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

Articles Posted in Civil Rights
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In this case, the plaintiff, Ricky Pendleton, is an inmate in the West Virginia prison system who follows the "Sufi Original Traditions" of Islam. His religious beliefs require a diet that promotes "compassion and harmlessness to living creatures," which he interprets to mean a diet of "vegetables, fruits and certain fish." In 2014, prison officials introduced a new diet program for those with religious dietary restrictions. However, the program only offered one "religious special diet" designed to meet the needs of all faiths by following the rules of the most diet-restrictive ones. This diet used soy as its primary protein source, which Pendleton's body had problems digesting. Pendleton requested a religious accommodation, but this request was denied. He filed two grievances, which were also denied. Pendleton then filed a pro se complaint against three prison officials. The district court dismissed Pendleton’s complaint, concluding he had not adequately alleged he was being forced to consume any foods forbidden by his religion.The United States Court of Appeals for the Fourth Circuit vacated and remanded the district court's judgment. The court held that Pendleton had plausibly alleged that prison officials imposed a substantial burden on his religious practice by forcing him to choose between a government-provided benefit (the diet) and his religious convictions. The court also rejected the argument that Pendleton could obtain a meat-free and soy-free diet by obtaining test results showing he has a medically significant allergy to soy. The court concluded that Pendleton need not produce documentation of his alleged soy allergy to survive a motion to dismiss. Instead, it was enough that he had plausibly alleged that he cannot digest soy and that he suffered gastrointestinal distress after switching to the religious special diet. The court also held that Pendleton’s Free Exercise Clause claim and his motion to be severed from the prison’s diet program should be reconsidered by the district court. View "Pendleton v. Jividen" on Justia Law

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The plaintiff, Peter Massaro, a police officer with the Fairfax County Police Department, alleged that his employer retaliated against him by transferring him to an inferior position after he filed a complaint about discrimination in promotion practices within the department. He sought relief under Title VII of the Civil Rights Act, the Age Discrimination in Employment Act, and 42 U.S.C. § 1983. The district court granted summary judgment to Fairfax County, dismissing all of Massaro's claims. The court held that Massaro failed to establish a causal connection between his initial discrimination complaint and his subsequent job transfer.Upon appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court ruled that the time gap between Massaro's complaint and his transfer was too long to support a causal inference. It found no evidence that the transfer was a result of a scheme to punish Massaro for his complaint. Instead, the court concluded that Massaro's transfer was a result of his own subsequent behavior that led to a violation of departmental policy.The court also dismissed Massaro's First Amendment claim, ruling that his promotion complaint made via an internal grievance process did not reflect a matter of public concern, and thus did not meet the threshold for First Amendment protection. View "Massaro v. Fairfax County" on Justia Law

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The United States Court of Appeals for the Fourth Circuit addressed a case where an inmate with celiac disease sued a doctor for depriving him of a gluten-free diet. The district court had granted summary judgment to the doctor because the plaintiff did not have an expert witness to testify about the standard treatment for celiac disease or the causal link between the doctor’s conduct and the plaintiff’s alleged harm. The appeals court held that no expert testimony was needed to avoid summary judgment in this case. The court found that the plaintiff had presented sufficient evidence to create a genuine dispute of material fact about the doctor's knowledge of his celiac disease and the excessive risk it posed by failing to respond reasonably, even without an expert.The court also clarified that expert testimony is not necessary to establish an Eighth Amendment claim of deliberate indifference. The court held that while determining whether medical professionals responded reasonably to a particular risk can involve an examination of the relevant standard of care, the fact that expert testimony may be necessary in some cases does not mean it was in this one. The court vacated the district court’s judgment and remanded the case for further proceedings. View "Phoenix v. Amonette" on Justia Law

