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

Robert Johnson, a prison guard in Bishopville, South Carolina, was shot multiple times in his home in an attack ordered by an inmate at the prison where Johnson worked. The inmate had used a contraband cell phone to communicate with the shooter. Johnson and his wife (together, Plaintiffs) sued several cellular phone service providers and owners of cell phone towers (collectively, Defendants) in state court, seeking to recover under state law negligence and loss of consortium theories. Specifically, Plaintiffs alleged that Defendants were aware that their services facilitated the illegal use of cellphones by prison inmates and that this illegal use created an unreasonable risk of harm to others. Defendants timely removed the case to federal court. The federal district court concluded that it had jurisdiction over the complaint and granted Defendants’ motions to dismiss for failure to state a claim. The Fourth Circuit affirmed, holding that the district court (1) erred in finding the existence of federal question jurisdiction, but the court properly exercised diversity jurisdiction over Plaintiffs’ state law claims; and (2) correctly held that Plaintiffs’ claims failed to state a claim as a matter of law. View "Johnson v. American Towers, LLC" on Justia Law

The Professional Massage Training Center (PMTC) filed suit against the Accreditation Alliance of Career Schools and Colleges (ACCSC) after ACCSC denied PMTC’s application for re-accreditation. The district court entered judgment in favor of PMTC, finding that ACCSC had violated the school’s due process rights. The court awarded the school more than $400,000 in damages and ordered ACCSC to fully reinstate its accreditation. The Supreme Court reversed in part and affirmed in part, holding (1) the district court erred in conducting a de novo approach to the accreditation process; (2) judged by the correct standard of review, the accreditation decision was well supported and not arbitrary or capricious; and (3) the district court correctly dismissed PMTC’s state law claims for breach of contract, negligence, and tortious interference. Remanded. View "Prof’l Massage Training v. Accreditation Alliance of Career Schs." on Justia Law

Plaintiff filed suit against Officer R.R. Ray, alleging a violation of 42 U.S.C. 1983 claim for excessive force and a state-law claim for assault and battery. Ray filed a motion for summary judgment on the basis of qualified immunity. The district court denied the motion, concluding that a reasonable jury could find that Ray employed excessive force in detaining Plaintiff. Plaintiff appealed, arguing that the district court erred in denying his motion for summary judgment concerning the excessive-force claim. The Fourth Circuit affirmed, holding that the district court properly denied Ray’s summary judgment motion because Ray was not entitled to qualified immunity at this stage in the litigation. View "Smith v. Ray" on Justia Law

Covol Fuels No. 4, LLC (Covol) and Pinnacle Mining Co., LLC (Pinnacle) were parties to a business agreement - a fully integrated contract - wherein Covol conducted coal fines recovery operations at Pinnacle’s mine in Wyoming County, West Virginia. Covol was authorized to unilaterally terminate the contract if its operations became economically unfeasible. After it became economically unfeasible for Covol to continue in the business, Covol initiated this action, alleging four claims. The district court granted summary judgment in favor of Pinnacle as to all claims. Covol appealed, contending that the district court erred in granting summary judgment on its breach of contract claim and on its tort claims. The Fourth Circuit affirmed in part and vacated in part, holding (1) genuine issues of material fact existed with respect to Covol’s breach of contract claim that a jury must decide; and (2) Covol’s tort claims were barred by the “gist of the action doctrine.” View "Covol Fuels No. 4, LLC v. Pinnacle Mining Co., LLC" on Justia Law

Plaintiff, a citizen of Taiwan, filed suit against the United States, seeking damages for the accidental killing of her husband and the intentional sinking of her husband's fishing vessel during a North Atlantic Treaty Organization (NATO) counter-piracy mission. Plaintiff's husband was one of three Chinese hostages captured by pirates. Because allowing this action to proceed would thrust courts into the middle of a sensitive multinational counter-piracy operation and force courts to second-guess the conduct of military engagement, the court agreed that the separation of powers prevents the judicial branch from hearing the case. Accordingly, the court affirmed the district court's dismissal of the action under the political question and discretionary function doctrines. View "Wu Tien Li-Shou v. United States" on Justia Law

