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

Plaintiff filed suit under 42 U.S.C. 1983 and North Carolina law against police officers, alleging, inter alia, that they fabricated evidence that led to plaintiff's arrest, convictions, and nearly-twelve-year incarceration. The district court granted the officers' motion for judgment on the pleadings under Rule 12(c). The court concluded that plaintiff waived his right to appeal the judgment in Officer Ledford's favor. The court also concluded that plaintiff has failed to state a claim on which relief can be granted in regards to Officers Ojaniit and Esposito. Further, plaintiff failed to plead any colorable state law claim as to these two officers. Accordingly, the court dismissed the appeal as to Officer Ledford and affirmed the judgment as to Officers Ojaniit and Esposito. View "Massey v. Ojaniit" on Justia Law

Plaintiff successfully sued various Greenwood County Sheriff's Office officials for First Amendment violations. The court held that qualified immunity, the absence of a policy or custom of discrimination, and the nature of the relief granted here - whether considered individually or together through a "totality of the circumstances" lens - could not support the denial of attorneys' fees to plaintiff, a prevailing civil rights plaintiff; the district court abused its discretion by denying these fees and the court reversed the judgment; and the court remanded with instructions to allow plaintiff to make a fee application and for ensuing determination of the reasonable fee award for his successful prosecution of the civil rights matter, including the time spent defending entitlement to attorney's fees. View "Lefemine v. Wideman" on Justia Law

Carnell, a "minority-owned" corporation, filed suit against the Housing Authority and Blaine based on claims of race discrimination, retaliation, and breach of contract. The court held that a corporation can acquire a racial identity and establish standing to seek a remedy for alleged race discrimination under Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d, but that the district court properly dismissed one of the defendants from liability on plaintiff's race discrimination claims; the district court abused its discretion in permitting the use of particular impeachment evidence, which should have been excluded as unfairly prejudicial under Federal Rule of Evidence 403; and the district court properly reduced certain damages awarded to plaintiff on its contract claims, but decided that the strict notice requirements of the Virginia Public Procurement Act, Virginia Code 2.2-4300 through 4377, required the court to narrow further the scope of recoverable contract damages. Accordingly, the court affirmed in part, vacated in part, and remanded for further proceedings. View "Carnell Construction Corp. v. Danville RHA" on Justia Law

Plaintiff filed suit challenging his arrests for refusing to obey Officer Early's repeated orders to confine his leafleting to the area designated for protest activities outside the First Mariner Arena in Baltimore. The designated protest area was defined by a written policy of the City and the BCPD. The court held that the policy was facially valid under the First Amendment as a reasonable time, place, and manner restriction. The court found that the district court committed no reversible error as to plaintiff's remaining claims. Accordingly, the court affirmed the district court's grant of summary judgment in favor of defendants. View "Ross v. Early" on Justia Law

Plaintiffs filed suit against police officers, the County, and the City after officers assaulted them outside of a nightclub. The court affirmed the district court's post-trial determination that plaintiffs' complaint sufficiently stated a cause of action for bystander liability under 42 U.S.C. 1983. In doing so, however, the court vacated and remanded the district court's summary judgment ruling to the opposite effect. The only defendant that the reversal of this issue impacted was Officer Lowery because he was the only defendant against whom the section 1983 count survived dismissal. The court affirmed the district court's grant of summary judgment to Officer Adey on the excessive force and battery counts with respect to all plaintiffs and the grant of summary judgment to Officer Lowery in his alleged role as a principal actor on the section 1983 count with respect to Plaintiffs Howard and Barnett. Because Officer Adey was not liable for either the battery or the excessive force counts as to any of plaintiffs, the County was also not liable under the Maryland constitutional count on the theory of vicarious liability. Finally, the district court did not abuse its discretion by denying plaintiffs' Rule 59(e) motion to alter or amend the ruling on summary judgment. Accordingly, the court affirmed in part, reversed in part, and remanded with instructions. View "Stevenson v. City of Seat Pleasant, MD" on Justia Law

