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

Articles Posted in Civil Rights
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The Fourth Circuit reversed the district court's dismissal of plaintiff's 42 U.S.C. 1983 claim, alleging that her Fourth Amendment rights were violated when an officer shot and killed her dog, Jax. The court held that the complaint plausibly stated a claim for an unconstitutional seizure of plaintiff's property for which the officer was not entitled to qualified immunity. Although the court acknowledged that there was evidence in the record on appeal that contradicted some of the allegations in the complaint, the complaint nonetheless alleged that the officer shot Jax when it was in plaintiff's yard, tethered, and incapable of reaching or harming the officer. Because the court must grant all reasonable inferences in favor of plaintiff, the court reversed and remanded for further proceedings. View "Ray v. Roane" on Justia Law

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Petitioner appealed the district court's grant of summary judgment denying his 28 U.S.C. 2254 petition for habeas corpus relief. Petitioner alleged due process violations stemming from a prison disciplinary proceeding that resulted in the revocation of twenty days of his good-time credits. The Fourth Circuit affirmed the denial of petitioner's claim regarding the DHO's failure to review the requested surveillance video during his hearing, because there was no clearly established violation of petitioner's right at the time. Therefore, the North Carolina Supreme Court did not act unreasonably in denying petitioner's claim. However, the court vacated the district court's determination that petitioner's conviction was supported by "some evidence" in the record. The court held that this case presented the exceedingly rare circumstance where the record contained no probative evidence to support petitioner's conviction. Therefore, petitioner's disciplinary conviction amounted to a violation of his due process rights. Accordingly, the court remanded with instructions to grant habeas relief as to the good-time credits. View "Tyler v. Hooks" on Justia Law

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A Maryland law requiring newspapers, among other platforms, to publish on their websites, as well as retain for state inspection, certain information about the political ads they decide to carry, violates the First amendment. The Fourth Circuit affirmed the preliminary injunctive relief awarded by the district court and explained that, while Maryland's law tries to serve important aims, the state has gone about this task in too circuitous and burdensome a manner to satisfy constitutional scrutiny. The court agreed with the district court that the law is a content-based law that targets political speech and compels newspapers, among other platforms, to carry certain messages on their websites. The court declined to decide whether strict or exacting scrutiny should apply to a disclosure law like the one at issue, and held that the law failed under the more forgiving exact scrutiny standard. View "The Washington Post v. McManus" on Justia Law

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Plaintiff, an inmate at a state prison, filed suit against officials at the VDOC under the Religious Land Use and Institutionalized Persons Act (RLUIPA) and the Free Exercise Clause of the First Amendment, alleging that the VDOC was denying him the ability to practice central tenets of his Muslim religion. The district court granted summary judgment to the VDOC. The Fourth Circuit vacated and remanded, holding that the VDOC's stated justifications for denying plaintiff access to a Friday prayer service known as Jum'ah and interfering with his ability to maintain a four-inch beard were invalid under both RLUIPA and the First Amendment. The court commended for consideration by the VDOC in further proceedings the full practical effect of observations made by former correctional officials that providing robust support for inmates' genuine religious exercise would actually enhance prison security and inmate rehabilitation. View "Greenhill v. Clarke" on Justia Law

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Plaintiff filed suit under 42 U.S.C. 1983 against defendant, alleging unlawful entry and use of excessive force in violation of the Fourth Amendment. In this case, police officers used a battering ram to enter plaintiff's dwelling to execute a warrant. The officers did not announce their presence before using the battering ram, and plaintiff responded by pulling out a gun. Although plaintiff never discharged the gun, 29 shots were fired at him and he was struck nine times. The Fourth Circuit affirmed the district court's denial of qualified immunity with respect to the excessive force claim, holding that disputes of material fact preclude an award of summary judgment. The court held that a reasonable jury could find under the facts presented that plaintiff did not pose a threat to the officers justifying the use of deadly force. Furthermore, in light of Cooper v. Sheehan, 735 F.3d 153 (4th Cir. 2013), the court held that plaintiff's Fourth Amendment right to be free from the use of excessive force was clearly established at the time the incident occurred. View "Betton v. Belue" on Justia Law

