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

The Fourth Circuit affirmed the district court's grant of summary judgment to the employer in an action alleging that the unauthorized review and disclosure of plaintiff's confidential personnel files to support her racial and religious discrimination claims constituted protected activity under Title VII.The court held that, under the opposition clause, unauthorized disclosures of confidential information to third parties are generally unreasonable. In this case, plaintiff's unauthorized review and duplication of confidential personnel files did not constitute protected opposition or participation activity. The court also held that section 704(a) of Title VII of the Civil Rights Act does not protect a violation of valid state law that poses no conflict with Title VII. The court explained that, like in plaintiff's opposition claim, she failed to meet her burden of proving that the sheriff terminated her employment because she engaged in protected activity. View "Netter v. Barnes" on Justia Law

Petitioner sought relief from the district court's gag order imposing stringent restrictions on participants and potential participants in a series of nuisance suits brought against the hog industry in North Carolina. Determining that a mandamus petition was the appropriate mechanism for challenging the gag order and that the mandamus petition was not moot, the Fourth Circuit held that petitioner met its burden of showing a clear and indisputable right to the requested relief. Applying strict scrutiny, the court held that the gag order breached basic First Amendment principles in both meaningful and material ways. In this case, the gag order harmed petitioner, farmers, and plaintiffs. Accordingly, the court vacated the gag order and allowed the parties to begin anew under the guidelines the court set forth. View "In re: Murphy-Brown, LLC" on Justia Law

The Fourth Circuit vacated the district court's order denying the EEOC's request under the Age Discrimination in Employment Act (ADEA) for retroactive monetary relief from the county. The court held that retroactive monetary awards, such as the back pay sought here, were mandatory legal remedies under the ADEA upon a finding of liability. The court's conclusion was not altered by the county's contention that the EEOC unduly delayed in the investigation. Accordingly, the court remanded for a determination of the amount of back pay to which the affected employees were entitled under the ADEA. View "EEOC v. Baltimore County" on Justia Law

The Fourth Circuit affirmed Defendant’s convictions for possession with intent to distribute heroin and cocaine based and possession of a firearm, holding that there was no reversible error in the proceedings below.Specifically, the Court held that the district court (1) did not abuse its discretion in denying Defendant’s motion to suppress statements he made to officers during the execution of a search warrant for his residence; (2) did not abuse its discretion in admitting “other acts” evidence under Fed. R. Evid. 404(b); (3) did not err in denying Defendant’s motion to disclose the identity of a confidential informant who provided information used to obtain the search warrant; and (4) did not err in enhancing Defendant’s sentence on the basis of his prior Maryland convictions. View "United States v. Bell" on Justia Law

Plaintiffs, a student and two student groups behind a Free Speech Event at the University of South Carolina, filed suit alleging that University officials violated their First Amendment rights when they required one of the students to attend a meeting to discuss complaints about their event. Plaintiffs also alleged a facial challenge to the University's general policy on harassment, arguing that it was unconstitutionally vague and overly broad.The Eleventh Circuit affirmed the district court's grant of summary judgment for the University defendants, holding that the University neither prevented plaintiffs from holding their Free Speech Event nor sanctioned them after the fact. Plaintiffs failed to show a credible threat that the University would enforce its harassment policy against their speech in the future, and thus they lacked standing to pursue their facial attack on the policy. View "Abbott v. Pastides" on Justia Law

