4th Circuit Case Commentaries

Post‑Hoc Alternative Grounds Do Not Cure Fabrications: Fourth Circuit Affirms Frivolous Asylum Finding and Demands Individualized Proof for Withholding/CAT Remands

Date: Nov 7, 2025

Post‑Hoc Alternative Grounds Do Not Cure Fabrications: Fourth Circuit Affirms Frivolous Asylum Finding and Demands Individualized Proof for Withholding/CAT Remands Case: Gurwinder Singh v. Pamela Jo...

De Novo, Not Clear Error: Fourth Circuit Requires BIA to Review Application of the § 1101(f)(6) False-Testimony Bar De Novo and Reaffirms Jurisdiction over Mixed Questions Post-Wilkinson

Date: Nov 7, 2025

De Novo, Not Clear Error: Fourth Circuit Requires BIA to Review Application of the § 1101(f)(6) False-Testimony Bar De Novo and Reaffirms Jurisdiction over Mixed Questions Post-Wilkinson Introduction...

No Civil Conspiracy Without an Independently Actionable Predicate; Interference with Parental Rights Requires Actual Removal from Custody

Date: Nov 3, 2025

No Civil Conspiracy Without an Independently Actionable Predicate; Interference with Parental Rights Requires Actual Removal from Custody Case: Amy Kissinger-Stankevitz v. Town of Tappahannock, et...

Fourth Circuit Holds that a Principal Officer’s Ratification Cures Appointments Clause Defects in Rulemaking and Is Not Impermissibly Retroactive

Date: Nov 3, 2025

Fourth Circuit Holds that a Principal Officer’s Ratification Cures Appointments Clause Defects in Rulemaking and Is Not Impermissibly Retroactive Case: Eliza Wille v. Howard Lutnik (and related...

No More Boilerplate: Fourth Circuit Requires Meaningful Engagement with Country‑Conditions Evidence in Gender‑Based Asylum and CAT Claims

Date: Nov 3, 2025

No More Boilerplate: Fourth Circuit Requires Meaningful Engagement with Country‑Conditions Evidence in Gender‑Based Asylum and CAT Claims Introduction In Reyna Alfaro‑Zelaya v. Bondi, the Fourth...

United States v. Cuellar: Fourth Circuit Reaffirms Co‑Conspirator Drug Quantity Attribution and the Presumption of Reasonableness for Below‑Guidelines Sentences

Date: Nov 3, 2025

United States v. Cuellar: Fourth Circuit Reaffirms Co‑Conspirator Drug Quantity Attribution and the Presumption of Reasonableness for Below‑Guidelines Sentences Court: United States Court of Appeals...

Fourth Circuit Confirms No Financial-Distress Prerequisite for Bankruptcy Court Jurisdiction: En Banc Rehearing Denied in Bestwall (Texas Two‑Step Context)

Date: Nov 2, 2025

Fourth Circuit Confirms No Financial-Distress Prerequisite for Bankruptcy Court Jurisdiction: En Banc Rehearing Denied in Bestwall (Texas Two‑Step Context) Introduction In Bestwall LLC v. Official...

No “Multiplicative” Preliminary Injunction Standard: Fourth Circuit Denies Shutdown-Based Extension to Fast-Track Clarification in AFT v. Bessent

Date: Nov 1, 2025

No “Multiplicative” Preliminary Injunction Standard: Fourth Circuit Denies Shutdown-Based Extension to Fast-Track Clarification in AFT v. Bessent Introduction In American Federation of Teachers v....

Order-by-Order CSA Compliance and Monetary Abatement: Fourth Circuit Holds Opioid Distribution Can Constitute a Public Nuisance Under West Virginia Law

Date: Oct 31, 2025

Order-by-Order CSA Compliance and Monetary Abatement: Fourth Circuit Holds Opioid Distribution Can Constitute a Public Nuisance Under West Virginia Law Case: City of Huntington, West Virginia &...

West Virginia Public Nuisance Law Embraces Opioid Distribution Claims and Permits Monetary Abatement: City of Huntington v. AmerisourceBergen (4th Cir. 2025)

Date: Oct 31, 2025

West Virginia Public Nuisance Law Embraces Opioid Distribution Claims and Permits Monetary Abatement: City of Huntington v. AmerisourceBergen (4th Cir. 2025) Introduction In City of Huntington, West...

