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

CSX argued that SCVA impermissibly discriminates against railroads in violation of the Railroad Revitalization and Regulatory Reform Act of 1976. The Fourth Circuit reversed the district court's determination that South Carolina had provided sufficient justification for the discriminatory tax. The court held that CSX has made a prima facie showing of discriminatory tax treatment based on the appropriate comparison class of other commercial and industrial real property taxpayers in South Carolina. Furthermore, the state's three justifications -- the equalization factor applied to railroad assessments, the combined effect of other tax exemptions applied to rail carriers, and assessable transfers of interest which trigger new appraisals -- were insufficient to justify the discriminatory tax scheme. View "CSX Transportation, Inc. v. South Carolina Department of Revenue" on Justia Law

Plaintiff filed suit pro se against Brivo, alleging discrimination based on race in violation of Title VII. In this case, within an hour of starting orientation at Brivo, Brivo's security architect approached plaintiff and confronted him about a newspaper article that he had found after running a Google search on plaintiff. The article reported plaintiff's tangential involvement in a shooting for which he faced no charges. Nonetheless, the security architect berated plaintiff about the incident, declared plaintiff unfit for employment at Brivo, and terminated him on the spot. The district court dismissed the case with prejudice, because plaintiff failed to plead sufficient facts to plausibly support a claim of discrimination.The Fourth Circuit held that it had appellate jurisdiction despite the district court's dismissal of the complaint without prejudice. Under Domino Sugar Corp. v. Sugar Workers Local Union 392, 10 F.3d 1064, 1067 (4th Cir. 1993), the order is appealable because the district court held that the circumstances surrounding plaintiff's termination did not expose Brivo to legal liability, and plaintiff has no additional facts that could be added to his complaint; under Chao v. Rivendell Woods, Inc., 415 F.3d 342, 345 (4th Cir. 2005), the order is appealable because the district court dismissed the complaint and directed that the case be closed; and the order is likewise appealable under Chao and In re GNC Corp., 789 F.3d at 511, because plaintiff has elected to stand on his complaint as filed.On the merits, the court held that the district court did not err by dismissing the Title VII claims at this point in the proceedings. The court held that plaintiff failed to plead sufficient facts to plausibly claim his termination or the Google search that lead to it was racially motivated. Accordingly, the court affirmed the judgment. View "Bing v. Brivo Systems, LLC" on Justia Law

The District of Columbia and the State of Maryland sued the President in his official capacity, alleging violations of the Constitution’s Foreign and Domestic Emoluments Clauses. The district court granted a motion to amend the complaint to add the President as a defendant in his individual capacity. The President, in that capacity, moved to dismiss the action, asserting absolute immunity. Approximately seven months passed without a ruling on that motion. The President in his individual capacity filed an interlocutory appeal. A Fourth Circuit panel concluded that the district court had effectively denied immunity to the President in his individual capacity so that the panel had jurisdiction to consider the interlocutory appeal. “[E]xercising that jurisdiction,” the panel held that Plaintiffs lacked Article III standing and remanded the case with instructions to dismiss.Acting en banc, the Fourth Circuit vacated the panel opinion and dismissed the interlocutory appeal. The district court neither expressly nor implicitly refused to rule on immunity but stated in writing that it intended to rule on the President’s individual capacity motion. A district court has wide discretion to prioritize its docket and the deferral did not result in a delay “beyond reasonable limits.” During the seven months, the district court managed the many other aspects of this litigation and issued opinions on the President’s motion to dismiss in his official capacity and a motion to certify an interlocutory appeal of the court’s rulings. View "District of Columbia v. Trump" on Justia Law

The District of Columbia and the State of Maryland sued the President in his official capacity, alleging violations of the U.S. Constitution’s Foreign and Domestic Emoluments Clauses. The district court dismissed claims concerning Trump Organization operations outside the District, for lack of standing, but denied the President’s motion with respect to alleged violations at the Washington, D.C. Trump International Hotel. After the denial of a motion for certification to take an interlocutory appeal (28 U.S.C. 1292(b)), the President petitioned for mandamus relief. A Fourth Circuit panel reversed and remanded with instructions to dismiss the complaint.The Fourth Circuit, en banc, vacated the panel opinion. The court accorded the President “great deference,” but stated that Congress and the Supreme Court have severely limited its ability to grant the extraordinary relief sought. The President has not established a right to a writ of mandamus. The district court promptly ruled on the request for certification in a detailed opinion that applied the correct legal standards. The court’s action was not arbitrary nor based on passion or prejudice; it “was in its nature a judicial act.” The President does not contend that the court denied certification for nonlegal reasons or in bad faith. Reasonable jurists can disagree in good faith on the merits of the claims. Rejecting a separation of powers argument, the court stated that the President has not explained how requests pertaining to spending at a private restaurant and hotel threaten any Executive Branch prerogative. Even if obeying the law were an official executive duty, such a duty would not be “discretionary,” but a “ministerial” act. View "In re: Donald Trump" on Justia Law

