James Marshall Sprouse
How Judge Sprouse rules, drawn from 23 signed orders. Every observation links to the order it came from.
Judge Sprouse no longer hears cases. This profile is preserved as a historical record of how they ruled here.
About Judge Sprouse
James Marshall Sprouse was a judge of the United States Court of Appeals for the Fourth Circuit. Appointed by President Jimmy Carter, Judge Sprouse received a commission on September 13, 1979. Judge Sprouse assumed senior status on October 31, 1992 and retired on July 31, 1995.
How Judge Sprouse decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
Applies deferential factual review without substituting the appellate court's preferred view when the record permits competing interpretations.
“Where there are two permissible views of the evidence, the factfinder’s choice between them cannot be clearly erroneous.”
In Carroll v. Wolpoff & Abramson, Sprouse rejected the FTC's position and held that the debt collector's follow-up letter remained subject to the statutory disclosure requirement.
“We find the position of the FTC unpersuasive”
Procedural preferences
In Harrington v. Holshouser, he remanded for findings on whether North Carolina had provided constitutionally adequate law-library access to prisoners.
“It is necessary, then, that we again remand this case to the district court with instructions to make appropriate findings of fact”
Uses substantial-evidence review to preserve administrative fact findings made under the correct legal standard.
“We must affirm if there is substantial evidence in the record to support the findings of fact.”
Cautions
In Neufeld v. City of Baltimore, he held that the district court improperly abstained from the federal challenge to Baltimore's satellite-antenna zoning rules.
“the district court improperly abstained under Burford”
In Davenport v. City of Alexandria, he upheld invalidation of a sidewalk-performance ordinance because the restriction was overbroad and acceptable alternative places for expression were lacking.
“Because of the impermissible overbreadth of the restriction and the lack of acceptable alternative forums for expression”
Signed rulings
A grounded sample of orders signed by this judge, with the verbatim dispositive language.
“Petition denied by published opinion.”
“Affirmed in part and remanded with instructions by published opinion.”
“Reversed and remanded for resentencing by published opinion.”
“affirm the holdings in Gwaltney's and Taylor's cases, but reverse the dismissal of Clea-ton’s claim.”
“AFFIRMED IN PART, VACATED IN PART, AND REMANDED.”
“The decision of the district court exempting from the bankruptcy estate Mrs. Wright’s contributions to the South Carolina Retirement System is AFFIRMED.”
“It is not necessary to reach the question of whether the contributions are property of the estate, as defined by § 541(a)(1) of the Bankruptcy Code,2 in view of our decision that, even if they were, they are exempt from the bankruptcy estate by operation of the South Carolina law exempting certain property from attachment, levy, and sale.”
“reverse that portion of the judgment relating to damages and remand it to the district court for a retrial on that issue”
A historical record
Judge Sprouse no longer hears cases. This profile stays available as a record of how they ruled here. If you're preparing for a matter, start from the court's current bench.