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

In August 2019, Eric Toon led Lieutenant Christopher Zerkle on a high-speed chase before returning to his home, where his girlfriend, Taylor Quinn, was sleeping. Zerkle and other officers, including Sergeants Paxton Lively and Rick Keglor, and Deputies Brandon Kay and Jamie Miller, arrived at Toon’s residence. The officers knocked on the door, which eventually opened outward, leading them to enter the home. Toon then broke a window, jumped out with an AR-15, and was fatally shot by Zerkle and another officer. Quinn, who followed Toon out of the window, was also injured.The United States District Court for the Southern District of West Virginia dismissed some claims and granted summary judgment in favor of the officers on the remaining claims. The court found that the officers reasonably believed they had consent to enter the home when the door opened and that Zerkle’s use of deadly force against Toon was justified. The court also concluded that Quinn’s injuries were accidental and not the result of intentional excessive force.The United States Court of Appeals for the Fourth Circuit reviewed the case and found that factual disputes precluded summary judgment on the warrantless entry claims and Quinn’s excessive force, battery, and trespass claims. The court held that the officers could not assume consent to enter the home merely because the door opened. The court also determined that there was sufficient evidence for a jury to find that Zerkle intentionally shot Quinn. The court affirmed the district court’s decision on the remaining claims, including the excessive force claim related to Toon and the failure to intervene claim against Zerkle. The case was reversed in part, affirmed in part, and remanded for further proceedings. View "Quinn v. Zerkle" on Justia Law

Michael Shipton, a middle-aged man with Type 2 diabetes, worked as an underground gas mechanic for Baltimore Gas & Electric (BGE). Due to his diabetes, he periodically missed work and was granted intermittent Family Medical Leave Act (FMLA) leave in August 2017 and January 2018 for hypoglycemia. In April 2018, Shipton took two days off for severe foot pain caused by neuropathy, but BGE informed him that his FMLA certification only covered hypoglycemia. After submitting a new medical certification for neuropathy, BGE approved his request. However, in June 2018, BGE terminated Shipton, citing conflicting medical documentation.Shipton filed a complaint in the United States District Court for the District of Maryland in June 2020, alleging FMLA interference and retaliation against BGE, Exelon Corporation, Exelon Business Services Company (EBSC), and several individual defendants. The defendants argued that Shipton was terminated based on an honest belief that he misused FMLA leave and that his claims were time-barred. The district court granted summary judgment in favor of the defendants, finding no evidence of willful FMLA violations to extend the statute of limitations and concluding that BGE had a legitimate reason for termination.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo and affirmed the district court's decision. The court held that Shipton failed to demonstrate a genuine dispute of material fact regarding his FMLA interference and retaliation claims. The court found that BGE had a legitimate, nondiscriminatory reason for termination based on conflicting medical documentation and that Shipton did not provide sufficient evidence to show pretext. Additionally, the court upheld the summary judgment in favor of Exelon, EBSC, and the individual defendants, concluding they were not Shipton’s "employer" under the FMLA. View "Shipton v. Baltimore Gas and Electric Company" on Justia Law

Nasanto Antonio Crenshaw, a 17-year-old, was shot and killed by Officer Matthew Sletten of the Greensboro, North Carolina police department while driving an allegedly stolen car. Crenshaw's mother, Wakita Doriety, filed a lawsuit against Officer Sletten for excessive force under 42 U.S.C. § 1983 and various state law claims. The City of Greensboro was also named as a defendant for the state law claims. The City moved to dismiss the claims, asserting governmental immunity, and the district court agreed, dismissing all claims against the City. Officer Sletten also moved to dismiss the claims against him, arguing that the video evidence contradicted the plaintiff's allegations.The United States District Court for the Middle District of North Carolina dismissed the claims against the City based on governmental immunity, ruling under Rule 12(b)(2). The court also dismissed the claims against Officer Sletten under Rule 12(b)(6), finding that the video evidence showed Crenshaw driving directly towards the officer, justifying the use of deadly force. The court concluded that the officer's actions were reasonable and dismissed the excessive force claim and the state law claims against him.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the dismissal of the claims against the City but reversed the dismissal of the claims against Officer Sletten. The appellate court held that the district court erred in dismissing the excessive force claim because the video did not blatantly contradict the plaintiff's allegations. The court found that the plaintiff's allegations, when properly construed, were sufficient to state a claim of excessive force under § 1983. The case was remanded for further proceedings on the claims against Officer Sletten. View "Doriety v. Sletten" on Justia Law

