4th Circuit Case Commentaries

Rule 19 Necessity Requires a Non-Speculative, Contract-Specific Showing—A Tribal Enterprise Is Not Automatically a Required Party in Joint-Employer FMLA/USERRA Suits

Date: Mar 14, 2026

Rule 19 Necessity Requires a Non-Speculative, Contract-Specific Showing—A Tribal Enterprise Is Not Automatically a Required Party in Joint-Employer FMLA/USERRA Suits Introduction In William Peterson,...

Explicit Threats to Fire for EEO Activity Can Create a Triable Retaliation Issue Despite Documented Performance Problems

Date: Mar 13, 2026

Explicit Threats to Fire for EEO Activity Can Create a Triable Retaliation Issue Despite Documented Performance Problems Introduction In Terrance Reeves v. Pete Hegseth, an unpublished decision of...

Submitting Briefs with Nonexistent Case Citations—Whether AI-Generated or Not—Constitutes Prejudicial Conduct Under D.C. Rule 8.4(d) and Warrants Fourth Circuit Discipline

Date: Mar 13, 2026

Submitting Briefs with Nonexistent Case Citations—Whether AI-Generated or Not—Constitutes Prejudicial Conduct Under D.C. Rule 8.4(d) and Warrants Fourth Circuit Discipline Case: In re: Eric Chibueze...

Fourth Amendment Privacy in Cloud-Storage Files: Hash-Matching Does Not Trigger the Private-Search Exception; Warrants Required to Open Unviewed Files (But Suppression May Be Barred by Attenuation)

Date: Mar 13, 2026

Fourth Amendment Privacy in Cloud-Storage Files: Hash-Matching Does Not Trigger the Private-Search Exception; Warrants Required to Open Unviewed Files (But Suppression May Be Barred by Attenuation)...

No Duty of Care Owed by Independent Insurance Adjusters to Non‑Insured Claimants Under North Carolina Law

Date: Mar 13, 2026

No Duty of Care Owed by Independent Insurance Adjusters to Non‑Insured Claimants Under North Carolina Law 1. Introduction Environmental Hydrogeological Consultants, Inc. v. North American Risk...

Fourth Circuit: ERISA § 502(a)(2) Defined-Contribution Loss Claims Are Individualized Monetary Claims Not Fit for Rule 23(b)(1) Mandatory Classes

Date: Mar 13, 2026

Fourth Circuit: ERISA § 502(a)(2) Defined-Contribution Loss Claims Are Individualized Monetary Claims Not Fit for Rule 23(b)(1) Mandatory Classes Case: Peter Trauernicht v. Genworth Financial Inc....

After Skrmetti and Medina: Medicaid Exclusions for Gender-Dysphoria Surgeries Survive Equal Protection/ACA Review, and Medicaid Availability/Comparability Duties Lack a Private Cause of Action

Date: Mar 13, 2026

After United States v. Skrmetti and Medina v. Planned Parenthood South Atlantic: Medicaid Exclusions for Gender-Dysphoria Surgeries Survive Equal Protection/ACA Review, and Medicaid...

VICAR Attempted Murder (Virginia) Requires Proof of Specific Intent to Kill; Shooting into a Residence Without Evidence of Targeted Occupancy Is Insufficient

Date: Mar 13, 2026

VICAR Attempted Murder (Virginia) Requires Proof of Specific Intent to Kill; Shooting into a Residence Without Evidence of Targeted Occupancy Is Insufficient 1. Introduction In United States v....

VICAR Attempted Murder Requires State-Law Specific Intent to Kill: Shooting into a Residence, Without Evidence of Known Occupancy, Is Insufficient

Date: Mar 13, 2026

VICAR Attempted Murder Requires State-Law Specific Intent to Kill: Shooting into a Residence, Without Evidence of Known Occupancy, Is Insufficient 1. Introduction In this published consolidated...

Shots Fired at a Residence Do Not Establish Virginia-Predicate VICAR Attempted Murder Without Proof of Specific Intent to Kill

Date: Mar 13, 2026

Shots Fired at a Residence Do Not Establish Virginia-Predicate VICAR Attempted Murder Without Proof of Specific Intent to Kill Case: United States v. Ronald Jenkins, Jr. (consolidated with appeals of...

