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

A coal miner was employed at the Burke Mountain Mine Complex until October 2019, when he was told the mine was “shut down” and his job was terminated without receiving advance notice. He brought a class action lawsuit on behalf of himself and other similarly situated employees against five related mining companies, alleging they failed to provide notice of termination as required by the Worker Adjustment and Retraining Notification Act (WARN Act). Evidence at trial showed that the companies shared common officers, directors, ownership, and business addresses, and that personnel and equipment were regularly exchanged among them. Employees testified that the companies operated interchangeably and were managed collectively by the same family.The United States District Court for the Southern District of West Virginia certified the class, denied summary judgment to both sides, and submitted the matter to a jury. The jury found the companies liable under the WARN Act, determining that they operated as a single employer and that at least 50 employees suffered an employment loss through termination or reduction in hours. The district court entered judgment for the plaintiff and, after trial, denied the defendants’ renewed motion for judgment as a matter of law or, alternatively, for a new trial. The companies appealed, challenging both the sufficiency of the evidence and the jury instructions.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court’s judgment. The court held that the jury had sufficient evidence to conclude the companies were a single employer under the WARN Act and that the district court’s instruction regarding the definition of employment loss was correct. The court also found that the companies forfeited any argument regarding an inconsistent jury verdict by failing to object before the jury was discharged. View "Gautier v. Tams Management, Inc." on Justia Law

A group of current and former battalion chiefs employed by the City of Alexandria Fire Department alleged that the City failed to pay them overtime wages as required by the Fair Labor Standards Act (FLSA). The battalion chiefs’ compensation was based on a complex pay structure. Chiefs worked either operational or administrative schedules. Operational chiefs rotated through 24-hour shifts within a nine-day cycle, and administrative chiefs worked a standard 40-hour week. The City paid the chiefs a predetermined amount per pay period, corresponding to either 80 administrative hours or 106 operational hours, regardless of the exact number of hours worked, with additional compensation for hours worked beyond their scheduled shifts.The United States District Court for the Eastern District of Virginia granted summary judgment for the City. The district court found that the chiefs were exempt from the FLSA’s overtime requirements under the “highly compensated employee” exemption. Specifically, the court held that the chiefs were paid on an hourly basis and applied the salary basis test found in 29 C.F.R. § 541.604(b). The court concluded the chiefs received guaranteed pay that satisfied the regulatory requirements and that the pay had a reasonable relationship to their usual earnings.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment but for different reasons. The appellate court held that the district court applied the wrong salary basis test, finding that the appropriate test was under 29 C.F.R. § 541.602(a), which applies to employees paid on a weekly or less frequent salary basis. The court concluded that, despite the complexity of the pay system, the chiefs received a predetermined salary not subject to improper deductions and, therefore, were compensated on a salary basis. As a result, the chiefs were correctly deemed exempt from overtime requirements, and the district court’s decision was affirmed. View "Kelly v. City of Alexandria" on Justia Law

The case concerns the fatal shooting of Kwamena Ocran by four Gaithersburg Police Department officers in January 2021. Ocran, who had recently been released from prison and was reported by a confidential informant to be armed, was surveilled by the officers after the informant indicated Ocran might attempt to sell a handgun. When Ocran left an apartment with the informant and was approached by the officers, he fled. The officers pursued him, and during the chase, multiple officers reported seeing a muzzle flash and believed Ocran fired a weapon in their direction. The officers collectively discharged 27 rounds, resulting in Ocran’s death. Forensic evidence revealed Ocran was shot multiple times in the back, and a handgun was found near his body, though no evidence indicated it had been fired.After discovery, Melody Cooper, Ocran’s mother and personal representative, brought a 42 U.S.C. § 1983 claim alleging excessive force in violation of the Fourth Amendment. The United States District Court for the District of Maryland denied the officers’ motion for summary judgment and rejected their claim of qualified immunity, finding genuine disputes of material fact existed—particularly regarding whether Ocran pointed or fired his weapon at the officers. The court also denied the officers’ motion for reconsideration.On appeal, the United States Court of Appeals for the Fourth Circuit dismissed the officers’ appeal to the extent it challenged the district court’s findings of disputed material facts, as such findings are not reviewable under the collateral order doctrine. The Fourth Circuit affirmed the district court’s ruling that, accepting the undisputed facts, the officers were not entitled to qualified immunity because the right to be free from deadly force when fleeing and not posing a significant threat was clearly established at the time of the incident. The case was remanded for further proceedings, including a jury trial. View "Cooper v. Doyle" on Justia Law