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Plaintiff filed suit challenging South Carolina's decision to terminate PPSAT's provider agreement because it offers abortion services. At issue was whether, and on what basis, the Medicaid Act's free-choice-of-provider provision affords a private right of action to challenge a state’s exclusion of a healthcare provider from its Medicaid roster. The Fourth Circuit affirmed the district court's grant of a preliminary injunction in favor of plaintiff and held that Congress's intent to create an individual right enforceable under 42 U.S.C. 1983 in the free-choice-provider provision is unambiguous. The court also held that a plain-language reading of the provision's mandate—that states "must" furnish Medicaid recipients the right to choose among providers "qualified to perform the service or services required"—bars states from excluding providers for reasons unrelated to professional competency. Because the individual plaintiff in this case has a private right of action to challenge South Carolina's denial of her right to the qualified and willing family-planning provider of her choice, the court agreed with the district court that she has demonstrated a substantial likelihood of success on her free-choice-of-provider claim. Furthermore, the district court did not abuse its discretion in enjoining South Carolina from terminating PPSAT's provider agreement; it was clear that plaintiff would suffer irreparable harm in the absence of a preliminary injunction; and the remaining preliminary injunction factors were satisfied. View "Planned Parenthood South Atlantic v. Baker" on Justia Law

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The Fourth Circuit reversed the district court's denial of habeas relief, holding that a juror's external communication with her pastor regarding the death penalty was not harmless. Given how Federal Rule of Evidence 606 limits the presentation of evidence in these circumstances, the court held that it was especially important for it to view the record practically and holistically when considering the effect that a juror's misconduct reasonably may be taken to have had upon the jury's decision. In this case, the juror shared the pastor's counsel with the other jurors in an apparent effort to convince someone it was okay to vote for the death penalty. The court remanded for further proceedings. View "Barnes v. Thomas" on Justia Law

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Plaintiff, a Virginia inmate, filed a 42 U.S.C. 1983 action against two Virginia Department of Corrections (VDOC) officials, alleging that defendants violated his Eighth Amendment rights by denying him treatment for his Hepatitis C virus (HCV). The Fourth Circuit vacated the district court's grant of summary judgment for defendants, holding that genuine disputes of material fact exist as to plaintiff's deliberate indifference claim against Defendant Schilling, the Health Services Director. In this case, there was sufficient evidence to establish a genuine issue of material fact as to Schilling's personal involvement in the denial of treatment for plaintiff's HCV. The court also held that genuine disputes of material fact exist as to plaintiff's deliberate indifference claim to Defendant Amonette, the Chief Physician, because a factfinder could determine that Amonette knew that HCV is a serious disease that affects a large percentage of those incarcerated in VDOC facilities. Furthermore, plaintiff presented evidence that Amonette knew that a lack of treatment for someone diagnosed with HCV, like plaintiff, creates a substantial risk of harm to that person. The court rejected defendants' alternative argument, which was based on a misreading of the opinion, and remanded for further proceedings. View "Gordon v. Schilling" on Justia Law

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Plaintiffs filed suit seeking to hold the United States liable for negligently performing a background check on Dylann Roof, the person who entered a church in Charleston, South Carolina and opened fire, killing nine worshippers. No one disputes that if the background check had been performed properly, it would have prevented Roof from purchasing the firearm he used. The district court dismissed plaintiffs' claims for lack of subject matter jurisdiction. The Fourth Circuit reversed and held that neither the discretionary function exception of the Federal Tort Claims Act nor the Brady Act's immunity provision in 18 U.S.C. 922(t)(6) affords the Government immunity in this case. In regard to the FTCA, the court held that this case turns on the NICS Examiner's alleged negligence in failing to follow a clear directive and the government could not claim immunity under these circumstances. The court held that the district court did not err by concluding that the government could not be held liable under the FTCA for declining to give Examiners access to the N-DEx, and the court rejected plaintiffs' claim that the government contravened a mandatory directive by failing to maintain data integrity during the NICS background check. In regard to the Brady Act, the court held that the district court erred in construing 18 U.S.C. 992(t)(6) to bar plaintiffs' claims where plaintiffs sued the government rather than any federal employee, and the federal employees whose conduct forms the basis of this suit were not responsible for providing information to the NICS system. View "Sanders v. United States" on Justia Law

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The Fourth Circuit affirmed the district court's grant of summary judgment for IPC in plaintiff's action under Title VII of the Civil Rights Act of 1965, alleging race-based discrimination claims. In regard to the disparate treatment claim, the court held that plaintiff's claims of disparate treatment for being denied positions, overtime, additional educational benefits and training were time-barred. As for plaintiff's timely claim that he was denied annual reviews, the court held that plaintiff offered no evidence demonstrating IPC's failure to give him annual reviews affected the terms, benefits and conditions of his employment. Furthermore, even if hostile treatment could qualify as an adverse employment action, plaintiff's claim that the hostile treatment he received at IPC constitutes an adverse employment action would fail as a matter of law. In regard to the race-based hostile work environment claim, the court held that the totality of the circumstances did not sufficiently demonstrate a severe or pervasive hostile work environment. Finally, plaintiff failed to create a genuine issue of material fact as to his constructive discharge claim. View "Perkins v. International Paper Co." on Justia Law