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

Plaintiffs filed suit challenging a state law redrawing the Wake County Board of Education electoral districts, arguing that under the new redistricting plan, some citizen’s votes will get significantly more weight than other’s in violation of the Fourteenth Amendment’s guarantees of one person, one vote and the North Carolina Constitution’s promise of equal protection. The district court granted defendants’ motions to dismiss and denied plaintiffs’ motion to amend as futile. The court concluded that plaintiffs’ allegations in support of their claim that the law violates the one person, one vote principle suffice to survive a motion to dismiss for failure to state a claim. Thus, plaintiffs have stated a claim upon which relief could be granted against the Wake County Board of Elections and the district court therefore erred in dismissing their suit. The court affirmed, however, the denial of the motion to amend because the state officials plaintiffs proposed to add as named defendants are not amenable to suit. View "Wright v. North Carolina" on Justia Law

Plaintiff appealed the district court's summary dismissal of his 42 U.S.C. 1983 claim against defendant on the ground that plaintiff failed to exhaust his administrative remedies pursuant to the Prison Litigation Reform Act (PLRA), 42 U.S.C. 1997e(a). Plaintiff's suit arose from allegations that prison officers used excessive force while transferring him to a different cell. The court reversed and remanded, holding that plaintiff reasonably believed that he had sufficiently exhausted his remedies by complying with an internal investigation. View "Blake v. Ross" on Justia Law

Plaintiff filed suit against the University under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., for discriminatory termination based on gender, retaliatory termination, and the creation of a hostile work environment. At issue was the effect of the Supreme Court’s decision in University of Texas Southwestern Medical Center v.Nassar on what Title VII retaliation plaintiffs must show to survive a motion for summary judgment. The court concluded that the McDonnell Douglas framework, which already incorporates a but for causation analysis, provides the appropriate standard for reviewing plaintiff’s claim. Applying this framework, the court found that summary judgment in favor of the University is not warranted on plaintiff's retaliation claim where a reasonable jury could conclude from plaintiff's evidence that the University's proffered justifications were not its real reasons for firing her and that the University's actual reason for firing her was to retaliate against her complaining about sexual harassment and for her subsequent complaints of ongoing retaliation. Therefore, the court reversed the district court's grant of summary judgment as to plaintiff's retaliation claim. The court affirmed the district court's grant of summary judgment on plaintiff's gender-based discrimination claim and hostile work environment claim. View "Foster v. Univ. of Maryland Eastern" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1982, alleging that correctional officers used excessive force when they forcibly extracted him from his prison cell. The officers appealed the district court's denial of their motion for summary judgment on the basis of qualified immunity. The parties agree that the law clearly established at the time of the extraction governs the entitlement to qualified immunity here. In Norman v. Taylor, the court held that absent the most extraordinary circumstances, a plaintiff cannot prevail on an Eighth Amendment excessive force claim if his injury is de minimis. Applying Norman, the court concluded that many of plaintiff's injuries could have an enduring impact on health and well-being and were not de minimis. Accordingly, the court affirmed the judgment of the district court. View "Ussery v. Mansfield" on Justia Law

After Radiance published an article online entitled “NAACP: National Association for the Abortion of Colored People” that criticized the NAACP’s stance on abortion, the NAACP sent Radiance a cease-and-desist letter. Radiance sought a declaratory judgment that it had not infringed any NAACP trademarks and the NAACP filed counterclaims alleging trademark infringement and dilution. The court concluded that the NAACP does not have actionable claims for trademark infringement in this case; Radiance's use of the NAACP's marks or colorable imitation falls squarely within the exceptions to trademark dilution specifically included in the Lanham Act, 15 U.S.C. 1051 et seq., to avoid encroaching on free speech rights; and therefore, the court reversed the district court's injunction and remanded with directions that defendant's counterclaims be dismissed. View "The Radiance Foundation, Inc. v. NAACP" on Justia Law