In January 2021, Julius Lamart Hodges, an inmate at the Prince William-Manassas Adult Detention Center, volunteered to work in the kitchen during a COVID-19 outbreak while most inmates quarantined. Hodges did not contract COVID-19 but claimed that his exposure to the virus constituted cruel and unusual punishment under the Eighth Amendment. He also alleged that his working conditions were harsh and that he was retaliated against for filing grievances about these conditions.The United States District Court for the Eastern District of Virginia dismissed Hodges’s complaint. The court found that Hodges failed to state a claim under the Eighth Amendment because he voluntarily chose to work and could have opted to quarantine. The court also dismissed his First Amendment retaliation claim, concluding that Hodges did not plausibly allege a causal connection between his grievances and any adverse action taken by the prison officials.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court’s dismissal. The Fourth Circuit held that Hodges’s Eighth Amendment claim failed because he voluntarily exposed himself to the conditions he complained about, and thus, the prison officials did not inflict those conditions upon him. The court also found that Hodges’s First Amendment retaliation claim was insufficient because he did not adequately allege a causal relationship between his grievances and the denial of his Work Release application. The court noted that the temporal gap between his grievance and the adverse action was too long to support an inference of causation.The Fourth Circuit modified the district court’s dismissal to be without prejudice, allowing Hodges the opportunity to amend his complaint if he could address the deficiencies identified by the court. View "Hodges v. Meletis" on Justia Law

Kenneth Ray Jenkins, a pretrial detainee at Wilson County Detention Center (WCDC) in 2018, alleged that he was subjected to unsanitary living conditions, including confinement in cells infested with feces, which led to a bacterial illness. Jenkins, who suffers from mental health disorders, claimed that he was denied his medication, placed in solitary confinement, and later moved to an unsanitary "Rubber Room." He further alleged that he was denied medical attention for severe rectal bleeding for several months, which resulted in a diagnosis of multiple medical conditions.Jenkins filed a pro se complaint under 42 U.S.C. § 1983, asserting violations of his Fourteenth Amendment rights. The United States District Court for the Eastern District of North Carolina dismissed most of his claims but allowed his conditions-of-confinement and deliberate-indifference claims against Sheriff Calvin Woodard to proceed. Jenkins requested additional time for discovery and appointment of counsel, both of which were denied by the district court. The court granted summary judgment in favor of Sheriff Woodard, finding that Jenkins failed to demonstrate a material factual dispute.The United States Court of Appeals for the Fourth Circuit reviewed the case and found that the district court abused its discretion in denying Jenkins’s requests for counsel and additional time for discovery. The appellate court noted that Jenkins’s severe mental illness, lack of legal knowledge, and inability to access legal materials and evidence while incarcerated demonstrated that he lacked the capacity to present his claims. The Fourth Circuit reversed the district court’s denials of Jenkins’s requests for discovery and counsel, vacated the summary judgment decision, and remanded the case for further proceedings, directing the district court to appoint counsel for Jenkins. View "Jenkins v. Woodard" on Justia Law

Petitioners opened brokerage accounts with Stifel, Nicolaus & Company, managed by Coleman Devlin. Dissatisfied with Devlin's performance, they filed for arbitration with the Financial Industry Regulatory Authority (FINRA), alleging negligence, breach of contract, breach of fiduciary duty, negligent supervision, and violations of state and federal securities laws. After nearly two years of hearings, the arbitration panel ruled in favor of Stifel and Devlin without providing a detailed explanation, as the parties did not request an "explained decision."Petitioners moved to vacate the arbitration award in the United States District Court for the District of Maryland, arguing that the arbitration panel manifestly disregarded the law, including federal securities law. The district court denied the motion, stating that the petitioners failed to meet the high standard required to prove manifest disregard of the law. The court noted that the petitioners were essentially rearguing their case from the arbitration.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court noted that the Supreme Court's decision in Badgerow v. Walters requires an independent jurisdictional basis beyond the Federal Arbitration Act (FAA) itself for federal courts to have jurisdiction over petitions to vacate arbitration awards. Since the petitioners did not provide such a basis, the Fourth Circuit vacated the district court's judgment and remanded the case with instructions to dismiss the petition for lack of jurisdiction. The court emphasized that claims of manifest disregard of federal law do not confer federal-question jurisdiction. View "Friedler v. Stifel, Nicolaus, & Company, Inc." on Justia Law

