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

A police officer in Columbia, South Carolina, shot and killed a high school senior, J.R., during the COVID-19 curfew. The officer was responding to a report of teenagers looking into cars and saw J.R. walking alone. When the officer approached, J.R. ran away. The officer chased J.R. and, during the pursuit, observed that J.R. was armed. Despite repeatedly commanding J.R. to stop, get on the ground, and show his hands, J.R. did not comply. At one point, J.R. crouched near a fence, picked up his gun, and then ran again. The officer fired multiple shots, ultimately striking J.R. in the forehead and killing him.J.R.’s mother, acting as his personal representative, sued the officer under 42 U.S.C. § 1983, asserting that the use of deadly force violated J.R.’s Fourth Amendment rights. The United States District Court for the District of South Carolina denied the officer’s motion for summary judgment based on qualified immunity, finding that although J.R. was armed, ignored commands, and turned to face the officer, there was no undisputed evidence that J.R. made a threatening movement with his weapon. The court concluded that genuine disputes of material fact remained and that it was clearly established law that deadly force could not be used under these circumstances.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The Fourth Circuit held that, at the time of the shooting, clearly established law prohibited a police officer from using deadly force against a fleeing, armed suspect who did not make a furtive or threatening movement with his weapon. The court concluded that the officer was not entitled to qualified immunity and allowed the case to proceed. View "Ruffin v. Davis" on Justia Law

In December 2021, an individual with a lower leg amputation and a history of medical episodes broke into a car dealership in Chesterfield County, Virginia. After the alarm was triggered, police—including an officer and his police K-9—responded to the scene. The individual hid in a storage room, unarmed and passively waiting to be arrested. When the officer and his leashed K-9 located him lying in a submissive, fetal-like position, the officer allegedly gave no orders or warnings before directing the dog to attack. The K-9 inflicted severe injuries, including to sensitive areas of the individual’s body, resulting in significant blood loss and destruction of his prosthetic leg. Following the incident, the individual was charged with trespassing and vandalism, but no violent offenses.The individual filed suit in the United States District Court for the Eastern District of Virginia, asserting a Fourth Amendment excessive force claim under 42 U.S.C. § 1983, as well as related state law claims. The officer moved to dismiss, arguing that the use of force was objectively reasonable and that qualified immunity applied because the right in question was not clearly established. The district court ruled that the complaint plausibly alleged a Fourth Amendment violation but concluded that the specific right was not clearly established, granting the officer qualified immunity and dismissing the federal claim. The court declined to exercise supplemental jurisdiction over the state law claims.The United States Court of Appeals for the Fourth Circuit reviewed the case and held that, as of 2013, it was clearly established that a non-threatening, unarmed, and passively-resisting suspect had a right to be free from unnecessary, gratuitous, and disproportionate force by deployment of a police K-9. The court vacated the district court’s judgment and remanded for further proceedings. View "Harrold v. Hagen" on Justia Law

Three equestrian trainers, each subjected to sanctions by the United States Center for SafeSport (SafeSport) for past misconduct, sought to challenge those sanctions. Navarro and Giorgio were permanently banned after SafeSport learned of their prior guilty pleas to child sexual abuse, while Shaffer received a suspension and probation following SafeSport’s investigation of complaints against her. Navarro and Giorgio pursued arbitration and internal grievance procedures that ultimately confirmed SafeSport’s sanctions. Shaffer declined to arbitrate, citing the cost. All three alleged that SafeSport’s procedures violated their constitutional rights because they were barred from Olympic sports without a prior hearing, and further argued that SafeSport, a private body, unconstitutionally exercises governmental authority.After their grievances and appeals were rejected by the United States Equestrian Federation (USEF) and the United States Olympic & Paralympic Committee (USOC), the trainers filed suit in the United States District Court for the Western District of Virginia. The district court dismissed their claims, holding that the trainers lacked standing to sue the USOC, that Shaffer failed to exhaust administrative remedies, that Appellees were not state actors and thus not subject to the Fifth Amendment, and that SafeSport’s powers did not violate the private non-delegation doctrine.The United States Court of Appeals for the Fourth Circuit reviewed the case. It affirmed the district court’s rulings that the trainers lacked standing to sue the USOC, that the Appellees were not state actors subject to the Due Process Clause, and that the court lacked jurisdiction over the private non-delegation claim. However, it reversed the district court’s finding on administrative exhaustion, holding that Shaffer was not obligated to arbitrate her constitutional claims before seeking relief in federal court. Thus, the judgment was affirmed in part and reversed in part. View "Navarro v. United States Center for SafeSport" on Justia Law

