Henry Franklin Floyd

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.

propertyprocedure

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.

labor & employmentbusiness & regulatory

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.

criminal lawprocedurecivil 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.

criminal lawprocedure

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.

federal powerprocedurehealthcare

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.

free speechtorts & liabilityelections

This case involves a federal habeas corpus petition under 28 U.S.C. § 2254 filed by a South Carolina state prisoner serving a life sentence for murder, who alleged inordinate delay in a pending state court habeas corpus action after multiple prior post-conviction relief applications. The magistrate judge recommended dismissal without prejudice without requiring a response from the state, and the district court adopted that recommendation after reviewing the petitioner's objections. The court reasoned that the petitioner's sole federal remedy for challenging his conviction is a § 2254 writ, which requires full exhaustion of state court remedies under 28 U.S.C. § 2254(b), and that the current filing did not satisfy the prerequisites for federal review. The petition was therefore dismissed without prejudice.

criminal lawprocedure

This case is a pro se civil rights suit brought by an inmate under 42 U.S.C. § 1983 against South Carolina prison officials, claiming they violated his First and Fourteenth Amendment rights by refusing to recognize his "Neterian Faith" as a religion and seeking an injunction to compel recognition along with costs. The magistrate judge recommended granting the defendants' motion for summary judgment, finding insufficient allegations against the director for supervisory liability, no affirmative causal link to any constitutional violation, and no basis to treat the claimed faith as qualifying for protection. The district judge adopted the report and recommendation in full after the plaintiff filed no objections, resulting in dismissal of the case. The court noted that absent objections, no further explanation or de novo review was required under applicable statutes and precedent.

civil rightsreligious liberty

This case is a habeas corpus petition under 28 U.S.C. § 2241 filed on behalf of Ali Saleh Kahlah al-Marri, a Qatari national initially arrested on criminal fraud charges linked to the 9/11 investigation, who was later designated an enemy combatant by the President and transferred to military detention in South Carolina. The court had previously determined that the President possesses authority to order such detention of a non-citizen captured inside the United States. In this opinion, the court addressed remaining claims regarding due process, right to counsel, and evidence standards in the enemy combatant proceeding. Applying the framework from Hamdi v. Rumsfeld, the court held that hearsay affidavits may be considered, extensive discovery is not required, and the government's evidence submission meets the minimum due process threshold for initial review of the detention, leading to denial of certain grounds for relief and recommittal for further proceedings.

criminal lawfederal powercivil rightsprocedure

This case involved former employees of Long John Silver's who initiated arbitration under the Fair Labor Standards Act alleging unpaid overtime, seeking to proceed as a class. After the arbitrator ruled that the arbitration agreement allowed a class proceeding and certified an opt-out class of current and former employees, the employer moved to vacate that award. The court denied the motion, applying the highly deferential standard of review for arbitration decisions under which an award may be overturned only if the arbitrator manifestly disregarded clearly established law or exceeded the scope of authority granted by the agreement. The court found neither basis applied here, as the arbitrator had construed the contract, invoked equitable principles supported by precedent, and acted within the powers to grant court-like relief.

labor & employmentprocedure

This case involved former employees of Long John Silver's who initiated a collective arbitration under the Fair Labor Standards Act alleging unpaid overtime, after an arbitrator ruled that the company's mandatory arbitration agreement was silent or ambiguous and thus permitted class proceedings. The employer filed suit in federal court seeking to vacate the arbitrator's clause-construction award, asserting jurisdiction under federal-question, diversity, and federal-commerce statutes. The court dismissed the action, holding that it lacked subject matter jurisdiction because the arbitrator's interpretation of the arbitration agreement did not present a substantial federal question and because the amount in controversy for diversity jurisdiction could not be established to a legal certainty.

labor & employmentprocedurebusiness & regulatory

This case is a products liability action arising from the death of Richard Hawes after falling from a collapsing deer stand. Plaintiff filed suit in state court against several defendants, including U.S.L. Products, Inc., which was later defaulted. U.S.L. removed the case to federal court based on diversity jurisdiction and moved to vacate the default, while Plaintiff sought remand to state court. The court denied the remand motion, finding the removal timely since the basis for federal jurisdiction was not clear from the initial complaint, and granted the motion to vacate the default to allow adjudication on the merits.

