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

The Professional Massage Training Center (PMTC) filed suit against the Accreditation Alliance of Career Schools and Colleges (ACCSC) after ACCSC denied PMTC’s application for re-accreditation. The district court entered judgment in favor of PMTC, finding that ACCSC had violated the school’s due process rights. The court awarded the school more than $400,000 in damages and ordered ACCSC to fully reinstate its accreditation. The Supreme Court reversed in part and affirmed in part, holding (1) the district court erred in conducting a de novo approach to the accreditation process; (2) judged by the correct standard of review, the accreditation decision was well supported and not arbitrary or capricious; and (3) the district court correctly dismissed PMTC’s state law claims for breach of contract, negligence, and tortious interference. Remanded. View "Prof’l Massage Training v. Accreditation Alliance of Career Schs." on Justia Law

After a jury trial, Appellant was convicted of first degree murder. The conviction was upheld on direct appeal. After unsuccessfully seeking habeas corpus relief in state court, Appellant filed a federal habeas petition alleging that he received ineffective assistance of counsel due to his trial counsel’s failure to request a jury instruction defining heat of passion. The district court denied the petition. The Fourth Circuit reversed, holding (1) the state habeas court’s denial of Appellant’s ineffective assistance claim was based on an unreasonable application of clearly established federal law set forth in Strickland v. Washington; and (2) Appellant’s counsel erred in failing to request the heat of passion jury instruction, and Appellant suffered prejudice as a result of this error. Remanded. View "Lee v. Clarke" on Justia Law

Plaintiff filed suit against Officer R.R. Ray, alleging a violation of 42 U.S.C. 1983 claim for excessive force and a state-law claim for assault and battery. Ray filed a motion for summary judgment on the basis of qualified immunity. The district court denied the motion, concluding that a reasonable jury could find that Ray employed excessive force in detaining Plaintiff. Plaintiff appealed, arguing that the district court erred in denying his motion for summary judgment concerning the excessive-force claim. The Fourth Circuit affirmed, holding that the district court properly denied Ray’s summary judgment motion because Ray was not entitled to qualified immunity at this stage in the litigation. View "Smith v. Ray" on Justia Law

Plaintiff, who was African American and female, applied for two open positions with the Maryland Department of Transportation’s State Highway Administration (Highway Administration). Plaintiff was not selected for either position. Plaintiff filed this lawsuit, alleging that the Highway Administration refused to her hire her because of her race and her sex in violation of Title VII of the Civil Rights Act. The district court dismissed the complaint for failure to state a claim, concluding that Plaintiff failed to plead adequate facts to give rise to a reasonable inference of discrimination. The Fourth Circuit affirmed, holding (1) the district court improperly applied the evidentiary standard set forth in McDonnell Douglas Corp. v. Green in analyzing the sufficiency of Plaintiff’s complaint; but (2) the court nevertheless reached the correct conclusion because Plaintiff failed to include adequate factual allegations to support a claim that the Highway Administration discriminated against her because she was African American or female. View "McCleary-Evans v. Md. Dep’t of Transp." on Justia Law

Plaintiff, a former inmate in the Virginia Department of Corrections facilities, filed numerous complaints about repeated physical and sexual abuse he suffered while imprisoned in the facilities. Plaintiff brought suit against various prison officials alleging violations of his right under the Eighth Amendment to be free from cruel and unusual punishment. The magistrate judge found that Defendants should have been more diligent in handling Plaintiff’s complaints but recommended that because Defendants did not actually know of the substantial risk of harm Plaintiff faced, his claims failed. The district court adopted in its entirety the findings and recommendation of the magistrate judge. The Fourth Circuit vacated the dismissal of Plaintiff’s claims against certain defendants, holding that the magistrate judge and district court failed to appreciate that the subjective “actual knowledge” standard required to find prison officials deliberately indifferent to a substantial risk of serious injury may be proven by circumstantial evidence that a risk was so obvious that it had to have been known. Remanded. View "Makdessi v. Fields" on Justia Law

