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

A 13-year-old male student at a Virginia Beach middle school received a sexually explicit photo from a female classmate and, several months later, showed the image to other students during the school day. After teachers reported the incident, the assistant principal removed the student from class, questioned him, and searched his phone’s photo gallery. The school resource police officer was notified and began a criminal investigation. The student ultimately showed the explicit photo to the officer, was read his Miranda rights, arrested, and charged in juvenile court with possession of child pornography. The juvenile court found sufficient evidence for guilt but deferred disposition; the charge was dismissed after the student completed court-imposed conditions.The student, through his mother and later counsel, sued the assistant principal, the school resource officer, the Virginia Beach School Board, and the City of Virginia Beach in the United States District Court for the Eastern District of Virginia. He alleged violations of his Fourth, Fifth, and Fourteenth Amendment rights, as well as conspiracy and Monell claims. The district court granted summary judgment to all defendants, finding the phone search reasonable under New Jersey v. T.L.O., the confession voluntary, no evidence of unlawful conspiracy, and no underlying constitutional violations to support Monell liability.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The court affirmed the district court’s judgment, holding that the assistant principal’s search of the student’s phone was justified at its inception and reasonable in scope under T.L.O., and that Riley v. California did not displace this standard in the school context. The court also held the student’s confession was voluntary under the Fifth and Fourteenth Amendments, found no evidence of a conspiracy to violate constitutional rights, and determined Monell liability could not attach absent an underlying constitutional violation. The court therefore affirmed summary judgment for all defendants. View "O.W. v. Carr" on Justia Law

A married couple, acting on behalf of their minor child, challenged West Virginia’s compulsory vaccination law after their daughter was disenrolled from a public virtual school because she was not fully vaccinated. The parents sought a religious exemption from the vaccination requirement, but were informed that only medical exemptions—based on specific medical contraindications or precautions certified by a physician—are permitted under state law. After being denied a religious exemption, the parents filed suit, claiming that the absence of a religious exemption violated their First Amendment right to freely exercise their Christian faith. They requested a preliminary injunction to allow their daughter’s re-enrollment in the virtual academy during the litigation.The United States District Court for the Northern District of West Virginia granted the preliminary injunction, finding that the parents were likely to succeed on their free exercise claim. The district court applied the test from Employment Division, Department of Human Resources of Oregon v. Smith, concluding that the vaccination law was not generally applicable, and thus subject to strict scrutiny, which it found the law did not survive.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s grant of preliminary relief. The Fourth Circuit held that West Virginia’s compulsory vaccination law is a neutral and generally applicable measure enacted under the state’s police power to protect public health, as recognized in longstanding Supreme Court precedent including Jacobson v. Massachusetts and Prince v. Massachusetts. The court found that the medical exemption process does not constitute a “mechanism for individualized exemptions” that would undermine general applicability under cases such as Fulton v. City of Philadelphia. The Fourth Circuit concluded that the law is subject to rational basis review, which it easily satisfies, and that the Free Exercise Clause does not require religious exemptions simply because medical exemptions exist. The court reversed the district court’s preliminary injunction and remanded the case. View "Perry v. Marteney" on Justia Law

Two students with disabilities, their parents, and an advocacy organization brought a lawsuit against the Virginia Department of Education and the Fairfax County School Board. The plaintiffs alleged systemic violations of the Individuals with Disabilities Education Act (IDEA), claiming that the defendants deprived eligible students of a free appropriate public education (FAPE) and failed to provide proper procedural safeguards, including fair due process hearings and impartial hearing officers. The complaint sought declaratory and injunctive relief under the IDEA, as well as constitutional claims for due process and equal protection.The United States District Court for the Eastern District of Virginia reviewed the case. It found that one student, D.C., and his parents had not exhausted IDEA's administrative remedies before filing suit, as they had not pursued a due process hearing regarding their complaints. The other student, M.B., and his parents had a separate, duplicative federal lawsuit pending that addressed the same issues, and the court dismissed their claims to avoid duplicative litigation. The advocacy organization, Hear Our Voices, Inc., was found to lack standing to sue either on behalf of its members or in its own right, as it had not identified any member with a viable claim and its alleged injury was not sufficient to confer organizational standing.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court's rulings. The appellate court held that the exhaustion requirement of the IDEA applied to all claims, regardless of whether they were statutory or constitutional in nature and regardless of whether the claims were alleged to be systemic. It also affirmed the dismissal of duplicative claims and found the advocacy organization lacked both representational and organizational standing. The judgment of the district court was affirmed. View "D.C. v. Fairfax County School Board" on Justia Law

