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

Justin Longworth, a federal inmate, alleged that he faced repeated sexual harassment and abuse by Sherry M. Beck, a correctional officer at the Federal Correctional Institution in Butner, North Carolina. Longworth claimed Beck engaged in daily aggressive sexual harassment and abuse, including forced oral sex, fondling, and groping. He did not immediately report Beck's conduct due to fear of retaliation. Other officials at the institution initially did nothing to stop or report Beck's abuse. Eventually, Beck was reported, fired, and Longworth was transferred to another facility, but Beck continued to harass him through letters.Longworth filed two separate lawsuits in the Eastern District of North Carolina. The first lawsuit was a Bivens action against the officials directly involved, alleging violations of his civil rights under the Fourth and Eighth Amendments. The district court dismissed the Bivens claims, finding that they presented new contexts and that special factors counseled hesitation in extending Bivens to this context. Longworth appealed the dismissal of his Bivens claims. The second lawsuit was an FTCA claim against the United States, alleging negligence by the officials. The district court dismissed the FTCA claim for lack of subject matter jurisdiction, finding that Beck was not acting within the scope of her employment during the alleged misconduct. Longworth did not appeal the FTCA judgment.The United States Court of Appeals for the Fourth Circuit reviewed the case and concluded that the district court's FTCA judgment precluded Longworth's Bivens appeal. The FTCA judgment bar provides that an FTCA judgment is a complete bar to any action by the claimant against the employee of the government whose act or omission gave rise to the claim. Since a judgment on the FTCA claim had been entered, Longworth could no longer pursue his Bivens action based on the same conduct. Consequently, the Fourth Circuit dismissed the appeal. View "Longworth v. Mansukhani" on Justia Law

In September 2020, inmate Garfield Holley, proceeding pro se, sued several officers at Wallens Ridge State Prison under Section 1983. Holley alleged that the officers transported him to a dental appointment in a dog cage and subjected him to subsequent mistreatment. He claimed that this treatment was in retaliation for filing a grievance about a delayed medical procedure. Holley, who has asthma, described being chained in a padlocked dog cage in near-freezing temperatures for over six hours, leading to pneumonia and delayed medical care. He also alleged a pattern of retaliatory treatment against prisoners who complained about their conditions.The United States District Court for the Western District of Virginia dismissed Holley's complaint without prejudice for failing to pay the filing fee, citing the three-strikes rule under the Prison Litigation Reform Act. The court found that Holley had not adequately alleged imminent danger of serious physical injury, as the incidents described occurred approximately two years before the complaint was filed. Holley's motion for reconsideration was denied, and he timely appealed.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The court concluded that Holley had adequately pleaded imminent danger of serious physical injury, noting the specificity of his allegations and the ongoing pattern of retaliatory treatment against prisoners at Wallens Ridge State Prison. The court found that Holley's allegations were sufficient to meet the imminent-danger exception to the three-strikes rule. Consequently, the Fourth Circuit reversed the district court's decision and remanded the case for further proceedings. View "Holley v. Combs" on Justia Law

Jacob Doe, a student at the University of North Carolina at Chapel Hill (UNC-CH), was found responsible for two allegations of sexual misconduct and subsequently expelled from the university system. Doe sued the university and several employees, claiming violations of his Fourteenth Amendment due process rights, Title IX, and various state laws. The district court largely denied the defendants' motions to dismiss, allowing Doe’s federal and most state law claims to proceed.The defendants appealed to the United States Court of Appeals for the Fourth Circuit. The appellate court found that the district court erred in rejecting the defendants' claims of sovereign and qualified immunity. The court held that the UNC institutions were entitled to sovereign immunity, reversing the district court’s decision to allow Doe’s claims against them. Additionally, the court determined that the individual university employees were entitled to qualified immunity regarding Doe’s due process claims for damages, as the right to cross-examination in university disciplinary proceedings was not clearly established at the time.However, the appellate court affirmed the district court’s decision to allow Doe to seek prospective injunctive relief for the alleged due process violations. The court recognized that Doe had adequately alleged a liberty interest due to the permanent expulsion and the ongoing harm from the erroneous disciplinary record. The court declined to exercise pendent appellate jurisdiction over the district court’s denial of the motion to dismiss Doe’s Title IX claim against UNC-CH, dismissing that portion of the appeal for lack of jurisdiction.In conclusion, the Fourth Circuit affirmed in part, reversed in part, and dismissed in part the district court’s rulings, allowing Doe’s claims for prospective injunctive relief to proceed while dismissing his claims for damages against the UNC institutions and individual employees. View "Doe v. The University of North Carolina System" on Justia Law

