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

Plaintiff, the mother of a minor child with special needs, brings this action for attorney’s fees under the Individuals with Disabilities Education Act (“IDEA”). The IDEA allows parents who prevail in state administrative proceedings challenging their children’s individualized education programs to recover attorney’s fees in federal court. But Plaintiff did not file her claim for fees until almost two years after her administrative hearing, and the district court dismissed her case as untimely. The district court concluded that a standalone fees action like Plaintiff’s is most comparable to an IDEA claim for substantive judicial review of an adverse administrative determination. And because Virginia, where Plaintiff lives, sets a 180-day limitations period for such substantive IDEA claims, the court deemed her claim time-barred.   The Fourth Circuit affirmed. The court explained that the IDEA contains no express statute of limitations for attorney’s fees actions, so courts must “borrow” an appropriate limitations period from state law. The court wrote that Va. Code Section 22.1-214(D), by allowing parties 180 days to seek substantive judicial review of IDEA due process hearings, provides an appropriate – even generous – analog to attorney’s fees actions under 20 U.S.C. Section 1415(i)(3)(B). The court also agreed with the district court that his 180-day limitations period does not begin to run until after the aggrieved party’s time to seek substantive review has expired, meaning that a party has 360 days from the date of the administrative decision to commence a fees action. View "Jemie Sanchez v. Arlington County School Board" on Justia Law

Plaintiff a longtime employee of the Virginia Department of Environmental Quality (“DEQ”), commenced this action against DEQ, claiming that it paid her less than it paid a male employee with the same position doing equal work, in violation of the Equal Pay Act. The district court entered summary judgment against Plaintiff, concluding that she lacked evidence to demonstrate that any higher-paid male employee was doing work “virtually identical” to the work she was doing. Indeed, the court explained that the record showed that the male employee whom Plaintiff had identified as a comparator was doing different and more complex work than she was, such that she could not show that she was paid less for equal work.   The Fourth Circuit affirmed. The court explained that the district court did not err in concluding that Plaintiff could not establish that she and the male employee performed “equal work.” To be sure, Plaintiff and the male employee performed similar work. But the differences in the actual work performed and the level of complexity involved were significant enough that their work cannot be fairly described as “substantially equal” or “virtually identical,” as required to establish a claim under the Equal Pay Act. View "Elizabeth Polak v. Virginia Department of Environmental Quality" on Justia Law

Plaintiff spent nearly three months in Middle River Regional Jail. And he alleges that Middle River’s practices during that time substantially burdened his Islamic faith while unconstitutionally favoring the practice of Christianity. He argues that he was kept from engaging in Friday Prayer.   Plaintiff’s claims regarding Friday Prayer implicate the Free Exercise Clause. Under that clause, prisons can impose burdens on inmates’ religious practice— even substantial burdens—so long as the prison rules that do so are “reasonably related to legitimate penological interests.” Middle River had three rules in place that kept Plaintiff from attending in-person Friday Prayer: no inmate led groups; no maximum-security prisoners allowed in any in-person groups; and prisoner services and classes by volunteer or donation only.   The Fourth Circuit affirmed the district court’s Free Exercise decision and remanded for further proceedings on the Establishment Clause. The court explained that Middle River’s policies do not violate the Free Exercise Clause. Each of the rules and regulations that combined to keep Plaintiff from engaging in communal Friday Prayer during his brief stay was reasonably related to a legitimate penological interest and, therefore, acceptable under Turner. Whether the challenged practices violate the Establishment Clause is a question best left to the district court to resolve in the first instance, with the benefit of intervening legal developments. View "David Firewalker-Fields v. Jack Lee" on Justia Law

