4th Circuit Case Commentaries

ADA “Qualified Individual” at the Time of Termination and No Per Se “100% Healed” Liability Without a Companywide Policy

Date: Feb 6, 2026

ADA “Qualified Individual” at the Time of Termination and No Per Se “100% Healed” Liability Without a Companywide Policy Introduction In Craige Robinson v. Mountaire Farms of North Carolina Corp....

Rape-Based Asylum Claims Require Case-Specific Proof of “Nexus,” Not Gender Assumptions

Date: Feb 6, 2026

Rape-Based Asylum Claims Require Case-Specific Proof of “Nexus,” Not Gender Assumptions Introduction In Maria Cortez Pineda v. Pamela Jo Bondi, Attorney General (4th Cir. Feb. 4, 2026) (unpublished),...

Mandate Rule Limits Post-Remand Appeals to the New Sentence, with Plain-Error Review of Unobjected Supervised-Release Conditions

Date: Feb 6, 2026

Mandate Rule Limits Post-Remand Appeals to the New Sentence, with Plain-Error Review of Unobjected Supervised-Release Conditions Introduction United States v. Larry Pyos, Jr. (4th Cir. Feb. 4, 2026)...

Fourth Circuit: Stale-Impeachment Limits for Cooperators, Constructive Possession Proof for Stash-House Guns, and Post-Arrest Concealment as Obstruction

Date: Feb 6, 2026

Fourth Circuit: Stale-Impeachment Limits for Cooperators, Constructive Possession Proof for Stash-House Guns, and Post-Arrest Concealment as Obstruction Case: United States v. Lawrence Jones (No....

Equal-Protection “Discriminatory Barrier” Standing and Ripeness in Local Permitting: No Permit Denial Required Where Plaintiff Is “Able and Ready” and Application Would Be Futile

Date: Feb 5, 2026

Equal-Protection “Discriminatory Barrier” Standing and Ripeness in Local Permitting: No Permit Denial Required Where Plaintiff Is “Able and Ready” and Application Would Be Futile 1. Introduction In...

Rule 1006 Summaries Must Be Non-Argumentative: “Notes” Commentary Crosses the Line (But Plain-Error Relief Requires Prejudice)

Date: Feb 5, 2026

Rule 1006 Summaries Must Be Non-Argumentative: “Notes” Commentary Crosses the Line (But Plain-Error Relief Requires Prejudice) Introduction In United States v. Jacky McComber (4th Cir. Feb. 2, 2026)...

United States v. Celedon: Heightened Explanation Required for Statutory-Maximum, Above-Range Revocation Sentences—Courts Must Address Nonfrivolous Mitigation Bearing on “Breach of Trust”

Date: Feb 2, 2026

United States v. Celedon: Heightened Explanation Required for Statutory-Maximum, Above-Range Revocation Sentences—Courts Must Address Nonfrivolous Mitigation Bearing on “Breach of Trust” Court: U.S....

Fourth Circuit Tightens Standing for Institutional-Reform Suits: PAIMI Protection & Advocacy Systems Lack Hunt-Style Associational Standing Absent Member-Control Indicia; Resource Diversion and Service Impacts Must Be Direct, Not Self-Inflicted or Third-Party Attenuated

Date: Feb 1, 2026

Fourth Circuit Tightens Standing for Institutional-Reform Suits: PAIMI Protection & Advocacy Systems Lack Hunt-Style Associational Standing Absent Member-Control Indicia; Resource Diversion and...

Subjective Interview Assessments and “Plainly Superior” Qualifications: Limits on Proving ADEA Pretext in Failure-to-Hire Cases

Date: Jan 31, 2026

Subjective Interview Assessments and “Plainly Superior” Qualifications: Limits on Proving ADEA Pretext in Failure-to-Hire Cases I. Introduction In Jeffrey Turner v. Town of Narrows (4th Cir. Jan. 28,...

Pendent Appellate Jurisdiction in Injunction Appeals and the Fourth Circuit’s Smith/Garcetti Validation of School Gender-Identity Guidelines

Date: Jan 31, 2026

Pendent Appellate Jurisdiction in Injunction Appeals and the Fourth Circuit’s Smith/Garcetti Validation of School Gender-Identity Guidelines I. Introduction Kimberly Ann Polk v. Montgomery County...

