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

After the Boards of Directors filed lawsuits raising claims related to a residential community, a resident filed a derivative action alleging similar claims against nearly identical defendants. The district court dismissed the derivative action and the Boards settled the lawsuits in the meantime.The Fourth Circuit held that the settlements mooted the resident's claims insofar as they were related to the ones asserted by the Boards. Therefore, the court dismissed his appeal as to those claims for lack of subject matter jurisdiction. To the extent the resident asserted claims falling outside the scope of those asserted by the Boards' complaints, the court concluded that those claims were either also rendered moot by the settlement agreements or were otherwise properly dismissed by the district court. View "Star v. TI Oldfield Development, LLC" on Justia Law

The Estate of Wayne Jones filed suit under 42 U.S.C. 1983 against police officers and the City after officers fired 22 bullets at Jones, a black man experiencing homelessness, and killed him. In this case, Jones, although armed with a knife, had been secured by the officers immediately before he was released and shot. Jones was also incapacitated at the time he was shot. The district court granted summary judgment to defendants.Although the Fourth Circuit agreed that the City is insulated from Monell liability premised on one incident of excessive force, the court reversed the grant of summary judgment to the officers on qualified immunity grounds. The court held that it was clearly established at the time that officers may not shoot a secured or incapacitated person and a reasonable jury could find that Jones was both secured and incapacitated in the final moments before his death.The court recognized that police officers are often asked to make split-second decisions, but expected them to do so with respect for the dignity and worth of black lives. The court noted yet another death of a black man at the hands of the police, the recent killing of George Floyd in Minneapolis. The court stated that this has to stop. To award qualified immunity at the summary judgment stage in this case would signal absolute immunity for fear-based use of deadly force, which the court cannot accept. View "Estate of Wayne A. Jones v. City of Martinsburg" on Justia Law

The Fourth Circuit affirmed the district court's imposition of a condition of supervised release requiring defendant to comply with the rules of his sex-offender treatment program, which ban him from viewing any materials that sexually arouse him. The court held that the ban is permissible under 18 U.S.C. 3583(d) and is not overbroad because the district court made an individualized assessment, based on the testimony of defendant's treatment provider, that it was necessary. Furthermore, it is enforced in a way that avoids the issues with which the vagueness doctrine is concerned, and it is not an impermissible delegation because only the district court will decide whether defendant violated his conditions of release. View "United States v. Van Donk" on Justia Law

Plaintiff filed a pro se 42 U.S.C. 1983 action alleging that prison officials opened, copied, misdirected, and otherwise interfered with his mail to and from his lawyer. The district court granted summary judgment to defendants.The Fourth Circuit considered the Turner factors and concluded that they weighed in favor of plaintiff, holding that defendants violated his First Amendment right to free speech by opening his mail outside of his presence. However, the court held that defendants are entitled to qualified immunity with respect to plaintiff's unreasonable search and seizure claim under the Fourth Amendment where, defendants have met their burden to show that their actions did not violate clearly established law. Finally, the court held that plaintiff forfeited his claims regarding his First Amendment right of access to the courts and his Sixth Amendment right to the effective assistance of counsel by failing to raise them in his informal brief. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Haze v. Harrison" on Justia Law

Plaintiffs alleged that Proclamation 9645, which imposed certain restrictions on the entry of individuals from eight countries, violates their rights under the Establishment Clause, as well as under other clauses of the Constitution, because it lacks a rational relationship to legitimate national security concerns and is motivated solely by anti-Muslim animus.The government filed a motion to dismiss plaintiffs' complaints for failure to state a claim based mainly on the Supreme Court's recent decision in Trump v. Hawaii, 138 S. Ct. 2392 (2018), which reversed a preliminary injunction against the enforcement of Proclamation 9645 that had been issued on facts that are essentially the same as those alleged here. The Hawaii Court held that the government had "set forth a sufficient national security justification to survive rational basis review" and thus plaintiffs had not demonstrated that they were likely to succeed on the merits of their claims.The Fourth Circuit reversed the district court's judgment and held that the district court misunderstood the import of the Supreme Court's decision in Hawaii and the legal principles it applied. The court held that Proclamation 9645 restricts the entry of foreign nationals from specified countries, giving reasons for doing so that are related to national security, and it makes no reference to religion. In this case, although the district court agreed that the Mandel standard is controlling, it failed to apply the standard of review properly, moving past the face of the Proclamation to consider in its analysis external statements made by President Trump. The court proceeded beyond consideration of only the facially stated purposes of Proclamation 9645 and determined whether plaintiffs have alleged plausible constitutional claims under the rational basis standard of review. Under the rational basis standard, plaintiffs' constitutional claims failed because the Proclamation was plausibly related to the Government's stated objective to protect the country and improve vetting processes. The court remanded with instructions to dismiss the complaints. View "International Refugee Assistance Project v. Trump" on Justia Law

