4th Circuit Case Commentaries

“Dual-Track Appeals & the Residency Presumption” – The Fourth Circuit’s New Guidance on CAFA Remand Orders in Television Tower, Inc. v. Goldberg

Date: Aug 5, 2025

“Dual-Track Appeals & the Residency Presumption” – New Fourth-Circuit Precedent on Reviewing CAFA Remand Orders Introduction In Television Tower, Inc. v. Goldberg, Nos. 24-141/142 & 24-1250/1251,...

“Beyond the Numbers” – Fourth Circuit Clarifies the Proof Standard for Selective-Enforcement Claims in United States v. Moore

Date: Aug 5, 2025

“Beyond the Numbers” – Fourth Circuit Clarifies the Proof Standard for Selective-Enforcement Claims in United States v. Moore Introduction In United States v. Keith Rodney Moore, the U.S. Court of...

Anderson v. Ferguson – No Clearly-Established Prohibition on Police Use of the “Mandibular-Angle” Pressure Point Technique

Date: Aug 5, 2025

Anderson v. Ferguson – No Clearly-Established Prohibition on Police Use of the “Mandibular-Angle” Pressure Point Technique Introduction In Albert Anderson v. B. Ferguson, No. 22-7199 (4th Cir....

“Geographic Proximity Alone Does Not Equal ‘Substantial Control’” – The Fourth Circuit Narrows Title IX Liability for Off-Campus Misconduct

Date: Aug 5, 2025

“Geographic Proximity Alone Does Not Equal ‘Substantial Control’” – The Fourth Circuit Narrows Title IX Liability for Off-Campus Misconduct Introduction In Jane Roe v. Marshall University Board of...

Colorado Navarro v. Bondi (4th Cir. 2025): Quantifying “More-Likely-Than-Not” Torture and Re-affirming the BIA’s Clear-Error Authority

Date: Aug 5, 2025

Colorado Navarro v. Bondi (4th Cir. 2025): Quantifying “More-Likely-Than-Not” Torture and Re-affirming the BIA’s Clear-Error Authority 1. Introduction In Jonathan Alexander Colorado Navarro v. Pamela...

“Speak Now or Forever Waive It” – The Fourth Circuit’s Specific-Objection Rule for Source-Code Attacks on Probabilistic DNA Software (United States v. Chavis, 2025)

Date: Aug 5, 2025

“Speak Now or Forever Waive It” – The Fourth Circuit’s Specific-Objection Rule for Source-Code Attacks on Probabilistic DNA Software (United States v. Brandon Chavis & Melissa Beasley, 4th Cir. 2025)...

No “Magic-Words” Requirement: The Fourth Circuit Re-Affirms Minimal-Explanation Standard for Compassionate-Release Denials

Date: Aug 5, 2025

No “Magic-Words” Requirement: The Fourth Circuit Re-Affirms Minimal-Explanation Standard for Compassionate-Release Denials 1. Introduction In United States v. Larry Antonio Burleigh, No. 23-6254 (4th...

“Preservation over Source-Code”: The Fourth Circuit’s Guidance on Challenging Probabilistic DNA Evidence and Indictment Variance in United States v. Melissa Beasley

Date: Aug 5, 2025

“Preservation over Source-Code”: Fourth Circuit Restricts Appellate Review of Probabilistic Genotyping Challenges and Clarifies Indictment-Variance Doctrine Introduction United States v. Melissa...

“Martinez v. Bondi”: The Fourth Circuit Clarifies the BIA’s Duty to Assess Prima-Facie Eligibility and Discretion in Motions to Reopen for Cancellation of Removal

Date: Aug 5, 2025

“Martinez v. Bondi”: The Fourth Circuit Clarifies the BIA’s Duty to Assess Prima-Facie Eligibility and Discretion in Motions to Reopen for Cancellation of Removal 1. Introduction The unpublished...

Fourth Circuit Clarifies Limits of § 1447(c): No Appellate Fee-Shifting and Stricter Policing of Successive Removals

Date: Aug 2, 2025

Fourth Circuit Clarifies Limits of § 1447(c): No Appellate Fee-Shifting and Stricter Policing of Successive Removals Introduction Donald Black v. Mantei & Associates, Ltd., No. 24-1439 (4th Cir. Jul....

