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

Lois Ann Brown slipped and fell on ice in the parking lot of a Wal-Mart in Lynchburg, Virginia, on January 28, 2021, following a snowstorm the previous night. The snowstorm ended by 6:15 AM, and Brown fell at approximately 8:30 AM. Brown did not see any salt or deicing chemicals on the ground or on her clothing after the fall. The store manager, Anthony Ware, confirmed that he did not see any salt or chemicals in the parking lot. Surveillance footage showed the contractor's truck driving around the parking lot but not stopping or applying any deicing measures.Brown initially filed a negligence lawsuit against Wal-Mart in state court, seeking $300,000 in damages. Wal-Mart removed the case to the United States District Court for the Western District of Virginia. The district court granted summary judgment in favor of Wal-Mart, holding that Brown failed to show that Wal-Mart had actual or constructive notice of the specific patch of ice and that Brown did not provide sufficient evidence to prove that Wal-Mart breached its duty of care.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the snowstorm itself provided Wal-Mart with notice of the ice and snow in the parking lot, creating a duty to use reasonable care to remove the hazards. The court found that there was a genuine dispute of material fact regarding whether Wal-Mart breached its duty of care. The evidence, including conflicting testimonies and surveillance footage, suggested that a reasonable jury could find for either party. Therefore, the Fourth Circuit vacated the district court's grant of summary judgment and remanded the case for further proceedings. View "Brown v. Wal-Mart Stores East, LP" on Justia Law

Eugene Kritter, an experienced helicopter pilot, owned and operated Kritter Cropdusting. While crop dusting over a farm in North Carolina, his helicopter collided with a low-hanging steel wire, resulting in his death. Kritter Cropdusting and Kritter’s estate filed a negligence lawsuit against the farm owners and operators, as well as Nutrien, the pesticide company that hired Kritter Cropdusting for the job.The United States District Court for the Eastern District of North Carolina granted summary judgment in favor of the defendants. The court concluded that the farm owners and operators owed no duty of care to Kritter to remove or warn about the wire, as the risk was not reasonably foreseeable to them. The court also found that neither Nutrien nor its employee, Elmore, owed Kritter a duty of care. Additionally, the court rejected the argument that Kritter was contributorily negligent and found that the wire was not an open and obvious condition.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that summary judgment was inappropriate because material questions of fact remained regarding whether the defendants owed a duty of care to Kritter. The court noted that under North Carolina law, issues of negligence are generally for the jury to decide, especially when facts are disputed or multiple reasonable inferences can be drawn. The court also found that the district court erred in concluding that the risk posed by the wire was not foreseeable and that Kritter’s death was incident to his work. The Fourth Circuit vacated the district court’s summary judgment and remanded the case for further proceedings. View "Kritter v. Mooring" on Justia Law

The case involves Raymond Dugan, who was convicted and sentenced in the Southern District of West Virginia for accessing child pornography. Dugan raised three main issues on appeal: the denial of his motion to compel discovery related to a foreign law enforcement agency's investigation, the denial of his motion to suppress evidence obtained from a search warrant, and the restitution order requiring him to pay $22,000 to five child victims.In the lower court, Dugan was convicted by a jury of accessing child pornography. He was sentenced to 54 months in prison, followed by five years of supervised release, and ordered to pay $22,000 in restitution. Dugan filed pretrial motions to compel discovery and suppress evidence, both of which were denied by the district court. The court found that the foreign agency's tip was reliable and that the search warrant was supported by probable cause. The court also ruled that the officers acted in good faith when executing the warrant.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court's decisions, holding that the denial of the motion to compel discovery was appropriate because Dugan's request was speculative and unsupported by evidence. The court also upheld the denial of the motion to suppress, finding that the search warrant was based on probable cause, given the deliberate steps required to access the child pornography website. Finally, the court found no abuse of discretion in the restitution order, as the district court had carefully considered the relevant factors and evidence in determining the amounts.The Fourth Circuit affirmed Dugan's conviction and sentence, including the restitution order. View "US v. Dugan" on Justia Law