U.S. Home challenges the district court's orders granting judgment, prejudgment interest, and attorneys' fees to Parkway in an action stemming from disputes over land and purchase development contracts.The Fourth Circuit held that the plain language of the contracts supports the district court's conclusion that Parkway's lawsuit is timely. In this case, Parkway's cause of action did not accrue until 2017, and the lawsuit was filed in the same year. However, the court held that the district court erred in ordering U.S. Home to pay prejudgment interest dating from May 27, 2008 and attorneys' fees. Under Maryland law, the court explained that Parkway is entitled to prejudgment interest only from the date of the purchase in 2017. Under the contract, Parkway may not be awarded attorneys' fees. Accordingly, the court reversed and vacated in part, remanding for instructions to award prejudgment interest from April 21, 2017. View "Parkway 1046, LLC v. U.S. Home Corporation" on Justia Law

The Fourth Circuit reversed defendant's sentence and remanded for resentencing, holding that 22 of his conditions for supervised release are inconsistent with his oral sentence and therefore void. In this case, the written judgment's 22 "standard" conditions are not part of defendant's sentence because the district court did not pronounce them orally at his sentencing hearing. The court explained that the requirement that discretionary conditions be pronounced in open court gives defendants a chance to object to conditions that are not tailored to their individual circumstances and ensures that they will be imposed only after consideration of the factors set out in 18 U.S.C. 3583(d). View "United States v. Rogers" on Justia Law

After Affinity was sued for allegedly submitting Medicaid reimbursement claims for services that they never provided, it sought coverage for the suit under its insurance policy with StarStone. StarStone denied coverage because the lawsuit's claims did not fall within the policy's coverage for "damages resulting from a claim arising out of a medical incident." The district court agreed and granted judgment on the pleadings against Affinity on a declaratory judgment claim and breach of contract claim.The Fourth Circuit first found that it had appellate jurisdiction over the appeal, because Affinity properly appeals from a "final" decision. In this case, Affinity properly appealed the district court’s order dismissing its contractual claims after voluntarily dismissing extra-contractual claims that were necessarily precluded by the order. On the merits, the court applied North Carolina law and held that the allegations in the underlying complaint fall within the insurance policy's coverage provision. The court found that the False Claims Act action "arises out of" a medical incident as required to fall under the coverage provision of StarStone's policy. Accordingly, the court vacated the district court's order granting StarStone's motion for judgment on the pleadings and vacated the order denying Affinity's motion for partial summary judgment. View "Affinity Living Group, LLC v. Starstone Specialty Insurance Co." on Justia Law

CSX argued that SCVA impermissibly discriminates against railroads in violation of the Railroad Revitalization and Regulatory Reform Act of 1976. The Fourth Circuit reversed the district court's determination that South Carolina had provided sufficient justification for the discriminatory tax. The court held that CSX has made a prima facie showing of discriminatory tax treatment based on the appropriate comparison class of other commercial and industrial real property taxpayers in South Carolina. Furthermore, the state's three justifications -- the equalization factor applied to railroad assessments, the combined effect of other tax exemptions applied to rail carriers, and assessable transfers of interest which trigger new appraisals -- were insufficient to justify the discriminatory tax scheme. View "CSX Transportation, Inc. v. South Carolina Department of Revenue" on Justia Law

Plaintiff filed suit pro se against Brivo, alleging discrimination based on race in violation of Title VII. In this case, within an hour of starting orientation at Brivo, Brivo's security architect approached plaintiff and confronted him about a newspaper article that he had found after running a Google search on plaintiff. The article reported plaintiff's tangential involvement in a shooting for which he faced no charges. Nonetheless, the security architect berated plaintiff about the incident, declared plaintiff unfit for employment at Brivo, and terminated him on the spot. The district court dismissed the case with prejudice, because plaintiff failed to plead sufficient facts to plausibly support a claim of discrimination.The Fourth Circuit held that it had appellate jurisdiction despite the district court's dismissal of the complaint without prejudice. Under Domino Sugar Corp. v. Sugar Workers Local Union 392, 10 F.3d 1064, 1067 (4th Cir. 1993), the order is appealable because the district court held that the circumstances surrounding plaintiff's termination did not expose Brivo to legal liability, and plaintiff has no additional facts that could be added to his complaint; under Chao v. Rivendell Woods, Inc., 415 F.3d 342, 345 (4th Cir. 2005), the order is appealable because the district court dismissed the complaint and directed that the case be closed; and the order is likewise appealable under Chao and In re GNC Corp., 789 F.3d at 511, because plaintiff has elected to stand on his complaint as filed.On the merits, the court held that the district court did not err by dismissing the Title VII claims at this point in the proceedings. The court held that plaintiff failed to plead sufficient facts to plausibly claim his termination or the Google search that lead to it was racially motivated. Accordingly, the court affirmed the judgment. View "Bing v. Brivo Systems, LLC" on Justia Law