4th Circuit Case Commentaries

Context-Driven Ambiguity Under Pennsylvania Contract Law: “Retail Store” and “Store Door Delivery” Can Encompass Automated Fulfillment Centers

Date: Jan 11, 2026

Context-Driven Ambiguity Under Pennsylvania Contract Law: “Retail Store” and “Store Door Delivery” Can Encompass Automated Fulfillment Centers I. Introduction In Walter Davis v. Bimbo Foods Bakeries...

Personal Rejection Is Not “Imputed Anti-Gang” Politics: Rigorous Nexus and PSG Membership Proof in MS-13 Gender-Based Asylum Claims

Date: Jan 10, 2026

Personal Rejection Is Not “Imputed Anti-Gang” Politics: Rigorous Nexus and PSG Membership Proof in MS-13 Gender-Based Asylum Claims Case: Ana Marquez-Cruz v. Pamela Bondi, No. 25-1219 (4th Cir. Jan....

“Required” Evidence and Unsworn Presentment Under 18 U.S.C. § 1546(a): Flexible Immigration Proof Becomes “Required” Once Chosen

Date: Jan 10, 2026

“Required” Evidence and Unsworn Presentment Under 18 U.S.C. § 1546(a): Flexible Immigration Proof Becomes “Required” Once Chosen Case: United States v. Oluwatoyin Aborisade (4th Cir. Jan. 8, 2026) |...

Mid-Trial Brady Disclosure as “Suppression” and the Limits of Federal Habeas Remedies

Date: Jan 10, 2026

Mid-Trial Brady Disclosure as “Suppression” and the Limits of Federal Habeas Remedies Case: Robert Gary Moore v. State of Maryland Court: United States Court of Appeals for the Fourth Circuit Date:...

Minor Inconsistencies and Intervening Misconduct Defeat FMLA Pretext; WVHRA Disability Requires Substantial Limitation at the Time of the Adverse Action

Date: Jan 9, 2026

Minor Inconsistencies and Intervening Misconduct Defeat FMLA Pretext; WVHRA Disability Requires Substantial Limitation at the Time of the Adverse Action Case: Dominique Spatafore v. City of...

Johnson v. Baltimore Police Department: Plausible Title VII Comparator Pleading Does Not Require a One-to-One Misconduct Match at Rule 12(b)(6)

Date: Jan 9, 2026

Johnson v. Baltimore Police Department: Plausible Title VII Comparator Pleading Does Not Require a One-to-One Misconduct Match at Rule 12(b)(6) Court: United States Court of Appeals for the Fourth...

Affirmance Based on an Alternative § 3553(a) Variance When the District Court Gives Independent Rationales (Evans/Assumed-Error Harmlessness Applied)

Date: Jan 8, 2026

Affirmance Based on an Alternative § 3553(a) Variance When the District Court Gives Independent Rationales (Evans/Assumed-Error Harmlessness Applied) Case: United States v. Robert Lee Strother (4th...

Title VII Undue Hardship in Healthcare: Substantial Patient-Safety Risk from an Unvaccinated Respiratory Therapist (and a Narrow “Futility” Principle for Alternative Accommodations)

Date: Jan 8, 2026

Title VII Undue Hardship in Healthcare: Substantial Patient-Safety Risk from an Unvaccinated Respiratory Therapist (and a Narrow “Futility” Principle for Alternative Accommodations) Introduction In...

Appellate Waiver and Decisionmaker-Knowledge Requirement in Title VII/§ 1981 Retaliation Claims

Date: Jan 8, 2026

Appellate Waiver and Decisionmaker-Knowledge Requirement in Title VII/§ 1981 Retaliation Claims Introduction In Leslie Anthony v. United Airlines, Incorporated, the Fourth Circuit (unpublished, per...

Fourth Circuit: No Interlocutory Jurisdiction Over Qualified-Immunity Appeals Turning on Disputed Facts (Autopsy Evidence Can Create a “Genuine” Dispute)

Date: Jan 8, 2026

Fourth Circuit: No Interlocutory Jurisdiction Over Qualified-Immunity Appeals Turning on Disputed Facts (Autopsy Evidence Can Create a “Genuine” Dispute) Case: Sabara Fisher Roberts v. Deputy J....

