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

Painter's Mill Grille, the owner and operator of a restaurant, and its principals filed a complaint against the restaurant's landlord and its agents. Plaintiff alleged that defendants, motivated by racial animus, interfered with plaintiff's business and its opportunity to sell the restaurant, including its leasehold interest, in violation of 42 U.S.C. 1981, 1982, and 1985(3), as well as state tort principles. The court agreed with the district court's conclusion that plaintiff's principals did not have standing to be plaintiffs and that Painter's Mill Grille did not set forth sufficient facts to state a claim to relief that was plausible on its face. Accordingly, the court affirmed the district court's dismissal of the complaint under Rule 12(b)(6). View "Painter's Mill Grille, LLC v. Brown" on Justia Law

Plaintiff filed charges of discrimination with the EEOC against his employer, Dollar General, alleging that Dollar General failed to provide reasonable accommodation for his disability in violation of the Americans with Disabilities Act of 1990 (ADA), 42 U.S.C. 12101-12213. While awaiting the EEOC's notice of his right to sue, plaintiff filed for Chapter 13 bankruptcy. Then plaintiff filed the present suit in district court. Dollar General moved for summary judgment, arguing that the filing of plaintiff's Chapter 13 bankruptcy petition deprived plaintiff of standing to maintain his ADA claim. The court agreed with its sister circuits and concluded that because of the powers vested in the Chapter 13 debtor and trustee, a Chapter 13 debtor could retain standing to bring his pre-bankruptcy petition claims. The court also concluded that because plaintiff was unable to show that he could perform the essential functions of his position with a reasonable accommodation, the district court properly granted summary judgment in Dollar General's favor. Accordingly, the court affirmed the judgment of the district court. View " Wilson v. Dollar General Corp." on Justia Law

Plaintiffs and their son appealed the district court's summary judgment holding that they were not entitled under the Fair Housing Amendments Act of 1988, 42 U.S.C. 3601-3631, to an accommodation and a modification that they requested from the HOA. Plaintiffs had requested a modification to add a ramp leading to the front door of their home for use by their son, who required the use of a wheelchair. Plaintiffs also requested an accommodation to an HOA policy prohibiting the use of certain types of vehicles to allow the son to use an ATV within the community. The court vacated the district court's holding on the merits of the modification request for the wheelchair access ramp because that claim was not ripe; affirmed the district court's holding with respect to the accommodation request for permission to use an ATV because that request was not "reasonable" within the meaning of the Act; and affirmed the district court's denial of defendants' request for attorneys' fees and costs. View "Scoggins v. Lee's Crossing Homeowners Assoc." on Justia Law

Plaintiff, an inmate serving a life sentence, filed suit under 42 U.S.C. 1983, alleging several constitutional violations relating to the conditions of his confinement. At issue on appeal was whether certain actions taken by prison officials after plaintiff's suspected receipt of contraband, including suspension of the inmate's visitation privileges for two years, violated his constitutional rights. The court concluded that the prison warden who imposed the challenged actions was shielded by qualified immunity from plaintiff's claim for monetary damages because, under the facts presented here, the inmate did not have a clearly established constitutional right to visitation. The court also held that because plaintiff's visitation privileges already have been restored, his request for injunctive relief must be dismissed as moot. Accordingly, the court dismissed in part and affirmed in all other respects the judgment of the district court. View "Williams v. Ozmint" on Justia Law

Plaintiff, an employee of NGA with a top secret security clearance, informed the NGA of his marriage after the investigation for his security clearance had been completed but before he had begun work. The NGA conducted a reinvestigation into his security clearance and then revoked the security clearance. Plaintiff commenced this action under the Administrative Procedure Act (APA), 5 U.S.C. 500 et seq., against the NGA and its Director to reverse the NGA's decision, to reinstate his security clearance, and to award him back pay, benefits, and attorneys' fees. The district court dismissed the complaint, concluding that it did not have subject-matter jurisdiction to review a security clearance determination. The court concluded that plaintiff's speculative and conclusory allegations of constitutional violations were essentially recharacterizations of his challenge to the merits of the NGA's security clearance determination and that the court did not have jurisdiction to review such a determination. Accordingly, the court affirmed the judgment. View "Hegab v. Long" on Justia Law

