Justia Criminal Law Opinion Summaries
Articles Posted in US Court of Appeals for the Fourth Circuit
Matherly v. Andrews
Plaintiff, who is civilly committed as a sexually dangerous person, filed suit against BOP employees challenging various conditions of his confinement at FCI Butner. The district court dismissed some of plaintiff's claims and then granted summary judgment as to the other claims. The Fourth Circuit held that the district court correctly dismissed BOP policies claims regarding double-bunking of civil detainees, forcing plaintiff to wear the same uniform as a prisoner, and limiting purchases at the commissary and his options on television to those of a prisoner; the commingling with prisoners claims where plaintiff was frequently in the presence of prisoners and that other prisoners taunted and harassed him; and the Fair Labor Standards Act (FLSA) claim where plaintiff did not qualify as an employee. The court also held that the district court correctly granted summary judgment as to the strip searches and mass shakedowns claims, the mail claims, and the educational and vocational programs claims. Accordingly, the court affirmed the judgment. View "Matherly v. Andrews" on Justia Law
United States v. Bolton
Defendant appealed his consolidated sentence for his marijuana distribution and cocaine distribution convictions in two separate cases. The Fourth Circuit held that the district court did not err by imposing the firearm enhancement where defendant failed to show by a preponderance of the evidence that the firearms were not connected to his drug distribution. Even if the district court erred by assuming it could not grant a safety valve reduction because of the firearm enhancement, any such error was harmless. The court also held that the district court did not err in refusing to reduce defendant's offense level for acceptance of responsibility, and defendant's sentence was substantively reasonable even if the district court varied upward from defendant's Guidelines range by 40 months. Accordingly, the court affirmed the judgment. View "United States v. Bolton" on Justia Law
United States v. Giddins
Defendant was convicted of bank robbery and conspiracy to commit bank robbery following a jury trial. The Fourth Circuit held that the statements defendant gave to police during the investigation of the crime was coerced, and that he did not voluntarily waive his Fifth Amendment rights. Furthermore, the error in introducing those statements was not harmless. The court need not address the additional issues raised by defendant and thus reversed the conviction. View "United States v. Giddins" on Justia Law