4th Circuit Case Commentaries

Reaffirming the “Sever-and-Remand” Doctrine for Defective Appeal Waivers and Sentencing Errors – Comment on United States v. Shoun Wright, Jr.

Date: Aug 25, 2025

Reaffirming the “Sever-and-Remand” Doctrine for Defective Appeal Waivers and Sentencing Errors – Comment on United States v. Shoun Wright, Jr. Introduction The Fourth Circuit’s unpublished decision...

“The Central-Thesis Explanation” Standard after United States v. Terriwanna Carmichael

Date: Aug 25, 2025

“The Central-Thesis Explanation” Standard after United States v. Terriwanna Carmichael 1. Introduction The Fourth Circuit’s unpublished decision in United States v. Terriwanna Carmichael, No. 24-4337...

The “Strickland Doctrine”: Clarifying Due-Process, Equal-Protection, and Sealing Standards for Federal Judiciary Employees

Date: Aug 19, 2025

The “Strickland Doctrine” Clarifying Due-Process, Equal-Protection, and Sealing Standards for Federal Judiciary Employees 1. Introduction In Caryn Strickland v. Nancy Moritz, the Court of Appeals for...

The “Pass-Through Speech” Doctrine: Fourth Circuit Invalidates Maryland’s Digital-Ad Tax Gag Clause

Date: Aug 19, 2025

The “Pass-Through Speech” Doctrine: Fourth Circuit Invalidates Maryland’s Digital-Advertising Tax Gag Clause Introduction Chamber of Commerce of the United States v. Brooke Lierman is the latest...

Unlicensed Firearms Dealing as “Illicit Trafficking”: Fourth-Circuit Affirms § 922(a)(1)(A) as an Aggravated Felony under INA § 1101(a)(43)(C)

Date: Aug 19, 2025

Unlicensed Firearms Dealing as “Illicit Trafficking”: Fourth-Circuit Affirms § 922(a)(1)(A) as an Aggravated Felony under INA § 1101(a)(43)(C) Introduction Genovevo Alvarez Ronquillo v. Pamela Bondi...

FRE 601 Trumps: Fourth Circuit Holds that State Expert-Qualification Rules Govern Medical-Malpractice Elements in Federal Court

Date: Aug 19, 2025

FRE 601 Trumps: Fourth Circuit Holds that State Expert-Qualification Rules Govern Medical-Malpractice Elements in Federal Court 1. Introduction In Manuel Moreno v. Dr. Carol C. Bosholm, Nos....

Moreno v. Bosholm – The Fourth Circuit Embraces Rule 601: State Expert-Competency Standards Now Control Medical Malpractice Claims in Federal Court

Date: Aug 19, 2025

Federal Rule of Evidence 601 Mandates Application of State Expert-Competency Rules in Federal Medical-Malpractice Actions: A Commentary on Manuel Moreno v. Carol Bosholm (4th Cir. 2025) 1....

Time-of-Conviction Prevails: Fourth Circuit Clarifies “Controlled Substance Offense” Analysis and Upholds Use of Virginia § 18.2-248 and 21 U.S.C. § 841(a)(1) Convictions for Career-Offender Status

Date: Aug 19, 2025

Time-of-Conviction Prevails: Fourth Circuit Clarifies “Controlled Substance Offense” Analysis and Upholds Use of Virginia § 18.2-248 and 21 U.S.C. § 841(a)(1) Convictions for Career-Offender Status...

The “Implicit Denial” Doctrine & A Re-affirmed Low Bar for Prison-Excessive-Force Claims – Commentary on Escobar-Salmeron v. Moyer (4th Cir. 2025)

Date: Aug 19, 2025

The “Implicit Denial” Doctrine & A Re-affirmed Low Bar for Prison-Excessive-Force Claims – Commentary on Escobar-Salmeron v. Moyer (4th Cir. 2025) Introduction Escobar-Salmeron v. Moyer is a...

Fourth Circuit Clarifies Constructive Exhaustion in FOIA: Post-Lawsuit Partial Productions Neither Moot the Action nor Revive Administrative-Appeal Requirements

Date: Aug 19, 2025

Fourth Circuit Clarifies Constructive Exhaustion in FOIA: Post-Lawsuit Partial Productions Neither Moot the Action nor Revive Administrative-Appeal Requirements Introduction Louise Trauma Center LLC...

