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

Articles Posted in Constitutional Law
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Plaintiff filed suit under 42 U.S.C. 1983 against defendant, alleging unlawful entry and use of excessive force in violation of the Fourth Amendment. In this case, police officers used a battering ram to enter plaintiff's dwelling to execute a warrant. The officers did not announce their presence before using the battering ram, and plaintiff responded by pulling out a gun. Although plaintiff never discharged the gun, 29 shots were fired at him and he was struck nine times. The Fourth Circuit affirmed the district court's denial of qualified immunity with respect to the excessive force claim, holding that disputes of material fact preclude an award of summary judgment. The court held that a reasonable jury could find under the facts presented that plaintiff did not pose a threat to the officers justifying the use of deadly force. Furthermore, in light of Cooper v. Sheehan, 735 F.3d 153 (4th Cir. 2013), the court held that plaintiff's Fourth Amendment right to be free from the use of excessive force was clearly established at the time the incident occurred. View "Betton v. Belue" on Justia Law

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Plaintiff filed suit challenging South Carolina's decision to terminate PPSAT's provider agreement because it offers abortion services. At issue was whether, and on what basis, the Medicaid Act's free-choice-of-provider provision affords a private right of action to challenge a state’s exclusion of a healthcare provider from its Medicaid roster. The Fourth Circuit affirmed the district court's grant of a preliminary injunction in favor of plaintiff and held that Congress's intent to create an individual right enforceable under 42 U.S.C. 1983 in the free-choice-provider provision is unambiguous. The court also held that a plain-language reading of the provision's mandate—that states "must" furnish Medicaid recipients the right to choose among providers "qualified to perform the service or services required"—bars states from excluding providers for reasons unrelated to professional competency. Because the individual plaintiff in this case has a private right of action to challenge South Carolina's denial of her right to the qualified and willing family-planning provider of her choice, the court agreed with the district court that she has demonstrated a substantial likelihood of success on her free-choice-of-provider claim. Furthermore, the district court did not abuse its discretion in enjoining South Carolina from terminating PPSAT's provider agreement; it was clear that plaintiff would suffer irreparable harm in the absence of a preliminary injunction; and the remaining preliminary injunction factors were satisfied. View "Planned Parenthood South Atlantic v. Baker" on Justia Law

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The Fourth Circuit reversed the district court's denial of habeas relief, holding that a juror's external communication with her pastor regarding the death penalty was not harmless. Given how Federal Rule of Evidence 606 limits the presentation of evidence in these circumstances, the court held that it was especially important for it to view the record practically and holistically when considering the effect that a juror's misconduct reasonably may be taken to have had upon the jury's decision. In this case, the juror shared the pastor's counsel with the other jurors in an apparent effort to convince someone it was okay to vote for the death penalty. The court remanded for further proceedings. View "Barnes v. Thomas" on Justia Law

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Plaintiff, a Virginia inmate, filed a 42 U.S.C. 1983 action against two Virginia Department of Corrections (VDOC) officials, alleging that defendants violated his Eighth Amendment rights by denying him treatment for his Hepatitis C virus (HCV). The Fourth Circuit vacated the district court's grant of summary judgment for defendants, holding that genuine disputes of material fact exist as to plaintiff's deliberate indifference claim against Defendant Schilling, the Health Services Director. In this case, there was sufficient evidence to establish a genuine issue of material fact as to Schilling's personal involvement in the denial of treatment for plaintiff's HCV. The court also held that genuine disputes of material fact exist as to plaintiff's deliberate indifference claim to Defendant Amonette, the Chief Physician, because a factfinder could determine that Amonette knew that HCV is a serious disease that affects a large percentage of those incarcerated in VDOC facilities. Furthermore, plaintiff presented evidence that Amonette knew that a lack of treatment for someone diagnosed with HCV, like plaintiff, creates a substantial risk of harm to that person. The court rejected defendants' alternative argument, which was based on a misreading of the opinion, and remanded for further proceedings. View "Gordon v. Schilling" on Justia Law

