Justia U.S. 4th Circuit Court of Appeals Opinion SummariesArticles Posted in Civil Procedure
Star v. TI Oldfield Development, LLC
After the Boards of Directors filed lawsuits raising claims related to a residential community, a resident filed a derivative action alleging similar claims against nearly identical defendants. The district court dismissed the derivative action and the Boards settled the lawsuits in the meantime. The Fourth Circuit held that the settlements mooted the resident's claims insofar as they were related to the ones asserted by the Boards. Therefore, the court dismissed his appeal as to those claims for lack of subject matter jurisdiction. To the extent the resident asserted claims falling outside the scope of those asserted by the Boards' complaints, the court concluded that those claims were either also rendered moot by the settlement agreements or were otherwise properly dismissed by the district court. View "Star v. TI Oldfield Development, LLC" on Justia Law
District of Columbia v. Trump
The District of Columbia and the State of Maryland sued the President in his official capacity, alleging violations of the Constitution’s Foreign and Domestic Emoluments Clauses. The district court granted a motion to amend the complaint to add the President as a defendant in his individual capacity. The President, in that capacity, moved to dismiss the action, asserting absolute immunity. Approximately seven months passed without a ruling on that motion. The President in his individual capacity filed an interlocutory appeal. A Fourth Circuit panel concluded that the district court had effectively denied immunity to the President in his individual capacity so that the panel had jurisdiction to consider the interlocutory appeal. “[E]xercising that jurisdiction,” the panel held that Plaintiffs lacked Article III standing and remanded the case with instructions to dismiss. Acting en banc, the Fourth Circuit vacated the panel opinion and dismissed the interlocutory appeal. The district court neither expressly nor implicitly refused to rule on immunity but stated in writing that it intended to rule on the President’s individual capacity motion. A district court has wide discretion to prioritize its docket and the deferral did not result in a delay “beyond reasonable limits.” During the seven months, the district court managed the many other aspects of this litigation and issued opinions on the President’s motion to dismiss in his official capacity and a motion to certify an interlocutory appeal of the court’s rulings. View "District of Columbia v. Trump" on Justia Law
In re: Donald Trump
The District of Columbia and the State of Maryland sued the President in his official capacity, alleging violations of the U.S. Constitution’s Foreign and Domestic Emoluments Clauses. The district court dismissed claims concerning Trump Organization operations outside the District, for lack of standing, but denied the President’s motion with respect to alleged violations at the Washington, D.C. Trump International Hotel. After the denial of a motion for certification to take an interlocutory appeal (28 U.S.C. 1292(b)), the President petitioned for mandamus relief. A Fourth Circuit panel reversed and remanded with instructions to dismiss the complaint. The Fourth Circuit, en banc, vacated the panel opinion. The court accorded the President “great deference,” but stated that Congress and the Supreme Court have severely limited its ability to grant the extraordinary relief sought. The President has not established a right to a writ of mandamus. The district court promptly ruled on the request for certification in a detailed opinion that applied the correct legal standards. The court’s action was not arbitrary nor based on passion or prejudice; it “was in its nature a judicial act.” The President does not contend that the court denied certification for nonlegal reasons or in bad faith. Reasonable jurists can disagree in good faith on the merits of the claims. Rejecting a separation of powers argument, the court stated that the President has not explained how requests pertaining to spending at a private restaurant and hotel threaten any Executive Branch prerogative. Even if obeying the law were an official executive duty, such a duty would not be “discretionary,” but a “ministerial” act. View "In re: Donald Trump" on Justia Law
Common Cause v. Lewis
In this gerrymandering action, brought exclusively under the North Carolina Constitution against certain state legislators, the Fourth Circuit held that the district court did not err in remanding because the Legislative Defendants do not have an enforcement role within the meaning of the Refusal Clause of 28 U.S.C. 1443(2). Consequently, the court need not address whether the Legislative Defendants refused to act or whether they asserted a colorable conflict with federal law. The court also held that the district court did not abuse its discretion in declining to award fees and costs, because the legislators removed within the statutorily mandated time limit and adhered to the district court's expedited briefing schedule. Accordingly, the court affirmed the district court's judgment. View "Common Cause v. Lewis" on Justia Law
SAS Institute, Inc. v. World Programming Ltd.
This case stemmed from litigation between SAS and WPL, software developers that compete in the market for statistical analysis software. The Fourth Circuit affirmed the district court's grant of an expansion injunction and an anti-clawback injunction issued pursuant to its All Writs Act authority. Although the court respected the judicial system and judges of the United Kingdom, the court explained that the district court here needed to ensure that a money judgment reached in an American court under American law—based on damages incurred in America—was not rendered meaningless. In this case, the district court chose to enforce its judgment in the most measured terms, concentrating on the litigants' U.S. conduct and collection efforts. The court wrote that failing to take even these modest steps would have encouraged any foreign company and country to undermine the finality of a U.S. judgment. View "SAS Institute, Inc. v. World Programming Ltd." on Justia Law
Mayor and City Council of Baltimore v. BP P.L.C.
