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

North Carolina's House Bill 289 authorized the state's Division of Motor Vehicles to issue, among other specialty license plates, a "Choose Life" plate. However, this law authorized no pro-choice specialty license plate. North Carolina vehicle owners who wanted a pro-choice specialty plate, along with the ACLU, filed suit challenging the statute. North Carolina argued that it could so discriminate because specialty plate messages constituted pure government speech free from First Amendment viewpoint-neutrality constraints. The court concluded that, because the specialty plate speech at issue implicated private speech rights and was not pure government speech, North Carolina's authorizing a "Choose Life" plate while refusing to authorize a pro-choice plate constituted viewpoint discrimination in violation of the First Amendment. Accordingly, the court affirmed the district court's grant of summary judgment and a permanent injunction in favor of the vehicle owners and the ACLU. View "American Civil Liberties Union v. Tata" on Justia Law

Plaintiff, a state prisoner housed at Red Onion State Prison (ROSP), filed suit under the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. 2000 cc et seq., and 42 U.S.C. 1983, challenging ROSP's 2010 Ramadan policy. ROSP had devised a new eligibility policy for 2010 where, in addition to signing up to participate in Ramadan, inmates had to provide some physical indicia of Islamic faith. The court vacated the district court's summary judgment order granting defendants qualified immunity on plaintiff's claims for monetary relief where defendants have failed to establish as a matter of law that the 2010 Ramadan policy, as applied to plaintiff, did not violate his First Amendment rights and where their alleged actions violated plaintiff's clearly established rights; vacated the district court's decision that the prison's abandonment of the policy mooted the claims for equitable relief where defendants failed to meet their "heavy burden" of establishing that it was "absolutely clear" that the 2010 Ramadan policy would not be reinstated; and remanded for further proceedings. View "Wall v. Wade" on Justia Law

Plaintiff, an employee of MTA for four decades, filed suit against MTA alleging various forms of discrimination after her position was terminated due to budget cuts. The court concluded that, because summary judgment was granted before plaintiff had a chance to discover facts essential to her claim, and she alleged discrimination occurring before any legislative activity, the district court's Rule 56(d) denial was an abuse of discretion. The court concluded, however, that the district court's dismissal of plaintiff's age discrimination and disability discrimination claims were barred by sovereign immunity. Accordingly, the court affirmed in part, reversed in part, and remanded. View "McCray v. Maryland Dep't of Transp." on Justia Law

These appeals concerned whether Fannie Mae and Freddie Mac were exempt from the payment of state and local taxes imposed on the transfer of real property in Maryland and South Carolina. Fannie Mae and Freddie Mac claimed that they were exempt from such transfer taxes under 12 U.S.C. 1723a(c)(2) and 1452(e) respectively. The district courts in Maryland and South Carolina rejected the Counties' claims, concluding that the general tax exemptions applicable to Fannie Mae and Freddie Mac, while not applicable to real property taxes, did cover real property transfer taxes, thus making a distinction between property and transfer taxes. The district courts also concluded that Congress acted within its Commerce Clause power. The court held that the real property exclusions from the general tax exemptions of section 1723a(c)(2) and 1452(e) did not include transfer and recordation taxes; in the absence of a particular constitutional right that would trigger heightened scrutiny, the court held that a congressional exemption from state taxation under the Commerce Clause was subject to rational-basis review; Congress could exempt Fannie Mae and Freddie Mac from state and local transfer taxes, even though they were collected in the context of interstate transactions, because the taxes could substantially interfere with or obstruct the constitutionally justified missions of Fannie Mae and Freddie Mac in bolstering the secondary mortgage market; and the Counties' remaining arguments for finding the statutory tax exemptions unconstitutional were rejected. Accordingly, the court affirmed the judgment of the district courts. View "Montgomery County, Maryland v. Federal National Mortgage Assoc." on Justia Law

