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

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

A retired teacher, Patsy Talley, received overpayments in her retirement benefits from the North Carolina Teachers’ and State Employees’ Retirement System (TSERS) for over eight years, totaling $86,173.93. When the overpayment was discovered, TSERS began reducing her monthly benefits to recoup the overpaid amount. Talley did not dispute the overpayment but argued that the recoupment process violated her due process rights because she was not provided a hearing before the reductions began.The United States District Court for the Eastern District of North Carolina dismissed all of Talley’s claims. The court held that her official capacity claims were barred by the Eleventh Amendment, her substantive due process claim failed because she received adequate post-deprivation process, and her equal protection claim did not allege a fundamental right or suspect class. The court also dismissed her individual capacity procedural due process claim, finding the defendants were entitled to qualified immunity. Additionally, the court denied Talley’s motion to amend her complaint to add new plaintiffs, citing procedural deficiencies and lack of good cause.The United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The appellate court agreed that the Eleventh Amendment barred the official capacity claims and that the individual capacity claims were barred by qualified immunity. The court found that Talley failed to state a substantive due process claim because she received adequate post-deprivation process and that her equal protection claim did not meet the rational basis review. The court also upheld the denial of her motion to amend the complaint, finding no abuse of discretion by the district court. View "Talley v. Folwell" on Justia Law

Maryland and South Carolina filed lawsuits in state courts against 3M Company and other chemical manufacturers, alleging contamination of their waterways with per- and polyfluoroalkyl substances (PFAS). The states filed separate complaints for PFAS contamination from aqueous film-forming foam (AFFF) and non-AFFF products, explicitly disclaiming any connection between the two in their non-AFFF complaints.In the District of Maryland, 3M removed Maryland's non-AFFF complaint to federal court under the federal officer removal statute, arguing that PFAS from its Military AFFF production was indistinguishably commingled with PFAS from its non-AFFF products. The district court remanded the case, giving dispositive effect to Maryland's disclaimer and concluding that 3M's federal work was not implicated. Similarly, in the District of South Carolina, 3M removed South Carolina's non-AFFF complaint, but the district court also remanded, crediting the state's disclaimer and finding no connection to 3M's federal work.The United States Court of Appeals for the Fourth Circuit reviewed the consolidated appeals. The court held that the states' disclaimers were not dispositive in determining the connection between 3M's federal work and the charged conduct. The court concluded that 3M plausibly alleged that PFAS contamination from its Military AFFF production was related to the states' claims, satisfying the nexus requirement for federal officer removal. The court vacated the district courts' decisions and remanded for further consideration of whether 3M met the other elements for federal officer removal, including acting under a federal officer and having a colorable federal defense. View "State of Maryland v. 3M Company" on Justia Law

In the early morning of November 1, 2019, a group of law enforcement officers, including Task Force Officer (TFO) Clarence Belton and Charlotte-Mecklenburg Police Officer Heather Loveridge, attempted to execute a search warrant at the house of a suspect, Larry McConneyhead, in Charlotte, North Carolina. During the operation, McConneyhead fled into his house, and a confrontation ensued. TFO Belton was accidentally shot by Officer Loveridge, who mistook him for the suspect. Belton suffered severe injuries, leading to multiple surgeries and permanent disability.The case was initially filed in North Carolina state court and then removed to the United States District Court for the Western District of North Carolina. Belton alleged excessive force under 42 U.S.C. § 1983 and several state law claims against Officer Loveridge and the City of Charlotte. Officer Loveridge moved for summary judgment, asserting qualified immunity for the federal claim and public officers’ immunity for the state claims. The district court denied her motion, citing genuine disputes of material fact regarding the circumstances of the shooting.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that the district court failed to conduct the proper analysis for determining qualified immunity, which requires identifying the specific constitutional right violated and whether that right was clearly established at the time of the incident. The Fourth Circuit vacated the district court’s order and remanded the case for further proceedings, instructing the lower court to apply the correct legal standards for qualified immunity and public officers’ immunity. View "Belton v. Loveridge" on Justia Law

