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

In August 2019, Eric Toon led Lieutenant Christopher Zerkle on a high-speed chase before returning to his home, where his girlfriend, Taylor Quinn, was sleeping. Zerkle and other officers, including Sergeants Paxton Lively and Rick Keglor, and Deputies Brandon Kay and Jamie Miller, arrived at Toon’s residence. The officers knocked on the door, which eventually opened outward, leading them to enter the home. Toon then broke a window, jumped out with an AR-15, and was fatally shot by Zerkle and another officer. Quinn, who followed Toon out of the window, was also injured.The United States District Court for the Southern District of West Virginia dismissed some claims and granted summary judgment in favor of the officers on the remaining claims. The court found that the officers reasonably believed they had consent to enter the home when the door opened and that Zerkle’s use of deadly force against Toon was justified. The court also concluded that Quinn’s injuries were accidental and not the result of intentional excessive force.The United States Court of Appeals for the Fourth Circuit reviewed the case and found that factual disputes precluded summary judgment on the warrantless entry claims and Quinn’s excessive force, battery, and trespass claims. The court held that the officers could not assume consent to enter the home merely because the door opened. The court also determined that there was sufficient evidence for a jury to find that Zerkle intentionally shot Quinn. The court affirmed the district court’s decision on the remaining claims, including the excessive force claim related to Toon and the failure to intervene claim against Zerkle. The case was reversed in part, affirmed in part, and remanded for further proceedings. View "Quinn v. Zerkle" on Justia Law

Nasanto Antonio Crenshaw, a 17-year-old, was shot and killed by Officer Matthew Sletten of the Greensboro, North Carolina police department while driving an allegedly stolen car. Crenshaw's mother, Wakita Doriety, filed a lawsuit against Officer Sletten for excessive force under 42 U.S.C. § 1983 and various state law claims. The City of Greensboro was also named as a defendant for the state law claims. The City moved to dismiss the claims, asserting governmental immunity, and the district court agreed, dismissing all claims against the City. Officer Sletten also moved to dismiss the claims against him, arguing that the video evidence contradicted the plaintiff's allegations.The United States District Court for the Middle District of North Carolina dismissed the claims against the City based on governmental immunity, ruling under Rule 12(b)(2). The court also dismissed the claims against Officer Sletten under Rule 12(b)(6), finding that the video evidence showed Crenshaw driving directly towards the officer, justifying the use of deadly force. The court concluded that the officer's actions were reasonable and dismissed the excessive force claim and the state law claims against him.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the dismissal of the claims against the City but reversed the dismissal of the claims against Officer Sletten. The appellate court held that the district court erred in dismissing the excessive force claim because the video did not blatantly contradict the plaintiff's allegations. The court found that the plaintiff's allegations, when properly construed, were sufficient to state a claim of excessive force under § 1983. The case was remanded for further proceedings on the claims against Officer Sletten. View "Doriety v. Sletten" on Justia Law

Rashad Matthew Riddick, an involuntarily committed patient at Central State Hospital in Virginia, alleged that he was subjected to extreme conditions of confinement. He claimed he was immobilized in four-point restraints for two weeks and then placed in seclusion for a year and a half. Riddick filed a civil rights lawsuit against the hospital’s director and the interim commissioner of the Virginia Department of Behavioral Health and Developmental Services, arguing that these conditions violated his Fourteenth Amendment rights.The United States District Court for the Eastern District of Virginia dismissed Riddick’s complaint. The court reasoned that Riddick failed to adequately plead the professional standard of care from which his treatment allegedly departed and did not sufficiently allege the interim commissioner’s personal involvement in his conditions of confinement. The court also denied Riddick’s requests for appointed counsel, finding that his claims were not complex enough to warrant such an appointment and that he had demonstrated an ability to represent himself.The United States Court of Appeals for the Fourth Circuit reviewed the case and reversed the district court’s dismissal. The Fourth Circuit held that plaintiffs like Riddick are not required to identify an accepted professional standard at the pleading stage. Instead, a substantial departure from professional judgment can be inferred from specific factual allegations. The court found that Riddick’s allegations of prolonged restraint and seclusion, along with the adverse effects on his mental health, were sufficient to suggest a substantial departure from professional judgment. The court also concluded that Riddick had adequately alleged the interim commissioner’s personal involvement by claiming that the commissioner approved the conditions of his confinement. The Fourth Circuit recommended that the district court appoint counsel for Riddick as the case proceeds. View "Riddick v. Barber" on Justia Law

