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

Plaintiff filed suit against Elk Run, alleging that the company committed fraud on the court and therefore deprived her coal miner husband of nearly a decade of benefits under the Black Lung Benefits Act (BLBA), 30 U.S.C. 901-945. Plaintiff contended that Elk Run had committed fraud on the court because it had not disclosed certain expert reports to its expert pulmonologists. The court affirmed the Board's finding that Elk Run's conduct was not sufficiently egregious to meet the high bar for a claim of fraud on the court because it did not amount to an intentional design aimed at undermining the integrity of the adjudicative process. The court found that Elk Run's conduct did not, under Supreme Court and circuit precedent, demonstrate the commission of a fraud upon the court. View "Fox v. Elk Run Coal Co., Inc." on Justia Law

After a deputy sheriff broadly publicized the corrupt and unlawful practices occurring in the Office of the Sheriff, the Sheriff terminated his employment. A jury awarded $1.1 million in favor of the deputy on his claim of retaliation for the exercise of his First Amendment rights. At issue was whether the district court erred in failing to grant qualified immunity to the Sheriff. The court found that the district court was right to conclude that the Sheriff violated the deputy's First Amendment right. The court concluded that it was clearly established at the time that an employee's speech about serious governmental misconduct was protected. Accordingly, the court held that the district court did not err in failing to grant qualified immunity to the Sheriff and affirmed the judgment. View "Durham v. Jones" on Justia Law

The Union sought to amend its collective bargaining agreement (CBA) with the IRS to permit probationary employees to use the agreement's grievance procedures to challenge removals alleged to be in violation of statutory rights or procedures. After the IRS refused to negotiate on the grounds that the proposal would grant probationary employees greater procedural protections that were authorized under law and regulation, the Union appealed to the FLRA. The FLRA granted judgment in favor of the IRS and the Union appealed. The court declined to reverse the FLRA's judgment because such a decision would ignore the statutory and regulatory frameworks that Congress and the executive branch have put in place, create a stark circuit split, and overturn nearly thirty years of settled public-employee practice. View "National Treasury Employees Union v. Federal Labor Relations Authority" on Justia Law

Plaintiff filed suit against Prudential, the plan administrator, and BioMerieux, her employer, after Prudential denied her long-term disability and short-term disability benefits. The district court entered summary judgment in favor of Prudential and BioMerieux. Plaintiff appealed. The court concluded that the language at issue in both plans was ambiguous and did not clearly confer discretionary decision-making authority on the plan administrator. Therefore, the administrator's eligibility determinations denying benefits to a covered employee were subject to de novo judicial review, and the district court erred in reaching a contrary conclusion. The court further held that the district court erred in concluding that the employer's group insurance plan required objective proof of disability in order for an employee to qualify for plan benefits. Accordingly, the court vacated and remanded for further proceedings. View "Cosey v. The Prudential Ins. Co." on Justia Law

Plaintiffs filed suit against the Sheriff of the City of Hampton, Virginia, in his individual capacity and in his official capacity, alleging that the Sheriff retaliated against plaintiffs in violation of their First Amendment rights by choosing not to reappoint them because of their support of his electoral opponent. The court concluded that, as to the claims of Plaintiffs Sandhofer, Woodward, and Bland, the district court properly analyzed the merits of the claims; as to the claims of Plaintiffs Carter, McCoy, and Dixon, the district court erred by concluding that plaintiffs failed to create a genuine dispute of material fact regarding whether the Sheriff violated their First Amendment rights; nevertheless, the district court properly ruled that the Sheriff was entitled to qualified immunity on Carter's McCoy's, and Dixon's claims seeking money damages against the Sheriff in his individual capacity, and that the Sheriff was entitled to Eleventh Amendment immunity against those claims to the extent they sought monetary relief against him in his official capacity; and the Sheriff was not entitled to Eleventh Amendment immunity on Carter's, McCoy's and Dixon's claims to the extent the remedy sought was reinstatement. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Bland v. Roberts" on Justia Law

WCS filed suit against the Unions and the Fund under the Labor Management Relations Act (LMRA), 29 U.S.C. 187, alleging that defendants orchestrated fourteen separate legal challenges against their commercial real estate project in order to force WCS to terminate their relationship with a non-unionized supermarket. WCS alleged that this was an illicit "secondary boycott" under 29 U.S.C. 158(b)(4)(ii)(B). The court affirmed the district court's decision to dismiss the complaint against the Fund because it was not a "labor organization" under the LMRA. The court concluded, however, that the district court erred in dismissing WCS's claims against the Unions where there remained a genuine issue of material fact as to whether the pattern of litigation alleged in WCS's complaint derived from "a policy of starting legal proceedings without regard to the merits and for the purpose of" waging a secondary boycott. Accordingly, the court vacated the dismissal of WCS's complaint as to the remaining union defendants and remanded for further proceedings. View "Waugh Chapel South, LLC v. United Food and Commercial Workers Union" on Justia Law

Mingo Logan challenged the award of benefits to claimant under the Black Lung Benefits Act (BLBA), 30 U.S.C. 921(c)(4). Because the court concluded that the ALJ did not in fact apply rebuttal limitations to Mingo Logan, and the Board affirmed the ALJ's analysis, the court did not reach Mingo Logan's challenge to the standard announced by the Board to rebut the section 921(c)(4) presumption of entitlement to benefits. The court affirmed the Board's award of benefits because it also found that Mingo Logan's other challenges to the ALJ's factual findings lacked merit. Accordingly, the court denied the petition for review. View "Mingo Logan Coal Co. v. Owen" on Justia Law

Claimant was awarded benefits under the Black Lung Benefits Act (BLBA), 30 U.S.C. 901-945. At issue was whether the awards of attorneys' fees properly reflected market-based evidence of counsel's hourly rate, as required by the lodestar analysis in Hensley v. Eckerhart. The court held that neither the ALJ nor the BRB abused its discretion in concluding that counsel provided sufficient market-based evidence of rates, and that the number of hours billed for attorneys' services reasonably reflected the work completed. The court also held that the award of fees for work performed by certain legal assistants was not supported fully by the record, and modified that award accordingly. View "Eastern Associated Coal Corp. v. DOWCP" on Justia Law

This case arose when plaintiff, a longshoreman, slipped and fell on Oldendorff's ship during loading operations. On appeal, Oldendorff challenged the judgment entered on a jury verdict under section 5(b) of the Longshore and Harbor Workers' Compensation Act, 33 U.S.C. 905(b). The court concluded that the district court did not err in denying plaintiff's motions for judgment as a matter of law where a jury could reasonably find Oldendorff liable for simple negligence. The court also concluded that the district court did not abuse its discretion in denying the motion for a new trial where the district court properly informed the jury that a shipowner may be "liable for injury resulting directly from an unsafe condition on the ship of which it was aware and which it voluntarily agreed and undertook to remedy, but failed to do so." Accordingly, the court affirmed the judgment of the district court. View "Bunn v. Oldendorff Carriers GmbH & Co." on Justia Law

In these two consolidated cases, at issue was whether the Board had a quorum at the time it issued its decisions in 2012. First, the court determined that Enterprise and Huntington did not prevail on their statutory challenges under the National Labor Relations Act, 29 U.S.C. 151 et seq. The court denied the Board's applications for enforcement of its orders, concluding that the President's three January 4, 2012 appointments to the Board were constitutionally infirm because the appointments were not made during "the Recess of the Senate." View "NLRB v. Enterprise Leasing Co." on Justia Law