In September 2020, a college student alleged she was sexually assaulted by a man during a late-night traffic stop in Virginia. She reported the incident to local law enforcement and participated in multiple interviews with detectives, who investigated her claims but found surveillance footage that was low-quality and recorded at a different time than the alleged assault. During a subsequent interview, detectives pressured her about inconsistencies in the evidence and, after the interview, she received threatening text messages. The detectives later told university officials she had confessed to fabricating her report. The sheriff then directed detectives to use her confession as probable cause for an arrest warrant charging her with filing a false police report. After her arrest, officers issued a press release with her personal information and photo, which led to widespread public shaming and emotional distress.Initially, she was convicted in a bench trial in Washington County District Court, but after appealing, her conviction was annulled and she was acquitted in a de novo bench trial in Washington County Circuit Court. She then sued the officers and the sheriff in the United States District Court for the Western District of Virginia, alleging violations of her constitutional rights and state law torts.The district court dismissed the complaint under Rule 12(b)(6), relying on an audio recording of the key interview. The court found the recording contradicted her claims of coercion, ruling that it showed a civil discussion without coercion and that her confession appeared voluntary. It also found her allegation of having no choice but to confess was not credible based on the recording.The United States Court of Appeals for the Fourth Circuit reviewed the case. It held that the district court erred by dismissing the complaint based on the audio recording, because the recording did not "blatantly contradict" her factual allegations as required by Fourth Circuit precedent. The appellate court vacated the dismissal and remanded the case for further proceedings. View "Bermeo v. Andis" on Justia Law

The dispute centers on a Florida-based construction project, where Westerfeld Construction by Glick, LLC served as the general contractor. Westerfeld, a Florida company, retained Jessup Construction, LLC as a subcontractor. Jessup and GSH of Alabama, LLC entered into a joint venture to work on the project and later obtained a $5.8 million loan from Mobilization Funding, LLC, a company with operations in South Carolina. The loan contracts involved Mobilization Funding, Jessup, GSH, and individual guarantors, and included South Carolina choice-of-law and venue provisions. Westerfeld was not a party to these loan contracts. When Jessup allegedly defaulted, Mobilization Funding sued Jessup, GSH, and the guarantors in South Carolina, and GSH, joined by individual guarantors, brought third-party claims against Westerfeld, alleging conspiracy and fraud.After removal, the United States District Court for the District of South Carolina reviewed Westerfeld’s motion to dismiss for lack of personal jurisdiction. Applying the prima facie standard, the district court held that it lacked both general and specific jurisdiction over Westerfeld. The court found Westerfeld had no offices, employees, or business activities in South Carolina and was not party to any South Carolina-centered agreements. The court also determined that GSH’s conspiracy allegations were conclusory and did not plausibly tie Westerfeld to conduct in South Carolina sufficient to establish jurisdiction. The district court dismissed the third-party complaint against Westerfeld and certified its order as final.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s ruling de novo. The Fourth Circuit affirmed, holding that Westerfeld did not have sufficient minimum contacts with South Carolina to justify the exercise of personal jurisdiction under the Due Process Clause. The court rejected both direct and conspiracy-based theories of jurisdiction, concluding that GSH failed to present plausible, particularized facts to support jurisdiction over Westerfeld. The judgment of dismissal was affirmed. View "Stokes v. Westerfeld Construction by Glick, LLC" on Justia Law

Cherry Grove Beach Gear, LLC, operated by Derek and Jacqueline Calhoun, began providing beach equipment rentals and setup services on public beaches in the City of North Myrtle Beach, South Carolina, starting in 2020. The City informed CGBG that its activities violated local ordinances, but the company continued operating despite repeated warnings and complaints from competitors. In response, the City enacted a new ordinance in June 2022 that explicitly restricted professional setup of beach equipment on City beaches to City officials only. CGBG persisted with its services and received several citations for noncompliance.Following these actions, CGBG filed a lawsuit in the United States District Court for the District of South Carolina, alleging that the City had unlawfully established a monopoly over beach equipment rentals and setup services, violating federal antitrust law. The district court granted summary judgment in favor of the City, determining that the municipal ordinances qualified for state action immunity from federal antitrust liability under the Parker doctrine, based on relevant South Carolina statutes.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s decision de novo. The Fourth Circuit held that the South Carolina statutes in question clearly articulated and affirmatively expressed state policy allowing municipalities to create exclusive franchises for beach equipment rentals and setup, and that the anticompetitive effects were a foreseeable result of this legislative authorization. The court also rejected CGBG’s argument for a “market participant exception” to state action immunity, noting that precedent does not recognize such an exception. Consequently, the Fourth Circuit concluded that the City is entitled to state action immunity and affirmed the district court’s judgment. View "Cherry Grove Beach Gear, LLC v. City of North Myrtle Beach" on Justia Law

