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

Plaintiff, a Sunni Muslim currently incarcerated in a state correctional facility, brought this action alleging that prison officials violated the Religions Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. 2000cc et seq., by refusing to permit him to grow a one-eighth-inch beard in compliance with the requirements of his faith. Because the prison officials did not explain how a one-eighth-inch beard would implicate health or security concerns, they failed to satisfy their burden under RLUIPA of showing that the general grooming policy that they relied upon was the least restrictive means of furthering a compelling governmental interest. Accordingly, the court vacated the grant of summary judgment and remanded for further proceedings. View "Couch v. Jabe" on Justia Law

In 2010, appellants unsuccessfully sought to enjoin the implementation of the 2011-2012 student assignment plan by the school board. On appeal, appellants argued that the district court committed legal error by failing to apply, and requiring the school board to rebut, a presumption that racial disparities in the 2011-2012 assignment plan resulted from the school board's prior unconstitutional conduct in operating a racially segregated school district. The court agreed and therefore vacated the district court's order and remanded for reconsideration. View "Everett v. Pitt Cty. Brd. of Educ." on Justia Law

Plaintiff sued defendant, a bail bondsman, and others, alleging civil rights violations under 42 U.S.C. 1983, as well as various state law tort claims. The claims stemmed from defendant's efforts to apprehend a fugitive in and around plaintiff's home. A jury found in plaintiff's favor on her section 1983, trespass, and assault claims. Defendant appealed, challenging the jury's verdict and damages award. The court held that defendant was not entitled to qualified immunity where neither history nor policy supported extending the defense to bail bondsmen. The court also held that there was sufficient evidence to support the jury's conclusion that plaintiff's consent was involuntary and the court affirmed the verdict on the 1983 claim. The court further held that there was a sufficient basis to support the jury's conclusion that plaintiff was in reasonable fear of bodily harm. Finally, the court affirmed the district court's denial of defendant's motion regarding the actual damages award and found no abuse of discretion in the district court's decision to leave the punitive damages award undisturbed. Accordingly, the court affirmed the judgment. View "Gregg v. Ham" on Justia Law

Plaintiff filed a complaint against Officer Robert M. Bauer and several other defendants, alleging claims under 42 U.S.C. 1983 for deprivation of her Fourth Amendment right to freedom from seizure without probable cause, and also asserting her state law claim for malicious prosecution. Considering the totality of the circumstances, the court concluded that no prudent person would have believed that plaintiff violated the impersonation statute at issue and therefore, plaintiff's arrest lacked probable cause and was unreasonable. Thus, plaintiff's constitutional right not to be unreasonably seized was violated. The court also held that the district court did not err in ruling that Officer Bauer was not, at this stage of the litigation, entitled to qualified immunity on plaintiff's section 1983 claim. View "Merchant v. Bauer" on Justia Law

Plaintiff, a minor, sustained serious injuries at birth due to the negligence of medical professionals who attended her delivery. As a result of plaintiff's injuries, DHHS, through the state Medicaid program, paid more than $1.9 million in medical and health care expenses on her behalf. Plaintiff instituted a medical malpractice action in state court and eventually settled the action for a lump some of approximately $2.8 million. The settlement agreement did not allocate separate amounts for past medical expenses and other damages. DHHS subsequently asserted a statutory lien on the settlement proceedings pursuant to N.C. Gen. Stat 108A-57 and 59 (third-party liability statues), which asserted that North Carolina had a subrogation right and could assert a lien upon the lesser of its actual medical expenditures or one-third of the medicaid recipient's total recovery. Plaintiff brought the instant action seeking declaratory and injunctive relief pursuant to 42 U.S.C. 1983, seeking to forestall payment under federal Medicaid law known as the "anti-lien provision," 42 U.S.C. 1396p. The court was persuaded that the unrebuttable presumption inherent in the one-third cap on the state's recovery imposed by the North Carolina third-party liability statutes was in fatal conflict with federal law. Accordingly, the court vacated the judgment in favor of the Secretary and remanded for further proceedings. View "E.M.A v. Cansler" on Justia Law

