4th Circuit Case Commentaries

Discretionary Revocation of Visa Petitions Immune from Judicial Review under 8 U.S.C. § 1252(a)(2)(B)(ii)

Date: Jun 3, 2025

Discretionary Revocation of Visa Petitions Immune from Judicial Review under 8 U.S.C. § 1252(a)(2)(B)(ii) Introduction This commentary examines the Fourth Circuit’s decision in MD Islam v. Director...

Wage Increase Threats as Coercion: Defining Employer Speech Boundaries under Sections 8(a)(1) and 8(c)

Date: Jun 3, 2025

Wage Increase Threats as Coercion: Defining Employer Speech Boundaries under Sections 8(a)(1) and 8(c) Introduction Garten Trucking LC v. NLRB is a Fourth Circuit decision issued on June 2, 2025,...

Coercive Versus Persuasive Employer Speech: Clarifying Section 8(c) Boundaries in NLRB v. Garten Trucking

Date: Jun 3, 2025

Coercive Versus Persuasive Employer Speech: Clarifying Section 8(c) Boundaries in NLRB v. Garten Trucking Introduction NLRB v. Garten Trucking LC arises from a union‐organizing campaign at Garten...

Possession as Presumption of Ownership: Fourth Circuit Upholds Virginia Law in Elam v. Early

Date: May 31, 2025

Possession as Presumption of Ownership: Fourth Circuit Upholds Virginia Law in Elam v. Early Introduction The dispute in William Nile Elam, III v. Stephen Timothy Early arises from a family quarrel...

Evaluating “Incapacitation” and Alternative Caregivers in Compassionate Release: United States v. Rosario-Cruzado

Date: May 31, 2025

Evaluating “Incapacitation” and Alternative Caregivers in Compassionate Release: United States v. Rosario-Cruzado Introduction United States v. Iza Mar Rosario-Cruzado (4th Cir. 2025) addressed the...

Necessity of Demonstrating Pretext in Pregnancy Discrimination and ADA Claims for Probationary Employees

Date: May 31, 2025

Necessity of Demonstrating Pretext in Pregnancy Discrimination and ADA Claims for Probationary Employees Introduction Sharise Parker v. Children’s National Medical Center, Inc. (4th Cir. 2025)...

Restrictive Equitable Estoppel for Non-Signatory Enforcement of Arbitration Agreements Under Maryland Law

Date: May 31, 2025

Restrictive Equitable Estoppel for Non-Signatory Enforcement of Arbitration Agreements Under Maryland Law Introduction The Fourth Circuit’s unpublished per curiam decision in Shamia Franklin v. Cleo...

Clarifying Fourth Amendment Seizures and the Bounds of Permissible Prolongation of Stops: United States v. Joseph

Date: May 29, 2025

Clarifying Fourth Amendment Seizures and the Bounds of Permissible Prolongation of Stops: United States v. Joseph Introduction United States v. Samuel Pierre Joseph (4th Cir. 2025) addresses two...

Bump-Up Exclusion Bars Indemnity for Shareholder Settlements in Merger Transactions

Date: May 29, 2025

Bump-Up Exclusion Bars Indemnity for Shareholder Settlements in Merger Transactions 1. Introduction In Towers Watson & Co. v. National Union Fire Insurance Co. of Pittsburgh, Pa. (4th Cir. 2025), the...

Deference to ALJ Findings in Longshore Act Claims: Substantial Evidence and APA Compliance

Date: May 29, 2025

Deference to ALJ Findings in Longshore Act Claims: Substantial Evidence and APA Compliance Introduction J. Larry Willis v. Director, Office of Workers’ Compensation Programs, U.S. Department of...

Fourth Circuit Clarifies Vehicle Protective Searches and Bounds on Traffic-Stop Extensions

Date: May 29, 2025

Fourth Circuit Clarifies Vehicle Protective Searches and Bounds on Traffic-Stop Extensions Introduction United States v. Joseph Dadisman is a 2025 decision of the Fourth Circuit that refines two...

Expressio Unius Exclusio: Omission of “Successors and Assigns” Language Precludes Covenants from Running with the Land

Date: May 28, 2025

Expressio Unius Exclusio: Omission of “Successors and Assigns” Language Precludes Covenants from Running with the Land Introduction Snowshoe Mountain, Inc. v. Ruby Dog Holdings, LLC (4th Cir. May 27,...

Express Aiming and Personal Jurisdiction Limits for Foreign Technology Defendants: NSO Group v. Khashoggi

Date: May 22, 2025

Express Aiming and Personal Jurisdiction Limits for Foreign Technology Defendants: NSO Group v. Khashoggi Introduction In Hanan Elatr Khashoggi v. NSO Group Technologies Limited (Fourth Circuit, May...

Express Aiming Requirement for Specific Personal Jurisdiction in Cross-Border Cyber Surveillance

Date: May 22, 2025

Express Aiming Requirement for Specific Personal Jurisdiction in Cross-Border Cyber Surveillance Introduction This commentary analyzes the Fourth Circuit’s decision in Hanan Elatr Khashoggi v. NSO...

Barnhill v. Bondi: Clarifying Causation and the Limits of the Cat’s Paw Doctrine in Title VII Retaliation Claims

Date: May 16, 2025

Barnhill v. Bondi: Clarifying Causation and the Limits of the Cat’s Paw Doctrine in Title VII Retaliation Claims Introduction The Fourth Circuit’s published decision in Lisa Barnhill v. Pamela Bondi,...

Treating Physician Opinion Rule: Narrative Requirement and Validation of Subjective Evidence in Mental Health Disability Determinations

Date: May 16, 2025

Treating Physician Opinion Rule: Narrative Requirement and Validation of Subjective Evidence in Mental Health Disability Determinations Introduction Krista Kay Miller filed applications for...

Independent Source Doctrine and Lascivious Exhibition Standards Clarified in United States v. Deritis

Date: May 15, 2025

Independent Source Doctrine and Lascivious Exhibition Standards Clarified in United States v. Deritis 1. Introduction United States v. Vincent Deritis, No. 23-4150 (4th Cir. May 14, 2025), presents a...

Constitutionality of Permanent Firearm Prohibition for Domestic Violence Misdemeanants under the Second Amendment

Date: May 15, 2025

Constitutionality of Permanent Firearm Prohibition for Domestic Violence Misdemeanants under the Second Amendment Introduction This commentary examines the Fourth Circuit’s decision in United States...

Scope of Discretionary Authority and Jurisdictional Limits in Qualified Immunity Interlocutory Appeals

Date: May 15, 2025

Scope of Discretionary Authority and Jurisdictional Limits in Qualified Immunity Interlocutory Appeals Introduction The Fourth Circuit’s unpublished per curiam decision in Katrina Reeves v. Howard...

Causal Link Requirement for Standing in Immigration Stay Procedure Challenges

Date: May 15, 2025

Causal Link Requirement for Standing in Immigration Stay Procedure Challenges Introduction The Fourth Circuit’s decision in Yeison Ortiz v. Kristi Noem establishes a clear principle: to challenge the...