Justia U.S. 4th Circuit Court of Appeals Opinion Summaries

Articles Posted in Civil Procedure
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The case involves the South Carolina Department of Parks, Recreation and Tourism (SCPRT) and Google LLC. The State of South Carolina, along with several other states, sued Google for violations of federal and state antitrust laws. Google subpoenaed SCPRT for discovery pertinent to its defense. SCPRT refused to comply, asserting Eleventh Amendment immunity and moved to quash the subpoena.The district court denied SCPRT's motion, holding that any Eleventh Amendment immunity that SCPRT may have otherwise been entitled to assert was waived when the State, through its attorney general, voluntarily joined the federal lawsuit against Google. SCPRT appealed this decision.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court found that by joining the lawsuit against Google, the State voluntarily invoked the jurisdiction of a federal court, thereby effecting a waiver of its Eleventh Amendment immunity as to all matters arising in that suit. And because SCPRT’s immunity derives solely from that of the State, South Carolina’s waiver of Eleventh Amendment immunity equally effected a waiver of SCPRT’s immunity. The district court, therefore, properly denied SCPRT’s motion to quash. View "SC Dept of Parks, Recreation and Tourism v. Google LLC" on Justia Law

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The case revolves around a dispute over a 15,000 square foot vacation home, the Chesapeake, located in Currituck County, North Carolina. The home is owned by Elizabeth LeTendre and has been the subject of litigation for over a decade regarding its compliance with county and state zoning requirements. The home's design includes a central area and two side wings, each structurally independent and less than 5,000 square feet. LeTendre's neighbors, Marie and Michael Long, contested that the Chesapeake violated a county zoning ordinance, which was upheld by the North Carolina Court of Appeals. The County then sued LeTendre to enforce the mandate and hold her in contempt if she refused to comply.LeTendre removed the case to federal court, seeking a declaratory judgment that the Chesapeake now complies with both county and state requirements. She argued that a recent amendment to North Carolina’s state zoning law abrogated the previous ruling. The district court agreed with LeTendre, holding that the County’s interpretation of a single-family detached dwelling, as applied to the Chesapeake, is “inconsistent with the State Building Code’s definition of a dwelling.”The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court held that the Building Code Council’s determination that the Chesapeake is “a building” controls. The court rejected the appellants' arguments that the district court's ruling violated principles of res judicata and the Rooker-Feldman doctrine, stating that the court was not reviewing whether the previous rulings correctly interpreted the Ordinance, but rather that the zoning amendment made the Council decision controlling. View "Currituck County v. LeTendre" on Justia Law

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The case involves Terrance Henderson, an inmate in the Virginia Department of Corrections, who filed a lawsuit seeking to prevent prison officials from deducting money from his prison trust account as restitution for an assault he committed on a fellow inmate in 2015. He also sought to compel the return of money already taken. Henderson claimed that the nearly six-year gap between the guilt-finding phase of his disciplinary hearing and his reconvened restitution hearing violated principles of due process.The United States District Court for the Eastern District of Virginia granted summary judgment to the defendants on Henderson's 42 U.S.C. § 1983 claim and dismissed his Virginia state-law claim without prejudice. Henderson appealed this decision.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court agreed that Henderson had a protected property interest in his prison trust account. However, the court found that even if the nearly six-year delay between the guilt-finding phase and the restitution hearing violated due process, the error was harmless because no evidence that could have aided Henderson's ability to contest the amount of restitution was lost due to the delay. The court also affirmed the district court's decision to decline to exercise supplemental jurisdiction over the remaining state-law claim. View "Henderson v. Harmon" on Justia Law

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Leslie Atkinson purchased a 2003 Chevrolet Avalanche through a retail installment sales contract, which granted the seller a security interest in the vehicle. The seller assigned the sales contract and the security interest to Credit Acceptance Corporation. When Atkinson defaulted on her payments, Credit Acceptance hired Carolina Repo to repossess the vehicle. During the repossession, Atkinson attempted to drive off in the vehicle, leading to a confrontation with the Carolina Repo representative. The representative called the Harnett County Sheriff’s Office for assistance, and Deputy Brent Godfrey arrived on the scene. Godfrey ordered Atkinson out of the vehicle so that the Carolina Repo representative could repossess it.Atkinson sued Godfrey and Sheriff Wayne Coats under 42 U.S.C. § 1983, alleging violations of the Fourth, Fifth, and Fourteenth Amendments. She claimed that Godfrey, in his individual capacity, violated her Fourth Amendment right against unreasonable seizures of property by facilitating Carolina Repo’s repossession. She also alleged that Coats, in his official capacity as the sheriff, failed to train officers and created policies that deprived her of the Fourth Amendment’s protection against unreasonable seizures of property.The defendants moved to dismiss Atkinson’s § 1983 claim, asserting that Atkinson did not allege facts showing they acted under color of law, that Godfrey was entitled to qualified immunity, and that, without an underlying constitutional violation, Atkinson failed to bring an actionable claim against the Sheriff’s Office through Coats in his official capacity. The district court denied the motion, finding it could not determine as a matter of law that Godfrey’s actions did not constitute state action, that Godfrey was entitled to qualified immunity, and that the Sheriff’s Office’s liability could be ruled out. Godfrey and Coats appealed the district court’s denial of their motion.The United States Court of Appeals for the Fourth Circuit reversed the district court’s denial of Godfrey’s motion to dismiss based on qualified immunity. The court found that neither the Supreme Court, the Fourth Circuit, the highest court of North Carolina, nor a consensus of other circuit courts of appeals had determined that conduct similar to that of Godfrey was unconstitutional. Therefore, the right alleged to be violated was not clearly established. The court remanded the case with instructions to grant Godfrey’s motion to dismiss. The court dismissed the appeal with respect to the claim against Coats, as the issues it presented were not inextricably intertwined with the resolution of the qualified immunity issues. View "Atkinson v. Godfrey" on Justia Law

