In Parkway 1046, LLC v. U.S. Home Corp., the Fourth Circuit held Parkway’s contract claim accrued in April 2017 when U.S. Home refused to reimburse Parkway; that Parkway’s award of prejudgment interest dates back to April 2017; and that Parkway could not receive attorney’s fees because it was not a “party” under the terms of the agreement.
Tag: Parole
In Cucalon v. Barr, the Fourth Circuit held Virginia Code § 18.2-248 is divisible by prohibited substance. Applying the modified categorical approach, the court held that distribution of cocaine under Virginia Code § 18.2-248, including distribution of that substance as an accommodation under Virginia Code § 18.2-248(D), satisfies the federal definitions of an “aggravated felony” and of a crime “relating to a controlled substance.”