Bank Compliance with West Virginia “Suggestion” Turnovers Is Ministerial and Not Conversion (W. Va. Code § 38-5-14)

Date: Mar 12, 2026

Bank Compliance with West Virginia “Suggestion” Turnovers Is Ministerial and Not Conversion (W. Va. Code § 38-5-14) Case: Cin Dale 3 v. Peoples Bank Corp. (4th Cir. Mar. 9, 2026) (published) Panel:...

Cedar Coal Company v. DOWCP — Medical Reports May Interpret Multiple Treatment-Record PFTs Without Violating Black Lung Evidence Limits

Date: Mar 9, 2026

Medical Reports May Interpret Multiple Treatment-Record PFTs Without Violating Black Lung Evidence Limits 1. Introduction In Cedar Coal Company v. Director, Office of Workers' Compensation Programs,...

Revocation Cannot Rest on Unpronounced “Standard” Conditions: Rogers Nullities May Be Raised Through a Revocation Appeal

Date: Mar 9, 2026

Revocation Cannot Rest on Unpronounced “Standard” Conditions: Rogers Nullities May Be Raised Through a Revocation Appeal 1. Introduction In United States v. John McLaurin (4th Cir. Mar. 6, 2026), the...

Judicial Review Survives § 1252(a)(2)(B)(ii) When USCIS Denies Discretionary Relief on a Pure Question of Statutory Interpretation

Date: Mar 8, 2026

Judicial Review Survives § 1252(a)(2)(B)(ii) When USCIS Denies Discretionary Relief on a Pure Question of Statutory Interpretation I. Introduction In Fredis Ortez Reyes v. United States Citizenship...

Standing Turns on Abandonment at the Time of Search in Bus-Luggage Cases; A Reliable Drug-Dog Alert Supplies Probable Cause Under the Automobile Exception

Date: Mar 8, 2026

Standing Turns on Abandonment at the Time of Search in Bus-Luggage Cases; A Reliable Drug-Dog Alert Supplies Probable Cause Under the Automobile Exception Case: United States v. Jose Duran Garcia...

Harmless-Error Treatment of Erlinger “Occasions” Jury-Right Violations After Guilty Pleas Where ACCA Predicates Are Plainly Separate

Date: Mar 8, 2026

Harmless-Error Treatment of Erlinger “Occasions” Jury-Right Violations After Guilty Pleas Where ACCA Predicates Are Plainly Separate Introduction In United States v. Manger Tobias Blackmon (4th Cir....

Padilla Advice Standard in the Fourth Circuit: Telling a Client He Is “Deportable/Removable” Suffices Without Predicting “Mandatory Deportation”

Date: Mar 8, 2026

Padilla Advice Standard in the Fourth Circuit: Telling a Client He Is “Deportable/Removable” Suffices Without Predicting “Mandatory Deportation” I. Introduction United States v. Sergio Carrillo...

Preservation on Appeal and the “High Bar” for Pretrial Detainee Deliberate-Indifference Claims Under Short v. Hartman

Date: Mar 7, 2026

Preservation on Appeal and the “High Bar” for Pretrial Detainee Deliberate-Indifference Claims Under Short v. Hartman 1. Introduction Beatrice V. Johnson v. Tanya Adams (4th Cir. Mar. 4, 2026) is an...

MDL Case-Management Orders Cannot Condition an FAA § 3 Stay Motion on Lead Counsel Consent (and a Denial of Leave That Forecloses the Motion Is Appealable as a “Refusal of a Stay”)

Date: Mar 7, 2026

MDL Case-Management Orders Cannot Condition an FAA § 3 Stay Motion on Lead Counsel Consent (and a Denial of Leave That Forecloses the Motion Is Appealable as a “Refusal of a Stay”) 1. Introduction...

MDL Case-Management Orders Cannot Condition an FAA § 3 Stay Motion on Lead Counsel Consent

Date: Mar 7, 2026

MDL Case-Management Orders Cannot Condition an FAA § 3 Stay Motion on Lead Counsel Consent Introduction In Donald Bouvet v. Illinois Union Insurance Company (consolidated with City of Wausau v....