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

Three individuals living with well-managed HIV, whose infections are controlled by daily medication and who have undetectable viral loads, sought to join or rejoin the U.S. Army. They were denied enlistment based on Department of Defense and Army policies that list HIV infection as a disqualifying medical condition, alongside numerous other chronic or communicable diseases. A nonprofit organization, Minority Veterans of America, also supported their challenge. The plaintiffs argued that these policies violate their equal protection rights under the Fifth Amendment and are arbitrary and capricious in violation of the Administrative Procedure Act.The United States District Court for the Eastern District of Virginia granted summary judgment to the plaintiffs. The court issued a permanent injunction barring the Military from denying accession to asymptomatic HIV-positive individuals with undetectable viral loads, prohibiting enforcement of HIV-specific policy provisions, and ordering reevaluation of prior decisions made under these policies. The district court concluded that the Military’s justifications—based on medical, cost, and diplomatic concerns—were irrational, arbitrary, and capricious.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the judgment. Applying rational basis review with heightened deference to military judgments, the Fourth Circuit found that the Military’s policies were rationally related to legitimate military purposes, including maintaining deployable, medically fit servicemembers, minimizing complications from chronic conditions, controlling costs, and addressing diplomatic issues with foreign host nations. The court distinguished this case from Roe v. Department of Defense, which concerned policies for current servicemembers rather than initial entry. The Fourth Circuit held that the Military’s HIV accession policy did not violate the Fifth Amendment or the APA and reversed the district court’s judgment, remanding with instructions to enter judgment for the Military. View "Wilkins v. Hegseth" on Justia Law

Daqua Ritter was indicted for three federal crimes connected to the murder of Ernest “Dime” Doe, a transgender woman in rural South Carolina. Ritter and Doe had a secretive sexual relationship, and Ritter was sensitive about public knowledge of this relationship, especially since Doe openly referred to Ritter as her boyfriend. Evidence at trial showed Ritter pressured Doe to keep their relationship hidden and reacted angrily when others mentioned it. Doe was found shot dead in a car, and Ritter was last seen with her hours before her death. After the murder, Ritter disposed of his gun and burned his clothes. A federal grand jury indicted Ritter for willfully causing bodily injury based on Doe's gender identity resulting in death, using a gun during a crime of violence, and making false statements to investigators.The United States District Court for the District of South Carolina presided over Ritter’s trial. A jury convicted Ritter on all charges, and the district court sentenced him to life in prison. Ritter moved for a new trial, claiming juror bias and prejudicial hearsay testimony, and challenged the sufficiency of evidence for two counts. The district court held an evidentiary hearing regarding juror bias and denied the motion for a new trial, finding the juror credible and impartial. It also denied the motion for a mistrial based on hearsay, issuing a curative instruction to disregard the testimony.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the district court did not abuse its discretion in finding no juror bias or in denying a mistrial based on hearsay, as the curative instruction was sufficient. The court also found that, viewed in the light most favorable to the government, there was sufficient evidence for the jury to convict Ritter on all counts, including motive based on gender identity and the likelihood that false statements would be communicated to federal law enforcement. The judgment was affirmed. View "United States v. Ritter" on Justia Law

A resident of a retirement community, who has celiac disease and relies on a gluten free diet, experienced multiple episodes of illness after consuming meals labeled as gluten free at the facility. She signed a residential contract based on assurances that her dietary needs would be accommodated. Over several years, she reported incidents of illness to staff, including a crab cake in 2018, a stuffed tomato in 2020, and chicken marsala in 2021, all purportedly gluten free. The facility made various adjustments in response to her complaints, including menu changes, staff training, and kitchen modifications. She continued to use her meal plan but gave away the food. In 2023, she filed suit alleging violations of federal disability rights statutes and several state-law claims.The United States District Court for the District of Maryland granted summary judgment to the retirement community on all claims. The court found her federal claims untimely and denied her request for injunctive relief, concluding she lacked standing. It also rejected her state-law breach of contract and negligence claims, holding they were barred by the statute of limitations and unsupported by evidence.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court’s judgment as to the federal claims, holding that the plaintiff lacked standing for injunctive relief under the Americans with Disabilities Act and that her Fair Housing Act and Rehabilitation Act claims were barred by the applicable statutes of limitations. It also affirmed dismissal of state-law claims related to the 2018 incident. However, the court vacated summary judgment as to her breach of contract and negligence claims arising from the January 2021 chicken marsala incident, finding genuine issues of material fact that should be resolved by a jury. The case was remanded for further proceedings on those claims. View "McGinn v. Broadmead, Inc." on Justia Law

