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

The United States Court of Appeals for the Fourth Circuit denied a motion filed by the United States Environmental Protection Agency (EPA) to transfer a case brought by the state of West Virginia to the Court of Appeals for the District of Columbia or to dismiss it due to improper venue. The case pertains to the EPA's disapproval of West Virginia's State Implementation Plan (SIP), which the state had submitted as part of its obligation under the Clean Air Act to address the emission of gases contributing to the formation of ground-level ozone. The EPA had disapproved West Virginia's SIP because it found that the plan did not sufficiently reduce ozone-forming emissions that were adversely affecting air quality in downwind states. The Fourth Circuit court also granted the state of West Virginia's motion to stay the EPA's final action pending the outcome of its petition for review. The court's decision on venue was based on its interpretation of the Clean Air Act, which stipulates that the venue for review of EPA actions depends on whether the action is nationally applicable or locally or regionally applicable. The court concluded that the EPA's disapproval of West Virginia's SIP was based on circumstances particular to West Virginia and therefore was locally or regionally applicable. View "State of West Virginia v. EPA" on Justia Law

In this case, plaintiffs Kewon English and Earl Powell were arrested for sexual assault and burglary and detained for over a year before their cases were nolle prossed and they were released. They sued Senior Investigator Joseph Clarke of the Richland County Sheriff’s Department, alleging that he had coerced them into signing false confessions. They also sued Sheriff Leon Lott and the Richland County Sheriff's Department for damages under § 1983, claiming their constitutional rights under the First, Fourth, Fifth, Sixth, and Fourteenth Amendments were violated. The United States Court of Appeals for the Fourth Circuit affirmed the grant of summary judgment on English’s claims and dismissed Clarke’s cross-appeal. The court determined that there was probable cause to arrest English based on the victim’s identifications. Regarding English's malicious prosecution claim, the court held that even assuming probable cause was negated, Clarke cannot be held responsible for English’s continued detention. The court found no evidence that the Richland County Sheriff's Department had any unconstitutional policy or custom, and that Clarke could not be held liable for the continued detention of English. Furthermore, the court dismissed Clarke's cross-appeal, ruling that the appeal turned on a question of fact and was therefore not suitable for interlocutory treatment. View "English v. Clarke" on Justia Law

In this case, Jordan Jones, a prisoner at North Carolina’s Avery-Mitchell Correctional Institution, sued multiple prison officials under § 1983. The suit challenged the conditions of his confinement and a transfer to another prison that he alleged was retaliatory. The United States Court of Appeals for the Fourth Circuit affirmed in part and reversed in part the district court's grant of summary judgment to the defendants.Jones had been placed in a “dry” cell, with the water turned off, for about 17 hours after he was suspected of having ingested contraband. He was allowed to clean himself only with toilet paper, despite having to defecate three times in a portable toilet. He also had to eat a meal with his hands, which he was unable to wash. The court concluded that while the conditions of Jones's confinement were deplorable, the officials were entitled to qualified immunity on this claim because it was not clearly established in April 2015 that these conditions posed a substantial risk of serious harm in violation of the Eighth Amendment.However, the court reversed the district court's grant of summary judgment to defendant Gregory Taylor on Jones's claim that his transfer to another prison was in retaliation for his filing of grievances. The court concluded that a reasonable jury could find that Taylor ordered the transfer in retaliation for Jones's grievances, and that Taylor was not entitled to qualified immunity on this claim because it was clearly established at the time of the transfer that such retaliation violated the First Amendment. The court remanded for further proceedings on this claim. View "Jones v. Solomon" on Justia Law

