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 CSX Transportation v. S.C. Department of Revenue, the Fourth Circuit held that South Carolina failed to justify its exclusion of railroads from a state law that caps the amount that appraisal values on commercial and industrial properties can increase, in a five-year period, at 15%.