A retired Navy chaplain, Allen Lancaster, sued several Navy officials in their official capacities, alleging discrimination in the Navy’s promotion practices. Lancaster claimed he was not promoted due to retaliation based on personal hostility and denominational prejudice. He sought declaratory and injunctive relief, including orders to remedy the harm to his career and to hold new promotion boards. Lancaster also challenged the six-year statute of limitations for civil actions against the United States and the constitutionality of a statutory privilege for selection board proceedings.The United States District Court for the Eastern District of Virginia dismissed Lancaster’s amended complaint with prejudice on res judicata grounds, referring to several prior decisions in the longstanding dispute over the Navy’s promotion procedures for chaplains. After Lancaster’s death, his widow, Darlene Lancaster, sought to reopen the case, substitute herself as the plaintiff, and amend the dismissed complaint. The district court denied these requests, leading to the current appeal.The United States Court of Appeals for the Fourth Circuit reviewed the case and determined that Lancaster’s death mooted his claims for prospective relief, as he could no longer benefit from the requested declarations and orders. The court also found that any potential claims for retrospective relief were barred by sovereign immunity, as the Lancasters failed to demonstrate an unequivocal waiver of this immunity. Consequently, the district court lacked subject matter jurisdiction to dismiss the case on res judicata grounds or to rule on the widow’s post-dismissal motion. The Fourth Circuit vacated the district court’s judgment and remanded the case with instructions to dismiss it without prejudice for lack of subject matter jurisdiction. View "Lancaster v. Secretary of the Navy" on Justia Law

Andrew Fields, while incarcerated at U.S. Penitentiary Lee, alleged that he was subjected to excessive force by several prison officials, violating his Eighth Amendment rights. Fields claimed that after failing to carry his inmate movement pass, he was berated, placed in administrative segregation, and had his legal documents and prescription eyeglasses seized. He further alleged that during his transfer to the Special Housing Unit (SHU), he was physically abused, including being hit and having his head rammed into a wall, despite posing no threat. Fields also claimed that prison staff denied him access to the Bureau of Prisons' administrative grievance procedure, preventing him from pursuing alternative remedies.The United States District Court for the Western District of Virginia dismissed Fields's complaint under the Prison Litigation Reform Act’s prescreening procedure, concluding that his allegations either did not state a constitutional violation or were not cognizable under Bivens v. Six Unknown Named Agents of Federal Narcotics Bureau. Fields appealed the dismissal, focusing solely on his Eighth Amendment excessive force claim.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo and concluded that Fields's allegations, if true, could overcome the limitations on Bivens claims. The court found that Fields's claim did not implicate systemic prison policies but rather concerned individual officers' conduct in violation of prison policy. The court also noted that Fields was denied access to alternative remedies due to the officers' actions. Consequently, the Fourth Circuit affirmed the dismissal of claims against the Bureau of Prisons and supervisory officials but reversed and remanded the excessive force claim against the individual officers who allegedly subjected Fields to abuse. View "Fields v. Federal Bureau of Prisons" on Justia Law

In January 2021, Julius Lamart Hodges, an inmate at the Prince William-Manassas Adult Detention Center, volunteered to work in the kitchen during a COVID-19 outbreak while most inmates quarantined. Hodges did not contract COVID-19 but claimed that his exposure to the virus constituted cruel and unusual punishment under the Eighth Amendment. He also alleged that his working conditions were harsh and that he was retaliated against for filing grievances about these conditions.The United States District Court for the Eastern District of Virginia dismissed Hodges’s complaint. The court found that Hodges failed to state a claim under the Eighth Amendment because he voluntarily chose to work and could have opted to quarantine. The court also dismissed his First Amendment retaliation claim, concluding that Hodges did not plausibly allege a causal connection between his grievances and any adverse action taken by the prison officials.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court’s dismissal. The Fourth Circuit held that Hodges’s Eighth Amendment claim failed because he voluntarily exposed himself to the conditions he complained about, and thus, the prison officials did not inflict those conditions upon him. The court also found that Hodges’s First Amendment retaliation claim was insufficient because he did not adequately allege a causal relationship between his grievances and the denial of his Work Release application. The court noted that the temporal gap between his grievance and the adverse action was too long to support an inference of causation.The Fourth Circuit modified the district court’s dismissal to be without prejudice, allowing Hodges the opportunity to amend his complaint if he could address the deficiencies identified by the court. View "Hodges v. Meletis" on Justia Law

