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

Plaintiffs-Appellants Thomas Sheppheard, Tyler Randall, and Adam Perry, on behalf of minor child J.P., filed a class action lawsuit against the Governor of West Virginia and the Acting Cabinet Secretary of the West Virginia Department of Homeland Security. They sought relief under the Eighth and Fourteenth Amendments, alleging unconstitutional conditions of overcrowding, understaffing, and deferred maintenance in West Virginia's prisons, jails, and juvenile centers. They claimed these conditions amounted to deliberate indifference to their health and safety.The United States District Court for the Southern District of West Virginia dismissed the case for lack of standing. The court found that the plaintiffs failed to establish that their injuries were traceable to the actions of the Governor or the Secretary, or that their injuries would be redressed by a favorable decision. The court noted that the issues were largely due to funding decisions by the West Virginia legislature, which was not a party to the suit. The court also highlighted that the Commissioner of the West Virginia Division of Corrections and Rehabilitation, not the Governor or the Secretary, had the authority to address the conditions in the facilities.The United States Court of Appeals for the Fourth Circuit affirmed the district court's dismissal. The appellate court agreed that the plaintiffs lacked standing because they could not show that their injuries were caused by the Governor's or the Secretary's actions. The court also found that the requested relief, such as appropriations and policy changes, could not be granted by the court as it lacked the power to compel the Governor or the Secretary to take such actions. The court emphasized that the plaintiffs' injuries were not redressable through the requested judicial intervention. View "Sheppheard v. Morrisey" on Justia Law

The case involves Justin Michael Wolfe, who was convicted of hiring Owen Barber to murder Daniel Petrole in 2001. Barber, the key witness, initially testified against Wolfe, implicating him in the murder-for-hire scheme. Wolfe was sentenced to death, but Barber later recanted his testimony, claiming he was coerced by the Commonwealth of Virginia with threats of the death penalty. Wolfe's conviction was vacated by the district court due to Brady violations and other prosecutorial misconduct, and the Commonwealth was ordered to retry Wolfe or release him.The United States District Court for the Eastern District of Virginia granted Wolfe habeas relief, finding that the Commonwealth had withheld exculpatory evidence and engaged in misconduct. The Fourth Circuit Court of Appeals affirmed this decision, but the Commonwealth continued to pursue charges against Wolfe. In a subsequent interview, Commonwealth officials again coerced Barber, leading him to invoke his Fifth Amendment rights, making him unavailable as a witness for Wolfe's retrial. Wolfe ultimately pled guilty to avoid the death penalty, receiving a 41-year sentence.Wolfe filed a new habeas petition in the Eastern District of Virginia, asserting claims of vindictive prosecution and due process violations based on the Commonwealth's intimidation of Barber. The district court dismissed the petition as untimely and found that Wolfe failed to present new, reliable evidence of actual innocence under the Schlup standard. Wolfe appealed to the Fourth Circuit Court of Appeals.The Fourth Circuit held that Barber's new declaration, which exculpated Wolfe and explained his previous invocation of the Fifth Amendment due to Commonwealth threats, constituted new, reliable evidence. The court found that Barber's declaration was credible and that no reasonable juror would have convicted Wolfe if they had heard Barber's recantation. The court vacated the district court's judgment and remanded for adjudication of Wolfe's substantive claims. View "Wolfe v. Dotson" on Justia Law

Demmerick Brown, an inmate at Red Onion State Prison in Virginia, violated the prison’s COVID-19 policy by removing his face mask to get a shave at the barber shop. As a result, the prison fined him fifteen dollars, which was deducted from his prison trust account. Brown claimed that he was not provided the necessary forms to present evidence and call witnesses at his disciplinary hearing, and his request to postpone the hearing was denied. He was found guilty and fined.Brown sued three prison officials under 42 U.S.C. § 1983, alleging a violation of his Fourteenth Amendment due process rights. The United States District Court for the Western District of Virginia dismissed his case, concluding that Brown lacked a property interest in the money in his prison trust account, and thus, the fine did not trigger due process protections.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court vacated the district court’s dismissal, holding that inmates do have a property interest in the money in their prison trust accounts, as established in Henderson v. Harmon. The court found that the fifteen-dollar fine deprived Brown of this property interest, and thus, the Due Process Clause was applicable. The court rejected the argument that the fine was de minimis, noting its significance within the prison context.The Fourth Circuit vacated the district court’s decision and remanded the case for further proceedings to determine what process was due and whether any errors in Brown’s disciplinary proceedings were harmless. View "Brown v. Stapleton" on Justia Law

