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

Articles Posted in Civil Rights
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Plaintiff, a former Federal Public Defender, was subject to sexual harassment by a supervisor. After attempting to pursue her administrative remedies, Plaintiff claimed she was constructively discharged and resigned. Plaintiff then filed claims under the Due Process and Equal Protection clauses, as well as under 42 U.S.C. Sections 1985(3) and 1986, against various executive and judicial officers. The district court dismissed all of Plaintiff's claims based on her failure to state a claim and Defendant's sovereign immunity.The panel held that Plaintiff's Due Process claim sufficiently plead a deprivation of her property interests, but failed to plead a deprivation of her liberty interest. The panel also held Plaintiff's Equal Protection claim adequately plead sex discrimination; however, her claims under 42 U.S.C. Sections 1985(3) and 1986 failed to state a claim upon which relief could be granted. Finally, the court determined that Plaintiff could only pursue back-pay benefits from all Defendant's named in their official capacity and that all Defendant's named in their individual capacity were entitled to dismissal under Bivens v. Six Unknown Named Agents, 403 U.S. 388 (1971). Thus, the court affirmed in part, reversed in part, and remanded the case to the district court for further proceedings. View "Caryn Strickland v. US" on Justia Law

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Plaintiff prevailed before the district court on his Section 1983 claim that North Carolina’s sex-offender registration system deprived him of procedural due process. That judgment was vacated and his case dismissed as moot after the legislature, because of the district court’s ruling, amended its statute to provide procedural protections to offenders like Plaintiff. When Plaintiff sought attorney’s fees, Defendant, state officials, argued that Plaintiff could not be a “prevailing party” under Section 1988 because the judgment in his favor had been vacated. The district court held that Plaintiff was entitled to attorney’s fees.   The Fourth Circuit affirmed the district court’s ruling that under 42 U.S.C. Section 1988, Plaintiff is a prevailing party entitled to attorney’s fees because the legislative change mooting his case came both after and in response to an award of judicial relief. The court reasoned that Plaintiff was a “prevailing party” under Section 1988 because he won a final judgment on the merits in the district court. He also obtained substantial judicial relief on his claim, including entry of a final injunction requiring that class members be removed from the registry and prohibiting their prosecution for offenses relating only to registered sex offenders. Further, the court found no abuse of discretion in the district court’s calculation of the fee award because the court properly concluded that Plaintiff was “fully successful,” and thus entitled to all the injunctive relief he requested. View "Kenneth Grabarczyk v. Joshua Stein" on Justia Law

Posted in: Civil Rights
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Plaintiff sued his former employer, the Maryland Military Department, and related entities, alleging that they discriminated against him on the basis of race in violation of Title VII 42 U.S.C. Sections 2000e to 2000e-17. The district court dismissed Holloway’s complaint for failure to state a claim.   The Fourth Circuit affirmed the district court’s dismissal of Plaintiff’s hostile work environment claim and reversed the dismissal of his unlawful termination and retaliation claims. The court reasoned that to state a claim for unlawful termination, a Title VII plaintiff must allege facts sufficient to raise a plausible inference that his employer discharged him because of his race. Here, Plaintiff alleged facts crucial to raise the inference of a Title VII violation “above a speculative level.”   Next, Title VII prohibits an employer from discriminating against an employee “because he has opposed any practice made an unlawful employment practice by [Title VII], or because he has made a charge, testified, assisted, or participated in any manner in an investigation, proceeding, or hearing” under Title VII. The court held that Plaintiff’s claim passes muster at the pleading stage.   However, the court held that Plaintiff failed to state a claim that he was subject to an abusive or hostile work environment based on his race or protected activity. The court rejected Plaintiff’s contention that one episode of yelling and pounding the table is sufficiently severe or pervasive to establish an abusive environment. View "Charles Holloway v. State of Maryland" on Justia Law

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Plaintiffs were the subjects of an unconstitutional search. Relying on the fruits of that search, prosecutors obtained grand jury indictments against Plaintiffs. After a court suppressed the evidence and dismissed the criminal charges against Plaintiffs, they sued the state trooper who conducted the search under 42 U.S.C. Sec. 1983.The Fourth Circuit affirmed the district court’s dismissal of Plaintiffs' claim, reasoning that their 1983 claim was based on an unconstitutional search and seizure of property and accrued at the time of the search. Thus, because Plaintiffs filed suit more than two years after the search the 1983 claim is time-barred.Plaintiffs argued that, even if a Fourth Amendment search claim typically accrues at the time of the search, this particular search claim did not accrue until the charges against them were dismissed because the claim “necessarily threatens to impugn” their prosecutions. Plaintiffs argue that a favorable-termination accrual rule is required anytime a 1983 claim “necessarily threatens to impugn” a prosecution. The court disagreed, finding that the accrual date is based on the nature of the constitutional violation when it is completed. The court found the claim accrued when the trooper performed the unlawful search in 2014. And the applicable two-year statute of limitations ran out well before Plaintiff’s sued in 2019. Thus the court affirmed the district court’s judgment. View "Fernando Smith v. Michael Travelpiece" on Justia Law