From “Significant Harm” to “Any Disadvantage”: Fourth-Circuit Adoption of Muldrow’s Adverse-Action Standard in Herkert v. Bisignano

Date: Aug 19, 2025

From “Significant Harm” to “Any Disadvantage”: Fourth-Circuit Adoption of Muldrow’s Adverse-Action Standard in Herkert v. Bisignano 1. Introduction Mary Frances Herkert, a disabled employee of the...

“Removal Is Not Enough” – Fourth Circuit Clarifies Mootness, Jurisdiction, and Standing in Terrorist Watch-List Litigation (Saadiq Long v. Bondi, 2025)

Date: Aug 19, 2025

“Removal Is Not Enough” – Fourth Circuit Clarifies Mootness, Jurisdiction, and Standing in Terrorist Watch-List Litigation I. Introduction In Saadiq Long v. Pamela Bondi, No. 24-1369/1403 (4th Cir....

Long v. Bondi: Watchlist-Driven Credential Denials Confer Standing and § 46110 Does Not Bar District-Court Review Once TSA Orders Are Superseded

Date: Aug 19, 2025

Long v. Bondi: Watchlist-Driven Credential Denials Confer Standing and § 46110 Does Not Bar District-Court Review Once TSA Orders Are Superseded Introduction The Fourth Circuit’s published decision...

The “Intentional-Withdrawal Waiver” Doctrine – Fourth Circuit confirms that a party who withdraws proffered evidence cannot challenge its exclusion on appeal (United States v. Breeland)

Date: Aug 19, 2025

The “Intentional-Withdrawal Waiver” Doctrine Fourth Circuit confirms that a party who withdraws proffered evidence cannot challenge its exclusion on appeal (United States v. Bernard K. Breeland, Jr.,...

“Beyond Miller”: The Fourth Circuit Declines to Extend Juvenile-Sentencing Protections to 18-Year-Old Offenders and Clarifies Evidentiary & Joinder Standards in Large-Scale VICAR Prosecutions – A Commentary on United States v. Duglas Ferrera (2025)

Date: Aug 19, 2025

“Beyond Miller”: The Fourth Circuit Declines to Extend Juvenile-Sentencing Protections to 18-Year-Old Offenders and Clarifies Evidentiary & Joinder Standards in Large-Scale VICAR Prosecutions – A...

No Safe Harbor in Fear: Fourth Circuit Narrows Duress Defence in Gang-Related VICAR Prosecutions

Date: Aug 19, 2025

No Safe Harbor in Fear: Fourth Circuit Narrows Duress Defence in Gang-Related VICAR Prosecutions 1. Introduction United States v. Elmer Martinez (consolidated appeals Nos. 22-4745, 22-4746, 23-4005,...

United States v. Martinez (2025): Fourth Circuit Defines the Outer Limits of the Duress Defence in VICAR Murders and Clarifies Knock-and-Talk Doctrine

Date: Aug 19, 2025

United States v. Martinez (4th Cir. 2025): Clarifying the Boundaries of Duress under 18 U.S.C. § 1959, the Admissibility of Gang-Violence Evidence, and the Proper Scope of Knock-and-Talk Searches...

Fourth Circuit Narrows “Gang-Duress” and Confirms Admissibility of Expert Gang Testimony after Crawford: A Commentary on United States v. Pablo Velasco Barrera (2025)

Date: Aug 19, 2025

Fourth Circuit Narrows “Gang-Duress” and Confirms Admissibility of Expert Gang Testimony after Crawford A Comprehensive Commentary on United States v. Pablo Velasco Barrera, 92 F.4th ___ (4th Cir....

“No Safe Harbor in Gang Coercion” – The Fourth Circuit’s Definitive Limits on Duress, Evidence, and Sentencing in United States v. Ronald Contreras (2025)

Date: Aug 18, 2025

“No Safe Harbor in Gang Coercion” – The Fourth Circuit’s Definitive Limits on Duress, Evidence, and Sentencing in United States v. Ronald Contreras (2025) 1. Introduction United States v. Ronald...

United States v. Crawford: Clarifying the Obstruction-of-Justice Enhancement and Reaffirming Limits on “Reasonable Doubt” Definitions

Date: Aug 18, 2025

United States v. Crawford: Clarifying the Obstruction-of-Justice Enhancement and Reaffirming Limits on “Reasonable Doubt” Definitions 1. Introduction United States v. Stephen C. Crawford, No. 24-4243...