Joel Aaron Burrell, a prisoner, filed a lawsuit against several correctional officers under 42 U.S.C. § 1983. Burrell sought to proceed in forma pauperis, which allows indigent prisoners to file lawsuits without prepaying filing fees. The district court denied his request, citing the three-strike rule under the Prison Litigation Reform Act, which prevents prisoners from proceeding in forma pauperis if they have had three prior lawsuits dismissed for being frivolous, malicious, or failing to state a claim. The district court identified three such dismissals in Burrell's case history and dismissed his current action when he did not pay the filing fee.Burrell appealed, arguing that two of the prior dismissals should not count as strikes. The first case was dismissed under the Younger abstention doctrine, which prevents federal courts from interfering with ongoing state proceedings. The second case was dismissed after Burrell failed to amend his complaint following a court order that found his initial complaint failed to state a claim.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court concluded that a dismissal under Younger abstention does not count as a strike because it does not assess the merits of the complaint. Regarding the second case, the court determined that while a failure to amend following a finding of failure to state a claim can count as a strike, it should not be counted if the dismissal occurred after the current lawsuit was filed.The Fourth Circuit held that the district court erred in applying the three-strike rule to Burrell's case. Since Burrell had only one valid strike at the time he filed the current lawsuit, the district court's dismissal was vacated and the case was remanded for further proceedings. View "Burrell v. Shirley" on Justia Law

A group of current and former pretrial detainees filed a putative class action against Prince George’s County, Maryland, and 11 state court judges, alleging that their detentions and the policies leading to them were unconstitutional. The plaintiffs sought a declaratory judgment, injunctive relief, and compensatory damages, claiming violations of the Due Process Clause and the Maryland Constitution.The United States District Court for the District of Maryland granted judgment on the pleadings, concluding that the judges and the county had absolute immunity from the plaintiffs’ claims for damages and an injunction, and that a declaratory judgment could not provide meaningful relief. The district court dismissed the judicial defendants based on absolute judicial immunity and dismissed the claims against the county based on quasi-judicial immunity. Additionally, the district court dismissed seven plaintiffs who had been released from pretrial detention, reasoning that they would not benefit from any available remedy.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court vacated the district court’s dismissal of the judicial defendants but concluded that the dismissal should have been for lack of subject matter jurisdiction due to the absence of an Article III case or controversy. The court held that the judicial defendants were acting in an adjudicative capacity, not as adversaries, and thus there was no justiciable controversy. The court also reversed the district court’s dismissal of the claims against the county, holding that municipalities do not enjoy immunity from suit under 42 U.S.C. § 1983. The court remanded the case for further proceedings consistent with its opinion, including the reinstatement of the claims of the seven plaintiffs who had been released from pretrial detention. View "Frazier v. Prince Georges County" on Justia Law

Martin Misjuns, a Fire Captain and paramedic with the Lynchburg Fire Department, was terminated after posting offensive social media content targeting transgender individuals. Misjuns alleged that his termination was due to his political and religious views, which he expressed on his Facebook pages. He claimed that the City of Lynchburg and its officials conspired to violate his constitutional rights, leading to his firing.The United States District Court for the Western District of Virginia dismissed all of Misjuns' claims. The court found that the claims against the individual defendants in their official capacities were duplicative and dismissed them. The court also dismissed Misjuns' breach of contract, equal protection, conspiracy, and wrongful termination claims. The court partially dismissed his First Amendment claims but later dismissed them entirely.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court's dismissal of Misjuns' claims. The court held that Misjuns failed to establish Monell liability against the City of Lynchburg, as he did not adequately plead that a policy or custom caused the alleged constitutional violations. The court also found that the City's Employment Policies & Procedures handbook did not constitute a binding contract, thus dismissing the breach of contract claim. Additionally, the court upheld the dismissal of the conspiracy and wrongful termination claims against the individual defendants, as those claims were not asserted against the City and had been dismissed by agreement.The Fourth Circuit concluded that Misjuns did not sufficiently plead facts to state a claim for relief on any of his six claims, affirming the district court's decision. View "Misjuns v. City of Lynchburg" on Justia Law

On January 9, 2021, Xzavier D. Hill, an 18-year-old, was shot and killed by Virginia State Troopers Seth W. Layton and Benjamin I. Bone. Hill's estate, represented by his mother, LaToya K. Benton, filed a lawsuit in the United States District Court for the Eastern District of Virginia, alleging that the troopers used excessive force in violation of 42 U.S.C. § 1983 and committed state law torts. The troopers moved for summary judgment, claiming qualified immunity. The district court granted the motion, finding that the troopers' actions were objectively reasonable and that no clearly established law indicated their conduct was unconstitutional.The district court found that the troopers were entitled to qualified immunity on both the constitutional and clearly established prongs. The court determined that the troopers reasonably believed Hill posed a danger by disobeying commands and reaching towards what they perceived to be a handgun. The court also concluded that there was no precedent clearly establishing that the troopers' actions were unlawful. Consequently, the court dismissed the state law tort claims, as they were dependent on the success of the federal excessive force claim.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the troopers were entitled to qualified immunity. The court found that all three Graham factors—severity of the crime, immediate threat to officers, and resisting arrest or evading arrest by flight—favored the troopers. The court also determined that there was no Supreme Court or Fourth Circuit precedent that clearly established the troopers' conduct as unconstitutional. Therefore, the judgment of the district court was affirmed. View "Benton v. Layton" on Justia Law

