4th Circuit Case Commentaries

Premeditation May Be Inferred From Seconds of Reflection Between Shots When Applying the § 2K2.1(c)(1)(A) Attempted First-Degree Murder Cross-Reference

Date: Sep 18, 2026

Premeditation May Be Inferred From Seconds of Reflection Between Shots When Applying the § 2K2.1(c)(1)(A) Attempted First-Degree Murder Cross-Reference 1. Introduction United States v. Angelo Reid,...

Fourth Circuit: Long-Present, Uninspected Entrants Are Detained Under § 1226(a), Not § 1225(b)(2)(A), and Must Receive Bond Hearings

Date: Sep 15, 2026

Fourth Circuit: Long-Present, Uninspected Entrants Are Detained Under § 1226(a), Not § 1225(b)(2)(A), and Must Receive Bond Hearings I. Introduction In a published decision issued September 10, 2026,...

Fourth Circuit: Long-Present, Uninspected Entrants Are Detained Under 8 U.S.C. § 1226(a) and Must Receive Bond Hearings; “Seeking Admission” Narrows § 1225(b)(2)(A)

Date: Sep 14, 2026

Fourth Circuit: Long-Present, Uninspected Entrants Are Detained Under 8 U.S.C. § 1226(a) and Must Receive Bond Hearings; “Seeking Admission” Narrows § 1225(b)(2)(A) I. Introduction In Oscar Lopez...

Fourth Circuit: Shackling During Labor/Immediate Postpartum Without Security Justification Violates the Eighth Amendment; Postpartum MOUD Denial Can Constitute Deliberate Indifference and Support ADA/RA Claims

Date: Sep 14, 2026

Fourth Circuit: Shackling During Labor/Immediate Postpartum Without Security Justification Violates the Eighth Amendment; Postpartum MOUD Denial Can Constitute Deliberate Indifference and Support...

Automatic Deletion Under Neutral Retention Policies Does Not Warrant a Criminal Spoliation Adverse-Inference Instruction Absent Prior Knowledge of Relevance and Willful Loss

Date: Sep 12, 2026

Automatic Deletion Under Neutral Retention Policies Does Not Warrant a Criminal Spoliation Adverse-Inference Instruction Absent Prior Knowledge of Relevance and Willful Loss I. Introduction In United...

Striking a Cooperating Witness’s Testimony as an Adequate Brady Cure; Conditional Intent and Two‑Step Digital Warrants Sustain VICAR Convictions

Date: Sep 12, 2026

Striking a Cooperating Witness’s Testimony as an Adeate Brady Cure; Conditional Intent and Two‑Step Digital Warrants Sustain VICAR Convictions 1. Introduction In United States v. Jairo Gustavo...

Curative Instruction by Striking a Witness’s Testimony Can Cure Mid‑Trial Brady Prejudice; Digital Warrants May Permit Broad Review Where Seizure Is Cabined to Enumerated Crimes

Date: Sep 12, 2026

Curative Instruction by Striking a Witness’s Testimony Can Cure Mid‑Trial Brady Prejudice; Digital Warrants May Permit Broad Review Where Seizure Is Cabined to Enumerated Crimes Case: United States...

Striking a Witness’s Testimony as a Sufficient Remedy for a Mid‑Trial Brady Disclosure (and Upholding Broad-Search/Narrow-Seizure Digital Warrants)

Date: Sep 12, 2026

Striking a Witness’s Testimony as a Sufficient Remedy for a Mid‑Trial Brady Disclosure (and Upholding Broad-Search/Narrow-Seizure Digital Warrants) 1. Introduction In United States v. Melvin Canales...

Fourth Circuit: Objective Recklessness Establishes Willful FBAR Liability, and Aggregate Willful FBAR Penalties Are Not “Grossly Disproportional” When Far Below the Statutory Maximum

Date: Sep 5, 2026

Fourth Circuit: Objective Recklessness Establishes Willful FBAR Liability, and Aggregate Willful FBAR Penalties Are Not “Grossly Disproportional” When Far Below the Statutory Maximum 1. Introduction...

Title VII Protects Individually Discerned “Body-as-a-Temple” Vaccine Objections; Mixed Motives and “Personal Decision” Language Do Not Defeat a Prima Facie Case at Summary Judgment

Date: Sep 3, 2026

Title VII Protects Individually Discerned “Body-as-a-Temple” Vaccine Objections; Mixed Motives and “Personal Decision” Language Do Not Defeat a Prima Facie Case at Summary Judgment Case: Delsonya...