Kenneth Ray Jenkins, a pretrial detainee at Wilson County Detention Center (WCDC) in 2018, alleged that he was subjected to unsanitary living conditions, including confinement in cells infested with feces, which led to a bacterial illness. Jenkins, who suffers from mental health disorders, claimed that he was denied his medication, placed in solitary confinement, and later moved to an unsanitary "Rubber Room." He further alleged that he was denied medical attention for severe rectal bleeding for several months, which resulted in a diagnosis of multiple medical conditions.Jenkins filed a pro se complaint under 42 U.S.C. § 1983, asserting violations of his Fourteenth Amendment rights. The United States District Court for the Eastern District of North Carolina dismissed most of his claims but allowed his conditions-of-confinement and deliberate-indifference claims against Sheriff Calvin Woodard to proceed. Jenkins requested additional time for discovery and appointment of counsel, both of which were denied by the district court. The court granted summary judgment in favor of Sheriff Woodard, finding that Jenkins failed to demonstrate a material factual dispute.The United States Court of Appeals for the Fourth Circuit reviewed the case and found that the district court abused its discretion in denying Jenkins’s requests for counsel and additional time for discovery. The appellate court noted that Jenkins’s severe mental illness, lack of legal knowledge, and inability to access legal materials and evidence while incarcerated demonstrated that he lacked the capacity to present his claims. The Fourth Circuit reversed the district court’s denials of Jenkins’s requests for discovery and counsel, vacated the summary judgment decision, and remanded the case for further proceedings, directing the district court to appoint counsel for Jenkins. View "Jenkins v. Woodard" on Justia Law

On June 7, 2019, around 4:20 a.m., two police officers detained Anthry Milla, who was sitting in his car in his driveway. The officers were investigating a nearby stabbing but had no description of a suspect. Milla was cooperative but closed his car door when the officers approached. The officers, suspecting involvement in the stabbing, detained Milla at gunpoint, searched his car, and found no evidence. Milla's parents confirmed his identity, and he was released after about eight minutes.Milla filed a pro se complaint under 42 U.S.C. § 1983, alleging Fourth Amendment violations. The United States District Court for the Eastern District of Virginia granted summary judgment to the officers, finding their actions justified under the totality of the circumstances. The court also held that the officers were entitled to qualified immunity, as they did not violate Milla's constitutional rights.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo and vacated the district court's decision. The appellate court found that the officers lacked reasonable, particularized suspicion to detain Milla. The court emphasized that proximity to a crime scene and Milla's actions, such as closing his car door, did not constitute reasonable suspicion. The court also vacated the district court's award of qualified immunity, as the officers' actions were not justified under established Fourth Amendment standards. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Milla v. Brown" on Justia Law

Harris Ford, an inmate in the North Carolina Department of Corrections, filed a lawsuit against six prison officials under 42 U.S.C. § 1983, alleging that they violated his Eighth Amendment rights by failing to protect him from an attack by another inmate. Ford claimed that he had informed the officials of the risk through numerous complaints and grievances, but they were deliberately indifferent, leading to the attack where he was severely injured.The United States District Court for the Middle District of North Carolina granted summary judgment in favor of the prison officials. The court concluded that Ford's complaints were not specific enough to enable the officials to investigate and respond appropriately. Additionally, the court found that Ford failed to demonstrate the necessary mens rea of deliberate indifference required for an Eighth Amendment violation.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's judgment regarding five of the six prison officials. The appellate court agreed that Ford did not provide sufficient evidence to show that these officials were deliberately indifferent to his safety. However, the court vacated the summary judgment concerning Officer Jerry Ingram. The court found that there was a genuine issue of material fact regarding whether Ingram's actions, specifically his public questioning of Ford about the threats, knowingly exacerbated the risk to Ford and contributed to the attack. The case was remanded for further proceedings against Officer Ingram. View "Ford v. Hooks" on Justia Law

An elderly couple in Greenville, North Carolina, reported a breaking-and-entering at their residence around 4:00 a.m., hearing glass break and a male voice yelling. Officer David Johnson, who was nearby, responded to the call. Upon arrival, Johnson heard loud yelling and saw Sean Rambert running towards him while yelling. Johnson commanded Rambert to get on the ground eight times, but Rambert did not comply and continued to charge at Johnson. Johnson fired multiple shots at Rambert, who continued to advance even after being shot. Rambert eventually fell and later died from his injuries.The United States District Court for the Eastern District of North Carolina denied Johnson’s motion for summary judgment based on qualified immunity. The court found genuine disputes of material fact regarding the reasonableness of Johnson’s conduct and concluded that a jury could determine that Johnson violated Rambert’s Fourth Amendment rights by using excessive force. The court also denied summary judgment on the remaining federal and state law claims against Johnson and the City of Greenville.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that Johnson was entitled to qualified immunity on the Fourth Amendment claim. The court found that Johnson’s use of deadly force was not objectively unreasonable given the circumstances, including Rambert’s aggressive behavior and failure to comply with commands. The court also determined that the law did not clearly establish that Johnson’s conduct was unconstitutional at the time of the incident. Consequently, the court reversed the district court’s denial of summary judgment on the § 1983 claim against Johnson. However, the court dismissed the appeal regarding the related state and federal claims and claims against the City of Greenville, remanding those issues for further proceedings. View "Rambert v. City of Greenville" on Justia Law