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The case involves three plaintiffs, Parker Wideman, Riley Draper, and William and Jessica Douglass, who were severely burned while cleaning a plant in Spartanburg, South Carolina. The plant, owned by Innovative Fibers LLC and Stein Fibers Ltd, converted recycled plastics into polyester fibers. The plaintiffs were employees of a third-party contractor, Advanced Environmental Options, hired to clean the plant. During the cleaning process, a fire broke out, causing severe injuries to the plaintiffs. The plaintiffs sued the plant owners for negligence under state common law.The case was initially filed in state court but was removed to federal court by the defendants. The defendants then moved to dismiss the case, arguing that the plaintiffs were "statutory employees" covered by South Carolina's Workers' Compensation Law. This law prohibits statutory employees from suing in tort in state courts and instead requires them to submit their claims to South Carolina’s Workers’ Compensation Commission. The district court agreed with the defendants and dismissed the case for lack of subject matter jurisdiction.The United States Court of Appeals for the Fourth Circuit vacated the district court's decision and remanded the case for further proceedings. The appellate court held that while state law can define the substantive rights asserted in federal diversity jurisdiction, it cannot strip federal courts of subject matter jurisdiction over any category of claims. The court concluded that the district court erred in dismissing the suit for lack of subject matter jurisdiction, as the dispute satisfied all the requirements of diversity jurisdiction. View "Wideman v. Innovative Fibers LLC" on Justia Law

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The case involves Bestwall, LLC, a company that filed for Chapter 11 bankruptcy in November 2017. The company sought to establish a trust to pay current and future asbestos-related claims against it. As part of this process, Bestwall requested all persons with pending mesothelioma claims against it to complete a personal injury questionnaire. Several individual claimants and the Official Committee of Asbestos Claimants objected to this request. The bankruptcy court granted Bestwall's motion and ordered all current mesothelioma claimants to complete the questionnaire. Some claimants, represented by the law firm of Maune, Raichle, Hartley, French & Mudd, LLC, filed a lawsuit in Illinois seeking an injunction to prevent Bestwall from enforcing the questionnaire order. In response, Bestwall moved in the bankruptcy court to enforce the order.The bankruptcy court held the claimants and their law firm in contempt for violating the questionnaire order. The court later sanctioned them jointly and severally in the amount of $402,817.70 for fees and expenses Bestwall incurred in defending the Illinois lawsuit and enforcing the questionnaire order. The claimants and their law firm appealed both the contempt order and the sanctions order to the district court, which dismissed the appeals for lack of jurisdiction.The United States Court of Appeals for the Fourth Circuit affirmed the district court's judgment. The court held that the contempt and sanctions orders were not final appealable orders because they did not terminate a procedural unit separate from the remaining bankruptcy case. The court noted that in normal civil litigation, a party may not immediately appeal a civil contempt order or attendant sanctions but must wait until final judgment to appeal. The same rule applies in bankruptcy, except the relevant final judgment may be a decree ending the entire case or a decree ending a discrete proceeding within the bankruptcy case. The court concluded that the contempt and sanctions orders did not terminate a procedural unit separate from the remaining bankruptcy case, and therefore, they were not final appealable orders. View "Blair v. Bestwall, LLC" on Justia Law