Plaintiff filed suit against Altarum, alleging that Altarum discriminated against him by wrongfully discharging him on account of disability and that Altarum failed to accommodate his disability. Plaintiff was terminated after he injured his legs on a subway platform and was on short-term disability benefits. On appeal, plaintiff challenged the district court's dismissal of his wrongful-discharge claim. The court concluded that, under the Americans with Disabilities Act Amendments Act of 2008, Pub. L. No. 110-325, 122 Stat. 3553, and its implementing regulations, an impairment is not categorically excluded from being a disability simply because it is temporary. In this instance, the impairment alleged by plaintiff fell comfortably within the amended Acts' expanded definition of disability. Therefore, the court reversed and remanded for further proceedings. View "Summers v. Altarum Institute, Corp." on Justia Law

Plaintiffs filed a putative class action suit challenging the legality of the toll charged by the MWAA for use of the Dules Toll Road. The district court dismissed the complaint on numerous grounds. The court concluded that plaintiffs' claims were barred neither by the standing requirement of Article III nor the prudential restrictions the court has recognized on its own judicial power; under the Elizabeth River Crossings OpCo, LLC v. Meeks framework, the tolls charged for passage on the Dules Toll Road are user fees, not taxes, under Virginia law; and therefore, their collection by the MWAA did not run afoul of the Virginia Constitution and did not violate the due process rights of motorists. Accordingly, the court affirmed the district court's dismissal of plaintiffs' complaint. View "Corr v. Metropolitan Washington" on Justia Law

Plaintiffs filed a class action challenging the constitutionality of the issuance and form of automated speeding citations issued under Maryland's speed camera program. The court found that the notice and hearing afforded by Maryland's speed camera statute satisfied due process where notice sent by first-class mail was reasonably calculated to provide actual notice of the speeding violation and civil penalties; the availability of a trial in state court, upon plaintiffs' election, provided adequate opportunity to be heard on any objections prior to the imposition of the statutory penalties; and any flaws in the citation or enforcement process could have been challenged in the state courts and plaintiffs failed to do so. Accordingly, the court affirmed the district court's grant of summary judgment in favor of the towns. View "Snider Int'l Corp. v. Town of Forest Heights, MD" on Justia Law

After individuals associated with Occupy Columbia were removed by law enforcement from a 24-hour per day protest on the grounds of the South Carolina State House, Occupy Columbia filed suit against defendants, including the Governor, seeking injunctive relief and damages under 42 U.S.C. 1983, the South Carolina Constitution, and South Carolina's common law. The court granted in part and denied in part. On appeal, defendants sought review of the district court's denial of qualified immunity to defendants. The court affirmed, concluding that Occupy Columbia has alleged a violation of a clearly established First Amendment right - the right to protest on State House grounds after 6:00 p.m. in the absence of a valid time, place, and manner restriction. View "Occupy Columbia v. Haley" on Justia Law

Plaintiff filed suit against defendant under, inter alia, 42 U.S.C. 1983 for violation of plaintiff's Fourth Amendment rights after defendant, a deputy sheriff, arrested plaintiff for withholding information about possibly rabid animals. On appeal, defendant challenged the judgment of damages plus attorney's fees entered against her in the section 1983 proceeding. The court concluded that, by securing a warrant that lacked adequate evidentiary support, defendant infringed plaintiff's Fourth Amendment right to be free from capricious arrest and this constitutional right was clearly established. Therefore, defendant could not shield herself from damages liability by invoking qualified immunity. Because the district court overstated plaintiff's degree of success, it erred in not making an attorney's fee award that would properly reflect her success in this case. Accordingly, the court affirmed the verdict of damages but vacated the attorney's fee award, remanding for an award of $100,000, exclusive of costs. View "McAfee v. Boczar" on Justia Law

After a deputy sheriff broadly publicized the corrupt and unlawful practices occurring in the Office of the Sheriff, the Sheriff terminated his employment. A jury awarded $1.1 million in favor of the deputy on his claim of retaliation for the exercise of his First Amendment rights. At issue was whether the district court erred in failing to grant qualified immunity to the Sheriff. The court found that the district court was right to conclude that the Sheriff violated the deputy's First Amendment right. The court concluded that it was clearly established at the time that an employee's speech about serious governmental misconduct was protected. Accordingly, the court held that the district court did not err in failing to grant qualified immunity to the Sheriff and affirmed the judgment. View "Durham v. Jones" on Justia Law