Week 10 (2020)
Week of March 9, 2020, through March 13, 2020
Williams v. Dimensions Health Corp. (Quattlebaum 3/13/2020): The Fourth Circuit held that a hospital admits a patient with good faith, and therefore meets the EMTALA’s “stabilization” requirement,” when it admits the patient with the intent to treat him. Because Williams failed to present any evidence that the hospital admitted him solely to satisfy the EMTALA’s requirements, the Court affirmed the district court’s grant of summary judgment to the hospital. Full Opinion.
Baehr v. Creig Northrop Team, P.C. (King 3/13/2020): The Fourth Circuit held that an individual does not have Article III standing to sue when, apart from showing a RESPA violation due to a lack of fair competition, he has not suffered an injury as a result of that lack of competition. Accordingly, because Baehr suffered no injury due to the defendants’ collusive practices, the Court remanded the matter for a dismissal. Full Opinion.
United States v. Rumley (Niemeyer 3/13/2020): The Fourth Circuit held that when a district court resentences defendants under the ACCA pursuant to Samuel Johnson, it is not compelled to use the same convictions as predicate offenses that the district court did in the original sentencing. Accordingly, the Court concluded that the district court did not err when it resentenced Rumley for possession of a firearm by a felon using a different predicate offense than the one that originally supported Rumley’s conviction. Full Opinion.
SAS Inst., Inc. v. World Programming Ltd. (Wilkinson 3/12/2020): The Fourth Circuit held that the district court properly exercised its authority under the All Writs Act to enjoin a United Kingdom business entity from licensing its products until it satisfied a money judgment obtained against it in the United States judicial system. The Court reasoned that, because the U.K. company’s failure to satisfy the money judgment frustrated the court’s orders, the All Writs Act allowed the court to provide this injunctive relief. Full Opinion.
United States v. Moreno Pena (Quattlebaum 3/11/2020) (amended 3/11/2020): The Fourth Circuit held that the district court erred in applying the “modified categorical approach”—rather than the “categorical approach”—to determine whether a burglary qualified as an aggravated felony under the Immigration and Nationality Act. However, because the Court concluded that the burglary would qualify as an aggravated felony under either approach, the Court affirmed the defendant’s conviction. Additionally, because the district court erred in applying the current sentencing guidelines instead of those in place at the time the crime was committed, the Court remanded the matter for resentencing. Full Opinion.
Cantu-Guerrero v. Lumber Liquidators, Inc. (King 3/10/2020): The Fourth Circuit held that the “coupon” settlement provisions of the Class Action Fairness Act applied where a class action settlement required the defendant to pay $14 million in store vouchers. Accordingly, the Court vacated the district court’s Attorney’s Fee Order and remanded the matter for the district court to determine the proper attorney’s fee amount. Full Opinion.
Biggs v. N.C. Dep’t of Pub. Safety (Diaz 3/10/2020): The Fourth Circuit held that a state institution does not waive its sovereign immunity by removing a case to federal court, as waiver can only occur where the institution clearly states its consent to be sued. The Court also held that a denial of reinstatement can serve as the basis for a court to waive an individual’s sovereign immunity to prevent ongoing violations of federal law. Accordingly, the Court affirmed the district court’s grant of summary judgment to the institutional defendant and vacated the grant of summary judgment to the individual defendant. Full Opinion.
United States v. Jackson
Decided: March 10, 2020
The Fourth Circuit held that a district court may, in exercise of its discretion, consider the amount of “banked” time a defendant would receive when reducing that defendant’s sentence. The Court reasoned that allowing defendants to credit excessive amounts of banked time toward a future sentence of incarceration could risk public safety and impair the public interest in deterrence. Accordingly, the Court held that the district court properly considered this factor when it reduced Jackson’s sentence.
In 2004, the defendant, Ronald Jackson, was convicted for conspiring to distribute 50 grams or more of crack cocaine. The district court sentenced Jackson to the mandatory minimum of 240 months’ imprisonment, to be followed by a ten-year term of supervised release. In 2019, pursuant to the First Step Act, Jackson moved for a sentence reduction, arguing that his sentence should be reduced to the new statutory minimum of ten years imprisonment and eight years of supervised release. However, because Jackson had already served roughly 15 years in prison, the Government argued that his sentence should be reduced to time served so that he could not bank the time served to offset any future term of imprisonment he might receive for violating the terms of his supervised release. The district court agreed with the Government, and reduced Jackson’s sentence to time served.
Jackson appealed the sentence reduction, arguing that the district court abused its discretion by considering the possibility of banked time in reducing his sentence. The Fourth Circuit concluded, however, that the district court properly exercised its discretion by taking banked time into account. The Court noted that, while a defendant may use banked time to offset future terms of imprisonment for violating a supervised release, he is not entitled to do so in every case. The Court noted that district courts enjoy a wide degree of discretion in sentencing—and resentencing—and must do so in light of the factors provided in 18 U.S.C. § 3553(a).
Here, the Court found two of the § 3553(a) factors to be particularly relevant to Jackson’s resentencing request: ensuring that the sentence will (1) protect the public from further crimes of the defendant and (2) afford adequate deterrence to criminal conduct. Here, the Court concluded that giving Jackson roughly five years of credit against imprisonment for violating his supervised release would impair both of those goals. Accordingly, the Court affirmed the district court’s decision to reduce Jackson’s sentence to time served.