Case Summaries: Fourth Circuit Court of Appeals (Nov. 14, 20, & 26, 2024

This post summarizes published criminal law and related cases released by the Fourth Circuit Court of Appeals during November 2024. Cases of potential interest to state practitioners are summarized monthly. Previous summaries of Fourth Circuit cases are available here. Substitution of juror based on her views of the evidence violated the defendant’s right to an impartial jury; substitution of the same juror without permitting the defendant to be heard violated the defendant’s due process right to be present U.S. v. Laffitte, 121 F.4th 472 (Nov. 14, 2024). The defendant worked as the CEO of the Palmetto State Bank in South Carolina. Along with former attorney Alex Murdaugh, he conspired to defraud Murdaugh’s clients to the tune of around $2 million dollars. The defendant was ultimately charged with wire fraud, bank fraud, and conspiracy, as well as other related offenses. During the first day of jury deliberations, one juror, Juror #93, notified the court that he needed to leave the courthouse to take prescription medicine. In a separate note from the same juror, the juror notified the district court that he was “feeling pressured to change [his] vote.” Laffitte Slip op. at 5. The word “pressured” was underlined twice. The court informed the parties of the notes and suggested that the juror be replaced with an alternate. The defense requested that the jury be released for the day, while the government preferred that the jury continue deliberating. While this discussion was ongoing, the district court received two more notes from the jury. [...]