Captain Gardenia Dorado-Ocasio, an Army officer, challenged a decision by the Army Board for Correction of Military Records (ABCMR) regarding an adverse performance evaluation she received. The evaluation was based on her failure to comply with her superior's orders and alleged retaliation against a subordinate. Dorado-Ocasio claimed the evaluation was biased and factually inaccurate. The ABCMR upheld the evaluation, finding no substantive errors or evidence of bias.The United States District Court for the Eastern District of Virginia reviewed the case and granted summary judgment in favor of the defendant, the Acting Secretary of the Army. The district court found that the ABCMR had adequately explained its decision and that the decision was not arbitrary or capricious.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The Fourth Circuit held that the ABCMR's decision was supported by substantial evidence and that the Board had provided a discernible path for its determination. The court emphasized the special deference given to military judgments and found that the ABCMR had met the required standard of review. The court concluded that the ABCMR's decision was not arbitrary, capricious, or contrary to law. View "Dorado-Ocasio v. Averill" on Justia Law

Angelo Jackson was identified as a suspect in a double murder in Montgomery County, Maryland, based on information from law enforcement officers. Detective Michael Carin used this information to obtain an arrest warrant for Jackson. After Jackson's arrest, Carin continued the investigation and found exculpatory evidence, including DNA and cellphone records, which led to the charges being dropped and Jackson's release after 65 days of detention.Jackson filed a lawsuit against Carin, alleging that Carin's affidavit for the arrest warrant and his grand jury testimony were deliberately false or made with reckless disregard for the truth. Jackson claimed that if the commissioner and grand jury had been presented with truthful evidence, they would not have found probable cause for his arrest and indictment.The United States District Court for the District of Maryland granted summary judgment in favor of Carin, finding that even with disputed material removed, the affidavit still provided probable cause for Jackson's arrest. The court also found that Carin was protected by qualified immunity on Jackson's federal claims and dismissed Jackson's gross negligence claim under Maryland law.The United States Court of Appeals for the Fourth Circuit affirmed the district court's judgment. The court concluded that Carin did not violate legal standards in his investigation and was shielded by qualified immunity. The court also found that Carin's actions were reasonable and based on information he received from other officers, and that Jackson failed to meet the burden of proving that Carin's statements were false, made with reckless disregard for the truth, or material to the probable cause determination. View "Jackson v. Carin" on Justia Law

Lisa Wheeler, a physician assistant and former Assistant Medical Director at Acadia Healthcare Company’s Asheville, North Carolina clinic, filed a complaint alleging that Acadia falsified medical records to claim payments from government healthcare programs. Wheeler claimed that Acadia, which provided methadone-assisted treatment for opioid use disorder, failed to provide required therapy and counseling services, instead fabricating therapy notes to submit fraudulent claims to Medicare, Medicaid, and other government programs.The United States District Court for the Western District of North Carolina dismissed Wheeler’s amended complaint, concluding that she failed to adequately plead that Acadia’s false claims were material or submitted to the government. The court found that Wheeler did not sufficiently allege that Acadia’s failure to provide therapy was material to the government’s payment decisions or that false claims were actually submitted to the government.The United States Court of Appeals for the Fourth Circuit reviewed the case and reversed the district court’s decision. The Fourth Circuit held that Wheeler adequately pled her claims of presentment, false statement, false certification, and fraudulent inducement under the False Claims Act. The court found that Wheeler’s allegations of falsified therapy notes and non-compliance with federal opioid treatment standards were material to the government’s payment decisions. The court also concluded that Wheeler sufficiently alleged that Acadia submitted false claims to government healthcare programs and that the fraudulent conduct was central to the government’s decision to pay.Additionally, the Fourth Circuit held that Wheeler adequately pled her reverse false claim, finding that the stipulated penalties in Acadia’s Corporate Integrity Agreement with the government constituted an obligation under the False Claims Act. The court remanded the case for further proceedings consistent with its opinion. View "United States ex rel. Wheeler v. Acadia Healthcare Company, Inc." on Justia Law