Plaintiff was convicted in 1993 of carnal knowledge of a minor without the use of force. In this appeal, plaintiff challenged Va. Code sections 9.1-900 et seq. and 18.2-370.5, which, together, classified her as a sexually violent offender and prevented her from entering the grounds of a school or daycare without first gaining permission from the Virginia circuit court and the school board or the owner of the daycare. Unless plaintiff gains such permission, she is not able to meet with her stepson's teachers at school, attend his school functions, or drop him off at or pick him up from school. Plaintiff's complaint included four counts: she alleged that defendants have violated her substantive due process, procedural due process, associational, and free exercise rights. The injuries she alleged with respect to the first, third, and fourth counts stemmed from impediments the Virginia statute and the school board policy placed on her ability to access school and church property. The court held that because she had not yet attempted to undertake the requisite steps to access these properties, she could not demonstrate that these claims were justiciable. While plaintiff's second count was justiciable, she failed to state a procedural due process claim upon which relief could be granted. Accordingly, the court affirmed the district court's dismissal of her claims. View "Doe v. Virginia Dept. of State Police" on Justia Law

Plaintiff, by and through her parents, sued the school principals and school board pursuant to 42 U.S.C. 1983, alleging violations of her First Amendment right to free speech and expression and her Fourteenth Amendment rights to due process and equal protection. Defendants prohibited plaintiff from wearing and on one occasion punished her for wearing Confederate flag shirts at school. When, as here, student speech threatened to disrupt school, school officials could prohibit or punish that speech. The school officials therefore did not violate plaintiff's First Amendment right when they refused to allow her to wear Confederate flag shirts and protest shirts at school, and the dress codes and their enforcement did not infringe on plaintiff's Fourteenth Amendment rights. Accordingly, the court affirmed the district court's grant of summary judgment for defendants. View "Hardwick v. Heyward" on Justia Law

Plaintiffs initiated this action pursuant to 42 U.S.C. 1983, asserting, inter alia, that Maryland's good-and-substantial-reason requirement for obtaining a handgun permit contravened the Second Amendment. The district court permanently enjoined enforcement of section 5-306(a)(5)(ii) of the Public Safety Article of the Maryland Code, to the extent that it conditions eligibility for a permit to carry, wear, or transport a handgun in public on having "good and substantial reason" to do so. Because the court disagreed with the district court's conclusion that the good-and-substantial-reason requirement could not pass constitutional muster, the court reversed the judgment. Under the applicable intermediate scrutiny standard, the State had demonstrated that the good-and-substantial-reason requirement was reasonably adapted to Maryland's significant interests in protecting public safety and preventing crime. The court also rejected plaintiffs' facial challenge. Accordingly, the court reversed the judgment of the district court. View "Woollard v. Gallagher" on Justia Law

Plaintiff appealed the district court's denial of relief on her claims of discrimination, retaliation, and hostile work environment, brought under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e, as well as wrongful discharge, assault, and battery, brought under Virginia law, against Huntington Ingalls, the successor to her former employer. According to plaintiff, Huntington Ingalls subjected her to an ongoing sexually hostile work environment and her claims centered on the actions of her supervisor. The court held that the district court properly declined to consider those allegations not included in plaintiff's EEOC charge; because the district court correctly determined that amending her complaint would be futile, it did not abuse its discretion in denying her leave to do so; because the department manager did not know of the protected activity, and because the supervisor, who allegedly influenced him, was not principally responsible for the decision to terminate plaintiff's employment, the court affirmed the district court's grant of summary judgment to Huntington Ingalls on the retaliatory discharge claim; and the court affirmed the district court's grant of summary judgment as to the assault and battery claims. View "Balas v. Huntington Ingalls Industries" on Justia Law

Plaintiffs, thirteenth North Carolina residents who lost access to in-home personal care services (PCS) due to a statutory change, brought suit challenging the new PCS program. The district court granted plaintiffs' motions for a preliminary injunction and class certification. Defendants appealed, raising several points of error. The court agreed with the district court's conclusion that a preliminary injunction was appropriate in this case. The court held, however, that the district court's order failed to comply with Federal Rule of Civil Procedure 65 because it lacked specificity and because the district court neglected to address the issue of security. Accordingly, the court remanded the case. View "Pashby v. Delia" on Justia Law