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

Terrence Hammock, a detainee at the Baltimore County Detention Center (BCDC), filed a lawsuit alleging severe violations of his constitutional rights. He claimed that BCDC served him rotten and unsafe food, causing him to get sick multiple times and lose weight. Additionally, Hammock, a practicing Muslim, alleged that he was denied the ability to attend Jum’ah services, a central practice of Islam, throughout his detention from September 2019 to at least March 2022.The United States District Court for the District of Maryland dismissed Hammock’s claims. The court found that his allegations regarding the food did not meet the standard of a “serious deprivation of a basic human need” under the Eighth and Fourteenth Amendments. It also held that the denial of Jum’ah services was justified by legitimate penological interests, particularly during the COVID-19 pandemic. The court denied Hammock’s motion for appointed counsel, stating that the case had not yet proceeded to discovery or trial.The United States Court of Appeals for the Fourth Circuit reviewed the case and found that the district court erred in dismissing Hammock’s claims. The appellate court held that Hammock sufficiently pleaded a claim of deliberate indifference based on the conditions of confinement, specifically the provision of rotten and mice-bitten food. The court also found that Hammock adequately pleaded a First Amendment claim, as the defendants did not present a penological interest to justify the denial of Jum’ah services for the entire period in question. The Fourth Circuit reversed the district court’s dismissal of Hammock’s claims and remanded the case for further proceedings, including the appointment of counsel for Hammock. View "Hammock v. Watts" on Justia Law

A Virginia statute established procedures for internet broadband service providers to access railroad property and lay cable across tracks. The Association of American Railroads (AAR) challenged the statute, arguing it was preempted by federal law and violated the Takings Clause of the U.S. Constitution. The district court dismissed the case, ruling that AAR lacked standing to bring the claims because they required the participation of individual member railroads.The United States District Court for the Eastern District of Virginia held that AAR lacked associational standing for both its preemption and Takings Clause claims. The court found that the preemption claim required a fact-intensive inquiry into whether the statute unreasonably burdened rail transportation, necessitating individual member participation. Similarly, the Takings Clause claim required individualized proof of inadequate compensation for each crossing, which also required member participation.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that AAR had standing to pursue its preemption claims, as these could be litigated without the participation of individual members. The court reasoned that the preemption claims involved general judgments about the statute's nature and operation, not specific operations of individual railroads. However, the court affirmed the district court's ruling on the Takings Clause claim, agreeing that it required individualized proof of compensation for each crossing, necessitating member participation.The Fourth Circuit thus affirmed the district court's judgment in part, reversed it in part, and remanded the case for further proceedings consistent with its opinion. View "Association of American Railroads v. Hudson" on Justia Law

GenBioPro, Inc., a manufacturer of generic mifepristone, filed a complaint against West Virginia officials, arguing that the state's law prohibiting most abortions was preempted by federal law. The company claimed that the FDA Amendments Act of 2007 (FDAAA), which regulates the distribution of high-risk drugs like mifepristone, preempted the state law. GenBioPro contended that the FDAAA established a comprehensive scheme for regulating REMS drugs with safe-use elements, leaving no room for state regulation.The U.S. District Court for the Southern District of West Virginia dismissed GenBioPro's complaint, finding no preemption. The court held that abortion regulation is a matter of health and safety traditionally occupied by the states. It determined that Congress had not expressed an intent to occupy the field of drugs subject to a REMS in a manner that would preempt West Virginia's abortion restrictions. The court also found that the FDAAA's requirement to consider patient access was a limitation on the FDA's own restrictions, not a command to ensure access for all patients.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The Fourth Circuit held that the FDAAA did not preempt West Virginia's abortion law. The court emphasized the presumption against preemption in areas of traditional state regulation, such as health and safety. It found that the FDAAA did not demonstrate a clear intention to displace the state's historic and sovereign right to regulate abortion. The court concluded that the FDAAA's focus on drug safety did not create a right to access specific high-risk drugs, and the statute did not preempt state laws regulating the incidence of abortion. View "GenBioPro, Inc. v. Raynes" on Justia Law