Harris Ford, an inmate in the North Carolina Department of Corrections, filed a lawsuit against six prison officials under 42 U.S.C. § 1983, alleging that they violated his Eighth Amendment rights by failing to protect him from an attack by another inmate. Ford claimed that he had informed the officials of the risk through numerous complaints and grievances, but they were deliberately indifferent, leading to the attack where he was severely injured.The United States District Court for the Middle District of North Carolina granted summary judgment in favor of the prison officials. The court concluded that Ford's complaints were not specific enough to enable the officials to investigate and respond appropriately. Additionally, the court found that Ford failed to demonstrate the necessary mens rea of deliberate indifference required for an Eighth Amendment violation.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's judgment regarding five of the six prison officials. The appellate court agreed that Ford did not provide sufficient evidence to show that these officials were deliberately indifferent to his safety. However, the court vacated the summary judgment concerning Officer Jerry Ingram. The court found that there was a genuine issue of material fact regarding whether Ingram's actions, specifically his public questioning of Ford about the threats, knowingly exacerbated the risk to Ford and contributed to the attack. The case was remanded for further proceedings against Officer Ingram. View "Ford v. Hooks" on Justia Law

The case revolves around the tragic death of sixteen-year-old Peyton Alexander Ham. His mother, Kristee Ann Boyle, acting as the representative of his estate, filed a lawsuit against State Trooper Joseph Charles Azzari Jr. for excessive force under 42 U.S.C. § 1983, and for assault, battery, and intentional infliction of emotional distress under Maryland state law. The incident occurred when Azzari responded to a dispatch reporting a suspicious man with a gun. Upon arrival, Azzari encountered Ham, who he believed was holding a gun. Azzari fired at Ham, who was actually holding a replica of a Sig Sauer. Azzari then noticed Ham had a knife and fired additional shots, resulting in Ham's death.The district court denied Boyle's request for additional time for discovery and granted Azzari's pre-discovery motion for summary judgment. The court determined that the evidence Boyle sought could not create a triable issue of fact regarding her claims and held that Azzari was entitled to summary judgment because his actions were reasonable even under Boyle’s proffered account of the relevant events.The United States Court of Appeals for the Fourth Circuit disagreed with the lower court's decision. The appellate court concluded that discoverable evidence could create a material dispute of fact and thus the district court abused its discretion in denying Boyle an opportunity to conduct discovery. The court did not assess the lower court's determination on the merits, but reversed its denial of Boyle’s motion for discovery, vacated its grant of summary judgment to Azzari as premature, and remanded the case for additional proceedings. View "Boyle v. Azzari" on Justia Law

The case involves Johnnie Simmons, Jr., who filed a pro se action against Hampton Roads Regional Jail corrections officers R. Whitaker, Benjamin Hull, and Derrick Brown. Simmons claimed that during an incident on February 8, 2019, Officer Whitaker choked him, which was caught on videotape. The district court granted summary judgment to Officers Hull and Brown, finding that their conduct did not violate the Eighth Amendment. Simmons appealed the decision.The district court had dismissed Officer Whitaker from the case due to lack of service. Officers Hull and Brown filed motions for summary judgment, arguing that the video footage and multiple officer affidavits established that Simmons could not prevail on his § 1983 bystander liability claims. The district court granted summary judgment for the defendants, crediting the video and the officers’ version of the event.The United States Court of Appeals for the Fourth Circuit found that the district court erred in its summary judgment analysis. The court held that the video evidence did not blatantly contradict Simmons's account, and the district court improperly ignored material admissible evidence in Simmons’s affidavit. The court also found that the district court applied the wrong legal standard, using the Eighth Amendment standard instead of the Fourteenth Amendment standard applicable to pre-trial detainees. The court affirmed in part, reversed in part, and remanded in part the district court's decision. View "Simmons v. Whitaker" on Justia Law

A group of plaintiffs sued multiple defendants, including white nationalists, white supremacists, and neo-Nazis, for their roles in the violent "Unite the Right" rally in Charlottesville, Virginia, in 2017. The plaintiffs alleged that the defendants conspired to commit racially motivated violence. A jury awarded the plaintiffs over $26 million in damages, including a historic $24 million in punitive damages. However, the district court reduced the punitive damages to $350,000, applying Virginia's punitive damages cap across all plaintiffs.The defendants appealed, challenging the district court's decision to hold them jointly and severally liable for the compensatory damages award. The plaintiffs cross-appealed, challenging the district court's application of Virginia's punitive damages cap.The United States Court of Appeals for the Fourth Circuit affirmed the district court's imposition of joint-and-several liability for the compensatory damages. However, the court held that Virginia's punitive damages cap applies on a per-plaintiff basis, not across all plaintiffs. Therefore, the court vacated the district court's ruling on the punitive damages cap and remanded the case with instructions to apply the cap accordingly. View "Sines v. Hill" on Justia Law