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

Sandlands and EDS challenged the validity of Horry County's Flow Control Ordinance. The Ordinance prohibits disposal of waste generated in the county at any site other than a designated publicly owned landfill. The court affirmed the district court's grant of summary judgment in favor of the county, concluding that the Ordinance did not violate the Dormant Commerce Clause because the Ordinance provides the same types of benefits and imposes the same types of burdens as the ordinances upheld in United Haulers Ass'n v. Oneida-Herkimer Solid Waste Management Authority. Further, the Ordinance did not violate the Equal Protection Clause because Sandlands and EDS have failed to show that they have been intentionally treated differently from other similarly situated companies. View "Sandlands C&D LLC v. Horry County" on Justia Law

After prevailing against the United States on the issue of just compensation in a condemnation proceeding, Granby and Marathon appeal the district court's denial of attorney's fees under the Equal Access to Justice Act (EAJA), 28 U.S.C. 2412. The district court concluded that, although the prelitigation position of the United States was admittedly unreasonable, the United States' overall position was substantially justified under the totality of the circumstances. The court vacated and remanded with instructions regarding how to properly weigh the government's prelitigation position in determining whether its position as a whole was substantially justified, and to consider, if necessary, whether special circumstances existed in the first instance. View "United States v. 515 Granby, LLC" on Justia Law

Plaintiff filed suit against officers under 42 U.S.C. 1983, as well as state law claims, after plaintiff was shot by the officers. Plaintiff, after hearing sounds of unknown persons outside his home, opened the front door carrying a shotgun and was shot by the officers. The court concluded that it had jurisdiction under the collateral order doctrine. The district court did not err in denying the officers qualified immunity from plaintiff's excessive force claims under section 1983 where a reasonable officer would not have had probable cause to feel threatened by plaintiff's actions and the constitutional right at issue - the right to be free from deadly force when posing no threat - was clearly established at the time the officers shot plaintiff. Accordingly, the court affirmed the district court's judgment as to the section 1983 claims. The court also affirmed the district court's denial of public officers' immunity with respect to plaintiff's state law tort claims. View "Cooper, Sr. v. Sheehan" on Justia Law

Plaintiff, a state prisoner, filed suit challenging the constitutionality of 42 U.S.C. 1997e(d)(2), a part of the Prison Litigation Reform Act of 1995 (PLRA), as violating his right to equal protection of the laws under the Fifth Amendment's Due Process Clause. Plaintiff challenged a provision that caps the attorneys' fee award that a successful prisoner litigant could recover from the government in a civil rights action at 150 percent of the value of the prisoner's monetary judgment. The court declined to apply heightened equal protection scrutiny in this case and joined its sister circuits in concluding that section 1997e(d)(2) was constitutional. Congress's goals in enacting section 1997e(d)(2) included reducing marginal or frivolous prisoner civil rights lawsuits and protecting the public fisc. Such goals were legitimate and Congress acted rationally in adopting the provision. Accordingly, the court affirmed the judgment of the district court. View "Wilkins v. Gaddy" on Justia Law

Motor Carriers filed suit against defendants under 49 U.S.C. 13706(b) of the Interstate Commerce Commission Termination Act. At issue was whether, absent a federal tariff, federal courts have subject matter jurisdiction over a motor carrier's breach of contract claim against a shipper for unpaid freight charges. The court concluded that it lacked jurisdiction over the appeal under the Act, finding that the district court lacked jurisdiction to adjudicate the dispute. Accordingly, the court vacated the judgment of the district court and remanded with instructions to dismiss. View "Gaines Motor Lines, Inc. v. Klaussner Furniture Ind." on Justia Law

Plaintiffs, out-of-state medical providers seeking to open facilities in Virginia, filed suit challenging Virginia's certificate-of-need requirement. In order to launch a medical enterprise in the state of Virginia, a firm was required to obtain a certificate of public need. Plaintiffs alleged, among other things, that Virginia's requirement violated the dormant Commerce Clause by discriminating in both purpose and effect. The district court dismissed the suit for failure to state a claim upon which relief could be granted. The court concluded that plaintiffs' Commerce Clause challenges required closer scrutiny and further proceedings before the district court. The court concluded, however, that plaintiffs' Fourteenth Amendment claims were properly dismissed. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Colon Health Centers v. Hazel" on Justia Law

College Newspapers challenged the ABC's ban on alcohol advertisements as violative of the First Amendment. The court concluded that the challenged regulation violated the First Amendment as applied to the College Newspapers where a regulation of commercial speech must satisfy all four Central Hudson Gas & Elec. Corp. v. Pub. Serv. Comm'n of N.Y. prongs in order to survive an as-applied challenge, and the regulation at issue here did not satisfy the fourth prong. The district court erred in concluding that the challenged regulation was appropriately tailored to achieve its objective of reducing abusive college drinking. Accordingly, the court reversed the district court's grant of summary judgment in favor of the ABC. View "Educational Media Co. v. Insley" on Justia Law

Plaintiffs filed suit against the Sheriff of the City of Hampton, Virginia, in his individual capacity and in his official capacity, alleging that the Sheriff retaliated against plaintiffs in violation of their First Amendment rights by choosing not to reappoint them because of their support of his electoral opponent. The court concluded that, as to the claims of Plaintiffs Sandhofer, Woodward, and Bland, the district court properly analyzed the merits of the claims; as to the claims of Plaintiffs Carter, McCoy, and Dixon, the district court erred by concluding that plaintiffs failed to create a genuine dispute of material fact regarding whether the Sheriff violated their First Amendment rights; nevertheless, the district court properly ruled that the Sheriff was entitled to qualified immunity on Carter's McCoy's, and Dixon's claims seeking money damages against the Sheriff in his individual capacity, and that the Sheriff was entitled to Eleventh Amendment immunity against those claims to the extent they sought monetary relief against him in his official capacity; and the Sheriff was not entitled to Eleventh Amendment immunity on Carter's, McCoy's and Dixon's claims to the extent the remedy sought was reinstatement. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Bland v. Roberts" on Justia Law

This case concerned efforts by the Town of Nags Head, North Carolina, to declare beachfront properties that encroach onto "public trust lands" a nuisance, and regulate them accordingly. In the related appeal of Sansotta v. Town of Nags Head, the district court adjudicated the claims but concluded that it was inappropriate for a "federal court to intervene in such delicate state-law matters," and abstained from decision under Burford v. Sun Oil Co. The court reversed the district court's decision to abstain in this case where resolving the claims in this case was not sufficiently difficult or disruptive of that policy to free the district court from its "unflagging obligation to exercise its jurisdiction." Accordingly, the court remanded for further proceedings. View "Town of Nags Head v. Toloczko" on Justia Law

Plaintiff filed suit against a correctional officer alleging that he used excessive force against plaintiff. Without provocation, the officer assaulted plaintiff for about two minutes before the officer moved plaintiff to a holding cell, knocking his head against a gate on the way out. The prison staff then kept plaintiff in ambulatory restraints for seventeen hours following the assault. On appeal, the officer appealed the district court's denial of his Rule 50(b) motion for judgment as a matter of law. Because no extraordinary circumstances were applicable to plaintiff's injuries and he suffered no more than de minimis injury, he could not, at the time the assault took place, state a claim upon which relief could be granted under the Eighth Amendment. Therefore, the right he sought to avail himself of was not clearly established in the Fourth Circuit at the time of the alleged suit and the officer was entitled to qualified immunity. Accordingly, the court reversed and remanded. View "Hill v. Crum" on Justia Law