This post summarizes published criminal law and related cases released by the Fourth Circuit Court of Appeals during May 2024. Cases of potential interest to state practitioners are summarized monthly. Previous summaries of Fourth Circuit cases are available here.
fourth circuit
Fourth Circuit Strongly Suggests Including Temporal Limitations on Search Warrants for Social Media Account Information
Earlier this year, the Fourth Circuit decided United States v. Zelaya-Veliz, 94 F.4th 321 (4th Cir. 2024). Phil summarized it here when it came out, but we thought it merited its own post because of its extended discussion of how the Fourth Amendment applies to search warrants for social media account information. The court’s discussion of the need for temporal limitations in such warrants is especially noteworthy, as is the court’s analysis of the scope of the information seized pursuant to the warrants approved by the court. We’ll start with a recap of the case, and then end with some thoughts for law enforcement and prosecutors, and for defenders.
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Is NC’s Disorderly Conduct at Schools Statute Unconstitutionally Vague?
I started wondering about that question after reading a recent decision by the Fourth Circuit Court of Appeals, Carolina Youth Action Project v. Wilson, 60 F.4th 770 (4th Cir. 2023) (summarized here). There, the court struck down two South Carolina state laws aimed in large part at regulating conduct and speech in and around schools. Those laws are similar to our version of disorderly conduct by disrupting schools. This post examines the holding of Carolina Youth Action Project and its potential implications for North Carolina law.