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

In the second year of the COVID-19 pandemic, Johns Hopkins University’s Applied Physics Lab required employees to be vaccinated against the disease. Sally Tarquinio, who suffers from “Lyme-induced immune dysregulation,” requested a medical exemption, fearing adverse effects from the vaccine. The lab found her condition unclear and requested to speak with her doctors, but Tarquinio refused. Consequently, the lab denied her exemption request and terminated her employment for non-compliance. Tarquinio sued under the Americans with Disabilities Act (ADA), and the district court granted summary judgment in favor of the lab.The United States District Court for the District of Maryland reviewed the case and found that Tarquinio had not provided sufficient evidence to support her need for an exemption. The court noted that the lab had made good faith efforts to understand her condition and accommodate her, but Tarquinio’s refusal to allow communication with her doctors prevented the lab from obtaining necessary information. The court concluded that without this information, the lab could not be held liable for failing to provide a reasonable accommodation.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 Tarquinio’s failure to engage in the interactive process by not providing adequate medical documentation or allowing the lab to speak with her doctors meant that the lab was not on proper notice of her need for accommodation. The court emphasized that the interactive process is essential for determining reasonable accommodations and that an employer cannot be held liable if the employee obstructs this process. Thus, the lab’s actions were deemed appropriate, and the summary judgment in favor of the lab was affirmed. View "Tarquinio v. Johns Hopkins University Applied Physics Lab" on Justia Law

Martin Misjuns, a Fire Captain and paramedic with the Lynchburg Fire Department, was terminated after posting offensive social media content targeting transgender individuals. Misjuns alleged that his termination was due to his political and religious views, which he expressed on his Facebook pages. He claimed that the City of Lynchburg and its officials conspired to violate his constitutional rights, leading to his firing.The United States District Court for the Western District of Virginia dismissed all of Misjuns' claims. The court found that the claims against the individual defendants in their official capacities were duplicative and dismissed them. The court also dismissed Misjuns' breach of contract, equal protection, conspiracy, and wrongful termination claims. The court partially dismissed his First Amendment claims but later dismissed them entirely.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court's dismissal of Misjuns' claims. The court held that Misjuns failed to establish Monell liability against the City of Lynchburg, as he did not adequately plead that a policy or custom caused the alleged constitutional violations. The court also found that the City's Employment Policies & Procedures handbook did not constitute a binding contract, thus dismissing the breach of contract claim. Additionally, the court upheld the dismissal of the conspiracy and wrongful termination claims against the individual defendants, as those claims were not asserted against the City and had been dismissed by agreement.The Fourth Circuit concluded that Misjuns did not sufficiently plead facts to state a claim for relief on any of his six claims, affirming the district court's decision. View "Misjuns v. City of Lynchburg" on Justia Law

Garten Trucking LC, a company specializing in the transportation of paper products, faced a union organizing campaign by the Association of Western Pulp and Paper Workers (AWPPW) in mid-2021. After losing a union representation election, AWPPW filed multiple unfair labor practice charges against Garten Trucking, alleging various violations of the National Labor Relations Act (NLRA). An Administrative Law Judge (ALJ) found Garten Trucking guilty of several violations, including unlawful interrogation and threats, and ordered a new election. The National Labor Relations Board (NLRB) affirmed the ALJ's findings and mandated bargaining with AWPPW.While the initial case was pending, AWPPW continued its organizing efforts, distributing a flyer claiming that Garten Trucking was required to bargain with the union and that the union's presence led to employee raises. In response, Garten Trucking's owner, Robert Garten, posted a message on the company's internal board, refuting the union's claims and suggesting that employees would have already received raises if not for the union's actions. The union filed another unfair labor practice charge, and the ALJ ruled that Garten's message violated Section 8(a)(1) of the NLRA by implying that union activities negatively impacted wage increases.The United States Court of Appeals for the Fourth Circuit reviewed the case, focusing on whether Garten's message constituted a coercive threat. The court upheld the NLRB's decision, finding substantial evidence that Garten's statement linking wage increases to union activities was coercive and violated the NLRA. The court emphasized that while employers are entitled to express their opinions on union activities, they cannot make statements that imply threats or promises of benefits based on union support. The court denied Garten Trucking's petition and granted the NLRB's cross-petition for enforcement. View "Garten Trucking LC v. National Labor Relations Board" on Justia Law