Environmental groups challenged the issuance of a permit by the U.S. Army Corps of Engineers for the development of the Cainhoy Plantation in South Carolina. The plaintiffs argued that the permit violated the Endangered Species Act (ESA) and the National Environmental Policy Act (NEPA). They claimed the permit improperly used a habitat surrogate to set the level of anticipated take of an endangered species and was issued after an Environmental Assessment (EA) rather than a more comprehensive Environmental Impact Statement (EIS).The United States District Court for the District of South Carolina denied the plaintiffs' motion for a preliminary injunction, finding that they did not have a sufficient likelihood of success on the merits of their claims. The court concluded that the Corps' decision to issue the permit based on an EA was reasonable and that the use of a habitat surrogate was justified under the circumstances.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The Fourth Circuit held that the Corps had taken the required "hard look" at the environmental consequences of the project as mandated by NEPA and that the use of a habitat surrogate was appropriate given the impracticality of monitoring the take of individual bats. The court found that the Corps' decision to rely on an EA instead of preparing an EIS was entitled to deference and that the plaintiffs had not demonstrated a likelihood of success on the merits of their claims. The court also noted that the surrogate used by the Service was enforceable and set a clear standard for determining when the level of anticipated take had been exceeded. View "South Carolina Coastal Conservation League v. United States Army Corps of Engineers" on Justia Law

The Pharmaceutical Coalition for Patient Access (the Coalition), a charitable organization involving drug manufacturers, challenged an unfavorable advisory opinion issued by the Office of the Inspector General (OIG) for the U.S. Department of Health and Human Services (HHS). The dispute centered on the Coalition’s proposed patient assistance program for Medicare beneficiaries, which aimed to subsidize co-pays for oncology drugs. The OIG determined that the program would violate the Anti-Kickback Statute if the required mens rea were present, as it would offer remuneration to induce the purchase of specific drugs.The United States District Court for the Eastern District of Virginia granted summary judgment in favor of the defendants, the United States, HHS, and related officials, and dismissed the Coalition’s claims. The court found that the OIG’s advisory opinion was not arbitrary or capricious and that the Coalition’s program would indeed fall within the Anti-Kickback Statute’s prohibitions.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The court affirmed the district court’s decision, agreeing that the word “induce” in the Anti-Kickback Statute should be construed under its ordinary meaning, not its specialized criminal law meaning. The court also concluded that “remuneration” in the statute includes any payment or compensation, not just corrupt payments that distort medical decision-making. The court found that the Coalition’s program involved a quid pro quo, as it offered subsidies for the purchase of specific drugs.The Fourth Circuit also upheld the district court’s dismissal of the Coalition’s disparate treatment claim for lack of subject matter jurisdiction, ruling that the OIG’s enforcement discretion is not subject to judicial review. The court concluded that the OIG had consistently applied the Anti-Kickback Statute to similar proposals and that the Coalition’s challenge was directed against the OIG’s enforcement discretion, which is unreviewable under the Administrative Procedure Act. View "Pharmaceutical Coalition for Patient Access v. United States" on Justia Law

Courthouse News Service, a news organization, sought remote online access to civil court records from the Circuit Court for Prince William County, Virginia, similar to the access granted to Virginia attorneys. Virginia law prohibits the clerk from providing such access to non-attorneys. Courthouse News sued, claiming this restriction violated its First Amendment and Equal Protection rights.The United States District Court for the Eastern District of Virginia dismissed Courthouse News's Equal Protection claim and granted summary judgment for the defendants on the First Amendment claims. The court found the restrictions to be content-neutral time, place, and manner regulations justified by the state's interests in the orderly administration of justice and protecting sensitive personal information.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court's ruling on the First Amendment and Equal Protection claims, holding that the access restriction was a content-neutral regulation narrowly tailored to serve significant governmental interests. The court found that the restriction did not violate the First Amendment as it provided ample alternative channels for accessing court records and did not burden more access than necessary. The court also concluded that the restriction did not violate the Equal Protection Clause for the same reasons it passed First Amendment scrutiny.However, the court vacated the district court's ruling on the Dissemination Restriction claim, finding that Courthouse News lacked standing to challenge it since the restriction only applied to those with remote access, which Courthouse News did not have. The case was remanded for the district court to dismiss this claim without prejudice. View "Courthouse News Service v. Smith" on Justia Law