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

The Fourth Circuit affirmed the district court's grant of summary judgment for IPC in plaintiff's action under Title VII of the Civil Rights Act of 1965, alleging race-based discrimination claims. In regard to the disparate treatment claim, the court held that plaintiff's claims of disparate treatment for being denied positions, overtime, additional educational benefits and training were time-barred. As for plaintiff's timely claim that he was denied annual reviews, the court held that plaintiff offered no evidence demonstrating IPC's failure to give him annual reviews affected the terms, benefits and conditions of his employment. Furthermore, even if hostile treatment could qualify as an adverse employment action, plaintiff's claim that the hostile treatment he received at IPC constitutes an adverse employment action would fail as a matter of law. In regard to the race-based hostile work environment claim, the court held that the totality of the circumstances did not sufficiently demonstrate a severe or pervasive hostile work environment. Finally, plaintiff failed to create a genuine issue of material fact as to his constructive discharge claim. View "Perkins v. International Paper Co." on Justia Law

The Fourth Circuit affirmed the district court's grant of summary judgment for IPC in an action brought by plaintiff under Title VII of the Civil Rights Act of 1965 and the Equal Pay Act of 1963 (EPA), alleging gender and race discrimination. In regard to plaintiff's hostile work environment constructive discharge claims, without commenting on the district court's decision concerning the severe or pervasive requirement, the court held on an alternative ground that plaintiff failed to present sufficient evidence creating a genuine issue of material fact that her working conditions were so intolerable that a reasonable employee would be compelled to resign. The court also held that plaintiff failed to present evidence that created a genuine issue of material fact regarding her retaliation claim. Finally, the court held that plaintiff failed to offer evidence that created a genuine issue of material fact concerning her alleged EPA violation. View "Evans v. International Paper Co." on Justia Law

Plaintiff, a former special agent with the Virginia State Police, filed suit under the Americans with Disabilities Act (ADA) and Title VII of the Civil Rights Act against the Commonwealth, seeking relief that includes compensatory damages, reinstatement, and back pay. The Fourth Circuit affirmed the district court's dismissal of the ADA claim, because the Commonwealth has not waived its sovereign immunity from that claim. However, the court reversed the district court's decision that claim preclusion barred the Title VII claims, because the initial forum did not have the power to award the full measure of relief sought in this litigation. Accordingly, the court remanded for further proceedings. View "Passaro v. Commonwealth of Virginia" on Justia Law

The Department sought interlocutory review of the district court's decision that the state waived Eleventh Amendment immunity with respect to claims under Maryland's Fair Employment Practices Act (FEPA). The Fourth Circuit exercised its jurisdiction under the collateral order doctrine and held that the state has not waived the protection of the Eleventh Amendment. In this case, the state did not waive its Eleventh Amendment immunity as to plaintiff's FEPA claims through a statutory consent to suit provision in Md. Code. Servs. 20-903. In the absence of the state's express consent to suit in federal court, the Department was entitled to the protection of the Eleventh Amendment with respect to the FEPA claims. View "Pense v. Maryland Department of Public Safety and Correctional Services" on Justia Law

After plaintiff was injured while replacing railroad crossties on a bridge spanning navigable waters, he filed a negligence claim against his employer under the Federal Employers' Liability Act (FELA). The Fourth Circuit reversed the district court's grant of the employer's motion to dismiss for lack of subject matter jurisdiction. The court held that plaintiff's injury did not occur "upon navigable waters," as required by the Longshore and Harbor Workers' Compensation Act, and thus the district court erred in dismissing plaintiff's FELA claim. The court remanded for further proceedings. View "Muhammad v. Norfolk Southern Railway Co." on Justia Law

Once a jury has evaluated witness credibility, weighed evidence, and reached a verdict, a litigant seeking to overturn that verdict faces a steep hurdle. Plaintiff filed suit against TWC, alleging that the company fired her based on illegal age discrimination. The jury found in favor of plaintiff and the district court denied TWC's motion for judgment as a matter of law. The Fourth Circuit affirmed, holding that there was sufficient evidence to support the jury's verdict and the district court managed the proceedings fairly. View "Westmoreland v. TWC Administration LLC" on Justia Law

The Fourth Circuit reversed the district court's grant of summary judgment to WCI on all of plaintiff's claims under Title VII of the Civil Rights Act of 1964 and 42 U.S.C. 1981. The court held that the district court erred by finding that plaintiff, who is black, had failed to establish an appropriate comparator and to produce evidence of pretext. In this case, plaintiff produced evidence that a white employee with the same supervisor, who had several workplace infractions, was permitted to return to his job after the employee became angry and yelled at his supervisor before quitting. The court held that the record as a whole could permit a reasonable factfinder to conclude that plaintiff and that employee were proper comparators. Furthermore, plaintiff has produced evidence that WCI's reason for his termination has changed substantially over time, and therefore has presented sufficient evidence of pretext. View "Haynes v. Waste Connections, Inc." on Justia Law

The Fourth Circuit affirmed the district court's grant of summary judgment for the University in an action brought by a sociology professor, alleging claims under the Equal Pay Act and Title VII. The court held that, although plaintiff established a pay disparity between her and two former administrators, she failed to present evidence creating a genuine issue of material fact that the administrators were appropriate comparators. The court also held that, in any event, the University based the administrators' higher pay on their prior service as University administrators, not their sex. View "Spencer v. Virginia State University" on Justia Law

The district court did not abuse its discretion by sanctioning plaintiff for her "flagrant and unremitting" violations of the Federal Rules of Civil Procedure. After plaintiff was constructively discharged as a nurse practitioner by the University, she filed four separate actions alleging claims arising out of the same course of events and alleging state torts of defamation and interference with prospective advantage, as well as violations of the False Claims Act, the Maryland False Health Claims Act, Title VII, and 42 U.S.C. 1981. The Fourth Circuit held that plaintiff's conduct under the procedural rules was inept and abusive to the degree that it rendered virtually useless five years of proceedings before the district court, and such abuse would likely have continued in any future proceedings. View "Rangarajan v. Johns Hopkins University" on Justia Law

The Fourth Circuit affirmed in part and reversed in part the district court’s grant of summary judgment in favor of Defendant, the Office of the Director of National Intelligence, on Plaintiff’s claims asserting violations of the Rehabilitation Act, 29 U.S.C. 701 et seq., and the Family and Medical Leave Act (FLMA), 29 U.S.C. 2601, et seq., holding that summary judgment was proper as to the Rehabilitation Act and FMLA retaliation claims but was not warranted as to Plaintiff’s FMLA interference claim. Plaintiff, a former employee of Defendant, asserted that Defendant discriminated against her and violated the FMLA by not hiring her for a permanent position following her completion of a five-year term. After exhausting her administrative remedies, Plaintiff filed this lawsuit. The district court granted summary judgment for Defendant on all counts. The Fourth Circuit held (1) the district court properly granted summary judgment as to Plaintiff’s Rehabilitation act and FMLA retaliation claims; but (2) summary judgment as to Plaintiff’s FMLA interference claim was precluded because a genuine issue of material fact remained as to whether Plaintiff provided notice of her disability and interest in FMLA leave sufficient to trigger Defendant’s duty to inquire. View "Hannah P. v. Coats" on Justia Law