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

A senior employee at a major financial institution managed a significant medical disability for nearly thirty years. Initially, he did so without formal accommodations and excelled, rising to a top leadership position. After a serious health setback in 2017 required him to adopt a new medical protocol, his need for flexibility at work increased, particularly in terms of immediate and unpredictable bathroom access. During the COVID-19 pandemic, remote work made this manageable. He moved back to the company’s headquarters in 2020, relying on assurances from his then-manager that he could work from home when needed. In 2021, with management changes and a planned return to office, he formally requested a permanent remote-work accommodation. Senior management, who were aware of his disability, reacted with skepticism and ultimately included him in a reduction in force, terminating his employment before the office fully reopened.The United States District Court for the Western District of North Carolina heard his claims under the Americans with Disabilities Act (ADA) for failure to accommodate, discriminatory discharge, and retaliation, as well as a claim for wrongful discharge under North Carolina law. A jury found for the plaintiff on all claims, awarding substantial damages, including back pay, front pay, emotional distress, and punitive damages. The district court denied the employer’s motions for judgment as a matter of law or a new trial and entered judgment on the verdict, later remitting punitive damages under the ADA to comply with statutory caps and awarding prejudgment interest under state law.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the verdict only as to the ADA retaliation claim, holding that substantial evidence supported a finding that the employee’s request for accommodation was a but-for cause of his discharge. However, the court reversed the verdicts on the failure-to-accommodate and disability-discrimination claims, finding insufficient evidence that any reasonable accommodation was denied or that the discharge was because of the disability itself. The court remanded for entry of judgment as a matter of law on those claims, vacated certain damages, and ordered adjustment of the back-pay award unless the plaintiff accepted a remittitur. The matter was remanded for further proceedings consistent with these rulings. View "Billesdon v. Wells Fargo Securities, LLC" on Justia Law

Police in Montgomery County, Maryland, responded to a high-priority call reporting that a Black male had placed three children into the trunk of a black Tesla, possibly indicating a kidnapping. Officers quickly traced the vehicle and address to Fareed Hayat. Upon arriving at his home, they found Hayat and his wife on the porch and initiated questioning. Hayat acted evasively, did not answer whether he had been at the location in question, cut off his wife’s conversation with officers, and attempted to retreat into his house, insisting the police could not enter. The officers prevented him from closing the door, entered the front hall, handcuffed Hayat, and checked on the children’s welfare. After confirming no kidnapping had occurred, the officers released Hayat.Hayat subsequently filed a lawsuit in the United States District Court for the District of Maryland against the officers, the Chief of Police, and Montgomery County. He alleged violations of his Fourth and Fourteenth Amendment rights, as well as various federal and state law claims. The district court dismissed most claims and granted summary judgment to the defendants on the remaining claims, finding that the officers had a reasonable suspicion justifying a Terry stop prior to Hayat’s retreat into his home. The court also held that the officers were justified in entering the home to complete the stop and to confirm the children’s welfare, given the exigency created by Hayat’s conduct.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The Fourth Circuit held that the officers had reasonable articulable suspicion to justify a Terry stop based on corroborated eyewitness accounts and Hayat’s suspicious behavior. The court further held that entry into the home was justified to complete the Terry stop and to ensure the safety of the children, under both the exigent circumstances and “hot pursuit” exceptions to the warrant requirement. The court concluded that Hayat’s Fourth Amendment rights were not violated. View "Hayat v. Diaz" on Justia Law

