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

Plaintiff filed suit against the administrator of detective David E. Abbott's estate under 42 U.S.C. 1983, alleging that the search of his person violated his Fourth Amendment right of privacy or, alternatively, his right of substantive due process under the Fourteenth Amendment. Plaintiff also brought a claim under 18 U.S.C. 2255(a), alleging that, as a result of the search, he was the victim of manufactured child pornography. The Fourth Circuit vacated the district court's judgment as to the section 1983 claim alleging a Fourth Amendment violation because a reasonable police officer would have known that attempting to obtain a photograph of a minor child's erect penis, by ordering the child to masturbate in the presence of others, would unlawfully invade the child's right of privacy under the Fourth Amendment. The court remanded plaintiff's section 1983 claim alleging Fourth Amendment violation to the district court for further proceedings; vacated the district court's dismissal of plaintiff's claim for damages under 18 U.S.C. 2255 as an alleged victim of child pornography, and remanded that claim for consideration by the district court in the first instance; and affirmed the district court's dismissal of plaintiff's remaining claims. View "Sims v. Labowitz" on Justia Law

Plaintiff, an inmate at the Red Onion State Prison, appealed the dismissal of his 42 U.S.C. 1983 claim that certain officials at Red Onion denied him medical treatment for serious mental and physical health needs, in violation of his Eighth Amendment rights. The Fourth Circuit applied the continuing violation doctrine and held that plaintiff's claims were not time-barred; plaintiff sufficiently alleged deliberate indifference by certain defendants to his serious mental health needs; but he has not adequately alleged deliberate indifference to his physical health needs. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "DePaola v. Clarke" on Justia Law

Plaintiff, the personal representative of Jamycheal Mitchell, filed suit against defendant and 49 others, alleging claims under 42 U.S.C. 1983 and state law. Jamycheal died from severe malnutrition in Regional Jail while awaiting a bed in the Hospital. Defendant was the Commissioner of the Virginia Department of Behavioral Health & Developmental Services, the agency responsible for overseeing state mental health hospitals. The Fourth Circuit held that it lacked jurisdiction to review the district court's denial of defendant's motion to dismiss the state law claims and remanded those claims to the district court. The court also held that Eleventh Amendment absolute immunity did not bar the suit where defendant was being sued in her personal capacity and plaintiff sought to recover only from defendant, not the Commonwealth of Virginia. Finally, the court held that defendant was entitled to qualified immunity from suit on the section 1983 claims where no clearly established law dictated that housing mentally ill inmates in prisons, rather than transferring them to state mental health facilities, automatically and alone amounted to an objectively excessive risk to inmate health and safety. View "Adams v. Ferguson" on Justia Law

Intervening defendants could not be required to pay a portion of prevailing plaintiffs' attorneys fees and costs, awarded under 42 U.S.C. 1988(b) and 52 U.S.C. 10310(e), when intervening defendants were not charged with any wrongdoing and could not be held liable for the relief that plaintiffs sought. In Independent Federation of Flight Attendants v. Zipes, 491 U.S. 754 (1989), the Supreme Court precluded the assessment of attorneys fees and costs against intervenors who were "blameless," meaning that they were not charged as wrongdoers and legal relief could not have been obtained from them. In this racial gerrymandering case, the Fourth Circuit held that Zipes was controlling and that the Commonwealth could not be held liable for attorneys fees and costs incurred by plaintiffs in litigating against the entry of Intervening Congressmen or against Intervening Congressmen's positions. Under the traditional American rule, plaintiffs must bear those intervention-related fees. Accordingly, the court vacated the district court's order awarding attorneys fees and costs, remanding for reconsideration of plaintiffs' petitions for fees. View "Brat v. Personhuballah" on Justia Law