While incarcerated in the general population at Central Prison in North Carolina, an individual was violently attacked by a “safekeeper”—a pre-trial detainee designated as requiring strict separation due to risk of violence. On the day in question, prison correctional officers responsible for enforcing separation between safekeepers and the general population failed to keep key security doors closed, contrary to prison policy. This lapse allowed the safekeeper to encounter and assault the plaintiff, resulting in severe facial injuries and lasting pain.The plaintiff brought a lawsuit under 42 U.S.C. § 1983 against three correctional officers, alleging deliberate indifference to his safety in violation of the Eighth Amendment. The United States District Court for the Eastern District of North Carolina granted summary judgment to the officers, finding that the record did not support a jury finding of Eighth Amendment liability and concluding that, even if it did, the officers were entitled to qualified immunity. The district court also allowed the officers, over the plaintiff’s objection, to file a late response to a summary judgment motion without applying the “excusable neglect” standard required under Federal Rule of Civil Procedure 6(b).The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that genuine disputes of material fact remained regarding both the officers’ liability for deliberate indifference and the applicability of qualified immunity. The Fourth Circuit further found that the district court had abused its discretion by failing to consider the correct standard when granting an extension of time for the officers’ late filing. The court vacated the district court’s summary judgment and extension orders, and remanded the case for further proceedings with instructions to apply the proper legal standards. View "Case v. Beasley" on Justia Law

The case concerns the non-reappointment of a local general registrar of elections in Lynchburg, Virginia. The plaintiff, previously appointed unanimously by a bipartisan electoral board, reapplied for her position after her term expired in 2023. By that time, the board’s partisan makeup had shifted to include two Republicans and one Democrat, reflecting state law. The board interviewed four candidates, including the plaintiff, but ultimately appointed a different candidate who was a registered Republican. The plaintiff, describing herself as an independent, alleged her non-reappointment was due to partisan bias rather than job performance.Following the board’s decision, the plaintiff sued the board and its two Republican members, alleging First Amendment violations tied to political animus. The United States District Court for the Western District of Virginia dismissed the claim against the board itself on sovereign immunity grounds, but allowed the suit against the individual members to proceed. After a jury trial, the verdict favored the defendants. The plaintiff then appealed, raising concerns about jury selection procedures and the exclusion of certain evidence.The United States Court of Appeals for the Fourth Circuit reviewed the appeal. It held that the district court did not abuse its discretion in managing voir dire, including its refusal to allow more pointed questioning about potential jurors’ political affiliations and beliefs. The Fourth Circuit also determined that the plaintiff had not preserved most evidentiary challenges for appellate review, as she failed to make sufficient proffers or obtain definitive rulings on excluded evidence. For the limited evidentiary exclusions properly preserved, the appellate court found no abuse of discretion. Thus, the Fourth Circuit affirmed the judgment in favor of the defendants. View "Gibbons v. Gibbs" on Justia Law

