In Dean v. Jones, the Fourth Circuit held that the district court misapplied the summary judgment standard and agreed with the appellant that the record would support a jury finding that correctional officers, of Central Prison in Raleigh, violated the Eighth Amendment by using force in retaliation for the appellant’s instigations.

In United States v. Brinkley, the The Fourth Circuit held that officers, armed with an arrest warrant, lacked probable cause to enter an apartment where they had reason to believe the defendant resided. In its decision, the court noted that the courts of appeal split on the quantum of proof required for an officer to show that he or she had reasonable belief to enter a residence with an arrest warrant.