The case concerns a challenge brought by several houses of worship from Quaker, Sikh, and Cooperative Baptist Fellowship religious traditions to a new policy adopted by the Department of Homeland Security (DHS) in January 2025. This policy rescinded longstanding guidelines that limited immigration enforcement actions at or near houses of worship, replacing them with a directive that left the decision to conduct enforcement actions largely to the discretion of immigration officers without specific guidelines or required supervisory approval. The plaintiffs alleged that the new policy has already caused, and will continue to cause, a decline in attendance at their worship services and ministries, thereby impeding their ability to exercise their religion communally and to minister to immigrant communities.Previously, the United States District Court for the District of Maryland granted the plaintiffs’ motion for a preliminary injunction, ordering DHS to follow its prior 2021 guidelines that limited immigration enforcement at or near the plaintiffs’ houses of worship. The district court found that the plaintiffs had standing and were likely to succeed on the merits of their claims under the Religious Freedom Restoration Act (RFRA), and that they would suffer irreparable harm without interim relief.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s decision. The Fourth Circuit held that the plaintiffs had met the requirements for standing, including injury-in-fact, traceability, and redressability, based on evidence of actual and likely future declines in attendance linked to the new policy. The court further concluded that the district court did not abuse its discretion in finding that the plaintiffs were likely to succeed on the merits of their RFRA claim, as the new policy substantially burdened their religious exercise. The government’s arguments under strict scrutiny were found to be waived, as they were not properly raised below. The Fourth Circuit affirmed the district court’s preliminary injunction. View "Yearly Meeting of the Religious Society of Friends v. Department of Homeland Security" on Justia Law

The case involves several married couples, each consisting of a U.S. citizen and a noncitizen spouse who is subject to a final order of removal. The noncitizen spouses are seeking lawful permanent residency through a process that requires them to first file a family-based petition, then seek special permission to reapply for admission, and finally apply for a provisional unlawful presence waiver. The waiver, if granted, would allow the noncitizen to leave the country to complete consular processing without triggering a lengthy inadmissibility bar. Several noncitizen plaintiffs were arrested by ICE at their immigration interviews, causing others to avoid or delay their own interviews out of fear of arrest and removal.The United States District Court for the District of Maryland certified a class of similarly situated couples and granted summary judgment in favor of the plaintiffs. The district court held that the government lacked authority to arrest or remove noncitizens during the provisional waiver process, finding this violated the relevant regulations, the Administrative Procedure Act, and the Due Process Clause. The court issued class-wide declaratory and injunctive relief, barring the government from interfering with plaintiffs’ participation in the waiver process through arrest or removal.Upon review, the United States Court of Appeals for the Fourth Circuit vacated the district court’s judgment and remanded for further proceedings. The Fourth Circuit held that the relevant regulations do not bar the government from arresting or removing noncitizens during the provisional waiver process and that the plaintiffs do not have a protected interest in accessing the process without risk of removal. The court also found the factual record insufficient to support the alternative theory that the government uses the waiver process to target noncitizens for removal. Thus, the award of summary judgment to the plaintiffs was vacated. View "Sanchez v. Mullin" on Justia Law

An African American employee worked as a driver for a metal recycling company in South Carolina for several months in 2017. During his employment, he experienced repeated racial harassment from white coworkers and supervisors, including the frequent use of racial slurs, exposure to racist cartoons, and derogatory comments both in person and on social media. The employee also believed he was denied training and promotional opportunities due to his race. He refrained from making complaints initially out of fear of retaliation, as a manager had previously warned him against associating with African American coworkers who had complained about discrimination. On June 13, 2017, after a racially offensive incident involving his manager, the employee complained directly to the manager about racial harassment and discrimination. He was immediately suspended and, after providing a written statement, was terminated a week later.After his termination, the employee filed suit in the United States District Court for the District of South Carolina, alleging a racially hostile work environment, race discrimination in training and promotion, and retaliatory discharge under 42 U.S.C. § 1981. The district court, adopting the magistrate judge’s recommendation in part, held that the hostile work environment and race discrimination claims were time-barred. The court also granted summary judgment to the employer on the retaliatory discharge claim, concluding that the employee’s termination was due to “belligerent and insubordinate conduct” rather than retaliation and that no reasonable jury could find otherwise.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s summary judgment ruling de novo. The Fourth Circuit held that genuine disputes of material fact existed as to whether the employer’s stated reason for termination was pretext for retaliation and whether retaliation was a but-for cause of the discharge. The appellate court therefore vacated the summary judgment on the retaliatory discharge claim and remanded the case for further proceedings. View "Stewart v. GES Recycling South Carolina LLC" on Justia Law