An Afghan infant was orphaned and injured during a joint U.S.-Afghan military operation and received emergency care at a U.S. military hospital. A U.S. Marine Corps Judge Advocate, Major Joshua Mast, and his wife, Stephanie Mast, initiated custody proceedings and ultimately obtained a Virginia adoption order for the child. Separately, the U.S. Embassy gave custody to a man claiming to be the child's uncle, and the infant was subsequently cared for by John and Jane Doe, who later evacuated from Afghanistan to the United States with the child during Operation Allies Refuge. After arriving in the U.S., the Masts took custody of the child. The Does then challenged the adoption in Virginia state court, but the Supreme Court of Virginia rejected their challenge.Following the state proceedings, the Does filed a federal lawsuit in the U.S. District Court for the Western District of Virginia, seeking, among other things, a protective order to prevent the defendants from disclosing their identities. The district court granted the protective order, concluding that disclosing the Does’ identities would pose a substantial risk to their safety and that of their family in Afghanistan. The order prohibited the defendants and their representatives from revealing any information that could directly or indirectly identify the Does or their family members unless a non-disclosure agreement was executed. After the Does engaged with the media while maintaining anonymity, the Masts moved to vacate or modify the protective order, arguing it was an unconstitutional restraint on speech. The district court denied the motion and held Joshua Mast in contempt for violating the order.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s order. The Fourth Circuit held that the protective order, while a content-based prior restraint, fit within a narrow exception because it was narrowly tailored to serve the government’s compelling interest in national security—specifically, the protection of individuals perceived as U.S. collaborators. The court found the order survived strict scrutiny and was not unconstitutionally vague. View "Doe v. Mast" on Justia Law

A federal inmate brought an action for damages against several officials at a federal prison, claiming they provided delayed or inadequate medical treatment and used excessive force against him during his incarceration. His allegations included delayed dental care, insufficient response to rectal bleeding, denial of participation in a mental health class, and the use of restraints and physical force during an incident involving his cellmate. He asserted that these actions violated his constitutional rights under the Eighth, Fourth, and Fifth Amendments.The United States District Court for the Western District of Virginia dismissed his complaint, holding that a damages remedy under Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics was not available for his claims. The court reasoned that his claims, both for inadequate medical care and excessive force, presented new contexts beyond those recognized in previous Supreme Court cases and that special factors counseled against extending a judicially implied damages remedy. The inmate appealed from the district court’s judgment.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the inmate’s inadequate medical treatment claims presented a new context distinct from Carlson v. Green, as the facts involved less severe circumstances and implicated broader, systemic prison management issues rather than deliberate malfeasance. The court further found that special factors, including Congress’s silence and provision of alternative remedies, counseled against extending Bivens. Regarding the excessive force claims, the Fourth Circuit found that the Supreme Court’s intervening decision in Goldey v. Fields expressly foreclosed recognizing a Bivens remedy in this context. Thus, the Fourth Circuit affirmed the district court’s dismissal, holding that a Bivens remedy was unavailable for the plaintiff’s claims. View "Spivey v. Breckon" on Justia Law

Nathaniel Martin was a passenger in a vehicle stopped by a United States Forest Service law enforcement officer in the Monongahela National Forest after the vehicle was found illegally parked on a single-lane bridge. The officer, Joshua Radford, initially cited the parking violation as the reason for the stop. However, as soon as the stop began, Radford immediately shifted focus, asking about firearms in the vehicle and then further questioning both the driver and Martin regarding other possible contraband. Firearms were discovered, and Martin was eventually arrested after a check revealed prior felony convictions. Notably, the officer did not issue a citation for the parking offense, and the initial minutes of the stop were not captured on bodycam video.After more than two years, Martin was charged in the United States District Court for the Southern District of West Virginia with being a felon in possession of a firearm. He moved to suppress the evidence and his statements, arguing that the stop violated his Fourth Amendment rights because the officer had abandoned the original purpose of the stop. The district court denied the motion to suppress, finding that the officer’s actions remained within the permissible scope of the stop and did not unlawfully extend it. Martin then entered a guilty plea, preserving his right to appeal the suppression ruling.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the officer’s immediate pivot from addressing the parking violation to investigating potential criminal activity was not reasonably related in scope to the original justification for the stop. The court distinguished this situation from prior precedent by noting the absence of circumstances suggesting officer safety concerns. The court reversed the district court’s denial of the suppression motion and vacated Martin’s guilty plea. View "US v. Martin" on Justia Law

Charles Byers was shot and killed by Corporal Gordon Painter, a Chesterfield County police officer, after an emergency call reported that Byers had tried to break into two homes and vandalized one. Byers, who suffered from schizoaffective disorder, was seen wandering barefoot in a neighborhood holding a hatchet. When police arrived, Byers refused multiple commands to drop the hatchet, but kept the weapon lowered at his side and did not make threatening movements. After a taser was deployed without effect, Officer Painter fired three shots at Byers, who was about 25 feet away with his head turned away. Byers then turned to flee, and Officer Painter fired additional shots, striking Byers in the back and causing his death.Byers' parents, as co-administrators of his estate, sued Officer Painter under 42 U.S.C. § 1983 for excessive force in violation of the Fourth Amendment, and for negligence under Virginia law, in the United States District Court for the Eastern District of Virginia. The district court denied Officer Painter’s motion to dismiss the § 1983 claim on qualified immunity grounds, finding that Byers did not pose an immediate threat at the time he was shot, and granted the motion to dismiss the negligence claim. Officer Painter appealed the denial of qualified immunity.The United States Court of Appeals for the Fourth Circuit reviewed the district court's denial of qualified immunity de novo, applying recent Supreme Court guidance that requires courts to consider the totality of the circumstances, not just the moments before deadly force is used. The Fourth Circuit held that, even considering the totality, Officer Painter’s use of deadly force was not objectively reasonable under the Fourth Amendment, and that the violation was clearly established at the time. The court affirmed the district court’s denial of Officer Painter’s motion to dismiss on qualified immunity grounds. View "Byers v. Painter" on Justia Law