A group of nine individuals, representing a putative class, alleged that a credit union systematically discriminated against racial minorities in its residential mortgage lending practices. The plaintiffs varied in racial background (eight Black, one Latino), state of residence, type of loan product sought, and financial circumstances. Despite these differences, they claimed the credit union used a single, semi-automated underwriting process for all applicants, which, through its proprietary algorithm, resulted in discriminatory outcomes against minority applicants. The complaint sought both damages and injunctive relief, and proposed a class consisting of all minority applicants for mortgage-related products from 2018 to the present who faced adverse actions compared to similarly situated non-minority applicants.The United States District Court for the Eastern District of Virginia partially granted the defendant’s motion to dismiss and struck the class allegations, relying on Federal Rules of Civil Procedure 12(f) and 23(d)(1)(D). The district court focused on the diversity of the plaintiffs’ circumstances, suggesting that the variations in loan types and applicant characteristics defeated the possibility of class certification, particularly under Rule 23(b)(3).On interlocutory appeal, the United States Court of Appeals for the Fourth Circuit addressed the standards governing class certification denials at the pleading stage before discovery. The Fourth Circuit held that district courts should only deny class certification at this stage if, on the face of the complaint, the Rule 23 requirements are not met as a matter of law. The appellate court affirmed the district court’s denial of class certification under Rule 23(b)(3), finding the lack of predominance and superiority apparent from the complaint due to the differences among the plaintiffs. However, the Fourth Circuit vacated the district court’s order as to Rule 23(b)(2), concluding that the complaint sufficiently alleged commonality for classwide declaratory and injunctive relief, and that the district court acted prematurely in denying certification under that provision. View "Oliver v. Navy Federal Credit Union" on Justia Law

Three advocacy organizations filed suit against the South Carolina Department of Juvenile Justice and its executive director, seeking institutional reforms to address alleged unconstitutional and unlawful conditions in the state’s juvenile detention facilities. The plaintiffs alleged that the facilities were overcrowded, understaffed, and dangerous, resulting in violence, isolation, and inadequate services for juveniles. They based their standing on their advocacy and direct representation work with affected youth, and described both the harm to juveniles and the impact on their own organizational missions.The United States District Court for the District of South Carolina dismissed the complaint without prejudice. The district court found that Disability Rights South Carolina (DRSC) had standing to sue on behalf of certain juveniles, but those claims were rendered moot when those juveniles left custody. The court also determined that Justice 360 had standing in its own right but concluded that its claims failed on the merits. The South Carolina State Conference of the NAACP was found to lack standing. The plaintiffs appealed the dismissal.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo and affirmed the district court’s dismissal. The Fourth Circuit held that the advocacy organizations lacked Article III standing to pursue the claims because they failed to demonstrate a sufficient personal stake in the outcome. The court found that DRSC did not meet the requirements for associational standing as its constituents lacked indicia of membership. The court also concluded that none of the organizations suffered a cognizable injury directly caused by the defendants’ actions, but rather incurred self-imposed costs through voluntary advocacy. The court further held that the plaintiffs could not bring claims under 42 U.S.C. § 1983 for the violation of rights belonging to others, as they had not alleged violations of their own federal rights. The dismissal was affirmed. View "South Carolina State Conference of the NAACP v. South Carolina Department of Juvenile Justice" on Justia Law

Adrian Roberts, a military veteran suffering from severe mental health issues, was the subject of an involuntary commitment order after his wife raised concerns about his safety and possession of weapons. Law enforcement officers, including a specially trained response team, attempted to execute the order, initially trying to persuade Adrian to leave his home peacefully. When he refused, the team forcibly entered his residence. Shortly after entry, Deputy Evans shot and killed Adrian. The circumstances surrounding the shooting were disputed: Evans claimed Adrian charged at officers with a machete, while Adrian’s wife alleged he was shot in the back while facing away.The United States District Court for the Eastern District of North Carolina reviewed the case after Adrian’s wife brought claims under 42 U.S.C. § 1983, alleging excessive force and unlawful entry. The district court granted Evans qualified immunity and summary judgment on the unlawful entry claim but denied both on the excessive force claim. The court found that genuine disputes of material fact existed, particularly regarding whether Adrian posed an immediate threat or was resisting arrest, and relied on the autopsy report suggesting Adrian may have been shot from behind. Because these factual disputes remained, the court concluded that a reasonable jury could find Evans violated Adrian’s clearly established rights.On appeal, the United States Court of Appeals for the Fourth Circuit considered whether it had jurisdiction to review the district court’s denial of qualified immunity and summary judgment on the excessive force claim. The Fourth Circuit held that it lacked jurisdiction because the district court’s decision was based on unresolved factual disputes rather than purely legal questions. The court emphasized it could not weigh evidence or resolve factual disputes at this stage, and dismissed the appeal for lack of jurisdiction. View "Roberts v. Evans" on Justia Law

