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

In March of 2020, West Virginia’s Governor began to adopt public-safety measures in response to the outbreak of the COVID-19 pandemic. Six months later, a group of Plaintiffs sued, challenging those measures as unconstitutional. The district court dismissed their case, holding that the amended complaint failed to state a valid constitutional claim.   On appeal, the Plaintiffs argued for the voluntary cessation exception. The Fourth Circuit vacated the district court’s judgment and remanded with instructions to dismiss the case. The court held that the case is moot because the Governor has long since terminated each of the challenged executive orders, and there is no reasonable chance they will be reimposed.  The court reasoned a defendant claiming mootness based on the voluntary cessation of a challenged practice must show that it is “absolutely clear that the allegedly wrongful behavior could not reasonably be expected to recur. Here, the Governor has not imposed any new COVID-19 restrictions, let alone restrictions similar in scope or subject matter to those Plaintiffs' challenge. Nor have Plaintiffs pointed to any conduct by the Governor suggesting that measures like gathering limits, capacity restrictions, or school closures will be reimposed in the future. View "Eden, LLC v. Jim Justice" on Justia Law

Plaintiff, Medical Mutual Insurance Company (“Med Mutual”) was the insurance carrier for numerous defendants in medical malpractice suit. Med Mutual provided the defense for the state case but, during discovery, alleged that one of the insureds had made a material modification to the Decedent’s medical records. Med Mutual brought the federal action seeking a declaratory judgment concluding that it has no obligation to provide insurance coverage for the defense of the state case. The district court declined to exercise jurisdiction over a declaratory judgment action while a parallel action was pending in state court.   The Fourth Circuit affirmed the district court’s decision. The court explained when a Section 2201 action is filed in federal court while a parallel state case is pending, the court has recognized that “courts have broad discretion to abstain from deciding declaratory judgment actions.” When deciding whether to hear such a declaratory judgment action, the court considers four factors: (1) whether the state has a strong interest in having the issues decided in its courts; (2) whether the state courts could resolve the issues more efficiently than the federal courts; (3) whether the presence of “overlapping issues of fact or law” might create unnecessary “entanglement” between the state and federal courts; and (4) whether the federal action is mere “procedural fencing”. Here, the factors favoring abstention are at least as strong, if not stronger, than those favoring retention and Med Mutual has not demonstrated an abuse by the district court of its broad discretion. View "Medical Mutual Insurance Co NC v. Rebecca Littaua" on Justia Law

Plaintiffs in this civil action served process on several of Defendants roughly a year after filing their complaint, in violation of Federal Rule of Civil Procedure 4(m)’s 90-day time requirement for service. The district court found insufficient Plaintiffs’ efforts to establish “good cause” for the delay, and because the court understood that a showing of good cause was a condition for any extension, it dismissed Plaintiffs’ claims against these Defendants.   The Fourth Circuit concluded that the record amply supports the district court’s ruling that Plaintiffs failed to show good cause for their failure to serve Defendants within the time period provided by Rule 4(m). Nonetheless, the court vacated the district court’s order of dismissal concluding that Rule 4(m) confers discretion on district courts to extend the time period for service even when good cause has not been shown.   The court explained that it does not fault the district court for its ruling in conformance with Mendez. But in light of the court’s holding, it was necessary to vacate the district court’s dismissal of the Plaintiffs’ claims against the five health care provider Defendants and remand to allow the court to consider in the first instance the parties’ arguments as to whether the court should exercise its discretion to extend the time for serving those defendants in the circumstances of this case, even though good cause was not shown. View "Edward Gelin v. Kyle Shuman" on Justia Law

