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

Plaintiff filed suit under 42 U.S.C. 1983 against the Board, the County Sheriff, and two deputy sheriffs, alleging that the deputies violated her Fourth Amendment rights when, after questioning her at her workplace, they arrested her on an outstanding civil warrant for removal issued by ICE. The court concluded that the deputies did not seize plaintiff until one of the two deputies gestured for her to remain seated while they verified that the immigration warrant was active; the civil immigration warrant did not provide the deputies with a basis to arrest or even briefly detain plaintiff; the individual defendants were immune from suit because at the time of the encounter neither the Supreme Court nor the court had clearly established that local and state law enforcement officers could not detain or arrest an individual based on a civil immigration warrant; and qualified immunity did not extend to municipal defendants. Therefore, the court affirmed in part, vacated in part, and remanded for further proceedings. View "Santos v. Frederick County Board" on Justia Law

Plaintiffs filed suit against the Town after the Town declared plaintiffs' cottages to be in violation of its nuisance ordinance. The cottages were considered nuisances as a result of storm or erosion damage. The court affirmed the district court's grant of summary judgment on plaintiffs' procedural due process claims because plaintiffs' procedural due process rights were not violated where the Town never deprived plaintiffs of any property interest; affirmed the grant of summary judgment on plaintiffs' equal protection claims because plaintiffs' equal protection rights were not violated where the Town had a rational basis for its decision to declare plaintiffs' cottages nuisances under the Town's ordinance; and remanded the takings claims based on the court's conclusion that a state and its political subdivisions waived the state-litigation requirement by removing a case to federal court. View "Sansotta v. Town of Nags Head" on Justia Law

In this pre-enforcement challenge to a package of immigration laws known as Act 69, the district court preliminarily enjoined certain sections of the Act on preemption grounds. On the merits, the court concluded that the district court was correct to enjoin Sections 4(A) and (C) because they criminalized actions that Congress has, as a policy choice, decided were a civil matter. The court also concluded that Sections 4(B) and (D) created an obstacle to the smooth functioning of federal immigration law, improperly placed in the hands of state officials the nation's immigration policy, and stripped federal officials of the authority and discretion necessary in managing foreign affairs. Accordingly, the court concluded that these sections, along with Sections 5 and 6(B)(2), were all preempted by federal law and, therefore, the court affirmed the district court's grant of a preliminary injunction. View "United States v. State of South Carolina" on Justia Law

Plaintiffs, current and former members of the armed forces, brought suit against defendants, two former Secretaries of Defense, alleging that they were victims of rape and sexual misconduct by fellow servicemembers during their military careers. Plaintiffs sought money damages pursuant to Bivens v. Six Unknown Agents of Federal Bureau of Narcotics. The court held that no Bivens action will lie where special factors counsel hesitation in creating an implied right of action and special factors clearly counsel hesitation in implying a cause of action for injuries arising out of military service. The court concluded that judicial abstention was the proper course in this case pursuant to Chappell v. Wallace, United States v. Stanley, and Feres v. United States. Accordingly, the court affirmed the district court's dismissal of the complaint. View "Cioca v. Rumsfeld" on Justia Law

SCV filed suit against the City and its officials alleging that Lexington City Code section 420-205(C) (the "Ordinance), which bans any private access to City-owned flag standards, contravenes the SCV's First Amendment rights and breached a consent decree resolving an earlier lawsuit between SCV and the City. The court concluded there was no legal support for requiring the City to relinquish its control over the flag standards because they are not a traditional public forum; inasmuch as the Ordinance was lawfully enacted to close a designated public forum, the court affirmed the dismissal of the SCV's free speech claim; in regards to the civil contempt claim relating to the Consent Decree, the court agreed with the district court's conclusion that, because there was no constitutional violation posed by the Ordinance, there could be no violation of the Decree; and, because the flag standards are no longer given over to private expression, their use is not governed by the Decree. Accordingly, the court affirmed the judgment of the district court. View "Sons of Confederate Veterans v. City of Lexington, VA" on Justia Law

Petitioner appealed the Secretary's determination that he had committed intentional and egregious violations of the Fair Housing Act (FHA), 42 U.S.C. 3601-3619, by discriminating on the basis of disability against Delores and Gregory Walker and ordered petitioner to pay a civil monetary penalty as well as damages for Ms. Walker's emotional distress. The Department alleged that petitioner violated the FHA by requiring Ms. Walker to provide a note from Mr. Walker's doctor, to obtain a renter's insurance policy with $1 million in liability coverage, and to assume responsibility for any damage Mr. Walker, who suffered from autism, might have caused to the property. The court rejected petitioner's contention that his conduct was justified under the circumstances, concluding that substantial evidence supported the Secretary's determination. View "Corey v. HUD" on Justia Law

Plaintiff filed a complaint against the State Board, alleging that it violated his First Amendment rights by causing him to self-censor certain speech on his website wherein he offered both free and fee-based dietary advice to website visitors. The court reversed the district court's holding that plaintiff did not have standing to bring these claims. The court concluded that the district court erred in not analyzing plaintiff's claims under the First Amendment standing framework where, under that analysis, plaintiff satisfied the injury-in-fact requirement by showing that the State Board's action had an objectively reasonable chilling effect on his speech. The court also concluded that plaintiff's claims were ripe for adjudication. Accordingly, the court vacated and remanded for further proceedings. View "Cooksey v. Futrell" on Justia Law

Defendant, indicted for conspiracy to distribute crack cocaine and heroin, was diagnosed with paranoid schizophrenia and deemed incompetent to stand trial. The district court, applying Sell v. United States, granted the government's motion to involuntarily medicate defendant for trial competency purposes. The district court did not mention or analyze any of the less intrusive alternatives suggested by the Supreme Court in Sell or by defendant himself. Therefore, the court vacated the district court's order and remanded for further proceedings because careful findings concerning the availability of less intrusive means were necessary to vindicate the Supreme Court's admonition that forcible medication motions should be carefully scrutinized due to their impact on personal liberty. View "United States v. Chatmon" on Justia Law

Plaintiff appealed the district court's grant of summary judgment to her former employer, Mission, on her hostile work environment claim brought under Title VII of the Civil Rights Act of 1963, 42 U.S.C. 2000e. The court concluded that the district court did not err in finding that plaintiff failed to establish that she had suffered a tangible employment action. The court also concluded that the undisputed facts demonstrated that Mission satisfied both elements of its affirmative defense. Mission could not be held vicariously liable for a supervisor's alleged harassment of plaintiff. Accordingly, the court concluded that the district court did not err in granting summary judgment to Mission. View "Crockett v. Mission Hospital, Inc." on Justia Law

Plaintiffs filed the underlying action seeking injunctive and declaratory relief pursuant to 42 U.S.C. 1983, alleging that the witness residency requirement on nominating petitions impermissibly burdened their rights to free speech and free association under the First Amendment. The parties filed cross-motions for summary judgment, with the Board's motion premised entirely on its assertion that plaintiffs have not suffered a legally cognizable injury and thus lacked standing. The district court denied the Board's motion as to standing and granted plaintiffs' motion on the merits. The district court declared the witness residency requirement unconstitutional and permanently enjoined its enforcement. Although the Board's witness residency requirement served the Commonwealth's interest in policing fraud potentially permeating the electoral process and therefore meeting the first part of the strict scrutiny standard, the Board produced no concrete evidence of persuasive force explaining why plaintiffs' proposed solution, manifestly less restrictive of their First Amendment rights, would be unworkable or impractical. Accordingly, the court affirmed in all respects the judgment of the district court. View "Libertarian Party of Virginia v. Judd" on Justia Law