Articles Posted in U.S. Court of Appeals for the Fourth Circuit

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Appellant challenged the district court's decision to grant the federal government's motion to dismiss the information filed against him in a juvenile delinquency proceeding without prejudice, and its decision to deny Appellant's motion to dismiss the information with prejudice. Appellant also challenged the district court's decision to authorize the federal government to disclose two confidential documents and Appellant's identity to third-parties, contending that the disclosed information should have been kept private. The court dismissed as interlocutory the appeal over the dismissal of the information without prejudice and the denial of Appellant's motion for dismissal with prejudice; affirmed the district court's authorization of disclosure of the confidential documents; and, because the court believed that the controversy surrounding the disclosure of Appellant's identity was moot on appeal, the court vacated the district court's decision to authorize disclosure of that information. View "United States v. Under Seal" on Justia Law

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Petitioner was sentenced to life imprisonment without parole for a nonhomicide offense he committed at the age of sixteen. After Graham v. Florida was decided, petitioner sought postconviction relief but the state courts denied it. The court concluded that petitioner's state court adjudication constituted an unreasonable application of Graham where Virginia courts unreasonably ignored the plain language of the procedures governing review of petitions for geriatric release, which authorize the State Parole Board to deny geriatric release for any reason, without considering a juvenile offender’s maturity and rehabilitation. In light of the lack of governing standards, the court concluded that it was objectively unreasonable for the state courts to conclude that geriatric release affords petitioner with the “meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation” Graham demands. Accordingly, the court affirmed the district court's grant of habeas relief and remanded so that petitioner can be resentenced in accordance with Graham and the Eighth Amendment. View "LeBlanc v. Mathena" on Justia Law