Case Summaries: Fourth Circuit Court of Appeals (July 2024)

This post summarizes published criminal law and related cases released by the Fourth Circuit Court of Appeals during July 2024. Cases of potential interest to state practitioners are summarized monthly. Previous summaries of Fourth Circuit cases are available here. No error to summarily deny suppression motion where facts were not in dispute; no constitutional violation for failure to inquire about racial bias during voir dire or for impairment of defendant’s peremptory strikes; defendant was not entitled to enforce terms of plea bargain between his witness and the government; no error to refuse to play the entirety of the defendant’s jail calls for the jury during closing argument U.S. V. Bowman, 106 F.4th 293 (July 1, 2024). Law enforcement in the Western District of Virginia had information that methamphetamine was being sold from the defendant’s residence. They obtained a search warrant for the home and cars within the curtilage and an arrest warrant for the defendant. Officers found nearly 1,000 grams of meth in the defendant’s car, a lock box containing a cell phone, and a drug ledger with detailed records of transactions. The defendant was not present when officers arrived, but his girlfriend, Carr, was present during some of the search. The defendant was arrested at a nearby hotel the same day. He was carrying more than $7,000 in cash and an additional cell phone. Officers asked the defendant to talk in the hotel room. Upon entering the room, unprompted, he stated, “I’m good at what I do, and I’m connected [...]