4th Circuit Opinions

United States v. Gregory Largent - Supervised Release Revocation Affirmed

Gregory Largent appealed his 18-month imprisonment sentence followed by lifetime supervised release imposed after revocation of his supervised release in the Northern District of West Virginia. He challenged the district court's modification of his supervised release condition requiring permission from the court to have contact with minors, arguing it violated Fed. R. Crim. P. 32.1(c) and his due process rights. He also challenged his revocation sentence as procedurally and substantively unreasonable. The Fourth Circuit applied plain error review and affirmed, finding no abuse of discretion since Largent was represented by counsel and had the opportunity to present evidence during the hearing where the condition was modified.

Patrick Nichols v. N. Bumgarner - Fourth Circuit Reverses Dismissal of Excessive Force Claim

The Fourth Circuit vacated the District of Maryland's dismissal of Patrick Nichols's 42 U.S.C. § 1983 excessive force claim against Montgomery County Police Officers Bumgarner and Schmidt. The appellate court held that Nichols's amended complaint, which alleged that Bumgarner slammed him to the ground and broke his left forearm while Schmidt placed a knee on his throat during a March 24, 2022 arrest, sufficiently stated a Fourth Amendment claim despite minimal factual detail. The court also found the district court erred in treating only Bumgarner as a defendant when the complaint identified Schmidt by name in the body.

Rahshjeem Benson v. Warden FCI Edgefield — Fourth Circuit Vacates Habeas Dismissal, Remands FSA Credits Dispute

The Fourth Circuit vacated the District Court for the District of South Carolina's dismissal of inmate Rahshjeem Benson's pro se habeas petition seeking approximately 150 First Step Act time credits he claims to have earned while detained at the Donald W. Wyatt Detention Center before his March 2022 transfer to FCI Edgefield. The BOP refused to credit those pre-transfer FSA credits because Benson's formal risk-and-needs assessment did not occur until his arrival at FCI Edgefield. The appeals court held that the district court erred in dismissing the petition without requiring the Government to respond and without conducting any discovery. The case is remanded for additional proceedings consistent with the opinion. The Fourth Circuit's opinion was filed April 22, 2026.