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

After plaintiff was terminated from his position as a police officer, he filed suit under 42 U.S.C. 1983, alleging retaliatory discharge in violation of the First Amendment based on the comments he made as a candidate for town council that were critical of his employer. The district court denied Police Chief Rob Hall qualified immunity. The court concluded, however, that Hall is entitled to qualified immunity because it was debatable at the time of plaintiff's dismissal that his speech interests as a citizen outweighed Hall’s interests as a public employer. Accordingly, the court reversed and remanded. View "Brickey v. Hall" on Justia Law

After William Gault terminated plaintiff from her position as deputy clerk, plaintiff filed suit challenging her termination on First Amendment grounds. The district court granted defendant's motion for summary judgment, holding that plaintiff occupied a confidential or policymaking position and was subject to termination for campaigning against her boss. The court reversed the district court’s decision to grant summary judgment to Gault based on the Elrod-Branti exception, determining that it could not, as a matter of law, conclude that party affiliation is an appropriate requirement for the effective performance of plaintiff's former position as a deputy clerk; Gault has not established the defense of qualified immunity; the court found unpersuasive Gault's contention that the Eleventh Amendment immunizes him from suit for monetary damages in his official capacity; and the history of this case does not present the court with an adequate Pickering record to review. The court vacated and remanded for further proceedings. View "Lawson v. Union County Clerk of Court" on Justia Law

After plaintiff was severely beaten by a fellow inmate, plaintiff filed suit against correctional officers, alleging that they were deliberately indifferent to a substantial risk to his safety in violation of 42 U.S.C. 1983. The district court denied summary judgment to the correctional officers based on qualified immunity. In light of the facts as the court may view them, and drawing reasonable inferences in plaintiff’s favor, the court found that the district court correctly held that material issues of fact precluded summary judgment for the correctional officers on the Eighth Amendment deliberate indifference claim. The court also concluded that an objectively reasonable correctional officer would have known that these actions were unreasonable, ran afoul of clearly established law, and violated plaintiff's rights. Accordingly, the correctional officers are not entitled to qualified immunity and the court affirmed the judgment. View "Cox v. Quinn" on Justia Law

Plaintiff, an Arab-American Muslim woman from Morocco, filed suit against Fairview, alleging claims, pursuant to 42 U.S.C. 1981, for race discrimination (Count I), hostile work environment (Count II), and retaliation (Count III); and pursuant to Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000(e) et seq., claims for discrimination based on religion, national origin, and pregnancy (Count IV), hostile work environment (Count V), and retaliation (Count VI). The district court granted summary judgment for Fairview on all six counts. In regard to the discrimination and retaliation counts, the court concluded that the evidence was sufficient to meet plaintiff's burden to show pretext. In this case, the evidence supports plaintiff's argument that when she complained to her supervisor, who was also her alleged harasser, the supervisor decided to terminate her and immediately got the decision approved. Furthermore, the absence of any evidence to support Fairview’s lack-of-work explanation is also important. Although Fairview claims that there were discussions of eliminating plaintiff's position in the past, there is no record evidence to support that claim. Accordingly, the court reversed and vacated as to Counts III and VI. Likewise, the court reversed as to the remaining counts. By failing to address numerous comments that were open to a racially motivated interpretation, and by circumscribing its analysis to just one comment without reviewing the totality of the circumstances, the district court committed reversible error in its grant of summary judgment for Fairview. View "Guessous v. Fairview Property Investments" on Justia Law

In these consolidated cases, plaintiffs filed suit challenging two redistricting laws, alleging that some Wake County School Board and Wake County Board of County Commissioners districts have been over-populated, while others have been under-populated. Plaintiffs further assert that these discrepancies result in some votes counting more while others count less, and that the discrepancies stem from illegitimate redistricting factors. The court concluded that, to succeed on the merits, plaintiffs in one person, one vote cases with population deviations below 10% must show by a preponderance of the evidence that improper considerations predominate in explaining the deviations. In this case, plaintiffs have proven that it is more probable than not that the population deviations at issue here reflect the predominance of an illegitimate reapportionment factor, namely an intentional effort to create a significant partisan advantage. Therefore, the district court committed reversible error in granting judgment for defendants. For the same reasons that plaintiffs succeed with their federal claim, they also succeed with their North Carolina state one person, one vote claim. Finally, the district court did not commit clear error in rejecting plaintiffs' racial gerrymandering claim. Accordingly, the court reversed and remanded in part, and affirmed in part. View "Raleigh Wake Citizens Ass'n v. Wake Cnty. Bd. of Elections" on Justia Law

