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

After the City initiated a "quick take" proceeding to take the property of Clear Sky Car Wash, Clear Sky filed suit to challenge the City's actions. Clear Sky alleged that the City's conduct violated the mandatory real property acquisition policies set forth in the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970 (URA), 42 U.S.C. 4651, which were applicable to state agencies when, as here, federal funds were involved. The district court granted the City's motion to dismiss. The court affirmed, concluding that section 4651 did not create enforceable rights. Therefore, Clear Sky lacked any basis for a private action to remedy violations under the URA. Further, 42 U.S.C. 1983 did not give Clear Sky enforceable rights to file suit. The court rejected Clear Sky's argument that it had an Administrative Procedure Act, 5 U.S.C. 551 et seq., claim against the USDOT to require it to enforce the policies of section 4651. Accordingly, the court affirmed the judgment of the district court. View "Clear Sky Car Wash LLC v. City of Chesapeake, VA" on Justia Law

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

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

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

Relators filed suit under the False Claims Act, 31 U.S.C. 3729-33, against Purdue. The district court dismissed the action on res judicata grounds because it gave preclusive effect to the court's decision in United States ex rel. Radcliffe v. Purdue Pharma L.P. Although the court rejected relators' assertion that Radcliffe was a jurisdictional dismissal, the court nonetheless agreed that the district court erred by giving Radcliffe preclusive effect. Because the Release executed by Mark Radcliffe did not bar non-signatories from proceeding against Purdue, the judgment enforcing the Release could not bar such claims. Accordingly, the court erred by dismissing this action as barred by principles of res judicata. The court also concluded that the pre-2010 version of the Act's public disclosure bar, 31 U.S.C. 3730(e)(4), applied in this case. Because the district court has not made the factual findings necessary to determine whether the public-disclosure bar precluded this action, the court must remand to the district court for discovery and further proceedings. View "US ex rel. Steven May v. Purdue Pharma L.P." on Justia Law

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

Plaintiff filed personal injury and wrongful death claims against the United States and Coast Guard under the Suits in Admiralty Act (SIAA), 46 U.S.C. 30901-30918. Plaintiff and her husband fell overboard their boat and her husband subsequently died of drowning. The court concluded that the Coast Guard neither increased the danger facing plaintiff and her husband nor induced reliance on the part of either plaintiff, her husband, or a third party. Accordingly, plaintiff could not prove that the Coast Guard breached its duty to her or her deceased husband, and the district court properly entered summary judgment on plaintiff's tort claims. The court also found that the rulings on the issues of spoliation and the timeliness of the motion reflected proper exercises of the district court's discretion and the court affirmed as to these issues. The court also affirmed the district court's ruling that the Coast Guard's response to plaintiff's Freedom of Information Act (FOIA), 5 U.S.C. 552, request satisfied its duty under that Act. View "Turner v. United States" on Justia Law