The “Middle Ground” Standard for Medical Rebuttal: Fourth Circuit Upholds ALJ’s Use of the 2000 Preamble as Guidance and Requires Individualized, Literature-Grounded Expert Opinions in Black Lung Cases

Date: Oct 31, 2025

The “Middle Ground” Standard for Medical Rebuttal: Fourth Circuit Upholds ALJ’s Use of the 2000 Preamble as Guidance and Requires Individualized, Literature-Grounded Expert Opinions in Black Lung...

No Advisory Opinions After Supervision Ends; PLRA Screenings Must Distinguish Absolute vs. Qualified Immunity and Substantive vs. Procedural Due Process (Crowder v. Herman)

Date: Oct 31, 2025

No Advisory Opinions After Supervision Ends; PLRA Screenings Must Distinguish Absolute vs. Qualified Immunity and Substantive vs. Procedural Due Process Crowder v. Herman, No. 24-6674 (4th Cir. Oct....

Payment Logistics, Not Testing Frequency: Fourth Circuit Clarifies Permissible Probation Roles in Drug-Testing Conditions on Supervised Release

Date: Oct 28, 2025

Payment Logistics, Not Testing Frequency: Fourth Circuit Clarifies Permissible Probation Roles in Drug-Testing Conditions on Supervised Release Introduction In United States v. Kevin Jamal Jones, No....

Common‑Area Visibility as the “Additional Nexus” for Proving Knowledge of Firearms in Joint‑Occupancy § 924(c) Cases

Date: Oct 27, 2025

Common‑Area Visibility as the “Additional Nexus” for Proving Knowledge of Firearms in Joint‑Occupancy § 924(c) Cases United States v. Aaric Murray and Richard Kirkland Johnson, No. 23‑4328 & 23‑4331...

United States v. Johnson (4th Cir. 2025): Circumstantial Proof of Firearm Knowledge in Jointly Occupied Homes Suffices for § 924(c) Aiding-and-Abetting

Date: Oct 27, 2025

United States v. Johnson (4th Cir. 2025): Circumstantial Proof of Firearm Knowledge in Jointly Occupied Homes Suffices for § 924(c) Aiding-and-Abetting Court: U.S. Court of Appeals for the Fourth...

Undue Hardship After Groff: Fourth Circuit Holds Health and Safety Risks and Aggregate Operational Disruption Justify Denial of Religious COVID-19 Vaccine Exemptions in Healthcare

Date: Oct 25, 2025

Undue Hardship After Groff: Fourth Circuit Holds Health and Safety Risks and Aggregate Operational Disruption Justify Denial of Religious COVID-19 Vaccine Exemptions in Healthcare Introduction In...

Repealed-State-Law Convictions Still Count for Federal Criminal History and Pre–Amendment Acquitted-Conduct Sentencing Remains Valid: Commentary on United States v. Adkins (4th Cir. 2025)

Date: Oct 25, 2025

Repealed-State-Law Convictions Still Count for Federal Criminal History and Pre–Amendment Acquitted-Conduct Sentencing Remains Valid: United States v. Adkins Introduction This commentary examines an...

Unpublished Clarification: Testimonial Inconsistencies Alone Do Not Trigger a Mental-Competency Inquiry; Adverse Credibility Can Make Country-Conditions Evidence Irrelevant to CAT Relief

Date: Oct 22, 2025

Unpublished Clarification: Testimonial Inconsistencies Alone Do Not Trigger a Mental-Competency Inquiry; Adverse Credibility Can Make Country-Conditions Evidence Irrelevant to CAT Relief Introduction...

United States v. Simpson: Fourth Circuit Declines to Enforce Appeal Waiver Lacking Consideration; Reaffirms Reliability-Based Sentencing Findings and Temporal-Spatial Nexus for Firearm Enhancements

Date: Oct 22, 2025

United States v. Simpson: Fourth Circuit Declines to Enforce Appeal Waiver Lacking Consideration; Reaffirms Reliability-Based Sentencing Findings and Temporal-Spatial Nexus for Firearm Enhancements...

Lay-Opinion Market-Rate Testimony Rejected and Pro Rata Setoff Allowed in Corporate Wind-Up: Fourth Circuit Affirms in All American Black Car Service, Inc. v. Gondal

Date: Oct 17, 2025

Lay-Opinion Market-Rate Testimony Rejected and Pro Rata Setoff Allowed in Corporate Wind-Up: Fourth Circuit Affirms in All American Black Car Service, Inc. v. Gondal Court: United States Court of...