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

Deque Systems Inc., a company specializing in web accessibility software, developed and registered multiple versions of its DevTools and Rules Help Pages products. To access these, users agreed not to copy, reverse-engineer, or otherwise misuse the software or its documentation. In 2021, BrowserStack, a competing firm, sought to develop its own accessibility testing tools. More than 100 BrowserStack employees created accounts with Deque—agreeing to Deque’s terms—and later, BrowserStack released an Accessibility Toolkit, which Deque alleged was developed by unlawfully copying and reverse-engineering DevTools and the Rules Help Pages.Deque filed suit in the United States District Court for the Eastern District of Virginia, claiming copyright infringement, false advertising, breach of contract, and unjust enrichment, and sought injunctive relief, damages, and other remedies. During discovery, Deque repeatedly failed to properly disclose its damages calculations and supporting evidence by the deadlines set in the court’s scheduling order. Despite several opportunities to supplement its disclosures and a late attempt to introduce expert testimony, Deque did not timely provide the required information. BrowserStack moved to exclude Deque’s damages evidence and for summary judgment. The district court granted these motions, finding that Deque’s noncompliance with disclosure rules was neither substantially justified nor harmless, and that Deque presented no evidence supporting injunctive or other relief.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed and affirmed the district court’s judgment. The Fourth Circuit held that the district court did not abuse its discretion in excluding all evidence of Deque’s damages under Federal Rule of Civil Procedure 37(c)(1) due to repeated and unjustified failures to comply with disclosure requirements. The court also held that summary judgment for BrowserStack was warranted because Deque could not establish entitlement to injunctive, declaratory, or monetary relief. View "Deque Systems Inc. v. Browserstack, Inc." on Justia Law

While incarcerated at Sussex 1 State Prison in Virginia, the plaintiff was accused of indecent exposure in July 2017. He consistently denied the charge and urged prison officials to review video footage from a RapidEye camera, which he claimed would show he was elsewhere when the incident occurred. The officials did not review the footage, stating it was of poor quality and not helpful, and ultimately found the plaintiff guilty after a delayed hearing. As a result of this conviction, and considering his prior offenses, the plaintiff’s security classification was increased and he was transferred to a higher-security facility. He requested that the video footage be preserved, but the prison officials failed to do so.The plaintiff filed suit, alleging procedural due process and First Amendment retaliation claims. The United States District Court for the Eastern District of Virginia initially dismissed the due process claim and granted summary judgment on the retaliation claim. On appeal, the United States Court of Appeals for the Fourth Circuit reversed, noting the importance of the missing video evidence to the plaintiff’s case and remanded for further proceedings. During discovery on remand, it became clear that the video footage had not been preserved, leading the plaintiff to move for spoliation sanctions. The magistrate judge began considering the sanctions motion, but the district court granted summary judgment to the defendants on all claims before ruling on the sanctions issue.The United States Court of Appeals for the Fourth Circuit held that the district court abused its discretion by granting summary judgment before addressing the plaintiff’s motion for sanctions related to the missing video footage. Because the footage was central to the claims, the appellate court vacated the district court’s decision and remanded with instructions to fully consider the sanctions motion. View "Shaw v. Foreman" on Justia Law

