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

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

The case concerns the fatal shooting of Kwamena Ocran by four Gaithersburg Police Department officers in January 2021. Ocran, who had recently been released from prison and was reported by a confidential informant to be armed, was surveilled by the officers after the informant indicated Ocran might attempt to sell a handgun. When Ocran left an apartment with the informant and was approached by the officers, he fled. The officers pursued him, and during the chase, multiple officers reported seeing a muzzle flash and believed Ocran fired a weapon in their direction. The officers collectively discharged 27 rounds, resulting in Ocran’s death. Forensic evidence revealed Ocran was shot multiple times in the back, and a handgun was found near his body, though no evidence indicated it had been fired.After discovery, Melody Cooper, Ocran’s mother and personal representative, brought a 42 U.S.C. § 1983 claim alleging excessive force in violation of the Fourth Amendment. The United States District Court for the District of Maryland denied the officers’ motion for summary judgment and rejected their claim of qualified immunity, finding genuine disputes of material fact existed—particularly regarding whether Ocran pointed or fired his weapon at the officers. The court also denied the officers’ motion for reconsideration.On appeal, the United States Court of Appeals for the Fourth Circuit dismissed the officers’ appeal to the extent it challenged the district court’s findings of disputed material facts, as such findings are not reviewable under the collateral order doctrine. The Fourth Circuit affirmed the district court’s ruling that, accepting the undisputed facts, the officers were not entitled to qualified immunity because the right to be free from deadly force when fleeing and not posing a significant threat was clearly established at the time of the incident. The case was remanded for further proceedings, including a jury trial. View "Cooper v. Doyle" on Justia Law

A sixteen-year-old boy and his friend were waiting for transportation under a carport near the boy’s home when they were approached by an off-duty Baltimore City police officer who had just returned from firearms training. The officer, dressed in plain clothes and carrying a loaded handgun, questioned the boys about their presence in the neighborhood. After a brief exchange, the officer brandished his gun at “low ready,” causing the boys to fear for their lives. The incident had a lasting traumatic effect on the boy, resulting in emotional distress, behavioral changes, and ultimately leading him to attend a boarding school to distance himself from the event.The boy filed suit under 42 U.S.C. § 1983 and Maryland state law against the officer, the Baltimore Police Department, the Mayor and City Council of Baltimore, and the State of Maryland. All claims against the institutional defendants were dismissed by the United States District Court for the District of Maryland, and some claims against the officer were dismissed at summary judgment. At trial, the district court submitted to the jury both constitutional claims and state law gross negligence claims, including gross negligence in the officer’s capacity as a private person. The jury found for the officer on constitutional claims but found him grossly negligent as a private person, awarding $250,000 in compensatory damages for emotional harm. The officer moved to alter or amend the judgment or for a new trial, arguing lack of notice on the private person claim and excessiveness of damages, but the district court denied the motion.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed. The court held that the complaint sufficiently alleged gross negligence as a private person and that the officer had notice of this claim. The court rejected the officer’s arguments regarding supplemental jurisdiction, plain error in jury instructions, and excessiveness of damages, finding no abuse of discretion or plain error by the district court. The judgment was affirmed. View "Nicholson v. Durant" on Justia Law

A Black woman who had worked for a community college for nearly two decades applied for a promotion to Assistant Dean of Workforce Solutions after serving as Director of Special Populations. The position required significant experience in workforce development, including knowledge of specific funding and grant-writing. The applicant pool included her and a Hispanic male colleague who had overseen larger programs and had more direct experience with the job’s requirements. A search committee interviewed candidates, with the final hiring decision made by the Vice President of Enrollment and Outreach Initiatives.The United States District Court for the District of Maryland initially dismissed her claims of race and gender discrimination under Title VII. On appeal, the United States Court of Appeals for the Fourth Circuit reversed and remanded in part, allowing her to pursue a disparate treatment claim focused on the college’s failure to promote her and its issuance of a corrective action letter for a payroll error. Following discovery, the district court granted summary judgment for the college, finding that the plaintiff did not present sufficient evidence of intentional discrimination, and that the employer’s stated reason—selecting the more qualified candidate—was not shown to be pretextual.Reviewing the case de novo, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s grant of summary judgment. The court assumed that the plaintiff established a prima facie case of discrimination but held that she did not meet her burden to show the employer’s justification was pretext. The court found that the selected candidate’s qualifications aligned more closely with the position, and that neither evidence of preselection, circumstantial evidence of discriminatory comments, nor disparate discipline sufficed to demonstrate intentional discrimination or pretext. The court thus affirmed the judgment in favor of the college. View "Hood-Wilson v. Board of Trustees, Community College of Baltimore" on Justia Law

An Indian professor employed at a public university in North Carolina applied for tenure after a probationary period, but his initial application was denied following negative evaluations from colleagues concerning his teaching, mentorship, and administrative performance. Several years later, the same professor reapplied and was granted tenure. After receiving tenure, he sued various university officials, alleging that the original denial was the result of racial discrimination in violation of the Equal Protection Clause and 42 U.S.C. § 1981, as well as retaliation for his non-traditional teaching methods in violation of the First Amendment. His complaint focused on negative statements and actions by two specific colleagues, while also asserting that other officials enabled or failed to remedy alleged bias.The United States District Court for the Eastern District of North Carolina dismissed the complaint for failure to state a claim under Rule 12(b)(6). The court found that the plaintiff’s allegations of racial discrimination were unsupported by facts connecting any defendant’s actions to race, and that his First Amendment retaliation claim failed to identify protected speech or a causal link between such speech and the tenure decision.The United States Court of Appeals for the Fourth Circuit affirmed the district court’s dismissal. The Fourth Circuit held that the plaintiff’s allegations did not plausibly suggest he was treated differently than similarly situated colleagues because of his race, as required for Equal Protection and § 1981 claims. The court also concluded that the complaint failed to plausibly allege protected speech or retaliation under the First Amendment. The Fourth Circuit emphasized the limited judicial role in reviewing academic tenure decisions and declined to address qualified immunity, as no plausible claim was stated. Thus, the district court’s judgment was affirmed. View "Katti v. Arden" on Justia Law