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Plaintiff filed 1983 against two nurses alleging that he was provided inadequate medical care during a health crisis he experienced while incarcerated. He was eventually sent a series of hospitals, where doctors told him a flesh-eating organism was damaging his internal organs.The first nurse was successfully served by the Marshals Service within Rule 4(m)’s 90-day period. The second nurse was not served because service was returned as “refused unable to forward.” The district court dismissed Plaintiff’s lawsuit on timeliness grounds after finding that Plaintiff’s amended complaint did not relate back under Rule 15(c) of the Federal Rules of Civil Procedure to his initial and timely complaint.At issue is whether the amended complaint adding Defendants is timely because it relates back to the date of the original complaint. The court found that the district court erred and the text of Rule 15(c)(1)(C) makes clear that the required “notice” and knowledge must come “within the period provided by Rule 4(m) for service.Next, the court addressed whether Defendants were provided the necessary notice within the Rule 4(m) notice period. The court ruled that Rule 15(c)’s requirements have been satisfied as to the first nurse. In regards to the second nurse, the court remanded to the district court for consideration of Plaintiff’s extension request, reasoning that the district court incorrectly believed that Plaintiff lost his chance to take advantage of Rule 15(c)’s relation-back rule. The court vacated the district court’s order granting the motion to dismiss. View "Patrick McGraw v. Theresa Gore" on Justia Law

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In the course of responding to a dispute between neighbors, a Deputy fatally shot a man while he was standing inside his home holding a loaded shotgun. The personal representative of the deceased's estate (“the Estate”), subsequently brought an action under 42 U.S.C. Sec. 1983, claiming that the Deputy used excessive force in violation of the deceased’s Fourth Amendment rights, along with various related state law claims.The Fourth Circuit vacated the district court’s grant of summary judgment on the following claims and remand the case for further proceedings: (1) the 1983 claim against the Deputy in his individual capacity; (2) the wrongful death claim for both compensatory and punitive damages under North Carolina law against the Deputy in his individual capacity; and (3) the claims under the Macon County Sheriff’s Office’s surety bond against the Deputy and Sheriff in their official capacities, and against Western Surety, for up to $25,000 in damages.Notably, the court found that parties’ factual disputes are quintessentially “genuine” and “material.” Assuming that a jury would credit the Estate’s expert evidence over the Deputy’s competing testimony and expert evidence, leads to the conclusion that the Deputy’s use of force was objectively unreasonable.The court affirmed the district court’s conclusions that: (1) the Estate’s Fourteenth Amendment claim fails as a matter of law; (2) Macon County’s liability insurance policy preserves the Sheriff’s Office’s governmental immunity from suit; and (3) the Estate’s claims brought directly under the North Carolina Constitution are precluded. View "Melissa Knibbs v. Anthony Momphard, Jr." on Justia Law

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The Estate filed suit alleging claims under 42 U.S.C. 1983 and state law after Deputy Sheriff Anthony Momphard, Jr. fatally shot Michael Knibbs while Knibbs was standing inside his home holding a loaded shotgun. The district court concluded that defendant was entitled to qualified immunity from the Estate's section 1983 claim and that the Estate's state law claims against Deputy Momphard, Macon County Sheriff Robert Holland, and the insurance companies that issued the Sheriff's Office a liability insurance policy and a surety bond necessarily failed.The Fourth Circuit vacated the district court’s award of summary judgment to Deputy Momphard on the Estate's section 1983 claim against him in his individual capacity. The court concluded that the district court erred in finding that there were no genuine issues of disputed material fact, and ultimately erred in finding that Deputy Momphard's use of force was reasonable as a matter of law at this stage in the proceedings. In this case, there is sufficient evidence for a reasonable jury to find that Knibbs never pointed his weapon at Deputy Momphard or made any furtive movements, thereby rendering unjustified the deadly force used against Knibbs. Furthermore, the court's case law demonstrates that the contours of Knibbs' constitutional right were clearly established at the time.The court also vacated the district court's summary judgment as to the wrongful death claim for both compensatory and punitive damages under North Carolina law against Deputy Momphard in his individual capacity, and the claims under the Macon County Sheriff's Office's surety bond against Deputy Momphard and Sheriff Holland in their official capacities, and against Western Surety, for up to $25,000 in damages. However, the court affirmed the district court's conclusions that the Estate's Fourteenth Amendment claim fails as a matter of law; Macon County's liability insurance policy preserves the Sheriff’s Office's governmental immunity from suit; and the Estate's claims brought directly under the North Carolina Constitution are precluded. The court remanded for further proceedings. View "Knibbs v. Momphard" on Justia Law