The Fourth Circuit affirmed the district court's remand order and held that the federal officer removal statute, 28 U.S.C. 1442, does not provide a proper basis for removal in a climate-change lawsuit against oil and gas companies. The court first held that Noel v. McCain, 538 F.2d 633 (4th Cir. 1976), remains binding precedent in this circuit and dismissed this appeal for lack of jurisdiction, insofar as it seeks to challenge the district court's determination with respect to the propriety of removal based on federal-question, Outer Continental Shelf Lands Act, admiralty, and bankruptcy jurisdiction. Although the court had jurisdiction to review the federal officer removal statute claim, the court agreed with Baltimore that none of the three contractual relationships defendants pointed to were sufficient to justify removal under the federal officer removal statute in this case, either because they failed to satisfy the acting-under prong or because they were insufficiently related to Baltimore's claims for purposes of the nexus prong. View "Mayor and City Council of Baltimore v. BP P.L.C." on Justia Law
Campbell v. McCarthy
Plaintiff, a civilian employee of the Army Corps of Engineers, filed suit challenging the Army's decision to suspend him from his employment pending review of his security clearance. The district court awarded summary judgment to the Army on claims under Title VII of the Civil Rights Act and Age Discrimination in Employment Act. The Fourth Circuit vacated the district court's judgment and dismissed the action in light of the Supreme Court's decision in Department of the Navy v. Egan, 484 U.S. 518 (1988). The court held that review of any of plaintiff's claims requires review of the suspension of his security clearance — a review that necessarily goes to the very heart of the protection of classified information — and thus Egan deprived the district court of subject matter jurisdiction to review each of the claims. Therefore, the district court erred by failing to dismiss these claims outright for lack of subject matter jurisdiction. View "Campbell v. McCarthy" on Justia Law
Fidrych v. Marriott International, Inc.
Plaintiff and his wife filed suit against Marriott after he was injured in an affiliated hotel in Milan, Italy. After Marriott failed to timely answer, the district court entered an entry of default. Five days after receiving notice of default, Marriott filed a motion to set aside the default, challenging the district court's personal jurisdiction over Marriott. The district court then set aside the default and subsequently granted Marriott's motion to dismiss based on lack of personal jurisdiction. The Fourth Circuit affirmed the district court's dismissal for lack of personal jurisdiction, holding that Marriott's contacts with South Carolina were not sufficient to render it "at home" in South Carolina, and thus the requirements for the exercise of contact-based general jurisdiction were not satisfied. Furthermore, the district court properly concluded that Marriott did not consent to the exercise of general jurisdiction when it obtained a Certificate of Authority to conduct business in the state. Finally, the court held that Marriott's case-related contacts with South Carolina were too tenuous and too insubstantial to constitutionally permit the exercise of specific jurisdiction over Marriott. However, the court vacated the district court's denial of sanctions, remanding the issue for reconsideration. View "Fidrych v. Marriott International, Inc." on Justia Law
Gunvor SA v. Kayablian
Gunvor, a Swiss corporate business entity, filed suit against United States citizen defendants and Amira Group in the Eastern District of Virginia. Gunvor invoked that court's alienage diversity jurisdiction and asserted various state law claims. The Fourth Circuit affirmed the district court's grant of defendants' motion to dismiss under Federal Rule of Civil Procedure 12(b)(7) because Gunvor failed to join Nemsss Petroleum, a British Virgin Islands corporation, which defendants asserted was necessary and indispensable to the action. The court held that Gunvor's own complaint places Nemsss at the heart of this case, and the district court’s factual findings follow inexorably from that account. Therefore, taking Gunvor at its word in its complaint, the court found no error in the district court's factual findings. The court also held that the district court did not abuse its discretion in deeming Nemsss a necessary party under Rule 19(a), and that Nemsss's absence would surely prejudice Nemsss. Therefore, Nemsss was an indispensable party and the district court did not err in dismissing the complaint. View "Gunvor SA v. Kayablian" on Justia Law
Posted in: Civil Procedure
Hulsey v. Cisa
The Fourth Circuit held that the Rooker-Feldman doctrine does not apply in this instance to dismiss a federal action alleging misconduct by litigants in two lawsuits previously tried in state court. The court held that plaintiff was not a state court loser complaining of an injury caused by a state court judgment and specifically seeking district court review and rejection of that judgment. Therefore, plaintiff's claims were not barred by the Rooker-Feldman doctrine. Accordingly, the court reverse and remanded, declining to resolve alternative arguments in the first instance. View "Hulsey v. Cisa" on Justia Law
Posted in: Civil Procedure