Plaintiff, an inmate, filed a complaint in state court against defendants, contending that defendants engaged in a campaign of harassment against him and asserted several claims against them, including violations of his federal constitutional rights. Following defendants' removal to federal district court, the district court remanded the case to state court, in part based on plaintiff's status as a "three-strikes" prisoner due to his frequent legal filings. Because the court found that the district court lacked a statutory or legal basis to remand plaintiff's action to state court, the court reversed the order and reinstated plaintiff's complaint for further proceedings. View "Lisenby, Jr. v. Lear, et al." on Justia Law

Plaintiff brought this action, alleging that her former employer, the County, unlawfully discriminated against her by offering her a less favorable severance package than that offered to male employees holding similar positions. The district court dismissed the complaint. The court held that the district court erred in dismissing plaintiff's complaint on the theory that the discriminatory denial of a non-contractual employment benefit could not constitute an adverse employment action; the district court's alternative rationale for dismissing the complaint, that she suffered no adverse employment action because the County fired her before it made its allegedly discriminatory offer, also failed because it ignored the well-pleaded factual allegations in the complaint and because Title VII protects both current and former employees from discriminatory adverse employment actions. The court granted leave to the district court to consider, in the first instance, two additional arguments raised by the County. Accordingly, the court reversed and remanded. View "Gerner v. County of Chesterfield, VA" on Justia Law

This appeal arose out of the district court's grant of summary judgment in favor of PCA on plaintiff's claims of sexual harassment in violation of Title VII. Because the court found that there were genuine issues of fact as to whether PCA took "tangible employment action" against plaintiff, the court reached neither the question of whether the district court erred by not determining whether Bobby Mills was a supervisor nor the question of whether the district court correctly applied the Faragher-Ellerth defense test. The court also held that there was uncertainty about whether there was a nexus between the harassment and plaintiff's alleged termination. Accordingly, the court vacated and remanded. View "Dulaney v. Packaging Corp. of America, et al." on Justia Law

Plaintiff, who is deaf, appealed the district court's ruling of summary judgment for defendants, arguing that he was entitled to have the jury hear his argument that he was not reasonably accommodated by defendants during their investigation, in violation of his rights under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101, et seq., and the Rehabilitation Act, 29 U.S.C. 701 et seq. Plaintiff claimed he suffered "emotional issues" and "persistent anger" because the county "violated [his] right to communicate" by handcuffing him behind his back and failing to explain their presence. Having concluded that the ADA applied to the investigation of criminal conduct, the court next determined whether the deputies' conduct was reasonable under the circumstances. The court found that due to the exigencies inherent in responding to a domestic violence situation, no further accommodations were required than the ones made by the deputies. Accordingly, the court affirmed the judgment. View "Seremeth, Jr. v. Bd. of County Commissioner" on Justia Law

Plaintiffs brought an action under 18 U.S.C. 1983 against defendants after defendants asked plaintiffs to remove large, graphic signs depicting aborted fetuses that plaintiffs were using as part of a roadside demonstration. Plaintiffs and defendants subsequently cross-appealed different portions of the district court's opinion and order. The court affirmed the district court's grant of summary judgment on grounds of qualified immunity to defendants in their individual capacities where, at the time of the anti-abortion demonstration at issue, it was not clearly established that law enforcement officers could not proscribe the display of large, graphic photographs in a traditional public forum. The court held that plaintiff was indeed awarded summary judgment on its request for a declaratory judgment that defendants' actions were an unconstitutional infringement on its First Amendment rights. There was no abuse of discretion in the district court's denial of attorney's fees to plaintiffs. Finally, the court held that there was no abuse of discretion in the district court's decision to order defendants to safeguard plaintiff's First Amendment rights and refrain from impermissible content-based restrictions in the future. Therefore, the court affirmed the district court's grant of summary judgment to defendants on grounds of qualified immunity, the denial of an award of attorney's fees to plaintiff, and the grant of injunctive relief to plaintiff against defendants. View "Lefemine v. Wideman" on Justia Law