proceduretorts & liability

The case concerns a habeas corpus petition filed by Ali Saleh Kahlah al-Marri, a Qatari national who entered the United States legally, was arrested on criminal fraud charges, and was later designated an enemy combatant by President Bush and transferred to military detention without trial. The sole issue addressed is whether the President has authority to detain a non-citizen lawfully present in the United States as an enemy combatant based on alleged ties to al Qaeda. The court reviewed the factual background, including the dismissal of criminal charges and transfer to military custody, and examined precedents such as Hamdi v. Rumsfeld while distinguishing between the rights of citizens and non-citizens under the Constitution. It considered whether such detention complies with due process and other constitutional protections, including the suspension clause.

criminal lawcivil rightsfederal power

This case is a habeas corpus petition challenging the military detention of U.S. citizen Jose Padilla, who was arrested in May 2002 at O'Hare Airport on a material witness warrant related to 9/11 investigations and later designated an enemy combatant by the President under the AUMF. The court considered whether the President had authority to hold Padilla in military custody without criminal charges under the circumstances. It decided that the President lacked such authority, distinguishing the facts from cases like Ex parte Quirin and Hamdi v. Rumsfeld because Padilla was captured inside the United States rather than on a foreign battlefield. The core reasoning centered on the Non-Detention Act's prohibition on detaining U.S. citizens absent specific congressional authorization, which the AUMF did not supply for this scenario, and rejected arguments for implied repeal or that Padilla had not fully entered the country.

criminal lawfederal powercivil rights

This case involved an insurance coverage dispute under a commercial general liability policy for goods in transit. Plaintiff Campbell sought a declaration that Defendant Northern Insurance was obligated to cover not only physical damage to a third-party crane that fell from one of its trucks during transport but also the third party's costs to rent a substitute crane during repairs; Defendant had paid for the repairs but denied the rental claim and refused to defend the underlying lawsuit. The court granted summary judgment to Defendant and denied Plaintiff's partial motion, holding that the policy language did not extend coverage to loss-of-use or rental expenses. It further rejected arguments for equitable estoppel or waiver based on any statements by the insurer's adjuster and found no basis for a bad-faith claim. The decision rested on standard contract interpretation principles under South Carolina law and the absence of factual disputes requiring trial.

business & regulatorypropertyprocedure

This ERISA case involved a beneficiary's claim for coverage of gastric bypass surgery under a self-funded health plan administered by CIGNA. The court reviewed the plan administrator's denial of benefits on cross-motions for summary judgment. It granted the plaintiff's motion, denied the defendant's motion, and reversed the denial of coverage. The court reasoned that the administrator abused its discretion because the denial lacked substantial evidence, was contradicted by the opinions of multiple board-certified physicians confirming medical necessity, and was inconsistent with the plan's plain terms defining allowable and medically necessary expenses.

healthcarebusiness & regulatory

In Johnson v. Ashcroft, the plaintiff brought a pro se action against the United States and IRS officials challenging a 1984 tax deficiency and proposed levy on state tax refunds stemming from his participation in Oasis Date Associates, a limited partnership, and alleging civil rights violations due to inconsistent tax calculations. The district court reviewed the magistrate judge's report and recommendation de novo after the plaintiff filed objections. It adopted the recommendation and granted the defendants' motion to dismiss, holding that res judicata barred the suit because the plaintiff's tax liability for the relevant years had been finally settled in prior litigation, including Johnson v. Commissioner. The dismissal was without prejudice to allow pursuit of any remaining Collection Due Process relief, and all pending motions were rendered moot.

taxescivil rights

The case involved twenty-five putative class actions brought by current and former employees of South Carolina school districts alleging violations of the Fair Labor Standards Act. Defendants moved to dismiss under Rule 12(b)(1) for lack of subject matter jurisdiction, asserting Eleventh Amendment sovereign immunity. The court granted the motions and dismissed the actions, holding that the school districts qualify as arms of the state. The core reasoning was that extensive state legislative control over school district governance, funding, and operations, combined with the absence of congressional abrogation or state consent in the FLSA, rendered the districts immune from private federal suits.

labor & employmentfederal powerprocedure