Deference to government powerSkepticism of government power
Habeas petitions in [5] and [7] directly test and limit presidential authority to designate and detain enemy combatants, reflecting skepticism toward executive power. Padilla v. Hanft ↗ Al-Marri v. Hanft ↗
This bankruptcy appeal concerns whether a Chapter 7 trustee can use strong-arm powers under 11 U.S.C. § 544(a)(3) to avoid two unrecorded mortgages on Florida real property that were later satisfied by the lenders. The Bankruptcy Court granted summary judgment to the lenders, holding that unreleased prior liens of record provided constructive notice that defeated the trustee's status as a hypothetical bona fide purchaser under Florida law. The District Court reversed, ruling that Florida precedent does not impose a per se inquiry duty on subsequent purchasers to contact holders of unreleased liens, and that the mere existence of such liens does not automatically defeat bona fide purchaser status. The case was remanded for the Bankruptcy Court to address the lenders' remaining defenses, including subrogation and other arguments under the Bankruptcy Code.
This ERISA case concerns a former employee's challenge to his employer's amendment of a pension plan that eliminated a $700 monthly supplemental benefit for certain early retirees. The plaintiff argued that the change violated ERISA's anti-cutback rule protecting accrued benefits and that the plan administrator abused its discretion by denying his claim for the supplement. The court considered cross-motions for summary judgment and determined that the supplement qualified as an ancillary benefit rather than a protected accrued benefit, allowing the amendment without violating the anti-cutback rule. It granted in part and denied in part the defendants' motion while denying the plaintiff's motion, and it applied the plan's terms to resolve the remaining benefits claim.
This case is a federal habeas corpus petition under 28 U.S.C. § 2254 challenging a South Carolina state court's criminal contempt finding against the petitioner for submitting a forged letter in a prior proceeding. The district court reviewed the magistrate judge's report recommending summary judgment for the petitioner. The court held that even assuming the state supreme court adjudicated the due process claim on the merits, its decision was contrary to or an unreasonable application of clearly established federal law from Cooke v. United States, which requires due process protections (such as assistance of counsel and the opportunity to call witnesses) in contempt proceedings that do not occur in open court. The core reasoning is that the petitioner's submission of the letter was not direct contempt in open court, the trial judge denied the petitioner's requests for counsel and an expert witness, and the petitioner was not adequately informed of or able to exercise basic defense rights.
This case involved a pro se federal prisoner's petition under 28 U.S.C. § 2241 challenging the Bureau of Prisons' denial of early-release eligibility under 18 U.S.C. § 3621(e) after he completed a drug-treatment program. The petitioner had been convicted of firearm possession in connection with a drug offense under 18 U.S.C. § 924(c), which the BOP's regulation at 28 C.F.R. § 550.55 categorically treats as disqualifying. The court adopted the magistrate judge's recommendation and granted the respondents' motion to dismiss, holding that the regulation is a valid exercise of BOP discretion under Supreme Court precedent in Lopez v. Davis and that the petitioner's objections, including arguments about possession versus use and APA notice-and-comment requirements, lacked merit under controlling Fourth Circuit authority.
This case involves a plaintiff's challenge under 42 U.S.C. § 405(g) to the Social Security Administration's denial of disability insurance benefits. The district court reviewed objections to a magistrate judge's report and remanded the case to the Commissioner pursuant to sentence four of § 405(g) for further administrative action. The court reasoned that the Appeals Council had failed to articulate any assessment or explanation for rejecting new evidence—a report from Dr. Kooistra diagnosing fibromyalgia and opining on work limitations—submitted after the ALJ's decision, which prevented proper substantial evidence review of the overall record. It adopted the approach from certain Fourth Circuit precedents requiring the agency to indicate the weight given to relevant evidence to assist judicial review.
This case involved a pro se plaintiff, a Libertarian candidate for Congress, who sued multiple media defendants for defamation after they published reports about his arrest for criminal domestic violence, allegedly embellishing details from the police report such as claims of beating his wife or causing visible injuries. The defendants moved to dismiss under Rule 12(b)(6), arguing protection under the fair report privilege for accurate summaries of official proceedings. The district court adopted the magistrate judge's recommendation without objections, granting the motion as to all defendants except Entercom Communications Corp. (d/b/a WORD/WYRD FM), allowing the claim against that remaining defendant to proceed to discovery on whether its specific broadcasts fell within the privilege.
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