The case involves the City of Myrtle Beach's response to a surge in violent crime in an area known as "the Superblock." Between 2015 and 2016, eleven people were shot, and dozens more were sexually assaulted, battered, or robbed in the Superblock, primarily around a small cluster of bars. The City increased police presence and investigated these establishments for compliance with safety regulations. Despite these measures, crime persisted, leading the City to shut down two bars for repeated legal violations, while a third bar closed due to lack of business. Years later, the bars and the landlord sued the City and the City Manager, alleging violations of the Takings Clause, Due Process Clause, Equal Protection Clause, and 42 U.S.C. § 1985, claiming the City unlawfully targeted them because their owners and clientele were predominantly racial minorities.The United States District Court for the District of South Carolina granted directed verdicts for the City on all claims during a jury trial. The court held that the appellants did not have a constitutionally protected property interest in the right to conduct their business. It found that the City's enforcement actions were within the legitimate bounds of state police power and rejected the § 1985 civil conspiracy claims based on the intra corporate conspiracy doctrine, which states that corporate and government agents cannot conspire with themselves.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The appellate court held that the City acted within its lawful authority to address serious public safety threats and enforce compliance with state and local regulations. The appellants' claims were deemed speculative and unsupported by the evidence presented at trial. The court found no discriminatory intent or violation of due process, and it upheld the application of the intra corporate conspiracy doctrine, concluding that the City officials did not possess a personal stake independent of their relationship to the City. View "Brady v. City of Myrtle Beach" on Justia Law

Lisa Barnhill, a white woman, sued the U.S. Attorney General, alleging racial and gender discrimination, retaliation, and a hostile work environment under Title VII of the Civil Rights Act of 1964. Barnhill claimed she faced discrimination from her African American supervisor and others while employed by the DEA. Some of her claims were dismissed under Fed. R. Civ. P. 12(b)(6), and others were resolved on summary judgment under Fed. R. Civ. P. 56(a).The United States District Court for the Eastern District of Virginia dismissed Barnhill's race and gender discrimination claims, finding she failed to allege facts showing discriminatory animus. The court also dismissed her retaliation claims related to promotion denials and a five-day suspension, concluding she did not plausibly allege a connection between her EEO proceeding and these adverse actions. However, the court allowed her retaliation claims related to a management review and temporary duty reassignment, as well as her hostile work environment claim, to proceed.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the dismissal of Barnhill's discrimination claims, agreeing she did not plausibly allege discriminatory animus. The court also affirmed the dismissal of her retaliation claims related to promotion denials and the suspension, finding no causal connection to her EEO proceeding. On summary judgment, the court found that the management review was initiated by a supervisor without discriminatory animus and that the temporary duty reassignment was justified by legitimate, nonretaliatory reasons. The court also concluded that Barnhill's hostile work environment claim failed because the adverse actions she experienced were responses to her own behavior, not severe or pervasive harassment.The Fourth Circuit affirmed the district court's decision, holding that Barnhill failed to establish the necessary elements for her claims. View "Barnhill v. Bondi" on Justia Law

Justin Longworth, a federal inmate, alleged that he faced repeated sexual harassment and abuse by Sherry M. Beck, a correctional officer at the Federal Correctional Institution in Butner, North Carolina. Longworth claimed Beck engaged in daily aggressive sexual harassment and abuse, including forced oral sex, fondling, and groping. He did not immediately report Beck's conduct due to fear of retaliation. Other officials at the institution initially did nothing to stop or report Beck's abuse. Eventually, Beck was reported, fired, and Longworth was transferred to another facility, but Beck continued to harass him through letters.Longworth filed two separate lawsuits in the Eastern District of North Carolina. The first lawsuit was a Bivens action against the officials directly involved, alleging violations of his civil rights under the Fourth and Eighth Amendments. The district court dismissed the Bivens claims, finding that they presented new contexts and that special factors counseled hesitation in extending Bivens to this context. Longworth appealed the dismissal of his Bivens claims. The second lawsuit was an FTCA claim against the United States, alleging negligence by the officials. The district court dismissed the FTCA claim for lack of subject matter jurisdiction, finding that Beck was not acting within the scope of her employment during the alleged misconduct. Longworth did not appeal the FTCA judgment.The United States Court of Appeals for the Fourth Circuit reviewed the case and concluded that the district court's FTCA judgment precluded Longworth's Bivens appeal. The FTCA judgment bar provides that an FTCA judgment is a complete bar to any action by the claimant against the employee of the government whose act or omission gave rise to the claim. Since a judgment on the FTCA claim had been entered, Longworth could no longer pursue his Bivens action based on the same conduct. Consequently, the Fourth Circuit dismissed the appeal. View "Longworth v. Mansukhani" on Justia Law