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

Plaintiff is a member of the nation of Gods and Earths (NOGE), a group whose adherents are also known as "Five Percenters." Plaintiff participated in a prison riot in 1995 with other Fiver Percenters and was placed in solitary confinement, where he has remained for 20 years. Plaintiff challenged his confinement under the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. 2000cc-1, claiming that a Department policy required him to renounce his affiliation with the NOGE, which he alleges is a religion, before the Department will release him from solitary confinement. Plaintiff also argued that defendants violated his rights to procedural due process. The district court granted defendant's motion for summary judgment. The court held that plaintiff's 20-year period of solitary confinement amounts to atypical and significant hardship in relation to the general population and implicates a liberty interest in avoiding security detention. Further, there is a triable dispute as to whether the Department’s process for determining which inmates are fit for release from security detention meets the minimum requirements of procedural due process. Accordingly, the court reversed as to this claim and affirmed as to the RLUIPA claim. View "Incumaa v. Stirling" on Justia Law

Plaintiff, an African-American flight attendant, filed suit alleging that United Airlines failed to adequately respond to a racist death threat left in her company mailbox. The district court concluded that plaintiff was subjected to a racially hostile work environment, but granted summary judgment to the airline after deciding that it was not liable for the offensive conduct. The court concluded that the district court properly concluded that a reasonable jury could properly construe the notes at issue as racially-tinged death threats so severe that it does not matter they were not pervasive. The court concluded that the anonymous nature of severe threats or acts of harassment may, in fact, heighten what is required of an employer, particularly in circumstances where the harassment occurs inside a secure space accessible to only company-authorized individuals. In this case, the conduct at issue is some of the most serious imaginable in the workplace – an unmistakable threat of deadly violence against an individual based on her race, occurring in the particularly sensitive space of an airport. Given the severity of the threat, a reasonable jury could find that United’s response was neither prompt nor reasonably calculated to end the harassment. Indeed, a reasonable jury could find that United’s response was instead reluctant and reactive, intended to minimize any disruption to day-to-day operations instead of identifying a perpetrator and deterring future harassment. Accordingly, the court vacated and remanded for further proceedings. View "Pryor v. United Air Lines, Inc." on Justia Law

Petitioner, a native and citizen of El Salvador, seeks review of the BIA's decision dismissing her appeal from an IJ's order of removal. At issue is the IJ's denial of petitioner's motion to suppress certain evidence and to terminate the removal proceeding. The court held that the exclusionary rule applies to egregious violations of the Fourth Amendment. The court joined the Second, Third, and Eighth Circuits and applied a totality of the circumstances test to determine the egregiousness standard. The court rejected petitioner's claim that her Fourth Amendment rights were violated when the search warrant at issue was invalid because it identified the premises as single-family home as oppose to a multi-unit dwelling. The court rejected petitioner's alternative arguments, concluding that petitioner's claims do not make out a constitutional violation, let alone an egregious one. The court held, however, that the nighttime execution of a daytime warrant violates the Fourth Amendment, absent consent or exigent circumstances. In this case, the 5:00 a.m. search of the premises violated the Fourth Amendment. The court held that, although the nighttime execution of the daytime warrant violated petitioner’s Fourth Amendment rights, such violation was not egregious under the totality of the circumstances. The court rejected petitioner's remaining claims and denied the petition for review. View "Yanez-Marquez v. Lynch" on Justia Law

Plaintiff filed suit against the Board, alleging that it violated his rights under the Family and Medical Leave Act of 1993 (FMLA), 29 U.S.C. 2601 et seq., and the Americans with Disabilities Act of 1990 (ADA), 42 U.S.C. 12101 et seq. Plaintiff was involved in an incident with a student at the high school where he was employed as an assistant principal. Plaintiff subsequently filed for medical leaves due to his post-traumatic stress disorder which was related to the CPS investigation that occurred after the incident. Plaintiff was also transferred to a different school. The court concluded that the evidence demonstrated that the Board did not interfere with plaintiff's FMLA rights and did not retaliate against plaintiff for exercising such rights. The court also rejected plaintiff's ADA claim, concluding that evidence demonstrated that the Board did not discriminate nor retaliate against him based on his disability. Further, the Board did not fail to accommodate plaintiff's condition. View "Adams v. Anne Arundel Cnty. Pub. Sch." on Justia Law