North Carolina's House Bill 289 authorized the state's Division of Motor Vehicles to issue, among other specialty license plates, a "Choose Life" plate. However, this law authorized no pro-choice specialty license plate. North Carolina vehicle owners who wanted a pro-choice specialty plate, along with the ACLU, filed suit challenging the statute. North Carolina argued that it could so discriminate because specialty plate messages constituted pure government speech free from First Amendment viewpoint-neutrality constraints. The court concluded that, because the specialty plate speech at issue implicated private speech rights and was not pure government speech, North Carolina's authorizing a "Choose Life" plate while refusing to authorize a pro-choice plate constituted viewpoint discrimination in violation of the First Amendment. Accordingly, the court affirmed the district court's grant of summary judgment and a permanent injunction in favor of the vehicle owners and the ACLU. View "American Civil Liberties Union v. Tata" on Justia Law

Plaintiff, a state prisoner housed at Red Onion State Prison (ROSP), filed suit under the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. 2000 cc et seq., and 42 U.S.C. 1983, challenging ROSP's 2010 Ramadan policy. ROSP had devised a new eligibility policy for 2010 where, in addition to signing up to participate in Ramadan, inmates had to provide some physical indicia of Islamic faith. The court vacated the district court's summary judgment order granting defendants qualified immunity on plaintiff's claims for monetary relief where defendants have failed to establish as a matter of law that the 2010 Ramadan policy, as applied to plaintiff, did not violate his First Amendment rights and where their alleged actions violated plaintiff's clearly established rights; vacated the district court's decision that the prison's abandonment of the policy mooted the claims for equitable relief where defendants failed to meet their "heavy burden" of establishing that it was "absolutely clear" that the 2010 Ramadan policy would not be reinstated; and remanded for further proceedings. View "Wall v. Wade" on Justia Law

Plaintiff, an employee of MTA for four decades, filed suit against MTA alleging various forms of discrimination after her position was terminated due to budget cuts. The court concluded that, because summary judgment was granted before plaintiff had a chance to discover facts essential to her claim, and she alleged discrimination occurring before any legislative activity, the district court's Rule 56(d) denial was an abuse of discretion. The court concluded, however, that the district court's dismissal of plaintiff's age discrimination and disability discrimination claims were barred by sovereign immunity. Accordingly, the court affirmed in part, reversed in part, and remanded. View "McCray v. Maryland Dep't of Transp." on Justia Law

Plaintiff filed suit against Altarum, alleging that Altarum discriminated against him by wrongfully discharging him on account of disability and that Altarum failed to accommodate his disability. Plaintiff was terminated after he injured his legs on a subway platform and was on short-term disability benefits. On appeal, plaintiff challenged the district court's dismissal of his wrongful-discharge claim. The court concluded that, under the Americans with Disabilities Act Amendments Act of 2008, Pub. L. No. 110-325, 122 Stat. 3553, and its implementing regulations, an impairment is not categorically excluded from being a disability simply because it is temporary. In this instance, the impairment alleged by plaintiff fell comfortably within the amended Acts' expanded definition of disability. Therefore, the court reversed and remanded for further proceedings. View "Summers v. Altarum Institute, Corp." on Justia Law

Plaintiffs filed a putative class action suit challenging the legality of the toll charged by the MWAA for use of the Dules Toll Road. The district court dismissed the complaint on numerous grounds. The court concluded that plaintiffs' claims were barred neither by the standing requirement of Article III nor the prudential restrictions the court has recognized on its own judicial power; under the Elizabeth River Crossings OpCo, LLC v. Meeks framework, the tolls charged for passage on the Dules Toll Road are user fees, not taxes, under Virginia law; and therefore, their collection by the MWAA did not run afoul of the Virginia Constitution and did not violate the due process rights of motorists. Accordingly, the court affirmed the district court's dismissal of plaintiffs' complaint. View "Corr v. Metropolitan Washington" on Justia Law