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Five adjacent Burtonsville, Maryland parcels are restricted from receiving sewer service. Several previous attempts to obtain approval of water and sewer category change requests were unsuccessful. The owners' alternative plan was to sell to a religious organization. They believed that land-use regulations must submit to “[c]hurch use [which] cannot be denied.” They entered into a contract with Canaan, contingent on the approval of the extension of a public sewer line for a new church. Such an extension required amendment of the Comprehensive Ten-Year Water Supply and Sewerage Systems Plan, which involves the Montgomery County Planning Board, the County Executive, the County Council, public hearings, and the Maryland Department of the Environment.Following denial of their requests, the owners sued under the Religious Land Use and Institutionalized Persons Act (RLUIPA) and the Free Exercise Clause of the First Amendment. The Fourth Circuit affirmed the summary judgment rejection of the claims. The land has been bound by decades of regulations restricting development for both religious and non-religious purposes. The parties were aware of the difficulties in developing the property when they entered into the contract; they could not have a reasonable expectation of religious land use. The restrictions are rationally related to the government’s interest in protecting the region’s watershed. View "Canaan Christian Church v. Montgomery County" on Justia Law

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Plaintiff filed suit under 42 U.S.C. 1983, alleging that his public high school suspended him in violation of the First, Fifth, and Fourteenth Amendments. Plaintiff's claims stemmed from the actions taken against him by school personnel after he engaged in a conversation with his classmates about the shooting at Marjory Stoneman Douglas Highschool. The district court held that plaintiff's suit was barred under Monell v. Department of Social Services, 436 U.S. 658 (1978), and dismissed the complaint for failure to state a claim on which relief could be granted.The Fourth Circuit concluded that the school board acted as the final policymaking authority in approving plaintiff's suspension, and thus Monell does not bar the suit. Furthermore, plaintiff's complaint plausibly alleges a First Amendment claim where the First Amendment does not permit schools to prohibit students from engaging in the factual, nonthreatening speech alleged here. In this case, plaintiff engaged in a factual conversation with his peers about a current event that is uniquely salient to the lives of American teenagers, a school shooting. The court stated that schools cannot silence such student speech on the basis that it communicates controversial or upsetting ideas. To do so would be incompatible with the very purpose of public education. However, the court concluded that the district court properly held that the complaint alleges no plausible Fifth or Fourteenth Amendment claim. Accordingly, the court reversed in part and affirmed in part. View "Starbuck v. Williamsburg James City County School Board" on Justia Law

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This case arose out of South Carolina's termination of Planned Parenthood's Medicaid provider agreement. The district court granted a preliminary injunction, concluding in relevant part that the individual plaintiff had demonstrated that she was likely to succeed on her Medicaid Act claim since the free-choice-of-provider provision conferred a private right enforceable under 42 U.S.C. 1983 and South Carolina had violated that provision by terminating Planned Parenthood's Medicaid provider agreement. The Fourth Circuit affirmed the district court's decision. The district court then issued a permanent injunction, which South Carolina now challenges in this appeal.The Fourth Circuit first concluded that this case presents a live case or controversy and rejected South Carolina's claim of mootness. Even assuming that the court were free to reexamine its precedents, the court declined to do so in this case. Rather, the court concluded that its previous decision was handed down as a matter of law and resolved the precise legal issue upon which South Carolina now seeks review.The court reaffirmed its prior decision, concluding that the free-choice-of-provider provision confers on Medicaid recipients an individual right enforceable under section 1983. The court stated that the statute plainly reflects Congress's desire that individual Medicaid recipients be free to obtain care from any qualified provider and it implements this policy in direct and unambiguous language. In this case, all three Blessing factors in determining whether a statute creates a private right enforceable under section 1983 are met. Furthermore, the Medicaid Act does not evince Congress's intent to specifically foreclose a remedy under section 1983. Finally, the Supreme Court's decision in O’Bannon v. Town Court Nursing Center, 447 U.S. 773 (1980), does not undermine the court's analysis. The court refused to nullify Congress's undeniable desire to extend a choice of medical providers to the less fortunate among us, individuals who experience the same medical problems as the more fortunate in society but who lack under their own means the same freedom to choose their healthcare provider. View "Planned Parenthood South Atlantic v. Kerr" on Justia Law