A man named Sylvester Demetrius Selby was shot and killed by Deputy Edward Glaser III of the Dare County Sheriff’s Office in North Carolina, after Selby, who was wounded and holding a knife and an apple, failed to comply with repeated commands to drop the knife. After initially exiting his home, Selby did not surrender but instead jumped down the porch steps toward the deputies while still holding the knife. Following the first shot, Selby dropped the knife and apple, flailed on the ground, and then attempted to stand up and flee, at which point he lunged in the direction of Deputy Glaser, who fired two additional shots, resulting in Selby’s death.Legacy Spencer, administrator of Selby’s estate, filed suit in the United States District Court for the Eastern District of North Carolina against Deputy Glaser (individually) and the Dare County Sheriff (officially), alleging violations of the Fourth Amendment (excessive force) and North Carolina state law (assault, battery, and wrongful death). The defendants moved to dismiss. The district court, referencing body camera footage that contradicted certain key factual allegations in the complaint, determined the use of force was objectively reasonable under the circumstances and dismissed all claims for failure to state a claim. It also found qualified immunity barred the federal claims and public official immunity barred the state claims against Deputy Glaser. The claims against the sheriff failed because they were premised on Glaser's reasonable actions.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the dismissal de novo. The court held that it was proper to consider the body camera videos at the dismissal stage where they blatantly contradicted the complaint’s allegations. The court concluded that Deputy Glaser’s use of force was reasonable and did not violate the Fourth Amendment or state law, affirming the district court’s judgment and dismissing all claims. View "Spencer v. Glaser" on Justia Law

Benjamin Carter, a Virginia state prisoner housed in the Restrictive Housing Unit at Sussex State Prison, alleged that prison officials subjected him to unconstitutional conditions of confinement, particularly harmful due to his serious mental illnesses. He also claimed that after he submitted an informal complaint seeking reclassification and transfer out of restrictive housing, officials retaliated against him by denying his requests and making threatening statements. Carter attempted to address these issues through the Virginia Department of Corrections' grievance process, submitting informal complaints and regular grievances about both the conditions and the alleged retaliation. His grievances were rejected and appeals denied. Carter initially filed a federal complaint about his conditions of confinement before the administrative process was completed, then filed an amended complaint after exhausting the grievance process, raising both Eighth and First Amendment claims.The United States District Court for the Eastern District of Virginia screened Carter’s complaints and dismissed his Eighth Amendment claim against the VDOC Director for failure to state a claim, finding no plausible supervisory liability. The court then granted summary judgment to the remaining defendants, holding that Carter had not exhausted administrative remedies as required by the Prison Litigation Reform Act (PLRA) when he filed his original complaint, and concluded he could not cure this by exhausting before filing an amended complaint. The court also held, in the alternative, that Carter failed to state retaliation claims against two defendants.The United States Court of Appeals for the Fourth Circuit reviewed the case. It held that Carter properly exhausted his First Amendment retaliation claims because he completed the administrative process before filing the amended complaint in which those claims were first raised, and the PLRA does not bar claims first pleaded in an amended complaint after exhaustion. The court vacated the district court’s dismissal of Carter’s Eighth Amendment claims, remanding for the district court to determine whether administrative remedies were truly “available” to Carter. The court also vacated the district court’s dismissal of retaliation claims against two defendants, finding Carter’s complaint stated plausible claims. The judgment was vacated and remanded for further proceedings. View "Carter v. Cabell" on Justia Law

