Corr sued in federal court seeking refund of fees collected by the Authority on a toll road to Dulles Airport. The federal court held he lacked standing and on the merits the tolls were not taxes and thus could be collected by the Authority. The panel affirmed. It held Corr had standing as his claim was particularized and sought a concrete result namely refund of the tolls. However, it held that his claim failed on the merits because, under Virginia constitutional law, the tolls were not taxes because they were voluntarily paid only by users of the toll road, the benefits of the tolls were voluntarily received by the payers of the toll, the proposed extension of the subway system would benefit users of the road through eventual reduction in traffic, this benefit was reasonably related to the payment of the toll and the tolls charged and the benefits were not used for the general good of all Virginians.
At Beckton’s bank robbery trial, the district court required him to either use a question and answer format for his direct testimony or have standby counsel take over the presentation of his case. Beckton chose not to testify and was convicted. The panel affirmed. It held that the district court did not abuse its discretion by requiring the question and answer format as this is within the scope of trial management. The panel also held there was no denial of the right to self-representation as Beckton could have both represented himself and testified if he had followed the district court’s instructions.