Plaintiff appealed from the decision rendered in the Eastern District of North Carolina in 2021 granting summary judgment to several officials of North Carolina’s Central Prison (the “Central Prison defendants”), against whom Plaintiff— a Central Prison inmate — pursued various state and federal claims. In awarding judgment to the Central Prison Defendants, the district court ruled that Plaintiff had failed to exhaust all administrative remedies available to him prior to filing his lawsuit in federal court, as required by the Prison Litigation Reform Act (the “PLRA”).   The Fourth Circuit vacated and remanded. The court explained that in these circumstances, however, the record presents numerous disputed issues of material fact about how North Carolina’s prison grievance procedure functions and is administered, including whether Plaintiff failed to exhaust administrative remedies of his own accord and whether such remedies were meaningfully “available” to him. Accordingly, because the district court’s award of summary judgment was erroneously premature and otherwise flawed. View "Matthew Griffin v. Nadine Bryant" on Justia Law

Plaintiff a deaf man, sought an interpreter to communicate with Novant Health Huntersville Medical Center during his wife’s childbirth there. After Novant Health failed to provide him with a live interpreter or a functioning Video Remote Interpreting device, Plaintiff filed this disability discrimination lawsuit. The district court dismissed his claim.   The Fourth Circuit reversed the district court’s judgment finding that the district court applied an incorrect standard of law. The court held that under the proper standard, Plaintiff has plausibly pled enough under the Rehabilitation Act to survive a Fed. R. Civ. P. 12(b)(6) dismissal motion. The court explained that Patients often arrive at hospitals in pain, unconscious, or feeling intense stress. In these situations, which can be not only confusing but overwhelming, a patient’s companion, often a spouse or a family member, may be the only advocate available. Plaintiff, a hearing-impaired individual, was unable to communicate his wife’s complicated medical history to her doctors during childbirth, despite repeated requests for some effective means of doing so. The situation was a highrisk one for the couple, and the medical event one of the highest urgency and meaning. To have that single advocate barred from communication with a hospital and its staff is to leave the patient stranded. View "Neil Basta v. Novant Health Incorporated" on Justia Law

Plaintiff’s estate sued the Virginia Department of Corrections (“Department”) and several prison officials under 42 U.S.C. Section 1983 and Virginia law, alleging that they violated the Eighth Amendment and state law by failing to provide Plaintiff treatment for his chronic hepatitis C until it was too late.   Defendants in this appeal are Dr. A and Dr. W. Plaintiff alleges that Dr. A designed treatment guidelines for inmates with hepatitis C that unconstitutionally excluded Plaintiff from receiving treatment. Plaintiff also alleges that Dr. W failed to follow those guidelines and committed both medical malpractice and Eighth Amendment violations in denying him appropriate treatment. Defendants unsuccessfully moved for summary judgment, alleging that they were protected by qualified immunity and, on Dr. W’s part, derivative sovereign immunity.   The Eighth Circuit reversed the district court’s denial of sovereign immunity to Dr. W and denial of qualified immunity to Dr. A but affirm its denial of qualified immunity to Dr. W. The court declined to hold that Dr. A was clearly on notice that he should have ordered the Department’s primary care providers to prescribe this novel treatment rather than referring patients to specialists for treatment.  Further, the court explained a prisoner’s purported right not to be subjected to a treatment regimen that prioritized antiviral treatment to prisoners with the most advanced levels of fibrosis was not clearly established when Dr. A designed the Guidelines in 2015. Moreover, three of the four factors strongly weigh in favor of sovereign immunity, and one only moderately weighs against it. Therefore, the court concluded that the district court erred by rejecting Dr. W’s sovereign-immunity defense. View "Jacob Pfaller v. Mark Amonette" on Justia Law

K.I., a minor who lives in Durham, North Carolina, was diagnosed with a variety of learning and psycho-social disorders. Dissatisfied with her school’s response to her request for special education services, K.I. and her mother J.I. asked for and received a hearing under North Carolina’s administrative procedures. Because they disagreed with the hearing decision, K.I. and J.I. tried to appeal it administratively. But their appeal was not considered because K.I. and J.I. did not follow North Carolina’s rules for filing appeals. K.I. and J.I. sued in federal court under the Individuals with Disabilities Education Act (the “IDEA”). The district court found that K.I. and J.I.’s failure to properly appeal under North Carolina’s administrative rules meant that they had not exhausted their administrative remedies. So, it dismissed the federal action for lack of subject matter jurisdiction. K.I. and J.I.’s appeal of that decision.   The Fourth Circuit affirmed. The court held that it agreed with the district court because K.I. and J.I. did not challenge the court’s ruling on the ADA and Section 504 claims; the issue is waived. Second, the court found that the district court correctly analyzed these claims. Both the ADA and Section 504 claims sought relief due to the alleged failure of Durham Public Schools and the State Board to provide a FAPE to K.I. Thus, under Fry, the IDEA’s exhaustion requirement applied to those claims. The court also affirmed the district court in dismissing the ADA and Section 504 claims. View "K.I. v. Durham Public Schools Board" on Justia Law