By grant of summary judgment in favor of the United States, the district court held that the Government’s provision of substitute facilities to Arlington County, Virginia (“the County”) constituted just compensation for the taking of three parcels of property. The County appealed, contesting the district court’s application of the summary judgment standard and raising several substantive arguments in support.The Fourth Circuit, finding error in the district court’s grant of summary judgment, vacated the district court’s ruling and remanded for further proceedings consistent with this opinion. The court concluded that the district court circumvented the summary judgment standard when it engaged in fact-finding despite the presence of genuinely disputed material facts. The court was persuaded that the genuine disputes identified as to the nature of one of the parcels were material. It is this contested distinction of that parcel that the district court overlooked when drawing inferences in favor of the Government, effectively determining as a decision on the merits that the parcel was not a separate parcel for condemnation purposes from the rest of the take. While the district court would not have committed procedural error by making that decision under Rule 71.1, it did err as such when resolving the case in a Rule 56 proceeding. View "US v. 8.929 Acres of Land in Arlington County, Virginia" on Justia Law

8 U.S.C. Section 1226(a) permits the Attorney General to detain aliens pending their removal hearings. Under those procedures, an alien is given notice and three opportunities to seek release by showing they are neither a flight risk nor a danger to the community.   A district court determined that a class of aliens had a likelihood of establishing that those procedures violated the Due Process Clause of the Fifth Amendment. That court then issued a preliminary injunction ordering, on a class-wide basis, that to continue detaining an alien under Section 1226(a), the government must prove by clear and convincing evidence that an alien is either a flight risk or a danger to the community. The district court also required immigration judges to consider an alien’s ability to pay any bond imposed and consider alternatives to detention.   The Fourth Circuit vacated the district court’s preliminary injunction order and held that under Section 1252(f)(1), the district court lacked jurisdiction to issue class-wide injunctive relief that enjoined or restrained the process used to conduct Section 1226(a) bond hearings. Further, the detention procedures adopted for Section 1226(a) bond hearings provide sufficient process to satisfy constitutional requirements. The court concluded for that reason-the aliens are unable to establish a likelihood of success on their due process claims. Nor have they shown that they are likely to suffer irreparable harm in the absence of preliminary relief, that the balance of equities tips in their favor or that an injunction is in the public interest. View "Marvin Miranda v. Merrick Garland" on Justia Law

A fire erupted at a cannabidiol oil extraction factory, leased and operated by JDBC Holdings, Inc, d/b/a The CBD Factories (“JDBC”). JDBC filed a claim for insurance coverage with Kinsale Insurance Company (“Kinsale”)., Kinsale filed a suit in the U.S. District Court for the Northern District of West Virginia alleging that it was not bound to provide coverage. The district court denied Kinsale’s motion for summary judgment, granted in part JDBC’s motion for partial summary judgment, and declared that Kinsale was bound to provide coverage. The district court certified its Order as a final judgment pursuant to Fed. R. Civ. P. 54(b) and stayed JDBC’s counterclaims for breach of contract and bad faith pending appeal.The Fourth Circuit held that it lacked jurisdiction to consider the appeal because the district court’s order was not a final decision. The court reasoned that though the district court resolved the key question of whether Kinsale was liable for providing coverage for the damage at the JDBC facility, “the order does not embody the essential elements of a money judgment because the court has not found all of the facts necessary to compute the amount of damages due.”Further, the court found that even if the district court’s order was a final judgment, the district court abused its discretion in concluding that there was no just reason for the delay to certify the partial summary judgment order for the court’s review. Therefore, the court dismissed the appeal and remanded the matter for further proceedings. View "Kinsale Insurance Company v. JDBC Holdings, Inc." on Justia Law

Nadella Corporation bought a ship, the MV Falcon Carrier, for scrap from Falcon Carrier Shipping Limited. Unbeknownst to Nadella, the ship was encumbered by a $368,000 debt. To recover that debt, the debt holder “arrested” Nadella’s new ship. Nadella then tried to recover that debt from the ship’s seller Falcon Carrier Shipping. Newbrook Shipping—the owner of those two ships arrested by Nadella—sued Nadella in South Africa and was considering another lawsuit in Nevis. Newbrook applied in Maryland federal court for an ex parte order under Sec. 1782 authorizing discovery from Nadella’s purported parent company, Global Marketing Systems. The district court rejected discovery for the speculative “proceeding” in Nevis but then granted the full application.On appeal, Global Marketing argues that the district court substantively erred in granting the entire application and approving service of process. The court stated that Sec. 1782 identifies four mandatory conditions that must be satisfied before an application can be granted. Here, the last condition, that the evidence sought must be “for use” in a foreign proceeding, is not fully satisfied.The court held that Section 1782 gives litigants access to federal courts to obtain discovery for use in international litigation. But that access is not unlimited. The district court erred by granting the full application when it held the speculative proceeding in Nevis did not provide a basis for Sec. 1782 discovery. The court remanded for the district court to consider Global Marketing’s arguments. View "In re: Application of Newbrook" on Justia Law