Fourth Circuit Reaffirms: No Fourth Amendment Privacy in a Stolen Vehicle Absent Innocent Acquisition; Broad Appeal Waivers Enforced While Preserved Suppression Issues Remain Reviewable

Date: Sep 3, 2026

Fourth Circuit Reaffirms: No Fourth Amendment Privacy in a Stolen Vehicle Absent Innocent Acquisition; Broad Appeal Waivers Enforced While Preserved Suppression Issues Remain Reviewable 1....

Quiah (4th Cir. 2026): DUI Indicators Permit Stop Extension; Short Continuance Within One Year Does Not Trigger Speedy-Trial Relief

Date: Sep 3, 2026

Observable DUI Indicators Justify Extending a Traffic Stop for Field Sobriety Testing; A 62‑Day Continuance and a Sub‑Year Time-to-Trial Are Not “Presumptively Prejudicial” 1. Introduction United...

Cisco Closes the Sosa Door: Alien Tort Statute Claims Limited to the “Blackstone Three”

Date: Sep 2, 2026

Cisco Closes the Sosa Door: Alien Tort Statute Claims Limited to the “Blackstone Three” 1. Introduction In Suhail Al Shimari v. CACI Premier Technology, Inc., No. 25-1043 (4th Cir. Aug. 28, 2026)...

Lowest Unit Charge Is Limited to Candidate “Use”: Political Parties and Joint Fundraising Committees with Non‑Candidate Members Are Ineligible

Date: Aug 28, 2026

Lowest Unit Charge Is Limited to Candidate “Use”: Political Parties and Joint Fundraising Committees with Non‑Candidate Members Are Ineligible I. Introduction Case: Sherrod Brown v. FCC (4th Cir....

Fourth Circuit Rejects the “Reason-for-Vacatur” Test: A Vacated Conviction Cannot Support Inadmissibility Under 8 U.S.C. § 1182(a)(2)(A)(i)

Date: Aug 26, 2026

Fourth Circuit Rejects the “Reason-for-Vacatur” Test: A Vacated Conviction Cannot Support Inadmissibility Under 8 U.S.C. § 1182(a)(2)(A)(i) I. Introduction In Lizbeyde Piedra v. Todd Blanche (4th...

Rogers Compliance Without Express PSR Adoption: Incorporation of Standard Supervised-Release Conditions by Specific Reference, and Corroborated Controlled Buys as Relevant Conduct Despite Informant Recantation

Date: Aug 26, 2026

Rogers Compliance Without Express PSR Adoption: Incorporation of Standard Supervised-Release Conditions by Specific Reference, and Corroborated Controlled Buys as Relevant Conduct Despite Informant...

Indefinite Telework That Fully Meets Medical Limitations Defeats an ADA § 12112(b)(5)(A) Failure-to-Accommodate Claim; Retaliation for Requesting an Accommodation Is Not Per Se Disability Discrimination

Date: Aug 26, 2026

Indefinite Telework That Fully Meets Medical Limitations Defeats an ADA § 12112(b)(5)(A) Failure-to-Accommodate Claim; Retaliation for Requesting an Accommodation Is Not Per Se Disability...

Bronchodilator Reversibility Does Not Defeat Legal Pneumoconiosis: Experts Must Address Residual Impairment and Coal-Dust Aggravation

Date: Aug 26, 2026

Bronchodilator Reversibility Does Not Defeat Legal Pneumoconiosis: Experts Must Address Residual Impairment and Coal-Dust Aggravation Case: Central Appalachian Coal Company v. DOWCP (Respondent...

Fourth Circuit Recognizes Limited Authority to Continue an Ongoing Terry Stop Into a Home When a Suspect Retreats and Child-Safety Exigencies Persist

Date: Aug 26, 2026

Fourth Circuit Recognizes Limited Authority to Continue an Ongoing Terry Stop Into a Home When a Suspect Retreats and Child-Safety Exigencies Persist 1. Introduction Case: Fareed Hayat v. Casey Diaz...

ADEA Prima Facie “Legitimate Expectations” Rule: Objective Certifications and Coworker Praise Do Not Create a Jury Issue Against Documented Academy Performance and Insubordination

Date: Aug 26, 2026

ADEA Prima Facie “Legitimate Expectations” Rule: Objective Certifications and Coworker Praise Do Not Create a Jury Issue Against Documented Academy Performance and Insubordination 1. Introduction In...