Concerned by Plaintiff’s “increasingly threatening” Facebook posts, two Marine veterans who had served with Plaintiff contacted the FBI. After interviewing Plaintiff, two FBI agents consulted with Michael Campbell, a local mental health evaluator, as to whether they should detain Plaintiff for a mental health evaluation. Campbell recommended that Plaintiff be detained. After interviewing Plaintiff, Campbell petitioned for and received a temporary detention order from a magistrate judge. Plaintiff was taken to a hospital, where he was involuntarily admitted for treatment for seven days. Following his release, Plaintiff filed suit under 42 U.S.C. 1983, seeking damages and injunctive relief against Campbell for violating his Fourth Amendment and First Amendment rights. The district court granted summary judgment to Campbell on the basis of qualified immunity. The Fourth Circuit affirmed, holding (1) Campbell did not violate Plaintiff’s Fourth Amendment rights based on existing precedent; (2) Plaintiff did not make out a First Amendment violation; and (3) injunctive relief was not appropriate on this record. View "Raub v. Campbell" on Justia Law

Defendant was charged with possession with intent to distribute one kilogram or more of heroin. If convicted, Defendant faced a mandatory minimum penalty of twenty years’ imprisonment. For several months, Defendant refused to plead guilty. The morning of his scheduled trial, however, Defendant accepted the government’s plea offer. Defendant subsequently filed a pro se motion to withdraw his guilty plea on the basis of ineffective assistance of counsel, arguing that his plea had been involuntary because he had been pressured to plead guilty by the district court. The Fourth Circuit vacated and remanded for further proceedings, holding that the district court committed plain error by impermissibly participating in the plea discussions. Remanded. View "United States v. Braxton" on Justia Law

After a jury-waived trial, a Virginia state judge convicted Petitioner on charges of brand larceny and breaking and entering. The state appellate courts denied Petitioner’s direct appeal, and the state supreme court denied Petitioner’s habeas petition. Petitioner subsequently filed this federal habeas petition. The district court granted habeas relief on one claim, concluding that the state supreme court unreasonably applied Strickland v. Washington in rejecting Petitioner’s ineffective assistance of counsel claim. As a resulting, the court vacated Petitioner’s convictions and sentence. The Fourth Circuit vacated the portion of the district court’s order granting habeas relief and remanded for dismissal of the petition, holding that the Virginia Supreme Court did not unreasonably conclude that Petitioner failed to establish Strickland prejudice. View "Jones v. Clarke" on Justia Law

After a jury trial, Appellants, Abukar Osman Beyle and Shani Nurani Shiekh Abrar, were convicted on twenty-six criminal counts arising from the armed abduction and murder of four U.S. citizens off the coast of Somalia. The Fourth Circuit affirmed, holding (1) the district court had jurisdiction over the charges of murder and concomitant use of a firearm because the site of the murders, thirty to forty nautical miles from the Somali coast, lay on the “high seas,” and thus, Appellants were within the reach of the U.S. criminal statutes under which they were convicted; and (2) Abrar was not denied his Fifth Amendment right to due process or his Sixth Amendment right to present witnesses material to his duress defense, and therefore, the district court did not err in denying Abrar’s motion to dismiss the indictment. View "United States v. Beyle" on Justia Law

After a jury trial, Defendant was convicted of three counts relating to marijuana trafficking and was sentenced to 121 months of incarceration. Defendant filed a motion to vacate his conviction and sentence, alleging that his trial and appellate counsel had provided ineffective assistance. The district court denied the motion. The Fourth Circuit affirmed, holding (1) Defendant was not prejudiced by his trial counsel’s failure to request an instruction that the jury find a drug weight based on the amount attributable to or reasonably foreseeable by Defendant; (2) Defendant was not prejudiced by his appellate counsel’s failure to raise the failure to request that instruction as an issue on direct appeal; and (3) Defendant’s trial counsel was not ineffective for failing to challenge the drug weight and advisory guidelines range at sentencing. View "United States v. Rangel" on Justia Law