A 14-year-old student, S.B., who had a history of trauma and mental health challenges, began high school in Appomattox County, Virginia, in August 2021. S.B. identified as male at school and was advised by a counselor that he could use the boys’ restroom. Following this, S.B. was subjected to harassment, threats, and sexual assault by male students. School staff, including counselors, were aware of the harassment and S.B.’s mental health vulnerabilities but did not inform S.B.’s adoptive mother, Blair, about the gender identity issues, the bullying, or the school’s responses. Instead, staff continued to affirm S.B.’s male identity without parental notification and failed to take effective action to stop the harassment. After a series of escalating incidents, S.B. suffered a breakdown, ran away, and was subsequently victimized by sex traffickers.Blair filed suit in the United States District Court for the Western District of Virginia against the school board and staff, alleging deliberate indifference to sexual harassment under Title IX, Monell liability for unconstitutional policy or failure to train, and violations of substantive due process rights. The district court dismissed all claims, finding insufficient allegations of deliberate indifference or Monell liability, and granted qualified immunity to the individual defendants on the due process claims.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s dismissal de novo. The Fourth Circuit held that Blair’s Title IX claim for deliberate indifference against the school board was sufficiently pleaded and should not have been dismissed, as the complaint alleged the school’s response to known harassment was clearly unreasonable. However, the court affirmed dismissal of the Monell and substantive due process claims, finding the allegations were conclusory or the rights not clearly established. The case was affirmed in part, reversed in part, and remanded for further proceedings on the Title IX claim. View "Blair v. Appomattox County School Board" on Justia Law

The case involves Jane Roe, a student at Marshall University, who was sexually assaulted by her ex-boyfriend, John Doe, at an off-campus party following a football game in September 2022. Roe reported the incident to the police, who then informed the university. The university's Title IX office reviewed the case but determined it fell outside their jurisdiction as the incident occurred off-campus and was not part of a university-sponsored event. The matter was referred to the Office of Student Conduct, which investigated and disciplined both Doe and Roe for their respective violations of the Student Code.In the United States District Court for the Southern District of West Virginia, Roe filed a lawsuit against the Marshall University Board of Governors, alleging deliberate indifference and retaliation under Title IX. The district court granted summary judgment in favor of the university, finding that the university's response did not amount to deliberate indifference and that the university did not retaliate against Roe for reporting the assault.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The court affirmed the district court's decision, holding that the university did not have substantial control over the context of the harassment, as the incident occurred at a private off-campus residence. Additionally, the court found that Roe failed to provide sufficient evidence to show that the university's reasons for disciplining her were pretextual. The court concluded that the university's actions were not retaliatory and upheld the summary judgment in favor of the university. View "Roe v. Marshall University Board of Governors" on Justia Law

E.R., the appellant, filed a complaint against the Beaufort County School District, alleging that the district failed to respond appropriately to her reports of sexual abuse and harassment while she was a student. E.R. claimed she was sexually assaulted by three male students and subsequently bullied and harassed by other students. Despite reporting these incidents to school officials, she alleged that no appropriate action was taken.The case was initially filed in South Carolina state court, asserting claims under Title IX and state law for negligence and gross negligence. The school district removed the case to federal court and moved to dismiss it, arguing that the claims were untimely under the South Carolina Tort Claims Act (SCTCA), which has a two-year statute of limitations. The district court agreed, applying the SCTCA's statute of limitations to both the Title IX and state law claims, and dismissed the case as it was filed more than two years after E.R. turned 18.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the appropriate statute of limitations for Title IX claims is the state's general personal injury statute of limitations, not the SCTCA's two-year period. The court reasoned that Title IX claims should borrow the statute of limitations from the most analogous state law cause of action, which in this case is the general personal injury statute. Since South Carolina's general personal injury statute of limitations is three years, E.R.'s claims were timely.The Fourth Circuit vacated the district court's dismissal of E.R.'s complaint and remanded the case for further proceedings consistent with its opinion. View "E.R. v. Beaufort County School District" on Justia Law

The plaintiffs in this case are parents of children with special needs attending public schools in Fairfax County, Virginia. They allege that the transition to remote learning during the COVID-19 pandemic constituted an unconstitutional "taking" of their children's Fifth Amendment property interest in public education. The plaintiffs argue that Virginia law establishes a fundamental right to public education, which they claim is a protected property interest under the Fourteenth Amendment's Due Process Clause and, by extension, should be considered private property under the Takings Clause.The United States District Court for the Eastern District of Virginia dismissed the plaintiffs' complaint for failure to state a claim under Rule 12(b)(6). The court reasoned that while the right to public education in Virginia may be a protected property interest under the Due Process Clause, it does not necessarily qualify as private property under the Takings Clause. The court noted that federal courts have long interpreted property interests protected by the Takings Clause as narrower than those protected by the Due Process Clause. The district court concluded that the right to public education is subject to regulation and revision by the Virginia government and cannot be bought or sold, distinguishing it from private property.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo and affirmed the district court's judgment. The Fourth Circuit agreed that the plaintiffs' children may have a property interest in public education under the Due Process Clause but held that this does not extend to the Takings Clause. The court emphasized that the Takings Clause applies only to private property and that public education, being subject to government regulation and not possessing the characteristics of private property, does not qualify. The court concluded that the plaintiffs failed to state a plausible claim for compensation under the Takings Clause. View "Chollet v. Brabrand" on Justia Law