After AutoZone was found liable for creating a hostile work environment and for intentional infliction of emotional distress, plaintiff was awarded both compensatory and punitive damages. The Fourth Circuit reversed the award of punitive damages for plaintiff's claim under Title VII of the Civil Rights Act of 1964 and plaintiff's state law claims. In this case, the evidence does not permit a finding that the sales manager at issue served in a managerial capacity such that liability for punitive damages could be imputed to AutoZone. Furthermore, plaintiff failed to carry his burden of presenting sufficient evidence from which a reasonable jury could conclude that the store manager and district manager at issue engaged in an intentionally discriminatory practice with malice or reckless indifference.The panel remanded with instructions for the district court to determine the final amount of plaintiff's compensatory damages award under his Title VII claim. The court rejected AutoZone's duplicative recovery, jury instruction, and evidentiary error challenges, affirming as to these claims. View "Ward v. AutoZoners, LLC" on Justia Law

Plaintiff filed suit against defendants after he was terminated for submitting two blog posts about the then Captain of the Internal Affairs Unit of the Maryland Natural Resources Police (MNRP). Among other things, the blog posts contained screenshots from the Captain's private Facebook page that showed photos of the Captain posing with scantily-clad women and various comments that he had made about gun violence.The Fourth Circuit affirmed the dismissal of plaintiff's First Amendment retaliation claim, holding that plaintiff's posts concern nothing more than purely personal speech, as they are devoid of any content that rises to a level of public concern. The court also affirmed the district court's dismissal of plaintiff's claim that defendants violated plaintiff's right to carry a concealed firearm under the Law Enforcement Officer Safety Act, holding that the Act was not privately enforceable under 42 U.S.C. 1983. Finally, the court affirmed the dismissal of plaintiff's defamation per se claim, holding that the statement at issue was not actionable as defamation. View "Carey v. Throwe" on Justia Law

In this gerrymandering action, brought exclusively under the North Carolina Constitution against certain state legislators, the Fourth Circuit held that the district court did not err in remanding because the Legislative Defendants do not have an enforcement role within the meaning of the Refusal Clause of 28 U.S.C. 1443(2). Consequently, the court need not address whether the Legislative Defendants refused to act or whether they asserted a colorable conflict with federal law. The court also held that the district court did not abuse its discretion in declining to award fees and costs, because the legislators removed within the statutorily mandated time limit and adhered to the district court's expedited briefing schedule. Accordingly, the court affirmed the district court's judgment. View "Common Cause v. Lewis" on Justia Law

The Fourth Circuit affirmed the district court's denial of habeas relief to petitioner, who was sentenced to death for two murders. The court held that the postconviction court's conclusion that petitioner could not show prejudice, even if counsel performed deficiently by failing to object to prison conditions evidence, is not contrary to clearly established federal law or an unreasonable determination of the facts. The court also held that petitioner's claim that the Supreme Court of South Carolina violated his due process and equal protection rights in his post-conviction proceedings is not a cognizable claim, and petitioner cannot obtain relief; the Supreme Court of South Carolina's conclusion that it was not deficient performance to refrain from objecting to the state's closing arguments is not contrary to clearly established federal law or an unreasonable determination of facts; trial counsel did not perform deficiently by failing to request a mitigating circumstance unsupported by the record; the trial court's instructions correctly explained that the jury should consider both statutory and non-statutory mitigating circumstances; and the post-conviction court's conclusion that any deficiency regarding this mitigating charge did not prejudice petitioner survives review under 28 U.S.C. 2254. Finally, the court held that petitioner failed to demonstrate that post-conviction counsel were ineffective in failing to raise any substantial claims. View "Sigmon v. Stirling" on Justia Law

Cybernet filed suit against three state officials under 42 U.S.C. 1983 for directing or participating in the unlawful destruction of its property in violation of the Fourth Amendment. Cybernet's claims stemmed from the execution of search warrants at two video sweepstakes stores owned and operated by Cybernet.The Fourth Circuit affirmed the district court's judgment and held that, taken as a whole, the items seized were within the parameters of the search warrant and any incidental damage that took place is not indicative of the kind of gratuitous damage that would exceed Fourth Amendment bounds. Therefore, the court held that there was no Fourth Amendment violation. Cybernet's motion to compel discovery failed for the same reason. View "Cybernet, LLC v. David" on Justia Law

Plaintiff filed suit against defendants under 42 U.S.C. 1983, alleging claims related to the demotion he suffered in 2012. Plaintiff alleged that defendants racially discriminated against him and seeks reinstatement of his prior position, the removal of negative materials from his personnel file, and reimbursement for his legal expenses. The district court granted summary judgment for defendants.The Fourth Circuit denied defendants' motion to dismiss plaintiff's appeal as moot based on plaintiff's retirement, because plaintiff has sworn that he would promptly return to work if reinstated to his prior position. The court affirmed the district court's grant of summary judgment to the Department, because its removal of this case did not constitute a waiver of sovereign immunity. Finally, the court vacated the district court's award of summary judgment to Defendant Hooks and remanded for further proceedings. In this case, plaintiff is seeking prospective, not retrospective, relief and thus his claim against Hooks falls under the sovereign-immunity exception articulated in Ex Parte Young, 209 U.S. 123 (1908). View "Biggs v. North Carolina Department of Public Safety" on Justia Law