Revocation Sentencing After Esteras: “Respect for the Law” and “Just Punishment” Are Permissible Only When Tied to Supervised-Release Violations, Not Retribution for the Underlying Conviction

Date: Jan 31, 2026

Revocation Sentencing After Esteras: “Respect for the Law” and “Just Punishment” Are Permissible Only When Tied to Supervised-Release Violations, Not Retribution for the Underlying Conviction I....

Ambiguous Bankruptcy Proofs of Claim Do Not Trigger MPPAA Notice/Demand or Acceleration (Fourth Circuit)

Date: Jan 29, 2026

Ambiguous Bankruptcy Proofs of Claim Do Not Trigger MPPAA Notice/Demand or Acceleration Case: International Painters and Allied Trades Industry Pension Fund v. Florida Glass of Tampa Bay, Inc. (4th...

Rule 60(b)(6) as the Exclusive Gateway to Reopen a Closed Case (Not Rule 54(b))—and Belated United States v. Georgia Theories Are Not “Extraordinary Circumstances”

Date: Jan 29, 2026

Rule 60(b)(6) as the Exclusive Gateway to Reopen a Closed Case (Not Rule 54(b))—and Belated United States v. Georgia Theories Are Not “Extraordinary Circumstances” Case: Frederick Allen v. Joshua...

APA Jurisdiction Bar to Injunctions Compelling Federal Grant Disbursements: Grant-Freezes and Terminations Sounding in Contract Must Proceed Under the Tucker Act

Date: Jan 29, 2026

APA Jurisdiction Bar to Injunctions Compelling Federal Grant Disbursements: Grant-Freezes and Terminations Sounding in Contract Must Proceed Under the Tucker Act Case: Solutions in Hometown...

United States v. Jacobs: As-Applied Challenges to § 922(g)(9) Survive Categorical Foreclosure and Require Post-Rahimi Factfinding

Date: Jan 28, 2026

United States v. Jacobs: As-Applied Challenges to § 922(g)(9) Survive Categorical Foreclosure and Require Post-Rahimi Factfinding Court: U.S. Court of Appeals for the Fourth Circuit Date: January 21,...

United States v. Kalub Shipman (4th Cir. 2026): § 1958 Murder-for-Hire Has No “Agreement Element,” Permitting Separate Punishment for Substantive Murder-for-Hire and Conspiracy

Date: Jan 28, 2026

§ 1958 Murder-for-Hire Does Not Require an Actual Murder-for-Hire Agreement—So Convictions for Both Murder-for-Hire and Conspiracy to Commit Murder-for-Hire Do Not Violate Double Jeopardy Case:...

Substantive Murder-for-Hire Under 18 U.S.C. § 1958 Requires No Actual Agreement: Separate Offenses for Double Jeopardy Purposes

Date: Jan 28, 2026

Substantive Murder-for-Hire Under 18 U.S.C. § 1958 Requires No Actual Agreement: Separate Offenses for Double Jeopardy Purposes I. Introduction In United States v. Nelson Evans (consolidated with...

Guidelines Career-Offender Miscalculation Is Harmless Where the District Court Announces an Alternative § 3553(a) Variance and the Sentence Is Substantively Reasonable

Date: Jan 28, 2026

Guidelines Career-Offender Miscalculation Is Harmless Where the District Court Announces an Alternative § 3553(a) Variance and the Sentence Is Substantively Reasonable Introduction In United States...

Sensitive Places After Bruen in the Fourth Circuit: Sensitive-Place Analysis at Bruen Step Two, a Proprietary-Property Rule for Public Transit, and Invalidating “Opt-In” Carry on Public-Facing Private Property

Date: Jan 23, 2026

Sensitive Places After Bruen in the Fourth Circuit: Sensitive-Place Analysis at Bruen Step Two, a Proprietary-Property Rule for Public Transit, and Invalidating “Opt-In” Carry on Public-Facing...

No “Agreement Element” in 18 U.S.C. § 1958: Separate Murder-for-Hire and Conspiracy Convictions Survive Double Jeopardy

Date: Jan 22, 2026

No “Agreement Element” in 18 U.S.C. § 1958: Separate Murder-for-Hire and Conspiracy Convictions Survive Double Jeopardy Case: United States v. Jaquate Simpson (consolidated appeals including United...