Brian and Susan Fernaays own a house on lot 31 in Brewers Creek Subdivision, Isle of Wight County, Virginia. A 20-foot drainage easement, shared with lot 32, contains an underground stormwater drainage pipe that has deteriorated over time, causing significant erosion. The Fernaayses estimate the repair cost at $150,000 and sued Isle of Wight County, claiming the County owns the easement and is responsible for maintaining the pipe. They argued that the County's failure to maintain the pipe resulted in an unconstitutional taking of their property under both the Virginia and U.S. Constitutions.The United States District Court for the Eastern District of Virginia reviewed the subdivision plat and the Declaration of Covenants and Restrictions. The court found that the easement was not dedicated to the County, meaning the County had no duty to maintain the drainage pipe. Consequently, the court granted summary judgment in favor of the County.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The appellate court concluded that the Brewers Creek Partnership did not unequivocally dedicate the drainage easement to the County. The court noted that the plat and the Declaration of Covenants and Restrictions did not manifest an intent to dedicate the easement or the pipe to the County. The language in the documents suggested that the easements were for the benefit of the lot owners and that the County was only permitted to use them, not obligated to maintain them. Therefore, the County was not responsible for the damage, and the Fernaayses, as property owners, would have to bear the maintenance costs. The judgment of the district court was affirmed. View "Fernaays v. Isle of Wight County" on Justia Law

Plaintiffs-Appellants Thomas Sheppheard, Tyler Randall, and Adam Perry, on behalf of minor child J.P., filed a class action lawsuit against the Governor of West Virginia and the Acting Cabinet Secretary of the West Virginia Department of Homeland Security. They sought relief under the Eighth and Fourteenth Amendments, alleging unconstitutional conditions of overcrowding, understaffing, and deferred maintenance in West Virginia's prisons, jails, and juvenile centers. They claimed these conditions amounted to deliberate indifference to their health and safety.The United States District Court for the Southern District of West Virginia dismissed the case for lack of standing. The court found that the plaintiffs failed to establish that their injuries were traceable to the actions of the Governor or the Secretary, or that their injuries would be redressed by a favorable decision. The court noted that the issues were largely due to funding decisions by the West Virginia legislature, which was not a party to the suit. The court also highlighted that the Commissioner of the West Virginia Division of Corrections and Rehabilitation, not the Governor or the Secretary, had the authority to address the conditions in the facilities.The United States Court of Appeals for the Fourth Circuit affirmed the district court's dismissal. The appellate court agreed that the plaintiffs lacked standing because they could not show that their injuries were caused by the Governor's or the Secretary's actions. The court also found that the requested relief, such as appropriations and policy changes, could not be granted by the court as it lacked the power to compel the Governor or the Secretary to take such actions. The court emphasized that the plaintiffs' injuries were not redressable through the requested judicial intervention. View "Sheppheard v. Morrisey" on Justia Law

Stephen Simmons pled guilty to violating the National Firearms Act by possessing an unregistered auto sear, a device that converts semi-automatic firearms to fire like machineguns. On the day of his offense, Simmons tested positive for methamphetamine and marijuana. Although he was not prosecuted for any drug-related crime, the district court applied multiple sentencing enhancements, penalizing him for possessing the unregistered auto sear, additional auto sears, silencers, and firearms as an unlawful user of controlled substances. Simmons argued that these enhancements violated his Second Amendment rights and that the term "unlawful user of any controlled substance" was unconstitutionally vague.The United States District Court for the Southern District of West Virginia applied sentencing enhancements that increased Simmons's offense level due to his status as an unlawful user of controlled substances and his possession of multiple and stolen firearms. The court calculated his total offense level as 25, resulting in an advisory Sentencing Guidelines range of 57 to 71 months' imprisonment. After applying a downward variance, the district court sentenced Simmons to 36 months in prison.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court rejected Simmons's Second Amendment challenge, noting that he conceded he had no constitutional right to possess auto sears or silencers, which are not protected by the Second Amendment. The court also dismissed his vagueness claim, as Simmons's conduct clearly fell within the definition of an "unlawful user" of controlled substances. However, the court found that the district court erred in applying sentencing enhancements for possessing ordinary firearms not covered by the National Firearms Act, as these firearms were not relevant to the offense for which Simmons was convicted. Consequently, the Fourth Circuit vacated Simmons's sentence and remanded the case for resentencing. View "US v. Simmons" on Justia Law

