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

The Fourth Circuit reversed the district court's determination that plaintiff was required to wait longer than 180 days to commence a civil action under Title VII and the Rehabilitation Act after amending his initial administrative complaint before the relevant agency. The court held that the text of Title VII, as well as the legislative context and purpose, plainly states that a claimant may commence a civil action 180 days from "the filing of the initial charge." Accordingly, the court remanded for further proceedings. View "Stewart v. Iancu" on Justia Law

The Fourth Circuit affirmed the district court's judgment concluding that defendant, chair of the Loudoun County Board of Supervisors, violated the First Amendment rights of one of her constituents, Brian Davison, when she banned Davison from the "Chair Phyllis J. Randall" Facebook page she administered. The court held that Davison had standing because she adduced facts establishing an injury in fact sufficient to justify the prospective declaratory relief awarded by the district court; considering the totality of these circumstances, the district court correctly held that defendant acted under color of state law in banning Davison from the Chair's Facebook Page; and the interactive component of the Chair's Facebook Page constituted a public forum, and defendant engaged in unconstitutional viewpoint discrimination when she banned Davison's page from that forum. In regard to Davison's cross-appeal, the court rejected his assertion that the district court reversely erred by dismissing his claim against defendant in her official capacity and by denying his motion to amend. View "Davison v. Randall" on Justia Law

The Fourth Circuit affirmed the district court's dismissal of plaintiff's action challenging various aspects of the Credit Union's website under the Americans with Disabilities Act. Plaintiff, a blind individual, alleged that his attempt to access the Credit Union's website was hindered in various ways. The court held that plaintiff, who is barred by law from making use of the Credit Union's services may not sue under the ADA for an allegedly deficient website. In this case, plaintiff was not eligible for membership in the Credit Union where he does not work for the Department of Labor and never has in the past. Accordingly, the court concluded that plaintiff's injury was not concrete, particularized, or immediately threatening. View "Griffin v. Department of Labor Federal Credit Union" on Justia Law

Plaintiff appealed the district court's grant of summary judgment in favor of DOC officials in an 42 U.S.C. 1983 action alleging due process violations. Plaintiff claimed that, as a result of actions of defendants, he suffered in solitary confinement for three-and-a-half years while in pretrial detention, in violation of his Fourteenth Amendment rights.Determining that it had appellate jurisdiction and the due process claims were not moot, the Fourth Circuit held that Defendants Charlton and Miller were entitled to summary judgment on each of the due process claims because they lacked sufficient personal involvement in the alleged constitutional deprivations. The court held, however, that Director Stirling and Sheriff Carroll were not entitled to qualified immunity on plaintiff's substantive and procedural due process claims arising from plaintiff's solitary confinement as a safekeeper. Because neither the report or the summary judgment properly applied the legal principles that control substantive and procedural due process claims being pursued by a pretrial detainee, the court held that the district court erred in awarding summary judgment to Director Stirling and Sheriff Carroll on these claims. View "Williamson v. Stirling" on Justia Law

The Fourth Circuit affirmed the district court's denial of petitioner's successive 28 U.S.C. 2255 motion in this criminal proceeding stemming from murders committed four decades ago. The court rejected petitioner's prosecutorial misconduct claim based on the discovered evidence of a former Deputy U.S. Marshal that a threat from a prosecutor stopped another individual from confessing on the witness stand during petitioner's trial. The court also rejected petitioner's freestanding actual innocence claim premised on DNA testing. The court held that petitioner failed to overcome the procedural bar of section 2255(h)(1), because neither claim was based on newly discovered evidence that, if proven and viewed in light of the evidence as a whole, would be sufficient to establish by clear and convincing evidence that no reasonable factfinder would have found petitioner guilty of murdering his wife and daughters.In the alternative, the court held that the prosecutorial misconduct claim failed on the merits where the factual findings were well-supported by the evidence and not clearly erroneous. Furthermore, petitioner failed to meet his extraordinarily high burden of showing actual innocence. View "United States v. MacDonald" on Justia Law

