmless. The court held that the defendant would have waived his right to a jury and admitted the prior offenses occurred on separate occasions had he been properly advised during his guilty plea.

Criminal Firearms Mandatory Minimum
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Apr 20 2026
25-1776 Per Curiam

Park v. Shin

The United States Court of Appeals for the Fourth Circuit affirmed a district court order denying attorney's fees and damages under the Fair Labor Standards Act. The appellate court found no reversible error in the lower court's refusal to enforce a settlement agreement provision.

Civil Labor
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Apr 20 2026
24-6490 Panel Decision

Spivey v. Breckon

The Fourth Circuit affirmed the dismissal of a federal inmate's Bivens action alleging inadequate medical care and excessive force, holding that no implied private right of action exists for these claims against federal prison officials. The court ruled that the plaintiff's allegations presented a new context distinct from Supreme Court precedent and that special factors counseled against extending Bivens remedies in this domain.

Civil Civil Rights - PLRA / Prisoner Civil Rights - Section 1983 Eighth Amendment - Cruel & Unusual
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Apr 17 2026
25-4233 2-1

UNITED STATES OF AMERICA v. NATHANIEL MARTIN

The Fourth Circuit reversed a district court's denial of a motion to suppress, holding that a Forest Service officer unreasonably extended a traffic stop to investigate unrelated criminal activity. The court found the officer abandoned the stop's original mission immediately, violating the Fourth Amendment under the standard set in Rodriguez v. United States.

Criminal Firearms
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Apr 17 2026
25-1659 Panel Decision

Eichin v. Ethicon Endo-Surgery, LLC

The Fourth Circuit affirmed summary judgment in a products liability case, holding that the district court correctly applied the strict good cause standard of Federal Rule of Civil Procedure 16(b)(4) to deny a late motion to amend a scheduling order. Because the plaintiff failed to demonstrate the requisite diligence in securing expert testimony, his claims were properly dismissed as fatal to his case.

Civil Summary Judgment Tort / Personal Injury
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Apr 17 2026
25-1385 Panel Decision

Kelly Milligan v. Merrill Lynch, Pierce, Fenner & Smith, Incorporated; Bank of America Corporation

The Fourth Circuit affirmed a district court ruling that a financial firm's long-term contingent incentive awards do not qualify as an employee pension benefit plan under ERISA. The court held that the WealthChoice Award program constitutes an exempt bonus plan because it is designed to incentivize retention and productivity rather than systematically defer income for retirement.

Civil Environmental (Civil) ERISA / Employee Benefits Summary Judgment
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