In Sicaran v. Barr, the Fourth Circuit held that it lacked jurisdiction to consider the petitioner’s arguments that she belonged to certain social groups, to gain asylum, under the Immigration and Nationality Act (INA). The petitioner failed to raise those arguments before the Immigration Judge or the Board of Immigration Appeals and, therefore, the Fourth Circuit concluded that the petitioner’s claims were not exhausted.
In Wise v. Circosta, the Fourth Circuit held that it was improper to grant an injunction to extend the deadline of absentee ballots for the general election in North Carolina, stating that where there is a close issue of state law, the federal court should abstain from federal intervention into local affairs.
In Middleton v. Andino, a majority of the Fourth Circuit’s non-disqualified judges in active service voted for rehearing en banc after Judge Childs (D.S.C.) enjoined South Carolina’s witness requirement for absentee voting in the November 2020 election.