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

Plaintiff filed suit under 42 U.S.C. 1983 against several correctional officers, medical personnel, and prison administrators for alleged violations of his constitutional rights after he underwent surgery to remove penile implants while incarcerated. Prior to his incarceration, plaintiff had marbles implanted in and tattoos drawn on his penis. Plaintiff alleged that prison officials threatened him with segregation for the remainder of his sentence and loss of parole eligibility if he did not consent to surgery to have the marbles removed. In his complaint, plaintiff alleged, among other things, physical injury and mental anguish. The court held that the Bell v. Wolfish factors weigh against reasonableness of the sexually invasive search and thus reversed the district court’s dismissal of plaintiff’s complaint. In this case, plaintiff pleaded sufficient facts to establish a Fourth Amendment claim plausibly entitling him to relief. The court also held that plaintiff's complaint plausibly satisfies both prongs of an Eighth Amendment claim. Furthermore, plaintiff's allegations are sufficient to state a class-of-one equal protection claim. The court rejected plaintiff's remaining claims. Accordingly, the court affirmed in part, reversed in part, and vacated in part. Because the district court did not consider plaintiff's potential due process claim, the court remanded for reconsideration of this claim. View "King, Jr. v. Rubenstein" on Justia Law

Plaintiff, enrolled in Marshall University's Master of Arts in Teaching (MAT) program, filed suit against defendants raising various claims, including violation of her due process and equal protection rights, after she unsuccessfully pursued reconsideration through Marshall’s internal grade-appeals process. Plaintiff had left her student-teaching post in protest over differences with her supervising teacher. Consequently, plaintiff was not awarded credit and did not receive her MAT nor teaching license. On appeal, plaintiff challenged the district court's order granting defendants' motion to dismiss. The court concluded that the district court properly determined both that sovereign immunity bars plaintiff's claims against the Marshall University Board of Governors, and that the allegations in plaintiff's pro se complaint against the other defendants failed to state a claim upon which relief can be granted. Accordingly, the court affirmed the judgment. View "Kerr v. Marshall Univ. Bd." on Justia Law

After plaintiff went to the police station to report the theft of his cable services, he ended up involuntarily detained for six days for a mental-health evaluation. Plaintiff then filed suit under 42 U.S.C. 1983, alleging that he was unlawfully seized without probable cause in violation of the Fourth and Fourteenth Amendments. The district court granted defendants' motion to dismiss for failure to state a claim. The court concluded that the claims against the mental-health evaluator and her employer were properly dismissed. However, as to the two officers who initially took plaintiff into custody, the court found that the allegations in the complaint were sufficient to survive the motion to dismiss. When the statements in the Incident Report are treated not as true, but as assertions made by the Officers, the court had little difficulty in concluding that plaintiff's claims against the Officers should not have been dismissed. Plaintiff alleged that he has no mental illness and the facts he describes in the complaint provided no basis for the Officers to have reasonably concluded otherwise. Accordingly, the court affirmed in part, vacated in part, and remanded for further proceedings. View "Goines v. Valley Cmty. Servs. Bd." on Justia Law

Plaintiff filed suit against employees of SCDC and others, alleging that the food served to him at a prison managed by the SCDC was so deficient as to violate his Eighth Amendment rights. The district court dismissed the complaint under Rule 12(b)(6), concluding that plaintiff's claim is barred by the doctrine of res judicata because it is the same as a complaint filed against SCDC employees by a fellow inmate in 2010, which the district court dismissed on the merits. The court concluded that, because plaintiff was a nonparty to the earlier suit, he is not precluded from pursuing the same claims on his own behalf in the instant action unless the state defendants are able to demonstrate that at least one of the six exceptions to the general rule against nonparty preclusion applies pursuant to Taylor v. Sturgell. Because the state defendants have not demonstrated that any of the exceptions apply, the court reversed and remanded for further proceedings. View "Duckett v. Fuller" on Justia Law

Maritime employed Elmer Escalante, an undocumented alien, at one of its two full-service carwashes. After Escalante filed a complaint against Maritime with the EEOC for discrimination in violation of Title VII of the Civil Rights Act, 42 U.S.C. 2000e et seq., the EEOC issued a subpoena seeking information from Maritime related to Escalante’s charges. The parties disagree on how Escalante’s undocumented status affects the EEOC’s authority to investigate his charges. The district court denied the EEOC's application for subpoena enforcement. The court held that the EEOC’s subpoena, designed to investigate Escalante’s Title VII charges, is enforceable. In this case, the plain language of Title VII provides a "plausible" or "arguable" basis for the EEOC's subpoena where Title VII allows any "person claiming to be aggrieved" to file charges with the EEOC, and nothing explicitly bars undocumented workers from filing complaints. Accordingly, the court reversed and remanded. View "EEOC v. Maritime Autowash, Inc." on Justia Law