A 13-year-old male student at a Virginia Beach middle school received a sexually explicit photo from a female classmate and, several months later, showed the image to other students during the school day. After teachers reported the incident, the assistant principal removed the student from class, questioned him, and searched his phone’s photo gallery. The school resource police officer was notified and began a criminal investigation. The student ultimately showed the explicit photo to the officer, was read his Miranda rights, arrested, and charged in juvenile court with possession of child pornography. The juvenile court found sufficient evidence for guilt but deferred disposition; the charge was dismissed after the student completed court-imposed conditions.The student, through his mother and later counsel, sued the assistant principal, the school resource officer, the Virginia Beach School Board, and the City of Virginia Beach in the United States District Court for the Eastern District of Virginia. He alleged violations of his Fourth, Fifth, and Fourteenth Amendment rights, as well as conspiracy and Monell claims. The district court granted summary judgment to all defendants, finding the phone search reasonable under New Jersey v. T.L.O., the confession voluntary, no evidence of unlawful conspiracy, and no underlying constitutional violations to support Monell liability.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The court affirmed the district court’s judgment, holding that the assistant principal’s search of the student’s phone was justified at its inception and reasonable in scope under T.L.O., and that Riley v. California did not displace this standard in the school context. The court also held the student’s confession was voluntary under the Fifth and Fourteenth Amendments, found no evidence of a conspiracy to violate constitutional rights, and determined Monell liability could not attach absent an underlying constitutional violation. The court therefore affirmed summary judgment for all defendants. View "O.W. v. Carr" on Justia Law

A married couple, acting on behalf of their minor child, challenged West Virginia’s compulsory vaccination law after their daughter was disenrolled from a public virtual school because she was not fully vaccinated. The parents sought a religious exemption from the vaccination requirement, but were informed that only medical exemptions—based on specific medical contraindications or precautions certified by a physician—are permitted under state law. After being denied a religious exemption, the parents filed suit, claiming that the absence of a religious exemption violated their First Amendment right to freely exercise their Christian faith. They requested a preliminary injunction to allow their daughter’s re-enrollment in the virtual academy during the litigation.The United States District Court for the Northern District of West Virginia granted the preliminary injunction, finding that the parents were likely to succeed on their free exercise claim. The district court applied the test from Employment Division, Department of Human Resources of Oregon v. Smith, concluding that the vaccination law was not generally applicable, and thus subject to strict scrutiny, which it found the law did not survive.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s grant of preliminary relief. The Fourth Circuit held that West Virginia’s compulsory vaccination law is a neutral and generally applicable measure enacted under the state’s police power to protect public health, as recognized in longstanding Supreme Court precedent including Jacobson v. Massachusetts and Prince v. Massachusetts. The court found that the medical exemption process does not constitute a “mechanism for individualized exemptions” that would undermine general applicability under cases such as Fulton v. City of Philadelphia. The Fourth Circuit concluded that the law is subject to rational basis review, which it easily satisfies, and that the Free Exercise Clause does not require religious exemptions simply because medical exemptions exist. The court reversed the district court’s preliminary injunction and remanded the case. View "Perry v. Marteney" on Justia Law

The case concerns a petitioner who was convicted in West Virginia state court in 2004 of sexually abusing his son. After the trial, it was discovered that, during jury deliberations, one juror told others that he knew the petitioner’s family and feared for his own family’s safety if the petitioner was acquitted. Four jurors later confirmed that the comments had been made, though the juror in question denied them. The petitioner argued this introduced an impermissible external influence into the deliberations, violating his right to an impartial jury.The trial court in West Virginia denied the petitioner’s request for a new trial, finding insufficient evidence of juror impartiality and concluding that the statements related only to the jury’s deliberative process, not to any external influence. The Supreme Court of Appeals of West Virginia affirmed this decision, holding that the comments were intrinsic to the deliberations and thus not grounds to set aside the verdict. The petitioner then sought federal habeas relief under 28 U.S.C. § 2254 in the United States District Court for the Southern District of West Virginia, which denied his petition, concluding the state court had not unreasonably applied Supreme Court precedent.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s denial of habeas relief de novo but applied the deferential standard required by § 2254. The Fourth Circuit held that the state court did not unreasonably apply clearly established Supreme Court law in finding that the juror’s comments were intrinsic, not external, to the deliberation process. The court concluded that, under existing Supreme Court precedent, the statements did not rise to the level of external influence necessary to violate the petitioner’s Sixth Amendment rights. Accordingly, the Fourth Circuit affirmed the district court’s judgment denying habeas relief. View "Daugherty v. Dingus" on Justia Law