Trina Cunningham, an employee of the Baltimore Department of Public Works, was responsible for monitoring water flow at the Patapsco Wastewater Treatment Plant. On June 3, 2019, while inspecting the plant's Grit Facility, Cunningham fell through a metal, grated catwalk that collapsed under her feet, causing her to drown in the wastewater chamber below. Her estate and family members filed a lawsuit against multiple defendants, including the City of Baltimore, various city officials, and several crane servicing companies, alleging negligence and other claims related to her death.The United States District Court for the District of Maryland granted motions to dismiss filed by most of the defendants, including Freeland Hoist & Crane, Inc., but did not address the claims against Crane 1 Services, Inc., and Overhead Crane Service, Inc., who had not filed motions to dismiss. The district court dismissed the entire complaint, despite the unresolved claims against these two defendants.The United States Court of Appeals for the Fourth Circuit reviewed the case and determined that the district court's order was not a final decision because it did not resolve all claims against all parties. The appellate court noted that the district court failed to address the claims against Crane 1 Services and Overhead Crane Services, and thus, the order was not appealable. Consequently, the Fourth Circuit dismissed the appeal for lack of jurisdiction and remanded the case to the district court to adjudicate the remaining claims. View "Estate of Cunningham v. Mayor and City Council of Baltimore" on Justia Law

In June 2015, Dylann Roof shot and killed nine people at Mother Emanuel AME Church in Charleston, South Carolina, including M.P.'s father, Reverend Clementa Pinckney. M.P., a minor, filed a lawsuit against Meta Platforms, Inc. (formerly Facebook, Inc.) and its subsidiaries, alleging that Facebook's algorithm recommended harmful content that radicalized Roof, leading to the murders. M.P. asserted claims of strict products liability, negligence, and negligent infliction of emotional distress under South Carolina law, as well as a federal claim under 42 U.S.C. § 1985(3) for conspiracy to deprive her of her civil rights.The United States District Court for the District of South Carolina dismissed M.P.'s complaint under Federal Rule of Civil Procedure 12(b)(6), concluding that Section 230 of the Communications Decency Act barred her state law tort claims. The court also found that M.P. failed to plausibly allege a claim under 42 U.S.C. § 1985(3).The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that M.P.'s state law tort claims were barred by Section 230 because they sought to hold Facebook liable as a publisher of third-party content. The court also determined that M.P. failed to plausibly allege proximate causation under South Carolina law, as her complaint did not provide sufficient factual foundation linking Roof's Facebook use to his crimes. Additionally, the court found that M.P. forfeited her challenge to the dismissal of her Section 1985 claim by not adequately addressing it in her appellate brief. The court also concluded that any potential claim under 42 U.S.C. § 1986 was barred by the one-year statute of limitations. Thus, the Fourth Circuit affirmed the district court's judgment granting Facebook's motion to dismiss. View "M.P. v. Meta Platforms Inc." on Justia Law

Andre Le Doux was driving on Interstate 81 in Virginia when he encountered a sudden traffic standstill due to a torrential downpour. As he braked, a vehicle behind him pushed his van into another vehicle, leaving his van exposed in the left lane. Ervin Worthy, driving a Western Express tractor trailer, saw the heavy rain and braked, but could not stop in time and collided with Le Doux’s van, causing severe injuries to Le Doux.Le Doux sued Worthy for negligence and willful and wanton negligence, and Western Express for vicarious liability and negligent hiring. The United States District Court for the Western District of Virginia excluded expert testimony from Le Doux’s meteorologist and accident reconstructionist due to gaps in radar data and inaccurate GPS timestamps. The court also excluded testimony from Le Doux’s trucking expert, finding it unnecessary for the jury to understand the standard of care for a tractor trailer driver in rainy conditions. Additionally, the court dismissed Le Doux’s negligent hiring claim against Western Express, reasoning that since Worthy was acting within the scope of his employment, the claim was redundant.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court’s exclusion of the expert testimonies, agreeing that the gaps in data and potential jury confusion justified the decision. The court also upheld the exclusion of the trucking expert’s testimony, finding that the jury could understand the necessary standard of care without it. Finally, the court affirmed the dismissal of the negligent hiring claim, holding that since the jury found Worthy not negligent, Western Express could not be liable for negligent hiring. The Fourth Circuit concluded that the district court did not abuse its discretion in its rulings. View "Le Doux v. Western Express, Inc." on Justia Law

Dr. Anita Jackson, an otolaryngologist, was convicted of various offenses related to her private medical practice in North Carolina. She was the leading Medicare biller for balloon sinuplasty surgery, a procedure treating chronic sinusitis. Jackson reused single-use medical devices, specifically the Entellus XprESS Multi-Sinus Dilation Tool, on multiple patients without proper sterilization, leading to potential contamination. She also incentivized employees to recruit Medicare patients for the procedure, often bypassing proper medical assessments. Additionally, Jackson falsified documents and patient signatures in response to Medicare audits.The United States District Court for the Eastern District of North Carolina convicted Jackson on all counts, including violating the Food, Drug, and Cosmetics Act (FDCA) by holding for resale adulterated medical devices, violating the federal anti-kickback statute, making materially false statements, committing aggravated identity theft, mail fraud, and conspiracy. Jackson was sentenced to twenty-five years in prison and ordered to pay over $5.7 million in restitution. She moved for a judgment of acquittal and a new trial, which the district court denied.The United States Court of Appeals for the Fourth Circuit reviewed the case. Jackson argued that the devices were not "held for sale" under the FDCA, that her actions were protected under 21 U.S.C. § 396, and that the Government relied on a defective theory of per se adulteration. She also challenged the exclusion of certain evidence and jury instructions. The Fourth Circuit found no reversible error in the district court's rulings, holding that the devices were indeed "held for sale," that § 396 did not protect her conduct, and that the Government's theory was valid. The court also upheld the exclusion of evidence and the jury instructions. Consequently, the Fourth Circuit affirmed all of Jackson's convictions. View "United States v. Jackson" on Justia Law