A group of children in West Virginia’s foster care system filed a class action lawsuit against state officials, alleging systemic failures by the state agencies responsible for their care. The plaintiffs claimed the state’s practices resulted in widespread abuses, neglect, inadequate placements, understaffing, and failure to provide necessary physical and mental health services. They alleged violations of their constitutional rights under the Fourteenth Amendment, as well as statutory violations under the Adoption Assistance and Child Welfare Act, the Americans with Disabilities Act, and the Rehabilitation Act. The class action encompassed approximately 6,800 foster children, with additional subclasses for kinship placements, children with disabilities, and those aging out of the system.The United States District Court for the Southern District of West Virginia initially dismissed the case on abstention and mootness grounds, but that decision was reversed by the United States Court of Appeals for the Fourth Circuit in Jonathan R. ex rel. Dixon v. Justice. Upon remand, the district court certified the General Class and ADA Subclass, denied certification of other subclasses, and proceeded with discovery. In February 2025, the district court, acting sua sponte and without notice or briefing, dismissed the case with prejudice for lack of standing, finding that it lacked power under Article III to grant the requested injunctive and declaratory relief and concluding the plaintiffs’ injuries were not redressable.The United States Court of Appeals for the Fourth Circuit reviewed the dismissal de novo. It held that federal courts have the authority and duty to remedy systemic constitutional violations, including through comprehensive injunctive relief and declaratory judgments in institutional reform cases. The court found that the plaintiffs’ injuries were sufficiently concrete and ongoing, and that the requested relief was likely to redress those injuries. The district court’s dismissal was reversed and the case remanded for further proceedings. The Fourth Circuit declined to reassign the case to a new judge and found West Virginia’s cross-appeal on class decertification unreviewable at this stage. View "Jonathan R. v. Morrisey" on Justia Law

A nurse formerly employed at a West Virginia hospital system brought a qui tam action on behalf of the United States under the False Claims Act. She alleged that the hospital system, its affiliated entities, and a former executive submitted claims to the federal government that were prohibited by the Stark Law and the Anti-Kickback Statute. Specifically, she claimed that the defendants’ compensation and financial arrangements with physicians created unlawful incentives for referrals, resulting in the submission of false claims to Medicare between 2013 and 2022. The complaint included detailed tables of claims and described physician compensation structures, as well as financial transfers between entities within the health system.The United States District Court for the Southern District of West Virginia reviewed the case after the government declined to intervene. The court dismissed the amended complaint for failure to plead fraud with the particularity required by Rule 9(b) of the Federal Rules of Civil Procedure. The district court found that the complaint did not sufficiently allege the necessary elements of a False Claims Act violation, including a plausible connection between physician compensation and prohibited referrals, or that any claims submitted were actually false under the Stark Law or the Anti-Kickback Statute. The district court also denied the plaintiff’s post-judgment motions to vacate the judgment and for leave to amend the complaint, finding that additional amendment would prejudice the defendants after years of litigation and access to substantial discovery.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s dismissal and denial of leave to amend. The Fourth Circuit held that the complaint did not plead fraud with the required particularity, failed to plausibly allege violations of the Stark Law or the Anti-Kickback Statute, and did not present facts sufficient to support claims of conspiracy or reverse false claims. The court found no abuse of discretion in denying post-judgment relief. View "United States ex rel. Kyer v. Thomas Health System, Inc." on Justia Law

The case centers on the operations of a chemical manufacturing facility in Parkersburg, West Virginia, owned by The Chemours Company. Chemours used hexafluoropropylene oxide dimer acid (HFPO-DA), a member of the PFAS class of chemicals, as a processing aid in polymer production. The company discharged wastewater containing HFPO-DA into the Ohio River under a Clean Water Act (CWA) permit that established specific effluent limits. However, from 2022 onward, Chemours exceeded these limits on multiple occasions. Local water testing showed that HFPO-DA concentrations sometimes surpassed newer, not-yet-enforceable federal health standards but did not exceed West Virginia’s own goals. Chemours entered into an administrative consent order with the EPA to address permit compliance.The United States District Court for the Southern District of West Virginia reviewed a citizen suit brought by West Virginia Rivers Coalition, Inc., seeking a preliminary injunction against Chemours for ongoing permit violations. The district court found that the Coalition had Article III associational standing through a member who avoided boating in the Ohio River due to Chemours’ discharges. The court granted the preliminary injunction, enjoining Chemours from exceeding permit limits and requiring remedial measures. Chemours appealed, challenging both the standing determination and the irreparable harm finding.The United States Court of Appeals for the Fourth Circuit examined both issues. The court agreed that the Coalition had established a substantial likelihood of standing at this stage. However, it found that the district court committed legal errors in its irreparable harm analysis, including incorrectly presuming harm from permit violations and conflating harm to the public with harm to the plaintiff. The Fourth Circuit also found clear error in the factual findings regarding irreparable harm. Accordingly, the Fourth Circuit vacated the preliminary injunction granted by the district court. View "West Virginia Rivers Coalition, Inc. v. The Chemours Company FC, LLC" on Justia Law