An African American police officer employed by the Baltimore Police Department attended a nightclub event in August 2018, where an altercation occurred between a member of her party and an on-duty police sergeant, resulting in the sergeant striking her friend. The officer testified against the sergeant before a grand jury and at his criminal trial, after which she was warned by colleagues that she was being targeted. Though criminal charges against her were declined, the department initiated internal disciplinary proceedings, ultimately filing charges against her in June 2020 for assault and making false statements. She was suspended with pay and later, after filing an EEOC complaint in February 2021 alleging race discrimination and retaliation, was forced to resign in lieu of termination in June 2022.The United States District Court for the District of Maryland reviewed her claims under Title VII and 42 U.S.C. § 1983, including allegations of race discrimination, retaliation, and municipal liability under Monell v. Department of Social Services of City of New York. The district court dismissed her original and amended complaints, concluding that she failed to plead plausible claims for relief, specifically finding her comparator evidence insufficient for the discrimination claim and that her retaliation and Monell claims lacked factual support.On appeal, the United States Court of Appeals for the Fourth Circuit applied de novo review to the district court’s dismissal. The court held that the officer had sufficiently alleged a Title VII racial discrimination claim by identifying multiple white or non-black comparators who engaged in similar conduct but received less severe discipline. However, it affirmed the dismissal of her retaliation claim, finding she failed to plausibly allege a causal connection between her protected activity and the adverse employment action. The court also affirmed the dismissal of the Monell claim, holding the complaint did not include specific factual allegations of a widespread pattern or practice. The judgment was therefore affirmed in part, reversed in part, and remanded. View "Johnson v. Baltimore City, Maryland" on Justia Law

In September 2020, a college student alleged she was sexually assaulted by a man during a late-night traffic stop in Virginia. She reported the incident to local law enforcement and participated in multiple interviews with detectives, who investigated her claims but found surveillance footage that was low-quality and recorded at a different time than the alleged assault. During a subsequent interview, detectives pressured her about inconsistencies in the evidence and, after the interview, she received threatening text messages. The detectives later told university officials she had confessed to fabricating her report. The sheriff then directed detectives to use her confession as probable cause for an arrest warrant charging her with filing a false police report. After her arrest, officers issued a press release with her personal information and photo, which led to widespread public shaming and emotional distress.Initially, she was convicted in a bench trial in Washington County District Court, but after appealing, her conviction was annulled and she was acquitted in a de novo bench trial in Washington County Circuit Court. She then sued the officers and the sheriff in the United States District Court for the Western District of Virginia, alleging violations of her constitutional rights and state law torts.The district court dismissed the complaint under Rule 12(b)(6), relying on an audio recording of the key interview. The court found the recording contradicted her claims of coercion, ruling that it showed a civil discussion without coercion and that her confession appeared voluntary. It also found her allegation of having no choice but to confess was not credible based on the recording.The United States Court of Appeals for the Fourth Circuit reviewed the case. It held that the district court erred by dismissing the complaint based on the audio recording, because the recording did not "blatantly contradict" her factual allegations as required by Fourth Circuit precedent. The appellate court vacated the dismissal and remanded the case for further proceedings. View "Bermeo v. Andis" on Justia Law