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The case revolves around a consent decree that was negotiated by the parties and previously approved by the district court. The decree prohibits the Receivership Estate of ERP Environmental Fund, Inc. from conducting surface coal mining at certain sites unless it is necessary for and incidental to reclamation of the site. The question presented is whether that prohibition also applies to a third-party permit transferee of a specific site—the Chestnut Oak Surface Mine in Lincoln County, West Virginia. The district court held that it did, stating that all third-party permit transferees are bound by the terms of the consent decree.The consent decree originated from a 2011 citizen suit under the Clean Water Act and the Surface Mining Control and Reclamation Act. The plaintiffs alleged that now-defunct Patriot Coal Corporation and three of its subsidiaries violated federal environmental laws by discharging excessive amounts of selenium in connection with its surface mining operations. To resolve the litigation, the parties negotiated a consent decree, which the U.S. District Court for the Southern District of West Virginia approved.In 2020, ERP ran out of money and ceased all operations. As a result, a West Virginia state court appointed Doss Special Receiver, LLC to administer ERP’s Receivership Estate. In 2022, the Receiver sought to finance its administration of the Receivership Estate by authorizing third parties to surface mine at a former Patriot Coal facility—the Buck Fork Surface Mine. The Conservation Groups intervened, arguing that such surface mining would violate Paragraph 63 of the Decree. The district court agreed.The United States Court of Appeals for the Fourth Circuit vacated the district court's decision and remanded the case with instructions. The court held that the district court's interpretation of the consent decree could not be squared with the plain text of the decree. The court found that the consent decree's prohibition on surface mining did not apply to a third-party permit transferee of a specific site. The court concluded that neither Paragraph 24 nor Paragraph 25 of the decree would bind a third-party permit transferee of the Chestnut Oak Surface Mine to Paragraph 63's prohibition on surface mining, a prohibition that expressly applies only to ERP and its Affiliated Companies. View "West Virginia Highlands Conservancy v. ERP Environmental Fund, Inc" on Justia Law

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In a case before the United States Court of Appeals for the Fourth Circuit, a private school, Concordia Preparatory School, was sued by a student and her mother for alleged violations of Title IX of the Education Amendments of 1972, which prohibits sex-based discrimination in federally-funded educational programs. The plaintiffs claimed that the school's tax-exempt status under 26 U.S.C. § 501(c)(3) constituted federal financial assistance, thus making it subject to Title IX.The school moved to dismiss the claim, arguing that it did not receive federal financial assistance and was therefore not subject to Title IX. The district court denied the school's motion, agreeing with the plaintiffs that the school's tax-exempt status constituted federal financial assistance for Title IX purposes. However, the court certified an interlocutory appeal on this issue.Upon review, the Fourth Circuit Court of Appeals disagreed with the district court's interpretation. The appellate court reasoned that while tax exemption is a benefit, it is not equivalent to "receiving Federal financial assistance" as required by Title IX. The court explained that the term "assistance" implies aid, help, or support, which suggests a grant of funds. Tax exemption, however, is merely the withholding of a tax burden rather than an affirmative grant of funds. Furthermore, the court distinguished tax exemption from the indirect receipt of federal funds as was the case in Grove City College v. Bell.As such, the Fourth Circuit reversed the district court's decision and held that tax-exempt status does not equate to "receiving Federal financial assistance" for purposes of Title IX. The case was remanded for further proceedings. View "Buettner-Hartsoe v. Baltimore Lutheran High School Association" on Justia Law

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The United States Court of Appeals for the Fourth Circuit examined a dispute between the plaintiffs, John and Dawn Harrell, and the defendant, Douglas DeLuca. The Harrells sued DeLuca, a general contractor from whom they purchased a home, for fraudulent inducement, constructive fraud, breach of contract, and violations of the Virginia Consumer Protection Act. The district court granted summary judgment in favor of DeLuca regarding the Harrells’ fraud claims based on one category of misrepresentations. The case otherwise proceeded to a bench trial where the court found DeLuca liable for breaching the contract, but not for the remaining claims. The Harrells appealed, arguing that summary judgment was inappropriate and that the district court should have made explicit findings related to their constructive fraud and breach-of-contract claims.The Court of Appeals upheld parts of the lower court's decision but also vacated parts of it. It agreed with the Harrells that the summary judgment was inappropriate, vacated it, and remanded the case for additional proceedings. It also agreed that the district court should have made explicit findings related to one of each of their constructive fraud and breach-of-contract claims. However, it affirmed the resolutions of the remaining claims which were not challenged by the Harrells on appeal. The court remanded the case back to the district court for further proceedings consistent with its opinion. View "Harrell v. Deluca" on Justia Law

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This case was heard in the United States Court of Appeals for the Fourth Circuit and involved the Estate of Arturo Giron Alvarez and 773 other plaintiffs, who brought claims against The Rockefeller Foundation (TRF), alleging the foundation's involvement in nonconsensual human medical experiments in Guatemala from 1946 to 1948. The experiments involved exposing people to sexually transmitted diseases (STDs) to study the diseases and potential treatments. The defendants had previously filed a motion for summary judgment, which was granted by the district court. The plaintiffs appealed this decision, specifically challenging the decision relating to TRF.The appeal hinged on the question of whether Dr. Soper, an Associate Director of TRF who was assigned to the Pan-American Sanitary Bureau (PASB) in Guatemala during the time of the experiments, was acting as an agent of TRF, thus making TRF liable for his actions. The court found that despite TRF paying Dr. Soper's salary during his time at the PASB, there was no indication that TRF was directing or controlling Dr. Soper’s work. Furthermore, the evidence showed that Dr. Soper considered himself no longer with TRF, and the PASB's constitution prohibited him from taking outside direction.The court concluded that TRF's connection to the experiments was too tenuous to be held liable for them. It affirmed the district court's grant of summary judgment in favor of TRF, stating that Dr. Soper was not an agent of TRF during the time of the experiments. View "In re Estate of Alvarez v. Rockefeller Foundation" on Justia Law