A man’s wife called 911 to request a welfare check after her husband threatened to harm himself. The dispatcher relayed to law enforcement that the man had made similar threats in the past, was not acting like himself, and was last known to be at a riverfront house. When the responding officer arrived, he found the man’s vehicle at the property but received no response to repeated knocks and announcements at multiple doors. The officer entered the house several times after announcing himself, ultimately discovering a suicide note and pill bottle. Upon further entry, the officer encountered the man in his bedroom. After a brief exchange in which the man repeatedly ordered the officer to leave, the man retrieved a rifle and advanced toward the officer, ignoring commands to stop. The officer fired, fatally wounding the man.The personal representative of the man’s estate filed suit in South Carolina state court against the responding officer, the county sheriff, and the sheriff’s office, alleging violations of the Fourth Amendment for unlawful entry and excessive force, as well as a claim for failure to train. The case was removed to the United States District Court for the District of South Carolina. The district court granted summary judgment to the defendants on all federal claims, holding that the officer’s entries and use of force were objectively reasonable and that he was entitled to qualified immunity. The court also found no basis for municipal liability and remanded the state-law claims to state court.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The Fourth Circuit held that the officer’s warrantless entries were justified under the emergency aid exception, given the objectively reasonable belief that the man was at risk of serious harm. The court also concluded that the use of deadly force was objectively reasonable under the circumstances. Accordingly, all federal claims were properly dismissed. View "Crosby v. Colleton County Sheriff's Office" on Justia Law

The plaintiff, a resident of Salem, South Carolina, frequently visited her local post office. During one visit, after experiencing poor service, she was confronted and physically attacked by a postal employee, resulting in significant injuries. The Postmaster, rather than assisting her or calling for help, allegedly exacerbated the situation by physically handling her and preventing her from seeking help. The plaintiff claimed the employee had a history of aggressive behavior known to postal management.The plaintiff initially filed suit in South Carolina state court against the individual employees and the United States. The case was removed to the United States District Court for the District of South Carolina, which, after the government substituted itself for the individual defendants under the Westfall Act and moved to dismiss, dismissed all claims. The district court determined the Federal Tort Claims Act (FTCA) did not waive sovereign immunity for most claims, including those arising from assault and battery, and that the claims for negligent hiring, supervision, and retention were barred by the discretionary function exception. The court also dismissed the Bivens constitutional claims and the FOIA claim for failure to exhaust administrative remedies.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s dismissal of most claims, holding that the FTCA’s intentional tort exception precludes claims against the government for injuries arising from assault and battery by a postal employee, even if pleaded as negligence. However, the Fourth Circuit reversed and remanded as to a narrow aspect of the negligence claim against the Postmaster, holding that under the Supreme Court’s decision in Sheridan v. United States, a claim may proceed if the government employee negligently created the risk of harm, independent of the tortfeasor’s employment status. The Fourth Circuit otherwise affirmed the district court’s judgment. View "Lusk v. Merchant" on Justia Law

While incarcerated at a maximum-security prison, Dashaun Simmons was fatally stabbed by another inmate, Jonathon Dominick, after a corrections officer, Gerald Bush, released Dominick and another inmate from their cells without proper verification of their authorization to leave. Simmons had a history of being attacked in various facilities and had reported threats and assaults at the current prison, though not specifically to Bush. On the day of the incident, Bush, unfamiliar with the inmates in this particular unit, relied on inmate statements rather than consulting the official list or a supervisor. After the stabbing, officers Cheryl Youngquist and Dontai Parks responded, with Youngquist initially failing to recognize the urgency but then calling for medical help, and Parks transporting Simmons to the medical team. Simmons died from his injuries.In the United States District Court for the District of South Carolina, Simmons’s estate brought suit against several prison officials under 42 U.S.C. § 1983, alleging violations of the Eighth Amendment due to deliberate indifference to Simmons’s safety and medical needs. The district court granted summary judgment in favor of the defendants, concluding that the officials were entitled to qualified immunity because there was no evidence of deliberate indifference or violation of clearly established law.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The Fourth Circuit affirmed the district court’s judgment, holding that the officers’ conduct did not violate the Eighth Amendment. The court found insufficient evidence that any defendant subjectively knew of and disregarded a substantial risk to Simmons’s safety or medical needs. The court also noted that mere violation of prison policy did not amount to constitutional deliberate indifference, and that, absent evidence of actual or constructive knowledge of a specific risk, qualified immunity applied. The judgment for the officers was therefore affirmed. View "Jackson v. Bush" on Justia Law