Plaintiff filed 1983 against two nurses alleging that he was provided inadequate medical care during a health crisis he experienced while incarcerated. He was eventually sent a series of hospitals, where doctors told him a flesh-eating organism was damaging his internal organs.The first nurse was successfully served by the Marshals Service within Rule 4(m)’s 90-day period. The second nurse was not served because service was returned as “refused unable to forward.” The district court dismissed Plaintiff’s lawsuit on timeliness grounds after finding that Plaintiff’s amended complaint did not relate back under Rule 15(c) of the Federal Rules of Civil Procedure to his initial and timely complaint.At issue is whether the amended complaint adding Defendants is timely because it relates back to the date of the original complaint. The court found that the district court erred and the text of Rule 15(c)(1)(C) makes clear that the required “notice” and knowledge must come “within the period provided by Rule 4(m) for service.Next, the court addressed whether Defendants were provided the necessary notice within the Rule 4(m) notice period. The court ruled that Rule 15(c)’s requirements have been satisfied as to the first nurse. In regards to the second nurse, the court remanded to the district court for consideration of Plaintiff’s extension request, reasoning that the district court incorrectly believed that Plaintiff lost his chance to take advantage of Rule 15(c)’s relation-back rule. The court vacated the district court’s order granting the motion to dismiss. View "Patrick McGraw v. Theresa Gore" on Justia Law

The plaintiffs filed suit in South Carolina state court against fourteen defendants (ten individuals and four agencies), alleging five causes of action. The circuit court reviewed five preserved issues: (1) the applicable statutes of limitations for plaintiffs' claims under the Rehabilitation Act ("RA") and the Americans with Disabilities Act ("ADA"); (2) whether the district court abused its discretion in excluding the witnesses' testimonies; (3) the plaintiffs' assertion that the district court improperly instructed the jury as to the duty owed under the South Carolina Tort Claims Act; (4) whether the district court improperly dismissed plaintiff’s RA claims; and (5) whether the court erred in dismissing plaintiff’s 1983 claims.The circuit court affirmed the district court’s decision to limit the plaintiffs' witness's testimony and further found that the court did not abuse its discretion by limiting the hybrid witness's testimony or by determining whether the defendant’s deposition had any potential to lead to admissible evidence.Further, the court found no error in the district court’s instruction or its' finding that the ADA and RA claims were subject to the South Carolina Human Affairs Law’s one-year statute of limitations. The plaintiffs failed to show reversible error as they neither pleaded nor proved any action or inaction by any individually named defendants that caused them harm. View "Johnny Timpson v. Anderson County Disabilities" on Justia Law

On remand from the United States Supreme Court, the Fourth Circuit evaluated eight distinct grounds for removal that twenty-six multinational oil and gas companies ("Defendants") argue provide federal jurisdiction over the Mayor and City Council of Baltimore’s (“Baltimore”) climate-change action.The circuit court looked to two legal doctrines that inform removal inquiries before a federal court: (1) the well-pleaded complaint rule, and (2) complete preemption. Here, the circuit court reasoned that the municipality has decided to exclusively rely upon state-law claims to remedy its own climate-change injuries, which it perceives were caused, at least in part, by the defendants’ fossil-fuel products and strategic misinformation campaign. The circuit court concluded that these claims do not belong in federal court. They declined to take a position on whether Baltimore will ultimately fail or succeed in proving its claims under Maryland law. Ultimately, the circuit court did not discern a proper basis for removal that permits a federal court to entertain Baltimore’s action; thus, the court affirmed the district court’s order granting Baltimore’s Motion to Remand. View "Mayor and City Council of Baltimore v. BP P.L.C." on Justia Law