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Plaintiffs filed suit seeking to hold the United States liable for negligently performing a background check on Dylann Roof, the person who entered a church in Charleston, South Carolina and opened fire, killing nine worshippers. No one disputes that if the background check had been performed properly, it would have prevented Roof from purchasing the firearm he used. The district court dismissed plaintiffs' claims for lack of subject matter jurisdiction. The Fourth Circuit reversed and held that neither the discretionary function exception of the Federal Tort Claims Act nor the Brady Act's immunity provision in 18 U.S.C. 922(t)(6) affords the Government immunity in this case. In regard to the FTCA, the court held that this case turns on the NICS Examiner's alleged negligence in failing to follow a clear directive and the government could not claim immunity under these circumstances. The court held that the district court did not err by concluding that the government could not be held liable under the FTCA for declining to give Examiners access to the N-DEx, and the court rejected plaintiffs' claim that the government contravened a mandatory directive by failing to maintain data integrity during the NICS background check. In regard to the Brady Act, the court held that the district court erred in construing 18 U.S.C. 992(t)(6) to bar plaintiffs' claims where plaintiffs sued the government rather than any federal employee, and the federal employees whose conduct forms the basis of this suit were not responsible for providing information to the NICS system. View "Sanders v. United States" on Justia Law

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The Fourth Circuit affirmed the district court's grant of summary judgment for IPC in plaintiff's action under Title VII of the Civil Rights Act of 1965, alleging race-based discrimination claims. In regard to the disparate treatment claim, the court held that plaintiff's claims of disparate treatment for being denied positions, overtime, additional educational benefits and training were time-barred. As for plaintiff's timely claim that he was denied annual reviews, the court held that plaintiff offered no evidence demonstrating IPC's failure to give him annual reviews affected the terms, benefits and conditions of his employment. Furthermore, even if hostile treatment could qualify as an adverse employment action, plaintiff's claim that the hostile treatment he received at IPC constitutes an adverse employment action would fail as a matter of law. In regard to the race-based hostile work environment claim, the court held that the totality of the circumstances did not sufficiently demonstrate a severe or pervasive hostile work environment. Finally, plaintiff failed to create a genuine issue of material fact as to his constructive discharge claim. View "Perkins v. International Paper Co." on Justia Law

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The Fourth Circuit affirmed the district court's grant of summary judgment for IPC in an action brought by plaintiff under Title VII of the Civil Rights Act of 1965 and the Equal Pay Act of 1963 (EPA), alleging gender and race discrimination. In regard to plaintiff's hostile work environment constructive discharge claims, without commenting on the district court's decision concerning the severe or pervasive requirement, the court held on an alternative ground that plaintiff failed to present sufficient evidence creating a genuine issue of material fact that her working conditions were so intolerable that a reasonable employee would be compelled to resign. The court also held that plaintiff failed to present evidence that created a genuine issue of material fact regarding her retaliation claim. Finally, the court held that plaintiff failed to offer evidence that created a genuine issue of material fact concerning her alleged EPA violation. View "Evans v. International Paper Co." on Justia Law

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Under the Supreme Court's decision in Wolff v. McDonnell, 418 U.S. 539 (1974), inmates at risk of being deprived of a liberty interest, like good time credits, have a qualified right to obtain and present video surveillance evidence. The Fourth Circuit vacated the district court's judgment in this case because the district court failed to make several factual critical determinations bearing on whether petitioner's disciplinary proceeding failed to comply with that right. Accordingly, the panel remanded for further proceedings. View "Lennear v. Wilson" on Justia Law

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Plaintiff, a former special agent with the Virginia State Police, filed suit under the Americans with Disabilities Act (ADA) and Title VII of the Civil Rights Act against the Commonwealth, seeking relief that includes compensatory damages, reinstatement, and back pay. The Fourth Circuit affirmed the district court's dismissal of the ADA claim, because the Commonwealth has not waived its sovereign immunity from that claim. However, the court reversed the district court's decision that claim preclusion barred the Title VII claims, because the initial forum did not have the power to award the full measure of relief sought in this litigation. Accordingly, the court remanded for further proceedings. View "Passaro v. Commonwealth of Virginia" on Justia Law

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After entering a settlement that released certain tort claims, plaintiff filed for Chapter 7 bankruptcy. When her debts were discharged and the bankruptcy proceedings closed, she filed suit seeking to rescind her settlement agreement as fraudulently induced and to pursue a tort action. The district court entered judgment in favor of defendants. The Fourth Circuit held that the district court's standing determination conflates Article III requirements with the distinct real-party-in-interest analysis. Rather, plaintiff has both Article III standing and the legal entitlement to pursue tort claims on her own behalf. In regard to judicial estoppel, the court also held that the district court relied on an improper presumption of bad faith, and therefore reached its conclusion without fully engaging in the necessary inquiry. Therefore, the court remanded to the district court for it to evaluate the appropriateness of judicial estoppel in light of all facts and circumstances without recourse to a presumption of bad faith. View "Martineau v. Wier" on Justia Law