Lisa Barnhill, a white woman, sued the U.S. Attorney General, alleging racial and gender discrimination, retaliation, and a hostile work environment under Title VII of the Civil Rights Act of 1964. Barnhill claimed she faced discrimination from her African American supervisor and others while employed by the DEA. Some of her claims were dismissed under Fed. R. Civ. P. 12(b)(6), and others were resolved on summary judgment under Fed. R. Civ. P. 56(a).The United States District Court for the Eastern District of Virginia dismissed Barnhill's race and gender discrimination claims, finding she failed to allege facts showing discriminatory animus. The court also dismissed her retaliation claims related to promotion denials and a five-day suspension, concluding she did not plausibly allege a connection between her EEO proceeding and these adverse actions. However, the court allowed her retaliation claims related to a management review and temporary duty reassignment, as well as her hostile work environment claim, to proceed.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the dismissal of Barnhill's discrimination claims, agreeing she did not plausibly allege discriminatory animus. The court also affirmed the dismissal of her retaliation claims related to promotion denials and the suspension, finding no causal connection to her EEO proceeding. On summary judgment, the court found that the management review was initiated by a supervisor without discriminatory animus and that the temporary duty reassignment was justified by legitimate, nonretaliatory reasons. The court also concluded that Barnhill's hostile work environment claim failed because the adverse actions she experienced were responses to her own behavior, not severe or pervasive harassment.The Fourth Circuit affirmed the district court's decision, holding that Barnhill failed to establish the necessary elements for her claims. View "Barnhill v. Bondi" on Justia Law

Two former employees sued Zen Nails Studio LLC and its owners for violating the Fair Labor Standards Act (FLSA) and a similar Maryland state law. After a five-day bench trial, the plaintiffs won and were awarded approximately 60% of their requested damages. The plaintiffs then sought $343,189.85 in attorney’s fees, but the district court awarded them $167,115.49, which was less than half of what they requested. The plaintiffs appealed the district court’s decision regarding the hourly rates used to calculate the attorney’s fees.The United States District Court for the District of Maryland, at Greenbelt, initially reviewed the case. The district court set the hourly rates for the plaintiffs’ attorneys, paralegals, and paraprofessionals based on the local rules' guidelines, which it treated as presumptively reasonable. The court then calculated the hours reasonably worked and reduced the total by 35% due to the plaintiffs achieving a moderately successful outcome. The plaintiffs challenged the district court’s reliance on the local rules' guidelines for setting the hourly rates.The United States Court of Appeals for the Fourth Circuit reviewed the case. The appellate court held that the district court erred by treating the hourly rates in the local rules as presumptively correct and requiring special justification for higher rates. The Fourth Circuit emphasized that while fee matrices can be a useful starting point, they should not be treated as setting a baseline that requires special justification to deviate from. The appellate court vacated the fee award and remanded the case for further proceedings, instructing the district court to consider all relevant evidence to determine the prevailing market rates without giving undue weight to the local rules' guidelines. View "De Paredes v. Zen Nails Studio LLC" on Justia Law

John Sigley applied for a Material Handler position with ND Fairmont LLC (NDF) and was offered the job contingent on passing a physical exam. During the physical, conducted by Industrial Therapy Solutions (ITS), Sigley denied having any back issues or seeing a chiropractor, despite having undergone three back surgeries and having a metal rod in his back. He passed the physical and began working on September 13, 2021. On October 28, 2021, Sigley called out of work due to back spasms and later disclosed his back condition to NDF's HR Manager, Joyce Hardway, and Environmental Health & Safety Manager, Justin Darrah. NDF confirmed Sigley's omission of his back condition during the physical and terminated him for dishonesty on November 2, 2021.Sigley filed a lawsuit against NDF, alleging disability discrimination under the Americans with Disabilities Act (ADA). The United States District Court for the Northern District of West Virginia granted summary judgment in favor of NDF, finding that Sigley was terminated for dishonesty, not because of his disability. The court also dismissed Sigley's claims of breach of confidentiality and failure to accommodate, as they were not properly pled in his complaint.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 Sigley failed to establish a prima facie case of discriminatory discharge, as he could not demonstrate that his termination raised a reasonable inference of unlawful discrimination. The court found that NDF had a legitimate, non-discriminatory reason for terminating Sigley—his dishonesty during the physical exam. The court also noted that Sigley's claims of breach of confidentiality and failure to accommodate were untimely and meritless, as he did not properly plead them and admitted he did not require an accommodation. View "Sigley v. ND Fairmont LLC" on Justia Law

Jeremy Smith, a customer care technician for Cox Enterprises, Inc., received long-term disability benefits for seven years due to severe back pain and multiple surgeries. In 2019, Aetna, the plan administrator, terminated his benefits, concluding he could work under certain conditions. Smith appealed, providing additional medical evidence, including a consultative examination from Dr. Harris, which supported his disability claim. Aetna upheld the termination, leading Smith to file a lawsuit under the Employee Retirement Income Security Act (ERISA).The United States District Court for the Eastern District of Virginia granted summary judgment in favor of Cox Enterprises, Inc. Welfare Benefits Plan. The court found that Aetna's decision was supported by substantial evidence and that it was reasonable for Aetna to discount the opinions of Smith's primary care physician and the Social Security Administration's disability determination.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that Aetna abused its discretion by failing to adequately discuss and consider conflicting evidence, particularly Dr. Harris's consultative examination and the Social Security Administration's disability determination. The court found that Aetna did not engage in a deliberate and principled reasoning process, as required by ERISA regulations. Consequently, the Fourth Circuit reversed the district court's decision and remanded the case for further proceedings, instructing the district court to remand the matter to Aetna for reconsideration of Smith's claim. View "Smith v. Cox Enterprises, Inc. Welfare Benefits Plan" on Justia Law