Plaintiff, who is blind, filed suit against the County, alleging violations of Section 504 of the Rehabilitation Act of 1973, 29 U.S.C. 794, or Title II of the Americans with Disabilities Act of 1990 (ADA), 42 U.S.C. 12131 et seq. Plaintiff was employed by the County when the County opened a new call center using software that was inaccessible to blind employees. The County did not transfer plaintiff to the new call center along with her sighted coworkers and the County also did not hire her for a vacant position there. The court reversed the grant of summary judgment in favor of the County on the Section 504 claim, finding that genuine issues of material fact remain as to whether plaintiff could perform the essential job functions of a call center employee; whether the County reasonably accommodated her; and if the County did not, whether its failure to do so may be excused because of undue hardship. However, the court affirmed the district court's grant of summary judgment in favor of the County on the Title II claim where public employees cannot use Title II to bring employment discrimination claims against their employers. View "Reyazuddin v. Montgomery Cnty, MD" on Justia Law

Plaintiffs, police officers for the Town of Mocksville, filed suit alleging that the Town and others violated plaintiffs' First Amendment rights when plaintiffs were terminated for speaking out about corruption and misconduct at the Mocksville Police Department. The court concluded that the evidence demonstrated that plaintiffs acted as private citizens on a matter of undisputed public concern by privately reaching out to the Governor's Office about suspected corruption and misconduct. Such actions cannot be considered as part of plaintiffs' daily professional activities. Further, it was clearly established law at the time that speech about serious misconduct in a law enforcement agency is protected. Accordingly, the court affirmed the district court's denial of summary judgment to Defendants Cook and Bralley. View "Hunter v. Mocksville, NC" on Justia Law

In 1970, the district court determined that the City and the Board were operating racially segregated schools and directed them to submit desegregation plans that would establish a nonracial, unitary school district. This appeal stemmed from the district court's two desegregation orders. Plaintiffs moved to enjoin the implementation of the Board's 2011-2012 student assignment plan because it failed to move the school district toward unitary status. The district court denied relief. The court vacated the district court's ruling, holding that the district court erred when it failed to place the burden on the Board to show that the 2011-12 student assignment plan moved the school district toward unitary status. Subsequently, the district court granted the Board's motion requesting that the district court declare the school district unitary and the district court dismissed plaintiffs' request for an injunction as moot. The court affirmed, concluding that the district court acted within its discretion in choosing to address the Board’s motion for declaration of unitary status before ruling on plaintiffs’ motion for injunctive relief. Further, the district court did not clearly err in determining that the school district is unitary. View "Everett v. Pitt Cnty. Bd. of Educ." on Justia Law

Plaintiffs filed suit challenging a state law redrawing the Wake County Board of Education electoral districts, arguing that under the new redistricting plan, some citizen’s votes will get significantly more weight than other’s in violation of the Fourteenth Amendment’s guarantees of one person, one vote and the North Carolina Constitution’s promise of equal protection. The district court granted defendants’ motions to dismiss and denied plaintiffs’ motion to amend as futile. The court concluded that plaintiffs’ allegations in support of their claim that the law violates the one person, one vote principle suffice to survive a motion to dismiss for failure to state a claim. Thus, plaintiffs have stated a claim upon which relief could be granted against the Wake County Board of Elections and the district court therefore erred in dismissing their suit. The court affirmed, however, the denial of the motion to amend because the state officials plaintiffs proposed to add as named defendants are not amenable to suit. View "Wright v. North Carolina" on Justia Law

Plaintiff appealed the district court's summary dismissal of his 42 U.S.C. 1983 claim against defendant on the ground that plaintiff failed to exhaust his administrative remedies pursuant to the Prison Litigation Reform Act (PLRA), 42 U.S.C. 1997e(a). Plaintiff's suit arose from allegations that prison officers used excessive force while transferring him to a different cell. The court reversed and remanded, holding that plaintiff reasonably believed that he had sufficiently exhausted his remedies by complying with an internal investigation. View "Blake v. Ross" on Justia Law

Plaintiff filed suit against the University under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., for discriminatory termination based on gender, retaliatory termination, and the creation of a hostile work environment. At issue was the effect of the Supreme Court’s decision in University of Texas Southwestern Medical Center v.Nassar on what Title VII retaliation plaintiffs must show to survive a motion for summary judgment. The court concluded that the McDonnell Douglas framework, which already incorporates a but for causation analysis, provides the appropriate standard for reviewing plaintiff’s claim. Applying this framework, the court found that summary judgment in favor of the University is not warranted on plaintiff's retaliation claim where a reasonable jury could conclude from plaintiff's evidence that the University's proffered justifications were not its real reasons for firing her and that the University's actual reason for firing her was to retaliate against her complaining about sexual harassment and for her subsequent complaints of ongoing retaliation. Therefore, the court reversed the district court's grant of summary judgment as to plaintiff's retaliation claim. The court affirmed the district court's grant of summary judgment on plaintiff's gender-based discrimination claim and hostile work environment claim. View "Foster v. Univ. of Maryland Eastern" on Justia Law