In this appeal to the United States Court of Appeals for the Fourth Circuit, James Dow Vandivere challenged a district court decision denying his motion for release from civil commitment under the Adam Walsh Act. Vandivere, who had been convicted of multiple crimes involving the sexual exploitation of minors and sentenced to almost twenty years in prison, was nearing the end of his sentence when the government moved to civilly commit him. The government argued, and the district court agreed, that Vandivere remained sexually dangerous. Vandivere filed a motion for discharge and, following a hearing, the district court found he remained sexually dangerous and denied his motion. Vandivere appealed, arguing that he was wrongly forced to bear the burden of proof at the hearing and that the district court erred in determining that he remained sexually dangerous.The Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The appellate court found that under the Adam Walsh Act, the burden of proof at an Adam Walsh Act discharge hearing is on the detainee to show his recovery by a preponderance of the evidence. The court also found this allocation of burden does not violate the detainee’s due process rights. Further, the appellate court found no error in the district court's conclusion that Vandivere remained sexually dangerous, stating that the district court had appropriately considered Vandivere's behavior while in custody, his persistent cognitive distortions about sexual abuse, his refusal to participate in sex offender therapy, and his proposed release plan. View "US v. Vandivere" on Justia Law

In this case heard before the United States Court of Appeals for the Fourth Circuit, the plaintiff, Daniella Easterbrook, appealed the denial of her application for disability benefits by the Social Security Administration. Easterbrook, who has suffered from persistent back pain since 2011, argued that the Administrative Law Judge (ALJ) failed to provide a "good reason," supported by substantial evidence, for not giving adequate weight to the opinions of her treating physician, Dr. John Kim.The court agreed with Easterbrook, stating that the ALJ erred in not applying the "treating source rule" to Dr. Kim's opinions and not providing a sufficient justification for giving his opinions less weight. The court noted that Dr. Kim's opinions were well-supported by medically acceptable clinical and laboratory diagnostic techniques and were consistent with the substantial evidence in the record.The court also found that the ALJ's reasons for discounting Dr. Kim's opinions, such as Easterbrook's decision not to undergo certain treatments, were inappropriate and did not constitute "good reasons." The court stated that a patient's refusal to pursue a specific type of medical treatment does not automatically call into question the severity of her pain.As a result, the court reversed the Commissioner's decision and remanded the case for a determination consistent with its opinion. View "Easterbrook v. Kijakazi" on Justia Law

Plaintiffs sought to enjoin the state from enforcing only this additional, preliminary handgun-licensure requirement. The district court originally dismissed that challenge for lack of Article III standing, but we reversed and remanded for a decision on the merits. On remand, the district court again rejected Plaintiffs’ claims, this time holding that Maryland’s handgun licensure law did not violate the Second Amendment. So Plaintiffs appealed once more.   The Fourth Circuit reversed the district court’s decision. The court explained that the challenged law restricts the ability of law-abiding adult citizens to possess handguns, and the state has not presented a historical analogue that justifies its restriction; indeed, it has seemingly admitted that it couldn’t find one. The court enjoined the enforcement explaining that under the Supreme Court’s new burden-shifting test for these claims, Maryland’s law fails. The court wrote that Maryland has not shown that this regime is consistent with the Nation’s historical tradition of firearm regulation. There might well be a tradition of prohibiting dangerous people from owning firearms. But, under the Second Amendment, mechanism matters. And Maryland has not pointed to any historical laws that operated by preemptively depriving all citizens of firearms to keep them out of dangerous hands. View "Maryland Shall Issue, Inc. v. Wes Moore" on Justia Law

Plaintiff filed suit in federal district court against Judge Goldston and others present at the search. Plaintiff claimed that the warrantless search and seizure of his property violated his Fourth and Fourteenth Amendment rights, that the restrictions on recording the incident violated the First Amendment, and that Judge Goldston’s practice of conducting “home visits” violated the Equal Protection Clause by disadvantaging pro se litigants like himself. He sought compensatory and punitive damages under 42 U.S.C. Section 1983, as well as attorney’s fees and injunctive and declaratory relief. Judge Goldston moved for summary judgment, claiming she was entitled to absolute judicial immunity. The district court denied her motion. At issue on appeal is whether Judge Goldston is entitled to judicial immunity.   The Fourth Circuit affirmed, holding that judicial immunity protects only judicial acts. It does not shield the conduct of judges who step outside their judicial role, as Judge Goldston did when searching Plaintiff’s home. The court explained that while Judge Goldston might have had the authority to order a search, the proper authority to conduct the operation was the local sheriff’s department or some other appropriate law enforcement agency. The court explained that just as “judges do not do double duty as jailers,” so too they do not do double duty as sheriffs. View "Matthew Gibson v. Louise Goldston" on Justia Law