Carmen Wannamaker-Amos, a Black woman, worked in quality management at Purem Novi, Inc. for over thirty years. Despite receiving positive reviews from her supervisors, she faced negative treatment from Javad Hosseini, Purem’s chief quality executive. Hosseini repeatedly urged her supervisors to fire her, and in January 2020, after a problem with an automobile part, he requested her termination. Purem terminated her two days later. Wannamaker-Amos sued Purem, alleging racial and sex discrimination under Title VII of the Civil Rights Act of 1964 and the Civil Rights Act of 1866.The United States District Court for the District of South Carolina granted summary judgment to Purem, ruling that Wannamaker-Amos failed to produce sufficient evidence that the nondiscriminatory reason given for her firing was pretextual. The court found that she did not meet her employer’s legitimate expectations at the time of her termination.The United States Court of Appeals for the Fourth Circuit reviewed the case and concluded that numerous issues of material fact were in dispute. The court found that Wannamaker-Amos provided ample evidence to dispute Purem’s claims about her performance and that Hosseini’s criticisms were baseless. The court also noted that Purem’s shifting reasons for her termination and failure to follow its own disciplinary policies could indicate pretext for discrimination. The court emphasized that it is the role of the jury to decide which party’s evidence is more persuasive.The Fourth Circuit vacated the district court’s grant of summary judgment and remanded the case for further proceedings, allowing a jury to determine whether Wannamaker-Amos was subjected to intentional discrimination. View "Wannamaker-Amos v. Purem Novi, Inc." on Justia Law

Kristen M. Barnett, a former registered nurse at INOVA Health Care Services, refused to receive the COVID-19 vaccine due to her religious beliefs. INOVA had a policy requiring vaccination unless an exemption was granted. Barnett initially received a medical exemption but later requested a religious exemption, which was denied. She was subsequently placed on administrative leave and then discharged for noncompliance. Barnett filed a lawsuit against INOVA, alleging religious discrimination under Title VII and the Virginia Human Rights Act (VHRA).The United States District Court for the Eastern District of Virginia granted INOVA's motion to dismiss Barnett's complaint in its entirety. The court found that Barnett failed to state a claim for reasonable accommodation under Title VII because her objection did not raise issues related to abortion or fetal cells. The court also dismissed her disparate treatment claims under Title VII and the VHRA, finding them duplicative and lacking a comparator.The United States Court of Appeals for the Fourth Circuit reviewed the case and reversed the district court's decision. The appellate court held that Barnett had sufficiently alleged religious discrimination for all three claims at the motion to dismiss stage. The court found that Barnett's allegations demonstrated her sincere religious beliefs and that her refusal to receive the vaccine was religious in nature. The court also found that Barnett's allegations supported a reasonable inference of discriminatory intent by INOVA.The Fourth Circuit reversed the district court's dismissal and remanded the case for further proceedings, allowing Barnett's claims to proceed. View "Barnett v. INOVA Health Care Services" on Justia Law

The case involves a class action lawsuit against Bojangles’ Restaurants, Inc. by several plaintiffs who allege that the company required them to perform unpaid off-the-clock work and made unauthorized edits to their time records. The plaintiffs, who worked as shift managers, claim that Bojangles violated its own policies and the Fair Labor Standards Act (FLSA) by not compensating them for all hours worked, including overtime.The United States District Court for the Western District of North Carolina conditionally certified a collective action for the FLSA claims and later certified class actions for state wage-and-hour law claims in North Carolina and South Carolina. The district court found that the proposed classes met the requirements for numerosity, commonality, and predominance under Federal Rule of Civil Procedure 23. The court relied on the fact that most class members worked opening shifts and were subject to Bojangles’ Opening Checklist, which allegedly required pre-shift work. The court defined the classes broadly to include all shift managers who worked at Bojangles in North Carolina or South Carolina within three years of the complaint.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s certification order. The appellate court found that the district court abused its discretion by employing an overly general approach in identifying the policies that allegedly unified the class members’ claims and by creating overly broad class definitions. The Fourth Circuit held that the district court failed to provide specific evidence of a common policy that mandated off-the-clock work and time-record edits for all class members. The court vacated the certification order and remanded the case for further proceedings, instructing the district court to refine the class definitions and ensure that common questions predominate over individualized issues. View "Stafford v. Bojangles' Restaurants, Inc." on Justia Law