Appellant appealed the district court’s dismissal of her amended complaint filed against her former employer, the United States Department of the Army. Appellant alleged that she experienced a hostile work environment due to race-based harassment from a co-worker and retaliation by her supervisors through both discrete acts and a retaliatory hostile work environment.   The Fourth Circuit affirmed the district court’s dismissal of Appellant’s discrete-act retaliation claim but vacated its dismissal of her race-based hostile work environment and retaliatory hostile work environment claim. The court explained that Appellant has stated a prima facie case. The court wrote that an “employee’s decision to report discriminatory behavior cannot immunize that employee from those petty slights or minor annoyances that often take place at work and that all employees experience,” but the consistent (even if not constant) conduct Appellant alleged plausibly qualifies as materially adverse. The court further wrote that it agreed that Appellant failed to allege a non-speculative link between her Title VII claim and her non-selection. View "Marie Laurent-Workman v. Christine Wormuth" on Justia Law

Respondent has long struggled with mental illness and a proclivity to violent outbursts. In 2017, Williams assaulted a security guard in Portland, Oregon—a federal crime because it happened at a Social Security office. Respondent pleaded guilty and was sentenced to just over four years in prison, to be followed by three years of supervised release. Federal prisoners on the cusp of being released may be civilly committed if they are “presently suffering from a mental disease or defect as a result of which [their] release would create a substantial risk” to the person or property of others. Here, the primary question is whether—in making such a risk assessment—a court must consider any terms of supervision that would govern the prisoner’s conduct post-release.   The Fourth Circuit held that a court must consider any terms of supervision that would govern the prisoner’s conduct post-release. Thus, because the record offers no assurances the district court appropriately considered the terms of Respondent’s supervised release before ordering him committed, the Fourth Circuit vacated the district court’s order and remanded for further proceedings. View "US v. Nathaniel Williams" on Justia Law

The Fourth Circuit affirmed the district court’s ruling denying Appellants’ motion for summary judgment based on a qualified immunity defense to a 42 U.S.C. Section 1983 claim for damages. Appellants appealed the district court’s denial of their respective summary judgment motions based on a qualified immunity defense to a 42 U.S.C. Section 1983 claim for damages asserted by Appellee. Appellee initiated the underlying action against Appellants, and various other South Carolina state officials after his son, (“Decedent”), was struck and killed by a vehicle while he was a pedestrian on Interstate 95 (“I-95”) in South Carolina.   Appellee alleged that Appellants violated Decedent’s Fourteenth Amendment substantive due process right to be free from deliberate indifference to his serious medical needs by failing to ensure Decedent was transported to a hospital or jail where he could receive adequate medical attention. The district court determined that, while Decedent’s right to freedom from deliberate indifference to his serious medical needs was clearly established at the time of the alleged violation, a genuine dispute of material fact barred a ruling on qualified immunity at the summary judgment stage.   Appellants contest the district court’s ruling that Decedent’s constitutional right was “clearly established.” The Fourth Circuit affirmed. The court explained that a pretrial detainee’s right to adequate medical care and freedom from deliberate indifference to his serious medical needs was clearly established and particularly recognized by both the Fourth Circuit and the Supreme Court at the time of the events in question. Further, the court wrote that Appellants have also not addressed the court’s “fundamental error” standard, nor have they attempted to show that they can meet it here. Thus, Appellants have not satisfied their burden of identifying a “fundamental error” warranting reversal on a ground not raised before the district court. View "Paul Tarashuk v. Jamie Givens" on Justia Law