by Kirsten E. Small
"They" tell you never to do this, but I'm starting with an apology: I've got a brief due in the Fourth Circuit today, so there will be no scintillating analysis of yesterday's Fourth Circuit decisions. Maybe I'll get back to y'all over the weekend, or maybe I'll sleep and play with my kids.
The Fourth Circuit published two decisions yesterday:
In United States v. Ayala, the court affirmed RICO and VICAR convictions against several MS-13 gang members.
Westmoreland Coal Co. v. DOWCP may warrant more comment over the weekend (sorry, kids). The court affirmed an award of black lung benefits (no biggie there) but vacated the award of attorney's fees because--even though the award was "not unreasonable in sum"--the the ALJ failed to identify a specific hourly rate after rejecting the hourly rate proposed by claimant's counsel.
Friday, April 9, 2010
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