Pleading “Reasonable Measures” Under the DTSA: Confidentiality Agreements as Sufficient at the Rule 12 Stage Commentary on Samuel Sherbrooke Corporate, Ltd. v. Mayer, No. 24‑2173 (4th Cir. Nov. 18,...
Conspiracy, Relevant Conduct, and Supervised Release: The Fourth Circuit’s Framework for International Firearms Trafficking in United States v. Nji I. Introduction In this consolidated appeal, the...
United States v. Palmer: Narrowing Rule 704(b) After Diaz and Rejecting Padilla-Based Collateral Attacks on State Pleas I. Introduction In United States v. Gregory Maxwell Palmer, No. 23‑4538 (4th...
Only Pre‑Motion Delay Counts: Speedy Trial Act Clarification and Supervised‑Release Pronouncement in United States v. Lamborn I. Introduction This published opinion of the United States Court of...
Freezing the Speedy Trial Act Clock at the Motion to Dismiss and Enforcing Oral Pronouncement of Supervised Release: Commentary on United States v. Le (4th Cir. 2025) I. Introduction This commentary...
United States v. Lamborn (Tony Le): Fourth Circuit Adopts Motion‑Cutoff Rule for Speedy Trial Act and Confirms Non‑Retroactivity of the Acquitted‑Conduct Guideline Amendment I. Introduction This...
Relevant Conduct, Willful Blindness, and Supervised Release Conditions in Firearms Conspiracies: United States v. Wilson Che Fonguh (4th Cir. 2025) I. Introduction The Fourth Circuit’s published...
United States v. Tita: Circumstantial Knowledge, Pinkerton Liability, and Supervised Release Conditions in a Firearms Smuggling Conspiracy I. Introduction In United States v. Tita (consolidated with...
United States v. Yoo: Limiting Speedy Trial Act Dismissals to Pre‑Motion Delay and Enforcing Oral Pronouncement of Supervised Release Conditions I. Introduction The Fourth Circuit’s published...
Self‑Executing Voluntary Dismissals Under Rule 41(a)(1)(A)(i): Converting a “Motion to Dismiss Without Prejudice” into a Notice in Connelly v. Daystar Builders, Inc. I. Introduction In Robert D....
United States v. Henderson: Supplemental Safety‑Valve Briefing as Good Cause for Late Guideline Objections and the Evidentiary Threshold for Firearm Enhancements I. Introduction United States v....
No Rule 11 Duty to Warn That Criminal Forfeiture Can Exceed the Statutory Maximum Fine; Broad Appeal Waivers Encompass Forfeiture Challenges Introduction In United States v. Shawn Johnson, Nos....
Forfeiture Is Not a “Fine” for Rule 11 Purposes: Fourth Circuit Upholds Plea Advisements, Enforces Appeal Waiver Over Forfeiture, and Reaffirms Bar on As‑Applied § 922(g)(1) Challenges Introduction...
Forfeiture Is Not a “Fine” for Rule 11 Purposes: The Fourth Circuit Clarifies Plea Colloquy Advisements and Appeal-Waiver Limits in United States v. Johnson Court: United States Court of Appeals for...
Alternative-Variance “Safety Valve”: The Fourth Circuit Reaffirms That an Explicit, Well‑Reasoned Alternative Sentence Can Neutralize a Guidelines Miscalculation on Plain‑Error Review Introduction...
Post-Loper Bright CIMT Doctrine: Knowing Receipt of Stolen Property Categorically Involves Moral Turpitude Introduction In Cesar Solis-Flores v. Pamela Jo Bondi, the Fourth Circuit revisited whether...
Extreme Speeding, Without Specific Warnings or Other Aggravating Factors, Is Not Willful and Wanton Negligence Under Virginia Law Introduction In Vasterling v. Dirle, No. 23-1702 (4th Cir. Nov. 12,...
Partial Disclosure Triggers Inquiry Notice: Fourth Circuit Clarifies Tolling, Accrual, and Unjust Enrichment in Mission Integrated Technologies, LLC v. Clemente Introduction This published Fourth...
Pretext Requires More Than Stray Remarks and Dissimilar Comparators: Fourth Circuit Clarifies Title VII Summary Judgment Standards Introduction In Derek Chapman v. Maryland Department of State...
Aggregation Controls FSA Credits: Any Disqualifying Conviction Bars First Step Act Time Credits for the Entire Aggregate Term Commentary on Gregory Allen Bonnie v. Warden Dunbar, No. 24-6665 (4th...