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The United States Court of Appeals for the Fourth Circuit upheld the convictions of three South Carolina law enforcement officers who were found guilty of various abuses of power. The trio, Sheriff George Underwood, Chief Deputy Robert Sprouse, and Lieutenant Johnny Neal, were convicted on multiple counts, including financial corruption, civil rights violations, and conspiracy.Underwood used his position as sheriff to enrich himself through illegal means, including forcing deputies to perform work on his personal property while on public payroll. He also orchestrated a scheme with Neal to skim money from the extra compensation meant for deputies at drunk-driver checkpoints. Additionally, Underwood and Sprouse misused county money for personal travel expenses.The court also found that Underwood abused his authority by targeting enforcement against opponents and refusing to investigate offenses reported against friends and supporters. Notably, Underwood unlawfully arrested a citizen for recording a car accident scene, which led to a violation of the citizen's civil rights.After the Federal Bureau of Investigation uncovered the corruption, Sprouse and Neal conspired to lie and fabricate documents to cover up their misconduct. The jury convicted the defendants on various counts, and the appeals court affirmed those convictions. The court also ruled that the district court's calculation of restitution for the losses sustained was reasonable. View "United States v. Underwood" on Justia Law

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This case was brought before the United States Court of Appeals for the Fourth Circuit. The plaintiff, David Duvall, a white man, was terminated from his position as Senior Vice President of Marketing and Communications at Novant Health, Inc. Duvall filed a lawsuit claiming he was fired due to his race and sex, in violation of Title VII of the Civil Rights Act of 1964. A North Carolina jury found in favor of Duvall, awarding him $10 million in punitive damages. Novant Health appealed this decision, arguing that the evidence presented at trial was insufficient to support the jury’s verdict.The evidence presented at trial showed that Duvall performed exceptionally well in his role, receiving strong performance reviews. Despite his performance, Duvall was abruptly fired and replaced by two women, one of whom was a racial minority and rated a lower performer than Duvall. This occurred during a diversity and inclusion initiative at Novant Health, which aimed to achieve racial and gender diversity within its leadership.The Court of Appeals upheld the jury's verdict of liability against Novant Health, finding sufficient evidence to support the claim that Duvall's race, sex, or both were motivating factors in his termination. However, the court vacated the jury's award of punitive damages, concluding that Duvall failed to prove that Novant Health discriminated against him despite perceiving a risk that its actions would violate federal law.The court also upheld the district court's award of back pay and front pay to Duvall, rejecting Novant Health's claim that Duvall failed to reasonably mitigate his damages. The court found that Duvall exercised reasonable diligence in seeking new employment after his termination. The case was remanded for entry of an amended judgment as to punitive damages. View "Duvall v. Novant Health, Inc." on Justia Law

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In the case before the United States Court of Appeals for the Fourth Circuit, the plaintiff, Kristin Cosby, claimed that the South Carolina Probation, Parole & Pardon Services (SCPPP) had discriminated against her based on her gender and retaliated against her for filing discrimination complaints in violation of Title VII of the Civil Rights Act of 1964. Cosby had previously worked for SCPPP, left, and then reapplied in 2012. When she was not rehired, Cosby filed a discrimination charge with the Equal Employment Opportunity Commission (EEOC), which found in her favor. SCPPP rehired her, but Cosby alleged that she was subsequently subjected to gender discrimination and retaliation, including being denied a promotion, being investigated for inappropriate relationships with subordinates, and ultimately forced to resign.The court affirmed the district court's granting of summary judgment to SCPPP. The court held that Cosby had failed to establish her gender discrimination claim under both the disparate treatment and hostile work environment theories. For the disparate treatment claim, Cosby failed to identify a valid comparator — a similarly situated individual of a different gender who was treated more favorably. In her hostile work environment claim, Cosby's internal complaint did not constitute protected activity under Title VII because it did not oppose an unlawful employment practice. The court also found no causal connection between Cosby's 2012 EEOC charge and any adverse employment action taken by SCPPP in 2018, defeating her retaliation claim. View "Cosby v. South Carolina Probation, Parole & Pardon Services" on Justia Law