A retired teacher, Patsy Talley, received overpayments in her retirement benefits from the North Carolina Teachers’ and State Employees’ Retirement System (TSERS) for over eight years, totaling $86,173.93. When the overpayment was discovered, TSERS began reducing her monthly benefits to recoup the overpaid amount. Talley did not dispute the overpayment but argued that the recoupment process violated her due process rights because she was not provided a hearing before the reductions began.The United States District Court for the Eastern District of North Carolina dismissed all of Talley’s claims. The court held that her official capacity claims were barred by the Eleventh Amendment, her substantive due process claim failed because she received adequate post-deprivation process, and her equal protection claim did not allege a fundamental right or suspect class. The court also dismissed her individual capacity procedural due process claim, finding the defendants were entitled to qualified immunity. Additionally, the court denied Talley’s motion to amend her complaint to add new plaintiffs, citing procedural deficiencies and lack of good cause.The United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The appellate court agreed that the Eleventh Amendment barred the official capacity claims and that the individual capacity claims were barred by qualified immunity. The court found that Talley failed to state a substantive due process claim because she received adequate post-deprivation process and that her equal protection claim did not meet the rational basis review. The court also upheld the denial of her motion to amend the complaint, finding no abuse of discretion by the district court. View "Talley v. Folwell" on Justia Law

Brooke N. Somers, a resident of Cecil County, Maryland, attended a Board of Education meeting on February 9, 2022, without wearing a mask, contrary to Maryland state emergency regulations. Officer Anthony Devine and John Roush informed her she could not enter without a mask. Somers claimed a medical exemption but was directed to sit in the lobby and watch the meeting via livestream. After causing a disturbance in the lobby and refusing to lower her volume or leave when ordered, Somers was arrested by Officer Devine. She resisted arrest, leading to a minor scuffle. Somers was charged with several offenses, convicted on two counts, but later acquitted on appeal.Somers filed a complaint in the United States District Court for the District of Maryland against multiple defendants, including Officer Devine. The district court dismissed claims against all defendants except Devine, granting him summary judgment on the basis of qualified immunity for all federal-law claims, including retaliatory arrest, unlawful arrest, excessive force, and malicious prosecution.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that an objectively reasonable officer could have found probable cause for Somers' arrest, thus entitling Officer Devine to qualified immunity on the retaliatory arrest, unlawful arrest, and malicious prosecution claims. The court also found that the force used by Officer Devine was minimal and reasonable given Somers' resistance, granting him qualified immunity on the excessive-force claims. Consequently, the Fourth Circuit affirmed the district court's judgment. View "Somers v. Devine" on Justia Law

Brian Farabee, who suffers from borderline personality disorder, has spent his adult life in hospitals or prison for crimes committed while hospitalized. He filed a lawsuit under 42 U.S.C. § 1983 against Dr. Robert Gardella, Dr. Christy McFarland, and Daniel Herr, alleging violations of his constitutional rights and the Americans with Disabilities Act. Farabee claimed that the defendants denied him clinically recommended treatment, unnecessarily restrained and isolated him, forcibly medicated him, and discriminated against him.The United States District Court for the Western District of Virginia granted summary judgment in favor of the defendants without allowing Farabee to conduct discovery or ensuring he was informed of Federal Rule of Civil Procedure Rule 56’s requirements. The court concluded that there was no material dispute of fact and that the defendants were entitled to summary judgment.The United States Court of Appeals for the Fourth Circuit reviewed the case and found that the district court erred in granting summary judgment before allowing Farabee to conduct discovery. The appellate court emphasized that summary judgment should only be granted after adequate time for discovery and that the district court should have provided Farabee, a pro se litigant, with an opportunity to gather evidence. The Fourth Circuit reversed and vacated the district court’s summary judgment decision and remanded the case for further proceedings. The appellate court also recommended that the district court appoint counsel to assist Farabee in litigating the case due to its complexity and Farabee’s limited ability to conduct discovery on his own. View "Farabee v. Gardella" on Justia Law