Plaintiff filed a personal injury suit against East West after he was nearly killed in a bulldozer accident. Plaintiff's direct employer is Ashland and Ashland hired East West as a subcontractor. The court affirmed the district court's dismissal of the complaint for lack of subject matter jurisdiction under Federal Rule of Civil Procedure 12(b)(1) where plaintiff's action is barred by the Virginia Workers' Compensation Act (VWCA), Va. Code Ann. 65.2-307, because plaintiff's injury occurred in Virginia and East West is a statutory co-employee under Virginia law. View "Demetres v. East West Construction, Inc." on Justia Law

Plaintiff filed suit against his former employer (ExxonMobil) and employees, alleging claims of fraud, intentional infliction of emotional distress, personal injury, and wrongful discharge. Plaintiff claimed that he was fired in retaliation for reporting illegal pharmacy practices, which caused him to suffer a heart attack and emotional stress. The court affirmed the district court's denial of plaintiff's motion to remand the case to state court and the dismissal of all but one of plaintiff's tort claims. The court concluded that plaintiff sufficiently stated a wrongful discharge claim under Virginia's public policy exception to its at-will employment doctrine. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Weidman v. Exxon Mobil Corp." on Justia Law

Plaintiff filed suit against defendants, alleging claims pursuant to the Victims of Trafficking and Violence Protection Act (TVPA), 18 U.S.C. 1589, 1590, 1595; the Fair Labor Standards Act (FLSA), 29 U.S.C. 206, 216; and Virginia contract law. Plaintiff is a citizen of the Philippines and moved to the United States to work for defendants in order to provide for her young daughter and elderly parents, all of whom reside in the Philippines. Plaintiff's claims stemmed from her allegations that she was forced to work for defendants for wages well below the minimum from 2002 until her escape in 2008. The district court dismissed plaintiff's claims as time-barred. In 2008, Congress amended the TVPA to include a ten-year statute of limitations, William Wilberforce Trafficking Victims Protection Reauthorization Act of 2008 (TVPRA), 18 U.S.C. 1595(c). The court held that applying the TVPRA's extended limitations period to claims that were unexpired at the time of its enactment does not give rise to an impermissible retroactive effect under Landgraf v. USI Film Products. In this case, plaintiff pled facts sufficient to support the conclusion that her claims were unexpired under the four-year limitations period when the 2008 TVPA went into effect. Therefore, the court concluded that, although plaintiff's state law claims are time-barred, her TVPA claims may be timely under the ten-year limitations period if they were tolled until within four years of the TVPRA's enactment, and her FLSA claim may be timely if she received actual notice of her rights within three years of filing this suit. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Cruz v. Maypa" on Justia Law

Plaintiff filed suit against defendant, the Assistant Director for Clinical Administration at Central State Hospital, after her son was murdered by another patient at the hospital. The court affirmed the district court's decision to strike plaintiff's expert witness because he was disclosed in an untimely fashion; affirmed the district court's denial of plaintiff's second motion to amend her complaint to add two defendants because such amendment would be futile; and affirmed the district court's conclusion that there was insufficient evidence to support the claims against defendant, who was an assistant director in charge of administrative matters at the time of the son's death.View "Wilkins v. Montgomery" on Justia Law

Petitioner filed suit for survivor's benefits under the Black Lung Benefits Act, 30 U.S.C. 901-945. Petitioner sought review of an April 2012 decision of the BRB affirming the denial of benefits by an ALJ. The court held that petitioner satisfied the test for survivor's benefits: she is the surviving spouse of a miner whose death was hastened by pneumoconiosis due at least in part to coal mine employment. Accordingly, the court reversed and remanded with directions to award benefits without further administrative proceedings.View "Collins v. Pond Creek Mining Co." on Justia Law