Thai Palace filed suit under 42 U.S.C. 1983 and the First Amendment, challenging the Board's revocation of its alcoholic beverage license, as well as its orders imposing conditions on the license. At issue on appeal is whether the district court properly applied the Rooker-Feldman doctrine to dismiss this federal action challenging the actions of a state administrative agency that were reviewed in state court. The court concluded that, at bottom, this federal action qualifies as an independent, concurrent action that does not undermine the Supreme Court’s appellate jurisdiction over state court judgments, and accordingly the Rooker-Feldman doctrine does not apply. Therefore, the court reversed and remanded for further proceedings. View "Thana v. Board of License Commissioners" on Justia Law

Plaintiff filed suit against FRBR, alleging claims for interference and retaliation in violation of the Family Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq., and failure to accommodate and discriminatory discharge in violation of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq. The court affirmed the district court's grant of summary judgment on the FMLA retaliation claim and the ADA claims. The court concluded, however, that there are genuine issues of material fact as to whether FRBR interfered with plaintiff’s FMLA rights by providing him defective notice that omitted his right to reinstatement at the conclusion of the medical leave term. Accordingly, the court held that the district court's grant of summary judgment as to that claim was not warranted. The court affirmed in part, vacated in part, and remanded for further proceedings. View "Vannoy v. Federal Reserve Bank" on Justia Law

Petitioner challenged the denial of her petition for a writ of habeas corpus, seeking relief as next friend of R.M.B., her minor son. R.M.B., a native of Guatemala, is being held as an unaccompanied alien child (a UAC) by the Office of Refugee Resettlement, an agency of DHHS. The court could not say that R.M.B.’s detention is based on an erroneous application or interpretation of the UAC definition where the Office found, after conducting a home study and gathering other evidence, that petitioner was incapable of providing for R.M.B.’s physical and mental well-being. The court rejected petitioner's contention that the Office lacks authority to detain R.M.B. now that his immigration proceedings have terminated. Even after R.M.B.'s immigration proceedings concluded, the Office was not entitled to release him to anyone unless it first determined that the proposed custodian was capable of providing for his physical and mental well-being. The court rejected petitioner's substantive due process claim, concluding that the Office's determination suffices to address any substantive due process concerns and renders inapposite those decisions involving challenges to state interference with control of children by fit parents. The court concluded, however, that the district court, in denying petitioner's procedural due process claim, did not utilize the proper Mathews v. Eldridge framework. Accordingly, the court affirmed in part, vacated in part, and remanded. View "Beltran v. Cardall" on Justia Law

Plaintiff, a political figure in the Libertarian Party of Virginia, filed suit challenging Virginia's three-tiered ballot ordering law, Virginia Code 24.2-613. The district court dismissed the complaint for failure to state a claim. Plaintiff principally argued on appeal that Virginia's three-tiered ballot ordering law advantages candidates from what he calls “major parties” and disadvantages candidates like him that hail from what he calls “minor parties.” The court noted that the text and history of the Constitution, well established Supreme Court precedent, and the structural principles inherent in our federal system counsel respect for the Virginia General Assembly’s power to administer elections in Virginia. With state legislatures’ longstanding authority to regulate elections in mind, the court employed the Supreme Court’s Anderson/Burdick decisional framework to distinguish those laws whose burdens are uniquely unconstitutional from the majority of laws whose validity is unquestioned. The court concluded that the three-tiered ballot ordering law imposes little burden on plaintiff’s constitutional rights, and Virginia articulates several important interests supporting the law. The ballot ordering law imposes only the most modest burdens on plaintiff's rights where the law is facially neutral and nondiscriminatory. Furthermore, the law is supported by important regulatory interests where the law may assist the voting process by reducing voter confusion and preserving party-order, as well as reduce multi-party factionalism and promote political stability. Therefore, the court concluded that it has no basis for finding the state statute unconstitutional and affirmed the judgment. View "Sarvis v. Alcorn" on Justia Law

NAAMJP filed suit challenging the conditions placed on the privilege of admission to the Bar of the United States District Court for the District of Maryland in Local Rule 701. Among other things, the Rule contains requirements based on the state of licensure and, in some instances, the location of the attorney’s law office. The district court granted defendants' motion to dismiss and denied NAAMJP's motion for summary judgment. The court concluded that Rule 701 does not violate the First Amendment where it qualifies as a general applicable licensing provision, prescribing which attorneys may practice in the District Court based on their state of licensure in relation to the location of their principal law office; Rule 701 does not violate the Equal Protection Clause where it does not infringe a fundamental right or disadvantage a suspect class; Rule 701 does not violate the Rules Enabling Act, 28 U.S.C. 2071, where the Rule does not violate any Acts of Congress or any federal rules of practice and procedure adopted by the Supreme Court pursuant to section 2072; and Rule 701 does not violate the Supremacy Clause where it remains a federal rule prescribed pursuant to federal statute. Accordingly, the court affirmed the judgment. View "NAAMJP v. Lynch" on Justia Law