Four individuals aged 18 to 20 sought to purchase handguns but were prohibited by 18 U.S.C. § 922(b)(1), which restricts the commercial sale of handguns to those under 21. They filed a lawsuit against the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), claiming that the statute violated their Second Amendment rights.The United States District Court for the Eastern District of Virginia granted summary judgment in favor of the plaintiffs. The court applied the text, history, and tradition test from New York State Rifle & Pistol Ass’n v. Bruen, determining that the Second Amendment protections apply to 18- to 20-year-olds and that the right to purchase a gun falls within the Amendment’s plain text. The court found that the government failed to demonstrate a historical tradition of firearm regulation supporting the constitutionality of § 922(b)(1).The United States Court of Appeals for the Fourth Circuit reviewed the case and reversed the district court’s decision. The appellate court held that § 922(b)(1) does not violate the Second Amendment. The court reasoned that historical traditions, including the common law infancy doctrine, supported restrictions on the sale of firearms to individuals under 21. The court found that both the infancy doctrine and § 922(b)(1) imposed similar burdens on minors' ability to purchase firearms and were motivated by concerns about the judgment and maturity of individuals under 21. The court concluded that § 922(b)(1) is consistent with the nation's historical tradition of firearm regulation and is therefore constitutional. The case was remanded with instructions to dismiss it. View "McCoy v. Bureau of Alcohol, Tobacco, Firearms and Explosives" on Justia Law

Martin Misjuns, a Fire Captain and paramedic with the Lynchburg Fire Department, was terminated after posting offensive social media content targeting transgender individuals. Misjuns alleged that his termination was due to his political and religious views, which he expressed on his Facebook pages. He claimed that the City of Lynchburg and its officials conspired to violate his constitutional rights, leading to his firing.The United States District Court for the Western District of Virginia dismissed all of Misjuns' claims. The court found that the claims against the individual defendants in their official capacities were duplicative and dismissed them. The court also dismissed Misjuns' breach of contract, equal protection, conspiracy, and wrongful termination claims. The court partially dismissed his First Amendment claims but later dismissed them entirely.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court's dismissal of Misjuns' claims. The court held that Misjuns failed to establish Monell liability against the City of Lynchburg, as he did not adequately plead that a policy or custom caused the alleged constitutional violations. The court also found that the City's Employment Policies & Procedures handbook did not constitute a binding contract, thus dismissing the breach of contract claim. Additionally, the court upheld the dismissal of the conspiracy and wrongful termination claims against the individual defendants, as those claims were not asserted against the City and had been dismissed by agreement.The Fourth Circuit concluded that Misjuns did not sufficiently plead facts to state a claim for relief on any of his six claims, affirming the district court's decision. View "Misjuns v. City of Lynchburg" on Justia Law

T.M. has a medical condition that causes psychosis when she ingests gluten. After an episode in 2023, she was involuntarily committed to Baltimore Washington Medical Center. Despite her and her father's request for voluntary admission, an administrative hearing led to her involuntary commitment. A clinical review panel approved forcibly injecting T.M. with antipsychotic medication, a decision affirmed by a Maryland administrative law judge. T.M. and the medical center later reached an oral agreement for her release, which was formalized in a consent order by a state court. The consent order required T.M. to follow certain conditions, including taking prescribed medications and dismissing other lawsuits.The United States District Court for the District of Maryland dismissed T.M.'s claims, citing the Rooker-Feldman doctrine, which prevents federal courts from reviewing state court judgments. The court found it lacked subject matter jurisdiction over T.M.'s claims and dismissed the parents' claims for failure to state a claim. T.M.'s claims were dismissed with prejudice, while the parents' claims were dismissed without prejudice.The United States Court of Appeals for the Fourth Circuit affirmed the district court's dismissal of T.M.'s claims for lack of subject matter jurisdiction under the Rooker-Feldman doctrine. The court held that T.M. was a state court loser seeking to overturn a state court judgment, which is barred by the doctrine. The court vacated the dismissal with prejudice and remanded with instructions to modify the judgment to dismiss T.M.'s claims without prejudice. The court also affirmed the dismissal of the parents' claims for failure to state a claim, noting that the complaint did not allege a violation of their First Amendment rights. View "T.M. v. University of Maryland Medical System Corporation" on Justia Law

In October 2022, NCIS investigators obtained a military warrant to seize but not search Joshua Lee Ray's cell phone. Despite this, they searched the phone and found evidence of child sexual abuse material. Ray moved to suppress the evidence, arguing the search violated the Fourth Amendment as the warrant did not authorize it. The district court granted the motion.The Government appealed, conceding the warrant did not authorize the search, there was no verbal authorization, and the warrant did not incorporate an affidavit requesting authorization. The Government argued the search was justified under the good faith exception.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the Government could not rely on the good faith exception because the warrant was not deficient; it simply did not authorize the search. The court emphasized that the NCIS exceeded the scope of the valid warrant, and the good faith exception did not apply to such conduct. The court affirmed the district court's decision to suppress the evidence. View "US v. Ray" on Justia Law