Plaintiff was brutally beaten by three Maryland corrections officers because they believed he had taken part in an assault on another officer. He sued their warden along with the officers who attacked him and their direct supervisors. A federal jury awarded Plaintiff $700,000. The warden appealed. He argued that this case should never have proceeded to trial because Plaintiff failed to exhaust his administrative remedies before suing. He also believes the district court should have found that the evidence failed to support the jury’s verdict and that he was entitled to qualified immunity.
The Fourth Circuit affirmed the district court. The court held that Plaintiff was not required to exhaust because no administrative remedies were available, the evidence supports the jury’s verdict, and the warden was not entitled to qualified immunity based on the facts found by the jury. The court explained that this case was properly tried before a jury because inmates cannot receive any relief through Maryland’s administrative grievance proceedings when the Intelligence and Investigative Division is investigating the subject matter of the grievance. And the jury’s role in trials is enshrined in the Seventh Amendment for good reason. Resolving factual disputes, weighing the evidence, and determining whom to believe is within its province. When a jury performs these functions, the court will not disturb its conclusions based on a cold record unless those conclusions lack evidentiary support. Here, the evidence was sufficient to support the jury’s conclusions. And based on how the jury resolved these issues, the warden’s conduct violated clearly established law. View "Kevin Younger v. Tyrone Crowder" on Justia Law

Appellant, a former employee of the Office of the Director of National Intelligence (“ODNI”), asserts that ODNI violated the Family and Medical Leave Act of 1993 (“FMLA”),by delaying her leave request and not hiring her for a permanent position. The district court determined that Appellant failed to meet her burden of proof to demonstrate that she was not selected for the permanent position “by reason of” ODNI’s FMLA interference.   The Fourth Circuit affirmed. The court concluded that t the record supports the district court’s finding that Appellant’s non-selection for the permanent position was the result of the hiring official’s poor impression of Appellant as a prospective employee and Appellant’s attendance problems prior to the FMLA interference. View "Hannah P. v. Avril Haines" on Justia Law

The United States and the Commonwealth of Virginia (together, the “governments”) appealed the district court’s dismissal of their complaint under the False Claims Act and Virginia state law. The governments alleged that Walgreen Co. (“Walgreens”) misrepresented that certain patients met Virginia’s Medicaid-eligibility requirements for expensive Hepatitis C drugs. The district court dismissed the complaint, holding that Virginia’s eligibility requirements violated the Medicaid Act, and therefore Walgreens’s misrepresentations were immaterial as a matter of law.   The Fourth Circuit vacated and remanded. The court held that the governments plausibly allege facts that establish materiality. The court wrote that the alleged misrepresentation (that Patient 12 couldn’t use the cheaper drug alternative) has nothing to do with the eligibility requirements Walgreens now challenges. The district court didn’t explain how the supposed illegality of Virginia’s eligibility requirements rendered this misrepresentation immaterial or how it otherwise failed to state a claim. Further, the court explained it is also persuaded that Walgreens can’t avoid liability by collaterally challenging the eligibility requirements’ legality under a line of cases beginning with United States v. Kapp. Moreover, the court explained that Walgreens offers no good reason why a contract law (and even more specifically, a collective-bargaining-contract-law) rule should displace the liability created by the False Claims Act, a federal statute. View "US v. Walgreen Co." on Justia Law