Biweekly Predetermined Pay with Hourly “Accounting” Satisfies § 541.602(a): Fourth Circuit Clarifies Salary-Basis for Highly Compensated Fire Chiefs

Date: Jan 7, 2026

Biweekly Predetermined Pay with Hourly “Accounting” Satisfies § 541.602(a): Fourth Circuit Clarifies Salary-Basis for Highly Compensated Fire Chiefs 1. Introduction In Anthony Kelly v. City of...

WARN Act: Functional “Single Employer” Liability Beyond Parent–Subsidiary Formalities; Disjunctive “Employment Loss” Proof and Forfeiture of Inconsistent-Verdict Challenges

Date: Jan 7, 2026

WARN Act: Functional “Single Employer” Liability Beyond Parent–Subsidiary Formalities; Disjunctive “Employment Loss” Proof and Forfeiture of Inconsistent-Verdict Challenges Case: Jules Gautier v....

Collateral-Order Limits in Qualified-Immunity Appeals and the Clearly Established Bar on Shooting a Nonthreatening, Fleeing Armed Suspect in the Back

Date: Jan 2, 2026

Collateral-Order Limits in Qualified-Immunity Appeals and the Clearly Established Bar on Shooting a Nonthreatening, Fleeing Armed Suspect in the Back Case: Melody Cooper v. Officer James Doyle (No....

Rule 12(b)(6) Limits on Using Recordings: Only Blatant Contradictions of Factual Allegations—Not Legal Characterizations or Credibility Judgments—Permit Dismissal

Date: Jan 2, 2026

Rule 12(b)(6) Limits on Using Recordings: Only Blatant Contradictions of Factual Allegations—Not Legal Characterizations or Credibility Judgments—Permit Dismissal Case: Dyanie Bermeo v. Blake Andis...

Disputed Oral “Sole Supplier” Deal and Compensation Terms Create Jury Issues, Precluding Summary Judgment (Fourth Circuit)

Date: Jan 2, 2026

Disputed Oral “Sole Supplier” Deal and Compensation Terms Create Jury Issues, Precluding Summary Judgment (Fourth Circuit) 1. Introduction East Coast Storage Equipment Co Inc v. ZF Transmissions Gray...

Speculation Is Not a Prima Facie “Exceptional and Extremely Unusual Hardship” Showing in Motions to Reopen for Non-LPR Cancellation

Date: Jan 2, 2026

Speculation Is Not a Prima Facie “Exceptional and Extremely Unusual Hardship” Showing in Motions to Reopen for Non-LPR Cancellation I. Introduction In Angel Cifuentes-Mendoza v. Pamela Jo Bondi,...

“Victim” in § 2B1.1 After Kisor: Identity-Identification Use Independently Supports the 10-or-More Victims Enhancement

Date: Jan 2, 2026

“Victim” in § 2B1.1 After Kisor: Identity-Identification Use Independently Supports the 10-or-More Victims Enhancement Case: United States v. Sampson Pearson (4th Cir. Dec. 30, 2025) (unpublished)...

Recall Reimbursement Is Not “Property Damage” Under a Product-Liability Indemnity Clause (South Carolina Contract Interpretation)

Date: Jan 1, 2026

Recall Reimbursement Is Not “Property Damage” Under a Product-Liability Indemnity Clause (South Carolina Contract Interpretation) Introduction In Metaldyne Powertrain Components Inc. v. Sansera...

Conspiracy-Based Specific Jurisdiction Requires Twombly-Level Plausibility and Particularized Facts (Fourth Circuit)

Date: Jan 1, 2026

Conspiracy-Based Specific Jurisdiction Requires Twombly-Level Plausibility and Particularized Facts (Fourth Circuit) Court: United States Court of Appeals for the Fourth Circuit Date: December 29,...

Reaffirming the Stringent Standard for Withdrawal of Guilty Pleas and Deference to Within-Guidelines Sentences in the Fourth Circuit: Commentary on United States v. Hollis

Date: Dec 28, 2025

Reaffirming the Stringent Standard for Withdrawal of Guilty Pleas and Deference to Within-Guidelines Sentences in the Fourth Circuit: Commentary on United States v. Hollis I. Introduction This...