Jacob Doe, a student at the University of North Carolina at Chapel Hill (UNC-CH), was found responsible for two allegations of sexual misconduct and subsequently expelled from the university system. Doe sued the university and several employees, claiming violations of his Fourteenth Amendment due process rights, Title IX, and various state laws. The district court largely denied the defendants' motions to dismiss, allowing Doe’s federal and most state law claims to proceed.The defendants appealed to the United States Court of Appeals for the Fourth Circuit. The appellate court found that the district court erred in rejecting the defendants' claims of sovereign and qualified immunity. The court held that the UNC institutions were entitled to sovereign immunity, reversing the district court’s decision to allow Doe’s claims against them. Additionally, the court determined that the individual university employees were entitled to qualified immunity regarding Doe’s due process claims for damages, as the right to cross-examination in university disciplinary proceedings was not clearly established at the time.However, the appellate court affirmed the district court’s decision to allow Doe to seek prospective injunctive relief for the alleged due process violations. The court recognized that Doe had adequately alleged a liberty interest due to the permanent expulsion and the ongoing harm from the erroneous disciplinary record. The court declined to exercise pendent appellate jurisdiction over the district court’s denial of the motion to dismiss Doe’s Title IX claim against UNC-CH, dismissing that portion of the appeal for lack of jurisdiction.In conclusion, the Fourth Circuit affirmed in part, reversed in part, and dismissed in part the district court’s rulings, allowing Doe’s claims for prospective injunctive relief to proceed while dismissing his claims for damages against the UNC institutions and individual employees. View "Doe v. The University of North Carolina System" on Justia Law

John Doe 2, a student athlete at North Carolina State University, alleged that he was sexually abused by Robert Murphy, the university’s Director of Sports Medicine, under the guise of medical treatment. Doe claimed that the university was deliberately indifferent to prior complaints of Murphy’s sexual misconduct. The district court dismissed Doe’s complaint, finding that he failed to plead facts supporting an inference that the university had actual notice of Murphy’s sexual harassment.The United States District Court for the Eastern District of North Carolina dismissed the complaint under Federal Rule of Civil Procedure 12(b)(6). The court concluded that a report of “sexual grooming” could not provide actual notice to the university of sexual harassment. The district court assumed without deciding that the report was made to an official with the requisite authority for Title IX purposes but found that the report did not describe an incident of sexual harassment and thus could not support a plausible inference of actual notice.The United States Court of Appeals for the Fourth Circuit reviewed the case and vacated the district court’s judgment. The Fourth Circuit held that a report of “sexual grooming” can objectively be construed as alleging sexual harassment, thus providing actual notice to the university. The court found that the district court erred in its conclusion and remanded the case for further proceedings to determine whether the report was made to an appropriate official with the authority to address complaints of sexual harassment and to institute corrective measures on behalf of the university. View "John Doe 2 v. North Carolina State University" on Justia Law

Davina Ricketts, a sophomore at a high school in North Carolina, decided to run for student council to address its lack of diversity. She faced racial harassment and cyberbullying from peers, and the school district allegedly failed to intervene. Ricketts filed a lawsuit claiming the school district was deliberately indifferent to her harassment. The district court dismissed her complaint and denied her motion to amend, stating her proposed amended complaint also failed to state a claim. Ricketts appealed the denial of her motion for leave to amend.The United States District Court for the Eastern District of North Carolina initially dismissed Ricketts' complaint and denied her motion to amend on futility grounds. The court reasoned that her proposed amended complaint did not sufficiently state claims for deliberate indifference, retaliation, or equal protection violations.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that Ricketts sufficiently alleged deliberate indifference, retaliation, and equal protection claims. The court held that Ricketts' allegations of racial harassment, the school administrators' authority and actual knowledge of the harassment, and their deliberate indifference were sufficient to state a Title VI claim. The court also found that Ricketts sufficiently alleged retaliation by showing she engaged in protected activity, faced materially adverse actions, and established a causal connection between the two. Additionally, the court held that Ricketts sufficiently alleged an equal protection claim against individual defendants and the Board of Education by showing discriminatory intent and a municipal custom or policy of indifference.The Fourth Circuit reversed the district court's judgment, directed the district court to allow Ricketts to amend her complaint, and remanded the case for further proceedings. View "Ricketts v. Wake County Public School System" on Justia Law