Virginia's regulation of the consumption, purchase, manufacture, and sale of alcohol through a series of interconnecting provisions found in Title 4.1 of the Virginia Code did not qualify as cruel and unusual punishment because it criminalizes plaintiffs' status as homeless alcoholics and did not violate Robinson v. California, 370 U.S. 660 (1962). Robinson held that, although states may not criminalize status, they may criminalize actual behavior even when the individual alleges that addiction created a strong urge to engage in a particular act. In this case, it is the act of possessing alcohol—not the status of being an alcoholic—that gave rise to criminal sanctions. The interdiction statute was a preventative tool and the state could use this sort of prophylactic device to identify those at the highest risk of alcohol problems and put them on notice that subsequent behavior could be subject to punishment.The Fourth Circuit also held that the interdiction provision did not violate plaintiffs' Fourteenth Amendment right to due process where interdiction carried no threat of imprisonment and therefore did not result in a loss of liberty. Finally, the interdiction provision did not violate plaintiffs' Fourteenth Amendment right to equal protection. The court applied rational basis review and held that the law was rationally related to Virginia's legitimate interest in discouraging alcohol abuse and its attendant risks to public safety and wellbeing. View "Manning v. Caldwell" on Justia Law

The Fourth Circuit reversed the district court's dismissal, on remand, of petitioner's juror bias claim. The court held that the district court failed to recognize the applicability of Supreme Court precedent requiring a hearing in these circumstances; erected inappropriate legal barriers and faulted petitioner for not overcoming them; and ignored judicially-recognized factors in determining whether a hearing was necessary. The court also concluded that the district court erred in Porter I by dismissing petitioner's separate but related juror bias claim pursuant to McDonough Power Equipment, Inc. v. Greenwood, 464 U.S. 548 (1984). Accordingly, the court remanded with instructions for the district court to allow discovery and hold an evidentiary hearing on petitioner's two separate juror bias claims. View "Porter v. Zook" on Justia Law

This appeal stemmed from and action brought by three police officers against the Town, alleging claims related to the officers' termination. On appeal, the officers challenged the district court's post trial rulings. The Fourth Circuit held that the district court erred when it concluded that each plaintiff's claim arose out of the "same" wrongful act and, in the alternative, the meaning of "interrelated" was unambiguous, and that under that unambiguous meaning, plaintiffs' claims arose out of "interrelated" acts. Therefore, the Town waived its governmental immunity for up to $1 million per plaintiff for damages resulting from the three wrongful terminations of plaintiffs, subject to the $3 million Annual Aggregate Limit of the Town's insurance policy.The panel also held that although the police chief was not a final policymaker of the Town regarding plaintiffs' terminations, the town manager was a final policymaker. Therefore, Bralley's unconstitutional actions may fairly be characterized as actions of the Town such that the Town may be held liable to plaintiffs for damages under section 1983. The panel reversed the district court's dismissal of plaintiff's First Amendment claims against the Town and remanded with instructions to enter judgment for plaintiffs. Finally, the district court did not abuse its discretion in awarding Plaintiff Medlin 1.75 years of front pay. View "Hunter v. Town of Mocksville" on Justia Law

Plaintiff filed suit against State's Attorney Oglesby for violations of his civil rights, and the State of Maryland under Title VII, asserting a vicarious liability claim against Maryland. The Fourth Circuit held that prosecutorial immunity barred plaintiff's claims against Oglesby where the reviewing and evaluating evidence in preparation for trial, making judgments about witness credibility, and deciding which witnesses to call and which cases may be prosecuted all were directly connected to the judicial phase of the criminal process, protected by absolute immunity. The court held, however, that no reasonable employee could believe that Oglesby violated Title VII at the trial-preparation meeting to which plaintiff objected, and thus plaintiff's allegations failed to state a claim under Title VII and should be dismissed. Accordingly, the court affirmed in part, and reversed in part, and remanded. View "Savage v. Maryland" on Justia Law

The Fourth Circuit affirmed the district court's dismissal of a habeas petition based on a claim under Simmons v. South Carolina, 512 U.S. 154 (1994). Under Simmons, a defendant is entitled to inform the jury when the alternative to a death sentence is life in prison without parole, but only if the prosecutor puts at issue the risk that he will be a danger to society if released from prison. The court held that the state court reasonably applied Simmons to petitioner's sentence when it held that the prosecutor in his case had not argued future dangerousness in support of the death penalty. View "Warren v. Thomas" on Justia Law