In 2018, Gary Washington was released from prison after serving 31 years for murder, following a writ of actual innocence. Washington filed a civil lawsuit against the police officers involved in his case, alleging they coerced a witness into providing false testimony, which was later recanted. The district court granted summary judgment in favor of the officers, dismissing Washington's claims of due process violations, malicious prosecution, detention without probable cause, failure to intervene, and intentional infliction of emotional distress. The court found Washington was collaterally estopped from relying on the witness's recantation because a prior state court had found it incredible. The district court also dismissed Washington's alternative due process Brady claim and his intentional infliction of emotional distress claim on independent grounds.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the state court decision granting Washington a writ of actual innocence was inconsistent with the prior post-conviction ruling that the recantation was incredible, precluding the application of collateral estoppel. The court also found that applying collateral estoppel to prohibit Washington from litigating the alleged misconduct was incompatible with equitable principles. The court agreed with the district court's dismissal of Washington's alternative due process Brady claim but reversed the dismissal of his intentional infliction of emotional distress claim, finding that wrongful incarceration for 31 years could constitute severe emotional distress.The Fourth Circuit reversed the district court's grant of summary judgment in part and affirmed it in part, allowing Washington's claims of due process violations, malicious prosecution, detention without probable cause, failure to intervene, and intentional infliction of emotional distress to proceed. View "Washington v. Pelligrini" on Justia Law

On February 1, 2020, four Pineville Police Department officers responded to a 911 call about a Black man allegedly waving a gun. They found Timothy Caraway walking alone with a cellphone in his hand. The officers, with weapons drawn, commanded Caraway to raise his hands and drop what they thought was a gun. As Caraway reached into his jacket to discard the gun, Officers Adam Roberts and Jamon Griffin fired twelve shots, hitting Caraway four times. Caraway sued the officers and the City of Pineville under 42 U.S.C. § 1983 and North Carolina law, alleging excessive force and assault and battery, among other claims.The United States District Court for the Western District of North Carolina granted summary judgment to the officers, finding they were entitled to qualified immunity on the Fourth Amendment excessive force claim and public official immunity on the state-law assault and battery claim. The court concluded that the officers' use of deadly force was reasonable because Caraway's gun was pointed at them in the moments before the shooting.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The appellate court held that the officers' use of deadly force was reasonable under the Fourth Amendment because Caraway's gun was pointed at the officers, posing an immediate threat. The court also upheld the grant of public official immunity on the state-law claims, finding that the officers acted without malice. The court declined to segment the shooting into different phases, noting the entire sequence lasted only a few seconds. View "Caraway v. City of Pineville" on Justia Law

The case involves a dispute over the award of black lung benefits to the surviving wife of the late Bruce E. Goode, who worked for American Energy as a coal miner and suffered from a severe chronic obstructive pulmonary disability. American Energy disputed the cause of his impairment, arguing that it was due to his long-term cigarette smoking, not his coal mine employment. An administrative law judge (ALJ) found that Mr. Goode’s disability arose from his coal mine employment and awarded black lung benefits. The Benefits Review Board affirmed the award.American Energy appealed, arguing that the ALJ applied an incorrect legal standard. The company contended that the Black Lung Benefits Act and its implementing regulations require a miner to prove that coal dust caused the lung disease or made it worse. American Energy argued that the ALJ reversed the burden of proof by finding that the company had not proven why Mr. Goode’s lung disease was not at least partially due to coal dust exposure.The United States Court of Appeals for the Fourth Circuit agreed that the ALJ applied the wrong legal standard in determining that Mr. Goode had legal pneumoconiosis. However, the court noted that the ALJ also concluded that Mr. Goode’s clinical pneumoconiosis entitled him to benefits. The court granted American Energy’s petition and vacated and remanded the Board’s order for further proceedings. View "American Energy, LLC v. Director, Office of Workers' Compensation Programs" on Justia Law