Implicit Non-Indigency Findings Satisfy 18 U.S.C. § 3014: A Commentary on United States v. Cansler (4th Cir. 2025)

Date: Aug 2, 2025

Implicit Non-Indigency Findings Satisfy 18 U.S.C. § 3014: A Commentary on United States v. Cansler (4th Cir. 2025) I. Introduction The Fourth Circuit’s unpublished per curiam decision in United...

“No Bivens for the Task-Force Warrant”: The Fourth Circuit’s New Limit on Constitutional Damages Actions Against U.S. Marshals

Date: Aug 2, 2025

“No Bivens for the Task-Force Warrant”: The Fourth Circuit’s New Limit on Constitutional Damages Actions Against U.S. Marshals Introduction In Evy B. Orellana v. Deputy United States Marshal Ryan...

“Speak It or Lose It” – Fourth Circuit Re-Affirms the Rogers Rule on Oral Pronouncement of Supervised-Release Conditions in United States v. Kymberly Starr

Date: Jul 31, 2025

“Speak It or Lose It” – Fourth Circuit Re-Affirms the Rogers Rule on Oral Pronouncement of Supervised-Release Conditions in United States v. Kymberly Starr 1. Introduction The Fourth Circuit’s...

“Disarming the Dangerous” after Bruen and Rahimi: The Fourth Circuit’s Endorsement of 18 U.S.C. § 922(g)(4) in United States v. Gould

Date: Jul 31, 2025

“Disarming the Dangerous” after Bruen and Rahimi: The Fourth Circuit’s Endorsement of 18 U.S.C. § 922(g)(4) United States v. James Gould (4th Cir. 2025) 1. Introduction United States v. James Gould...

“Distance Is No Defense” – Fourth Circuit Affirms Joint & Several Liability of Non-Present Partners and Clarifies Preservation Rules in Last-Clear-Chance Negligence Cases

Date: Jul 31, 2025

“Distance Is No Defense” – Fourth Circuit Affirms Joint & Several Liability of Non-Present Partners and Clarifies Preservation Rules in Last-Clear-Chance Negligence Cases Introduction Robbie G....

“Raise It or Lose It” – Preservation of Last-Clear-Chance Theories and Broad Trial-Management Discretion under Plyler v. Cox (4th Cir. 2025)

Date: Jul 31, 2025

“Raise It or Lose It” – Preservation of Last-Clear-Chance Theories and Broad Trial-Management Discretion under Plyler v. Cox (4th Cir. 2025) I. Introduction In Plyler v. Cox, the United States Court...

Columbia Gas v. RDFS – Fourth Circuit Affirms Expansive Maintenance Rights Under General Pipeline Easements and Clarifies Limits of the “Law-of-the-Case” Doctrine

Date: Jul 31, 2025

Columbia Gas v. RDFS – Fourth Circuit Affirms Expansive Maintenance Rights Under General Pipeline Easements and Clarifies Limits of the “Law-of-the-Case” Doctrine Introduction Columbia Gas...

The “No-Return Email” Doctrine: Fourth Circuit Clarifies that Employment Contracts Must Explicitly Require Employees to Return Company Emails

Date: Jul 31, 2025

The “No-Return Email” Doctrine: Fourth Circuit Clarifies that Employment Contracts Must Explicitly Require Employees to Return Company Emails 1. Introduction Aerotek, Inc. v. Kenneth Nosky, No....

“Same Taxpayer” Fixed at the Time of Payment: Fourth Circuit Clarifies § 6621(d) Interest-Netting After Mergers

Date: Jul 31, 2025

“Same Taxpayer” Fixed at the Time of Payment: Fourth Circuit Clarifies § 6621(d) Interest-Netting After Mergers 1. Introduction Bank of America Corporation v. United States, decided on 29 July 2025...

Self-Forwarded Emails and the Scope of Post-Employment Covenants: Allegis Group, Inc. v. Bero

Date: Jul 31, 2025

Self-Forwarded Emails and the Scope of Post-Employment Covenants: The Fourth Circuit Defines the Limits of “Use” and “Return” Obligations in Allegis Group, Inc. v. Christopher Bero 1. Introduction...