A former employee brought a class-action lawsuit against his previous employer, alleging that the company’s practices concerning rounding employees’ time entries and automatically deducting meal breaks resulted in violations of the Fair Labor Standards Act and the North Carolina Wage and Hour Act. The employer operated manufacturing facilities in North Carolina and used policies that rounded employee work time and deducted unpaid meal breaks regardless of whether an employee actually took the break. Plaintiffs argued these policies led to unpaid overtime and wages.The United States District Court for the Middle District of North Carolina initially certified two classes under Federal Rule of Civil Procedure 23 and conditionally certified a collective action under the FLSA. However, after further developments and evidence showing that individualized inquiries would be necessary to determine whether employees were harmed by the time-rounding and meal-deduction policies, and that not all employees suffered wage loss, the district court decertified the classes and collective action. Subsequently, the named plaintiffs settled their individual claims with the employer, and the district court dismissed all remaining substantive claims with prejudice.The United States Court of Appeals for the Fourth Circuit was asked to review the district court’s order decertifying the classes and collective action. The court held that because the plaintiff voluntarily settled his individual claims before filing the appeal, he lacked standing to challenge the district court’s decertification order. The court reasoned that once the individual claims underlying the request for class certification are settled or dismissed voluntarily, the plaintiff no longer retains a concrete interest sufficient to satisfy Article III’s case-or-controversy requirement. Accordingly, the Fourth Circuit dismissed the appeal for lack of jurisdiction. View "Mebane v. GKN Driveline North America, Inc." on Justia Law

A group of former employees of a company that operated a manufacturing facility in Virginia sued the company after it announced it would close and began terminating employees. They alleged violations of the Worker Adjustment and Retraining Notification Act (WARN Act) due to insufficient notice of the plant closure, and violations of the Employee Retirement Income Security Act (ERISA) relating to the improper termination of a severance plan. The employees initially named an investment group and several related parties as defendants, claiming they were alter egos or successors of the company and should be jointly liable. However, before trial, the employees voluntarily dismissed the investment group and related parties without prejudice, focusing instead on the liability of the company itself.The United States District Court for the Western District of Virginia granted summary judgment in part, including dismissing claims by employees who signed releases, and ultimately entered a money judgment against the company after a bench trial. The employees were unable to collect on this judgment due to the company's insolvency. They then filed a new lawsuit against the investment group and various related parties, seeking to enforce the prior judgment on alter ego and veil piercing theories and claiming federal jurisdiction under the WARN Act and ERISA.The United States Court of Appeals for the Fourth Circuit reviewed the district court's dismissal of the new lawsuit for lack of subject matter jurisdiction. The Fourth Circuit held that federal courts lack subject matter jurisdiction to enforce a prior federal judgment against parties not found liable in the original action, absent independent allegations of new federal statutory violations. The court affirmed the district court's dismissal, concluding that neither federal question jurisdiction nor ancillary jurisdiction applied because the plaintiffs did not allege new violations of the WARN Act or ERISA. View "Messer v. Garrison Investment Group, LP" on Justia Law

A large group of cities, towns, and counties in West Virginia sued a pharmacy benefit manager, alleging that it contributed to the oversupply of opioids in their communities, thus creating a public nuisance. The local governments sought an injunction requiring the defendant to fund the abatement of the ongoing public nuisance and to compensate them for the costs of rectifying it. This proposed “abatement fund” was described as covering not just eliminating the oversupply itself, but also providing addiction treatment, education, and community rehabilitation.The United States District Court for the Northern District of West Virginia denied the defendant’s demand for a jury trial, determining that the Seventh Amendment did not confer a right to a jury trial because this was a governmental public nuisance action seeking only abatement, which the court characterized as an equitable remedy. The district court also ordered a bifurcated bench trial on the public-nuisance claim, with a potential statewide abatement phase, and denied the defendant’s motions for reconsideration or for interlocutory appeal.The United States Court of Appeals for the Fourth Circuit reviewed the case on a petition for a writ of mandamus. The Fourth Circuit held that the Seventh Amendment entitles the defendant to a jury trial because the relief sought by the local governments included a classic legal remedy—compensation for downstream harms resulting from the alleged public nuisance, such as addiction treatment and community rehabilitation. The court explained that, at the time of the Founding, only courts of law—not equity—could award such monetary relief for the consequences of a public nuisance. Therefore, the defendant was entitled to a jury trial on the public-nuisance claim, and the petition for mandamus was granted in part. View "In re: Express Scripts, Inc." on Justia Law

