Harris v. Pittman (Harris 6/18/2019): The Fourth Circuit overturned the District Court’s decision to grant Defendant’s motion for summary judgment with respect to Plaintiff’s § 1983 claim, on qualified immunity grounds. In particular, the Fourth Circuit found that the evidence construed in the light most favorable to Plaintiff showed that genuine issues of material fact bearing on Defendant’s qualified immunity defense precluded summary judgment. Full Opinion
Seay v. Sheriff Al Cannon (Keenan 6/21/2019): The Fourth Circuit reversed the District Court’s decision denying Petitioner’s habeas corpus petition. There, the South Carolina state court granted the government’s request for a mistrial after one of the government’s critical witnesses failed to appear at trial. Petitioner claimed that the state court’s decision to grant a mistrial violated the Double Jeopardy Clause of the Fifth Amendment. Employing a strict scrutiny standard of review, the Fourth Circuit held that the government failed to satisfy a showing of manifest necessity, which is required before a mistrial can be granted. Therefore, it vacated the District Court’s judgment and remanded the case with instruction to award habeas corpus relief. Full Opinion
United States v. White
Decided: June 18, 2019
Argued: May 8, 2019
The Fourth Circuit, in an opinion written by Judge Paul Niemeyer, reversed the District Court’s decision to dismiss the government’s civil proceeding under 18 U.S.C. § 4248. The Fourth Circuit reasoned that Chapter 313 of Title 18, and § 4248 in particular did not authorize the District Court to dismiss the § 4248 proceeding against Oliver White, “Defendant,” based on a finding of mental incompetency. In addition, the Fourth Circuit concluded that contrary to the District Court’s holding, § 4248 did not violate Defendant’s constitutional rights under the Due Process Clause.
The underlying proceeding was brought by the United States government against Defendant in order to certify that Defendant was a sexually dangerous person and as such should be committed to the custody of the Attorney General. Defendant sought a competency hearing to prove his incompetence, contending that his mental incompetence would preclude subjecting him to a § 4248 hearing. The District Court granted the competency hearing and found that Defendant currently suffered from a mental disease or defect, which rendered him unable to understand the nature and consequences of the proceeding against him. In light of these findings, the District Court concluded that § 4248 permits a court to dismiss a section § 4248 proceeding against an incompetent person who contests all three elements and alternatively that permitting such a § 4248 proceeding and ensuing commitment would violate procedural due process as applied to that person.
The Fourth Circuit addressed both of the District Court’s findings in turn. As to the first finding—that § 4248 permits a court to dismiss a proceeding against an incompetent person contesting all three elements—the Fourth Circuit concluded that § 4248 made no such provision. In fact, the Fourth Circuit concluded that § 4241 actually made the opposite conclusion. As to the District Court’s second finding—that a § 4248 proceeding and ensuing commitment would violate procedural due process as to a person deemed mentally incompetent—the Fourth Circuit once again disagreed. The District Court cited Matthews v. Eldridge, which provides for a three-part balancing test to determine if an individual’s procedural due process rights have been violated. In particular, Matthews calls for a court to weigh (1) a defendant’s liberty interest, (2) the risk of an erroneous deprivation of that interest under current procedures, and (3) the government’s interest and burden of providing any additional procedure that would be required. The Fourth Circuit weighed these factors and found that § 4248 strikes a proper balance under both the Due Process Clause and Matthews.
Joshua Hill