Jason Wayne Gowen, a pretrial detainee at the Lynchburg Adult Detention Center, was placed in solitary confinement for 125 days after complaining about hot conditions in his cell and encouraging other inmates to do the same. Gowen filed a lawsuit against several correctional officers, alleging violations of his First Amendment rights due to retaliation for his grievances and his Fourteenth Amendment rights for being placed in solitary confinement without due process.The United States District Court for the Western District of Virginia dismissed Gowen’s First Amendment retaliation claim, stating that he failed to show a causal connection between his grievances and the adverse actions taken against him. The court later granted summary judgment to the officers on Gowen’s Fourteenth Amendment due process claim, concluding that he failed to exhaust his administrative remedies as required by the Prison Litigation Reform Act.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that Gowen adequately alleged a First Amendment retaliation claim by showing that he engaged in protected activity, faced adverse action, and established a causal connection through temporal proximity and the officers' awareness of his grievances. The court also determined that Gowen did not forfeit his argument regarding the exhaustion of administrative remedies, as his verified complaint contained sufficient evidence of his attempts to use the grievance process and the officers' failure to respond.The Fourth Circuit reversed the district court’s dismissal of Gowen’s First Amendment retaliation claim and vacated the summary judgment on his Fourteenth Amendment due process claim. The case was remanded for further proceedings consistent with the appellate court’s findings. View "Gowen v. Winfield" on Justia Law

Several property management companies advertised their apartment buildings on Facebook, targeting users who are 50 years old or younger. Neuhtah Opiotennione, who is older than 50, did not see these advertisements and claimed that the companies discriminated against her based on her age. She filed a lawsuit seeking a declaratory judgment, a permanent injunction, and damages.The United States District Court for the District of Maryland dismissed Opiotennione’s complaint, ruling that she lacked standing to sue because she had not suffered a concrete and particularized injury in fact. The court found that Opiotennione had not demonstrated how the alleged discrimination personally affected her.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo and affirmed the district court’s decision. The Fourth Circuit held that Opiotennione failed to allege a concrete and particularized injury in fact. The court noted that merely being a member of the disfavored age group did not constitute a particularized injury. Additionally, the court found that Opiotennione did not allege that she was personally denied information or housing opportunities by the defendants, as she had not actively sought information from them. The court also rejected her claims of informational and stigmatic injuries, concluding that she had not demonstrated a personal denial of information or a concrete stigmatic injury. Thus, the Fourth Circuit affirmed the district court’s dismissal of the case for lack of standing. View "Opiotennione v. Bozzuto Management Co." on Justia Law

In the early morning of November 1, 2019, a group of law enforcement officers, including Task Force Officer (TFO) Clarence Belton and Charlotte-Mecklenburg Police Officer Heather Loveridge, attempted to execute a search warrant at the house of a suspect, Larry McConneyhead, in Charlotte, North Carolina. During the operation, McConneyhead fled into his house, and a confrontation ensued. TFO Belton was accidentally shot by Officer Loveridge, who mistook him for the suspect. Belton suffered severe injuries, leading to multiple surgeries and permanent disability.The case was initially filed in North Carolina state court and then removed to the United States District Court for the Western District of North Carolina. Belton alleged excessive force under 42 U.S.C. § 1983 and several state law claims against Officer Loveridge and the City of Charlotte. Officer Loveridge moved for summary judgment, asserting qualified immunity for the federal claim and public officers’ immunity for the state claims. The district court denied her motion, citing genuine disputes of material fact regarding the circumstances of the shooting.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that the district court failed to conduct the proper analysis for determining qualified immunity, which requires identifying the specific constitutional right violated and whether that right was clearly established at the time of the incident. The Fourth Circuit vacated the district court’s order and remanded the case for further proceedings, instructing the lower court to apply the correct legal standards for qualified immunity and public officers’ immunity. View "Belton v. Loveridge" on Justia Law

Angelo Jackson was identified as a suspect in a double murder in Montgomery County, Maryland, based on information from law enforcement officers. Detective Michael Carin used this information to obtain an arrest warrant for Jackson. After Jackson's arrest, Carin continued the investigation and found exculpatory evidence, including DNA and cellphone records, which led to the charges being dropped and Jackson's release after 65 days of detention.Jackson filed a lawsuit against Carin, alleging that Carin's affidavit for the arrest warrant and his grand jury testimony were deliberately false or made with reckless disregard for the truth. Jackson claimed that if the commissioner and grand jury had been presented with truthful evidence, they would not have found probable cause for his arrest and indictment.The United States District Court for the District of Maryland granted summary judgment in favor of Carin, finding that even with disputed material removed, the affidavit still provided probable cause for Jackson's arrest. The court also found that Carin was protected by qualified immunity on Jackson's federal claims and dismissed Jackson's gross negligence claim under Maryland law.The United States Court of Appeals for the Fourth Circuit affirmed the district court's judgment. The court concluded that Carin did not violate legal standards in his investigation and was shielded by qualified immunity. The court also found that Carin's actions were reasonable and based on information he received from other officers, and that Jackson failed to meet the burden of proving that Carin's statements were false, made with reckless disregard for the truth, or material to the probable cause determination. View "Jackson v. Carin" on Justia Law