Plaintiffs appealed the district court's dismissal of their civil rights actions under Title IX of the Education Amendments of 1972 and 42 U.S.C. 1983, seeking the reinstatement of three claims: a Title IX sex discrimination claim against the University of Mary Washington; a Title IX retaliation claim against UMW; and a section 1983 claim against UMW's former president, Dr. Richard Hurley, for violating the Equal Protection Clause of the Fourteenth Amendment.The Fourth Circuit affirmed the dismissal of the section 1983 claim and held that, at the time of President Hurley's challenged conduct, the equal protection right to be free from a university administrator's deliberate indifference to student-on-student sexual harassment was not clearly established by either controlling authority or by a robust consensus of persuasive authority. The court vacated the dismissal of the retaliation claim insofar as it is premised on UMW’s deliberate indifference to student-on-student retaliatory harassment. The court affirmed the dismissal of the aspect of the retaliation claim that relied exclusively on President Hurley's June 2015 letter. Finally, the panel vacated the dismissal of the Title IX sex discrimination claim against UMW where plaintiffs have sufficiently alleged a sex discrimination claim under Title IX, predicated on UMW's deliberate indifference to the specified student-on-student harassment. View "Feminist Majority Foundation v. Hurley" on Justia Law

Plaintiff and her daughter filed suit against the county, challenging an in-school Bible lesson program for public elementary and middle school students as violating the Establishment Clause. The Fourth Circuit reversed the district court's dismissal of the complaint, holding that plaintiffs have standing because they alleged two actual, ongoing injuries: (1) near-daily avoidance of contact with an alleged state-sponsored religious exercise, and (2) enduring feelings of marginalization and exclusion resulting therefrom. The court also held that plaintiffs' claims were redressable because an injunction would meaningfully redress their injuries. The court also held that the district court erred in treating the temporary suspension of the program as raising ripeness concerns, and plaintiffs' claims were not moot. View "Deal v. Mercer County Board of Education" on Justia Law

Nursing Homes, on behalf of eleven residents, filed suit against the Secretaries, alleging that the Secretaries wrongfully denied the residents Medicaid benefits in violation of the Fourteenth Amendment and several federal statutes.The Fourth Circuit affirmed the district court's dismissal of the complaint for lack of subject matter jurisdiction and failure to state a claim. The court held that the Eleventh Amendment barred the Nursing Homes' constitutional and Medicaid Act claims for damages or other relief based on past actions; the Nursing Homes' claims for declaratory and injunctive relief were moot and required dismissal because the court lacked subject matter jurisdiction; and, because the Nursing Homes failed to state a viable Americans with Disabilities Act claim, they failed to state a cognizable Rehabilitation Act claim. View "Wicomico Nursing Home v. Padilla" on Justia Law

In 2004, after pleading guilty to selling crack cocaine to a government informant, Lester was sentenced to almost 22 years in prison because he was designated a career offender under the then-mandatory Sentencing Guidelines. This enhancement depended on a past conviction for a “crime of violence,” Lester’s 1990 Georgia conviction for walkaway escape. In 2005, the Supreme Court stripped the Sentencing Guidelines of legal force and made them purely advisory; in 2009, the Court ruled that the generic crime of failing to report to a prison was not a crime of violence. Lester’s sentence should have been up to 11 years shorter. Lester sought habeas corpus relief. The district court denied his petition. The Fourth Circuit vacated, noting that its 2018 decision in United States v. Wheeler permits Lester’s challenge although Lester had already filed a petition under 28 U.S.C. 2255. In limited circumstances, courts, including the Fourth Circuit, allow a prisoner otherwise unable to file a second or successive section 2255 petition to seek relief under 28 U.S.C. 2241. A sentencing error “need not result in a sentence that exceeds statutory limits in order to be a fundamental defect.” Lester’s case must be considered on the merits. View "Lester v. Flournoy" on Justia Law

Lawlor worked at a Fairfax County apartment complex and had access to keys to each apartment. On September 24, 2008, Lawlor consumed alcohol and a large amount of crack cocaine and sexually assaulted, bludgeoned, and killed a tenant in that complex, Genevieve Orange. A Virginia state court sentenced Lawlor to death; the sentencing jury found that there was a probability Lawlor “would commit criminal acts of violence that would constitute a continuing serious threat to society,” Va. Code 19.2–264.4.C. Lawlor exhausted state court direct appeal and post-conviction remedies then sought review of his death sentence under 28 U.S.C. 2254. The district court dismissed his petition. The Fourth Circuit reversed. The state court excluded specialized and relevant testimony of a qualified witness who would have explained that Lawlor “represents a very low risk for committing acts of violence while incarcerated,” where the jury’s only choices were life in prison without parole or death. That ruling was an unreasonable application of clearly established Supreme Court precedent that “evidence that the defendant would not pose a danger if spared (but incarcerated) must be considered potentially mitigating,” and “such evidence may not be excluded from the sentencer’s consideration.” The error had a substantial and injurious effect. View "Lawlor v. Zook" on Justia Law