The Committee filed suit under 42 U.S.C. 1983 against the Commonwealth, alleging that the Incumbent Protection Act, Va. Code Ann. 24.2-509(B), infringes on its First Amendment right to freedom of association by preventing it from determining the method of nomination in contravention of the terms of the Party's Plan of Organization. Senator Hanger and Moxley, who sought the Party’s nomination for Senator Hanger’s seat on the 24th District, both moved to intervene. The district court subsequently granted defendants’ motions to dismiss. The court affirmed the district court’s holding that the Committee lacks standing to bring this suit because the language of the Plan is clear and unambiguous: the Plan delegates to the Committee the authority to determine the nomination method unless Virginia law otherwise limits that authority. Because the Party has made a voluntary choice to limit the Committee’s authority in this way, plaintiffs have “no complaint that the party’s right to govern itself has been substantially burdened by” the Act because “the source of the complaint is the party’s own decision.” Because neither Virginia law nor the Plan gives Moxley “a legally protected interest” in determining the nomination method in the first place, he fails to establish that he has standing independent of the Party. Accordingly, the court affirmed the judgment. View "24th Senatorial Dist. v. Alcorn" on Justia Law

After G.G., a transgender boy, began to use the boys’ restrooms with the approval of the school administration, the local school board passed a policy banning G.G. from the boys’ restroom. G.G. filed suit alleging that the school board impermissibly discriminated against him in violation of Title IX, 20 U.S.C. 1681(a), and the Equal Protection Clause of the Constitution. The district court dismissed G.G.’s Title IX claim and denied his request for a preliminary injunction. The court reversed the dismissal of G.G.’s Title IX claim, concluding that the district court did not accord appropriate deference to the relevant Department of Education regulations. In this case, the Department’s interpretation of its own regulation, 34 C.F.R. 106.33, as it relates to restroom access by transgender individuals, is entitled to Auer v. Robbins deference and is to be accorded controlling weight. The court also concluded that the district court used the wrong evidentiary standard in assessing G.G.’s motion for a preliminary injunction. The district court evaluated G.G.’s proffered evidence against a stricter evidentiary standard than is warranted by the nature and purpose of preliminary injunction proceedings to prevent irreparable harm before a full trial on the merits. Therefore, the district court abused its discretion when it denied the preliminary injunction without considering G.G.’s proffered evidence. The court vacated the district court's denial of the preliminary injunction and remanded for consideration under the correct standard. View "G. G. v. Gloucester Cnty. Sch. Bd." on Justia Law

S.B., by and through his mother, filed suit against the Board, alleging primarily that by allowing other students to harass S.B. based on his disability, the Board violated section 504 of the Rehabilitation Act, 29 U.S.C. 701 et seq. S.B.'s father, a teacher and athletic director at the school, filed suit in his own right, claiming that the Board also violated section 504 by retaliating against him for advocating on S.B.’s behalf. The district court granted summary judgment for the Board. The court affirmed the judgment because no evidence support's the claims. In this case, S.B. has provided no evidence that the Board acted with the deliberate indifference necessary to hold it liable for student-on-student harassment. Nor does the record substantiate the father's allegation of a causal connection between his advocacy for S.B. and any adverse action taken by the Board. View "SB v. Board of Educ. of Harford" on Justia Law

Plaintiff filed suit against Defendant Terry and others after he was pulled over, tased three times, and arrested. Plaintiff was charged with an excessive noise violation, no license in possession, and disorderly conduct, all of which were nol prossed. The parties filed a stipulation of dismissal as to all claims except for the 42 U.S.C. 1983 claim for excessive force against Terry in his individual capacity. The district court denied Terry summary judgment based on qualified immunity. The court's analysis of the Graham v. Connor factors when measured against the level of force used by Terry against plaintiff leads the court to conclude that such force was not objectively reasonable in light of the totality of the circumstances in this case. Therefore, plaintiff has established that Terry's use of his taser constituted excessive force in violation of plaintiff's Fourth Amendment rights. Further, no reasonable officer would have believed that Terry’s use of the taser was justifiable at all and certainly not on three occasions. Accordingly, the court affirmed the district court’s denial of Terry’s motion for summary judgment based on qualified immunity. View "Yates v. Terry" on Justia Law

Plaintiff filed suit against Defendant Terry and others after he was pulled over, tased three times, and arrested. Plaintiff was charged with an excessive noise violation, no license in possession, and disorderly conduct, all of which were nol prossed. The parties filed a stipulation of dismissal as to all claims except for the 42 U.S.C. 1983 claim for excessive force against Terry in his individual capacity. The district court denied Terry summary judgment based on qualified immunity. The court's analysis of the Graham v. Connor factors when measured against the level of force used by Terry against plaintiff leads the court to conclude that such force was not objectively reasonable in light of the totality of the circumstances in this case. Therefore, plaintiff has established that Terry's use of his taser constituted excessive force in violation of plaintiff's Fourth Amendment rights. Further, no reasonable officer would have believed that Terry’s use of the taser was justifiable at all and certainly not on three occasions. Accordingly, the court affirmed the district court’s denial of Terry’s motion for summary judgment based on qualified immunity. View "Yates v. Terry" on Justia Law