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

Plaintiff brought an action alleging that his dismissal from medical school for unprofessional behavior violated the Rehabilitation Act of 1973, 29 U.S.C. 794, and the Americans with Disabilities Act (ADA), 42 U.S.C. 12182. The district court granted summary judgment in favor of the medical school and plaintiff appealed. Because the court agreed with the district court that, with or without a reasonable accommodation of plaintiff's ADHD and anxiety disorder, plaintiff was not "otherwise qualified" to participate in the medical school's program, the court affirmed the judgment. View "Halpern v. Wake Forest Univ. Health" on Justia Law

Plaintiff sued his employer under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., asserting that his inability to work more than eight hours per day and rotate day/night shifts as a result of physical impairments rendered him disabled under the ADA. The district court granted summary judgment to the employer and plaintiff subsequently appealed. The court held that an inability to work overtime did not constitute a "substantial" limitation on a major life activity under the ADA and the record contained no evidence indicating that plaintiff's inability to work overtime "significantly restricted" his ability to perform a class of jobs or a broad range of jobs in various classes. Therefore, the court affirmed the judgment of the district court. View "Boitnott v. Corning Inc." on Justia Law

Plaintiff appealed the district court's order granting summary judgment to the United States on her claim seeking money damages for alleged violations of the Privacy Protection Act (PPA), 42 U.S.C. 2000aa. Plaintiff, a photojournalist who claimed a special interest in covering protests, political demonstrations, and grassroots activism, was identified on a security camera as being present during a protest demonstration during the International Monetary Funds' annual spring meeting. Police officers executed a search warrant, believing it likely that plaintiff's residence contained evidence of suspected criminal activity that occurred during the protest. Plaintiff was never arrested or charged with any crimes relating to the incident. Plaintiff subsequently brought an action against the United States under the PPA and the district court granted summary judgment in favor of the United States. The court agreed with the district court that there was probable cause to believe plaintiff conspired with a group of vandals or aided and abetted the offenses committed by the group. Accordingly, the court concluded that the United States was entitled to summary judgment based on the "suspect exception" to the PPA and affirmed the judgment. View "Sennett v. United States, et al." on Justia Law

This appeal arose from an unsuccessful Title VII action brought by the Equal Employment Opportunity Commission (EEOC) against Great Steaks, Inc. The EEOC accused Great Steaks of subjecting female employees to a sexually hostile work environment. Although at the start of the case the EEOC asserted its claim on behalf of multiple claimants, that number diminished to one by trial. After a three-day trial, the jury rendered a verdict in Great Steaks' favor. Great Steaks subsequently moved for an award of attorneys' fees, maintaining it was entitled to such an award under three statutory provisions. The district court denied the motion for attorneys' fees in its entirety. On appeal, Great Steaks contended that the district court erred in doing so. Upon review of Great Steaks' claims of error and the laws it cited as grounds for relief, the Fourth Circuit found no abuse of discretion in the district court's decision. The Court affirmed the district court's decision. View "EEOC v. Great Steaks, Inc." on Justia Law

Plaintiff filed a racial discrimination action under Title VII in a North Carolina state court, naming the Secretary as a defendant. The Secretary removed the case to federal court under 28 U.S.C. 1442(a) and then filed a motion to dismiss. The court concluded that because the United States and the Secretary did not consent to be sued in a North Carolina state court under Title VII, the state court lacked subject matter jurisdiction. Inasmuch as removal to the federal court, under the doctrine of derivative jurisdiction, did not cure that jurisdictional defect, the court affirmed the district court's order. View "Bullock v. Napolitano" on Justia Law

Defendant was indicted on the charge of possessing a firearm while being a felon in violation of 18 U.S.C. 922(g)(1). Defendant, an African American, moved to dismiss the indictment, claiming that the U.S. Attorney's Office selected him for prosecution under a federal-state law enforcement initiative known as Project Exile because of his race, in violation of the equal protection component of the Fifth Amendment's Due Process Clause. On appeal, defendant requested that the court reverse the district court's order denying his motion for discovery and remand the case for discovery and an evidentiary hearing. The court held that defendant failed to make a credible showing that a similarly situated defendant of another race had evaded prosecution under Project Exile in order to obtain discovery on his selective prosecution claim and that defendant had failed to carry his burden of producing some evidence to make a credible showing of both discriminatory effect and intent. Accordingly, the judgment of the district court was affirmed. View "United States v. Venable" on Justia Law

Plaintiff appealed the district court's order affirming the Commissioner's denial of her application for supplemental security income (SSI). The court found that substantial evidence supported the ALJ's conclusion that plaintiff was not disabled within the meaning of the Social Security Act, 42 U.S.C. 301 et seq. Accordingly, the court affirmed the district court's grant of judgment on the pleadings in favor of the Commissioner. View "Hancock v. Astrue" on Justia Law

Plaintiff, a North Carolina registered lobbyist, commenced this action under 42 U.S.C. 1983 against the North Carolina State Board of elections to challenge the constitutionality of North Carolina's "Campaign Contributions Prohibition," N.C. Gen. Stat. 163-278.13C, which prohibited any registered lobbyist from contributing to the campaign of any candidate for the North Carolina General Assembly or the Council of State. Applying the "closely drawn" standard of scrutiny that the court concluded was applicable to such contribution restrictions, the court held that the statute was constitutional, both facially and as applied to plaintiff, as a valid exercise of North Carolina's legislative prerogative to address potential corruption and the appearance of corruption in the State.

Plaintiff filed a complaint under Title VII against her former employer, alleging that it engaged in religious discrimination and retaliation against her. After the district court denied the employer's motion for summary judgment, the employer filed an interlocutory appeal, contending that the plain language of 42 U.S.C. 2000e-1(a), the religious organization exemption, barred plaintiff's claims. The court held that because the plain language of section 2000e-1(a) exempted religious organizations like the employer from plaintiff's claims of religious discrimination, the district court erred in denying the employer's motion for summary judgment. Therefore, the court reversed the district court's order and remanded with instructions to enter judgment in favor of the employer.

Plaintiff, an unincorporated association made up of homeless and formerly homeless people that advocated for their rights, sued defendants, alleging that defendants had conspired to establish the Conrad Center on Oliver Hill Way, a site removed from Richmond's downtown community, for the purpose of reducing the presence of the homeless population in the downtown area by providing services for them in a remote location. Plaintiff claimed that the relocation of homeless services to the Conrad Center violated 42 U.S.C. 1983 and 1985(3); the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq.; the Equal Protection Clause of the Fourteenth Amendment; and the Fair Housing Act (FHA), 42 U.S.C. 3601 et seq. The court held that plaintiff did not state a valid section 1985(3) conspiracy claim; plaintiff's 1983 and equal protection claims were barred by the applicable statute of limitations; plaintiff's FHA claims were barred by the two-year statue of limitations and, more fundamentally, they failed to state a claim upon which relief could be granted; and plaintiff's ADA retaliation claim was properly dismissed. Accordingly, the court affirmed the judgment of the district court.