After a jury trial, Appellants, four individuals, were convicted of multiple offenses arising from a string of robberies they committed in December 2012. The Fourth Circuit affirmed the convictions, holding (1) the trial judge did not abuse his discretion or violate the Federal Rules of Evidence by admitting certain evidence; (2) assuming the admission of evidence recovered from one appellant’s cell phone violated the Sixth Amendment where not everyone in the phone’s chain of custody testified at trial, the error was harmless beyond a reasonable doubt; and (3) there was sufficient evidence to convict Appellants on every charged offense. View "United States v. Reed" on Justia Law

A written state policy mandates that all persons sentenced to death in Virginia be confined on “death row” while awaiting execution. Inmates on death row live in separate single cells, with minimal visitation and recreational opportunities. After incarceration on Virginia’s death row for almost six years, Plaintiff brought this 42 U.S.C. 1983 action alleging that his confinement on death row violated his procedural Due Process rights and seeking injunctive relief. The district court granted summary judgment for Plaintiff and issued an injunction ordering Virginia prison officials to either alter the policy or to improve the conditions. The Fourth Circuit reversed, holding (1) contrary to Plaintiff’s contention, harsh and atypical confinement conditions in and of themselves do not give rise to a liberty interest in their avoidance; and (2) Plaintiff failed to point to a Virginia law or policy providing him with an expectation of avoiding the conditions of his confinement and failed to establish that those conditions imposed an atypical and significant hardship in relation to the ordinary incidents of prison life. View "Prieto v. Clarke" on Justia Law

In 1998, Appellant was convicted of capital murder and sentenced to death. In 2005, the U.S. Supreme Court remanded Appellant’s case in light of its decision in Roper v. Simmons, which stated that the death penalty may not be imposed on juvenile offenders under the age of eighteen. The Virginia Supreme Court subsequently commuted Appellant’s sentence to life without the possibility of parole. In 2012, the Supreme Court decided Miller v. Alabama, which held that a mandatory life without the possibility of parole sentence imposed on a homicide offender who was a juvenile at the time of the offense violates the Eighth Amendment. One year later, Appellant sought collateral review of his sentence by filing a petition under 28 U.S.C. 2254, arguing that his sentence violates the Eighth Amendment because Miller applies retroactively on collateral review. The district court dismissed Appellant’s petition as untimely. The Supreme Court affirmed, holding that the Miller rule is not retroactively applicable to cases on collateral review. View "Johnson v. Ponton" on Justia Law

In 2009, Appellant pleaded no contest in a state court to carnal knowledge and soliciting the production of child pornography. Appellant later filed an amended pro se habeas corpus petition alleging ineffective assistance of counsel. The state court dismissed Appellant’s petition without an evidentiary hearing, concluding that Appellant had not shown deficient performance. After the state Supreme Court denied Appellant’s petition for appeal, Appellant filed a pro se habeas corpus petition in the federal district court. The court dismissed the petition based on the state court’s reasoning. The Fourth Circuit remanded, holding (1) the district court owed no deference to the state court’s ruling and should have reviewed the state court’s decision de novo; and (2) the district court mistakenly concluded that it had no discretion to grant an evidentiary hearing. Remanded. View "Gordon v. Braxton" on Justia Law

Plaintiff filed suit challenging Henrico County's ordinance prohibiting solicitation within county roadways. Plaintiff is homeless and supports himself by soliciting donations in the County. The district court granted summary judgment for the County, concluding that the ordinance is content-neutral and a narrowly tailored time, place, and manner restriction on speech. Plaintiff argued on appeal that the County bears the burden of proof and that the County's evidence was insufficient to establish that the ordinance is narrowly tailored or that it leaves open ample alternative channels of communication. McCullen v. Coakley held that a content-neutral regulation is narrowly tailored if it does not burden substantially more speech than is necessary to further the government's legitimate interests. McCullen clarified the law governing the evidentiary showing required of a governmental entity seeking to uphold a speech restriction under intermediate scrutiny. Because the parties did not have McCullen's guidance at the time they prepared their cross motions for summary judgment, the court vacated the district court's order and remanded for further factual development and proceedings under McCullen's standard. View "Reynolds v. Middleton" on Justia Law