The plaintiff, a community advocate, posted a lengthy video—obtained from internal office security footage of a local police department—on his Facebook page. Only a few department employees had access to this footage. In response, a special agent from the Virginia State Police investigated how the plaintiff obtained the video, suspecting possible computer trespass under Virginia law. The agent sought and obtained warrants to search the plaintiff’s Facebook and Gmail accounts, believing these accounts might contain evidence relevant to the investigation. Although the plaintiff moved to quash both warrants for lack of probable cause, a state court denied the motions, and the Supreme Court of Virginia refused his appeal. Ultimately, the local prosecutor determined there was insufficient evidence to charge anyone with computer trespass.Following these events, the plaintiff filed a federal lawsuit in the United States District Court for the Western District of Virginia, alleging that the searches violated his First and Fourth Amendment rights and were conducted in retaliation for his criticism of local government. After amending his complaint once, the plaintiff sought to amend it a second time. The district court dismissed his claims, concluding that his failure to plead the absence of probable cause was fatal, and denied leave to amend as futile.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court’s decisions. The Fourth Circuit held that, in order to state a First Amendment retaliatory search claim, the plaintiff was required to plead the absence of probable cause or show he qualified for a narrow exception, and he had done neither. The court further held that the same requirement applied to his Fourth Amendment claim. The court also agreed that denying leave to amend was proper, as the proposed amendment would not have stated a valid claim. View "Stanley v. Bocock" on Justia Law

During the COVID-19 pandemic, an employer instituted a company-wide vaccine mandate that applied to all employees, including those working remotely. Two remote employees requested religious exemptions from the vaccine requirement. One objected on the basis of her Christian beliefs regarding the use of fetal cell lines in vaccine development, while the other cited her conscience and faith, referencing Catholic teachings. Both exemption requests were denied, and the employees were subsequently terminated.After their terminations, the two employees initiated a lawsuit in the United States District Court for the District of Maryland. Their claims included religious discrimination under Title VII of the Civil Rights Act and two disability discrimination claims under the Americans with Disabilities Act (ADA): one for unlawful medical inquiry and one for being “regarded as” disabled due to their unvaccinated status. The district court dismissed all claims, concluding that the plaintiffs had not sufficiently pleaded that their objections were based on religious beliefs and finding that neither ADA theory was viable because vaccination status is not equivalent to a disability.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s decision de novo. The Fourth Circuit held that the plaintiffs’ complaints plausibly alleged that their opposition to the vaccine mandate was an essential part of their religious faith and that their refusal to be vaccinated was connected to those beliefs. Therefore, the court found that the district court erred in dismissing the Title VII religious discrimination claims at the pleading stage. However, the Fourth Circuit affirmed the dismissal of both ADA claims, holding that an inquiry into vaccination status is not a disability-related inquiry and that being unvaccinated does not constitute a physical or mental impairment under the ADA. The case was affirmed in part, vacated in part, and remanded for further proceedings on the Title VII claims. View "Finn v. Humane Society of the United States" on Justia Law

David Ray Gunter, who had a mechanical heart valve and required daily anticoagulant medication (Coumadin), was arrested and detained at two North Carolina county jails. During his detention, Gunter did not consistently receive his prescribed medication, missing doses over several days due to failures by the contracted medical provider and jail staff. After his release, he suffered serious medical complications, including blood clots and subsequent surgeries. Gunter alleged these injuries were the result of inadequate medical care during his incarceration.The United States District Court for the Middle District of North Carolina granted summary judgment for defendants on Gunter’s constitutional claims under 42 U.S.C. § 1983, including deliberate indifference and Monell claims, finding insufficient evidence that jail officials or contracted medical providers acted with deliberate indifference or that county policies caused the deprivation. The district court also granted summary judgment to Southern Health Partners, Inc. (SHP) on the medical malpractice claim, finding that Gunter’s expert testimony did not establish a breach of the standard of care by SHP, and excluded expert evidence it found speculative. However, the district court found genuine disputes of fact regarding medical malpractice claims against two individual medical providers, but ultimately found no proximate cause. The district court denied Gunter’s motion to compel deposition of the defendants’ expert as untimely and granted a motion to strike a post-deposition declaration from Gunter’s expert.The United States Court of Appeals for the Fourth Circuit reversed the district court’s dismissal of Gunter’s deliberate indifference claim against the medical provider defendants, the Monell claim against the counties, and the medical malpractice claims against SHP and two medical providers, holding that genuine disputes of material fact remained. The appellate court also reversed the exclusion of certain expert testimony and the grant of the motion to strike, but affirmed the denial of the motion to compel. The case was remanded for further proceedings. View "Swink v. Southern Health Partners Inc." on Justia Law