The case concerns efforts by the City of Baltimore to redevelop 13.8 acres in the Poppleton neighborhood through an agreement with a private developer. To facilitate the project, the city used eminent domain to acquire hundreds of properties, which were then transferred to the developer at an allegedly favorable price. Over the years, the project was beset by delays and amendments, resulting in only minimal development and leaving much of the area vacant and in disrepair. Plaintiffs, consisting of neighboring property owners and a community organization, claimed the city’s actions reduced their property values and exposed them to environmental nuisances.The United States District Court for the District of Maryland dismissed the plaintiffs’ claims. It found they lacked Article III standing for their Fifth Amendment takings claim because their own properties were not subject to eminent domain, and held that their private nuisance claim failed to state a claim under Maryland law. The court reasoned that the plaintiffs’ injuries, stemming from the taking of their neighbors’ properties, did not give them standing to challenge the use of eminent domain, and that their allegations of nuisance were insufficiently specific or actionable under state law.On appeal, the United States Court of Appeals for the Fourth Circuit agreed that both claims must be dismissed but for different reasons. The court held that the plaintiffs had Article III standing for the takings claim because they alleged concrete injury through diminished property values. However, it concluded the takings claim failed on the merits since the plaintiffs did not own any property actually taken. The court also ruled that, because all federal claims were dismissed at an early stage, the district court should have declined supplemental jurisdiction over the state law nuisance claim and dismissed it without prejudice. The declaratory judgment request failed as all substantive claims were dismissed. The Fourth Circuit vacated in part and remanded with instructions. View "Poppleton Now Community Association, Inc. v. La Cite Development, LLC" on Justia Law

An Afghan infant was orphaned and injured during a joint U.S.-Afghan military operation and received emergency care at a U.S. military hospital. A U.S. Marine Corps Judge Advocate, Major Joshua Mast, and his wife, Stephanie Mast, initiated custody proceedings and ultimately obtained a Virginia adoption order for the child. Separately, the U.S. Embassy gave custody to a man claiming to be the child's uncle, and the infant was subsequently cared for by John and Jane Doe, who later evacuated from Afghanistan to the United States with the child during Operation Allies Refuge. After arriving in the U.S., the Masts took custody of the child. The Does then challenged the adoption in Virginia state court, but the Supreme Court of Virginia rejected their challenge.Following the state proceedings, the Does filed a federal lawsuit in the U.S. District Court for the Western District of Virginia, seeking, among other things, a protective order to prevent the defendants from disclosing their identities. The district court granted the protective order, concluding that disclosing the Does’ identities would pose a substantial risk to their safety and that of their family in Afghanistan. The order prohibited the defendants and their representatives from revealing any information that could directly or indirectly identify the Does or their family members unless a non-disclosure agreement was executed. After the Does engaged with the media while maintaining anonymity, the Masts moved to vacate or modify the protective order, arguing it was an unconstitutional restraint on speech. The district court denied the motion and held Joshua Mast in contempt for violating the order.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s order. The Fourth Circuit held that the protective order, while a content-based prior restraint, fit within a narrow exception because it was narrowly tailored to serve the government’s compelling interest in national security—specifically, the protection of individuals perceived as U.S. collaborators. The court found the order survived strict scrutiny and was not unconstitutionally vague. View "Doe v. Mast" on Justia Law