The Fourth Circuit affirmed the district court's grant of summary judgment in favor of a school resource officer in an action brought by an elementary school student under 42 U.S.C. 1983, alleging excessive force in violation of the Fourth Amendment and several state laws. The officer decided to handcuff the student for fighting with another student three days prior. The court held that, under the totality of the circumstances, the officer's actions were not objectively reasonable in light of the facts and circumstances where the student was a ten year old girl who was sitting calmly and compliantly in a closed office surrounded by three adults and was answering questions about the incident at issue. Although the officer used excessive force, the student's right not to be handcuffed under the circumstances was not clearly established at the time of her seizure. Therefore, the officer was entitled to qualified immunity. The court also held that there was insufficient evidence in the record for a reasonable jury to conclude that the officer acted maliciously or with gross negligence when she handcuffed the student. View "E.W. v. Dolgos" on Justia Law

The Fourth Circuit affirmed the district court's grant of summary judgment in favor of a school resource officer in an action brought by an elementary school student under 42 U.S.C. 1983, alleging excessive force in violation of the Fourth Amendment and several state laws. The officer decided to handcuff the student for fighting with another student three days prior. The court held that, under the totality of the circumstances, the officer's actions were not objectively reasonable in light of the facts and circumstances where the student was a ten year old girl who was sitting calmly and compliantly in a closed office surrounded by three adults and was answering questions about the incident at issue. Although the officer used excessive force, the student's right not to be handcuffed under the circumstances was not clearly established at the time of her seizure. Therefore, the officer was entitled to qualified immunity. The court also held that there was insufficient evidence in the record for a reasonable jury to conclude that the officer acted maliciously or with gross negligence when she handcuffed the student. View "E.W. v. Dolgos" on Justia Law

Movant filed a motion under 28 U.S.C. 2244(b)(3)(A), seeking authorization to file a second or successive application for a writ of habeas corpus to challenge his 2001 sentence of four life terms plus 45 years imposed by a Virginia state court for nonhomicide crimes he committed as a juvenile. The Fourth Circuit denied the motion because the claim movant sought to present to the district was raised in his first federal application for a writ of habeas corpus, and therefore movant failed to make a prima facie showing that his successive habeas application would allege a claim that was not presented in a prior application, as the statute required. View "In re: Jarius Phillips" on Justia Law

The Fifth Circuit reversed the district court's grant of summary judgment against plaintiff in a 42 U.S.C. 1983 action primarily alleging that plaintiff's First Amendment Free Exercise Clause rights, as well as his rights under the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. 2000cc et seq., were violated because of his former prison's failure to accommodate his religious dietary needs. The court held that plaintiff's prospects for meaningful redress were sufficient to give him standing to seek prospective relief regarding the content of the Common Fare menu; defendants have not demonstrated that plaintiff had lost all legally cognizable interest in the outcome of his request for prospective relief from the suspension; and, on the merits, plaintiff has shown a genuine factual dispute as to whether his rights were substantially burdened by the prison's serving him foods that Nation of Islam dietary rules prohibited him from eating. The court explained that defendants failed to offer any institutional interest that they claimed justified the burdening of a prisoner's rights. Accordingly, the court remanded for further proceedings. View "Carter v. Fleming" on Justia Law

A Baltimore City ordinance that requires pregnancy clinics that do not offer or refer for abortions to disclose that fact through signs posted in their waiting rooms, as applied to the Greater Baltimore Center for Pregnancy Concerns, violates the First Amendment's Free Speech Clause. The Fourth Circuit held that, although the City's interests in addressing allegedly deceptive advertising and to prevent health risks that can accompany delays in seeking to end a pregnancy were plainly important, the City could pursue its goals through less restrictive means and there was only a loose fit between the compelling disclosure at issue and the purported ills identified by the government. Therefore, the ordinance failed to satisfy heightened First Amendment scrutiny. View "Greater Baltimore Center v. Mayor and City Council of Baltimore" on Justia Law

The Fourth Circuit vacated the district court's grant of summary judgment for MIA in an action alleging salary discrimination under the Equal Pay Act (EPA), 29 U.S.C. 206(d). The court held that the EEOC established a prima facie violation of the EPA, and that genuine issues of material fact exist regarding whether the pay disparity was due to factors other than gender. Accordingly, the court remanded for further proceedings. View "EEOC v. Maryland Insurance Admin." on Justia Law