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A former medical student at the University of Virginia School of Medicine, Kieran Bhattacharya, sued multiple university officials, alleging they reprimanded, suspended, and expelled him in violation of the First Amendment because of his views expressed during a faculty panel on microaggressions. The officials asserted that they took these actions due to Bhattacharya’s confrontational and threatening behavior.The United States District Court for the Western District of Virginia held that Bhattacharya could not provide evidence that the officials punished him due to his speech, siding with the officials. Bhattacharya appealed to the United States Court of Appeals for the Fourth Circuit.The Fourth Circuit affirmed the district court's decision. The court held that Bhattacharya failed to present evidence sufficient to create a triable issue as to whether his speech caused the actions taken against him. The court found that the university's administrators appropriately exercised their authority to ensure the safety of the school’s faculty and staff. The court also affirmed the district court's denial of Bhattacharya's request to amend his complaint to add a conspiracy claim and the dismissal of his due process claim. View "Bhattacharya v. Murray" on Justia Law

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In the case before the United States Court of Appeals for the Fourth Circuit, Bikachi Amisi, a contract nurse, sued Officer Lakeyta Brooks and Officer Roy Townsend for violating her Fourth Amendment rights when she was mistakenly strip searched on her first day of work at Riverside Regional Jail. Amisi also brought several tort claims under Virginia state law. The defendants moved for summary judgment, arguing they were entitled to qualified immunity and good-faith immunity under Virginia law. They also argued that the Virginia Workers’ Compensation Act’s exclusivity provision barred Amisi's claims. The district court denied their motions and the defendants appealed.The Court of Appeals affirmed the district court's decision. It held that both officers were not entitled to qualified immunity, a legal protection that shields officers who commit constitutional violations but who could reasonably believe their actions were lawful, because their actions were not reasonable and Amisi’s right to be free from unreasonable strip searches was clearly established. The court also held that the Virginia Workers' Compensation Act did not bar Amisi's state-law claims because her injuries did not arise out of her employment. The Court further held that Officer Townsend was not entitled to immunity under Virginia law as his belief that his conduct was lawful was not objectively reasonable. View "Amisi v. Brooks" on Justia Law

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In this case, a police officer, Michael Roane, shot and killed Tina Ray’s dog while attempting to serve an arrest warrant. The United States Court of Appeals for the Fourth Circuit vacated the district court's entry of summary judgment in favor of Roane and remanded the case for trial. The crux of the case was the dispute over Roane's perception of the threat posed by the dog. Roane asserted that he believed the dog was unrestrained and posed an immediate threat to his safety. However, Ray and other witnesses testified that Roane had stopped his retreat and took a step towards the dog before shooting, suggesting that he knew the dog could no longer reach him and did not pose an imminent threat. The Court of Appeals held that this dispute over material facts was for a jury to resolve, not a court, and could not be decided prior to trial. The court also held that if a jury credits Ray's allegations and draws permissible inferences in her favor, it could infer that Roane's shooting of the dog was an unreasonable seizure under the Fourth Amendment. The court also rejected Roane's claim to qualified immunity. View "Ray v. Roane" on Justia Law

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The case involves Robert Mestanek, a citizen of the Czech Republic, who filed two Form I-130 petitions to establish his eligibility for lawful permanent residence in the United States based on his marriages to two different U.S. citizens. The first petition was filed by his then-wife Angel Simmons, and the second by his current wife Mary Mestanek. The United States Citizenship and Immigration Services (USCIS) denied both petitions, the first on the grounds that Robert’s marriage to Angel was fraudulent, and the second based on the “marriage fraud bar” which prohibits approval of Form I-130 petitions for any noncitizen who has previously been found to have entered into a fraudulent marriage to circumvent immigration laws. The Mestaneks filed suit in federal district court seeking judicial review of USCIS’s denial of Mary’s Form I-130 petition. The district court granted summary judgment in favor of USCIS, and the Mestaneks appealed. The United States Court of Appeals for the Fourth Circuit affirmed the lower court's decision, agreeing that USCIS’s denial was neither arbitrary nor contrary to law. The court rejected all of the Mestaneks’ arguments, including their contention that USCIS applied the wrong legal standard for marriage fraud, and their assertion that the administrative record was incomplete and insufficient for judicial review. The court also found no due process violation by USCIS. View "Mestanek v. Jaddou" on Justia Law