Several individuals attended a Loudoun County School Board meeting intending to speak during the public-comment period about recent news involving the Board’s reinstatement of a student who had previously been arrested and allegedly threatened another student. They wished to express concerns regarding the Board’s handling of school safety, particularly in relation to this specific student. During the meeting, the School Board Chair interrupted several of these individuals, invoking a Board policy that prohibits speakers from targeting, criticizing, or attacking individual students during public comments, and advised that such concerns should instead be directed privately to school officials.After these interruptions, the affected individuals filed suit in the United States District Court for the Eastern District of Virginia. Their complaint alleged that, as applied to them, the Board’s policy constituted impermissible viewpoint discrimination under the First Amendment, and that the policy was unconstitutionally vague. They sought a temporary restraining order and a preliminary injunction to prevent enforcement of the policy against them. The district court denied both requests, finding that the plaintiffs had not demonstrated a sufficient likelihood of success on the merits of their claims.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s denial of the preliminary injunction. The Fourth Circuit affirmed the lower court’s decision, holding that the plaintiffs were unlikely to succeed on either claim. The court found that the policy was a reasonable, viewpoint-neutral restriction appropriate to the limited public forum of the school board’s meetings, and that the interruptions were consistent with the policy’s facial requirements, not discriminatory based on viewpoint. Furthermore, the court determined that the policy language—prohibiting comments that “target, criticize, or attack individual students”—was not unconstitutionally vague, providing sufficient notice and guidance for enforcement. The judgment of the district court was affirmed. View "Platt v. Mansfield" on Justia Law

A sixteen-year-old boy and his friend were waiting for transportation under a carport near the boy’s home when they were approached by an off-duty Baltimore City police officer who had just returned from firearms training. The officer, dressed in plain clothes and carrying a loaded handgun, questioned the boys about their presence in the neighborhood. After a brief exchange, the officer brandished his gun at “low ready,” causing the boys to fear for their lives. The incident had a lasting traumatic effect on the boy, resulting in emotional distress, behavioral changes, and ultimately leading him to attend a boarding school to distance himself from the event.The boy filed suit under 42 U.S.C. § 1983 and Maryland state law against the officer, the Baltimore Police Department, the Mayor and City Council of Baltimore, and the State of Maryland. All claims against the institutional defendants were dismissed by the United States District Court for the District of Maryland, and some claims against the officer were dismissed at summary judgment. At trial, the district court submitted to the jury both constitutional claims and state law gross negligence claims, including gross negligence in the officer’s capacity as a private person. The jury found for the officer on constitutional claims but found him grossly negligent as a private person, awarding $250,000 in compensatory damages for emotional harm. The officer moved to alter or amend the judgment or for a new trial, arguing lack of notice on the private person claim and excessiveness of damages, but the district court denied the motion.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed. The court held that the complaint sufficiently alleged gross negligence as a private person and that the officer had notice of this claim. The court rejected the officer’s arguments regarding supplemental jurisdiction, plain error in jury instructions, and excessiveness of damages, finding no abuse of discretion or plain error by the district court. The judgment was affirmed. View "Nicholson v. Durant" on Justia Law

A dual citizen of the United States and Pakistan, the defendant traveled from the U.S. to Pakistan in 2009, along with four others, with the intent to join jihad in Afghanistan. Upon arrival, the group attempted to make contact with terrorist organizations and made efforts to cross into Afghanistan. Pakistani authorities arrested them in Sargodha, Pakistan, and subsequently tried and convicted them on terrorism-related offenses. The defendant served approximately ten years in a Pakistani prison. After completing his sentence, he was extradited to the United States, where he faced federal charges arising from the same underlying conduct.The United States District Court for the Eastern District of Virginia arraigned the defendant and, after he waived his Speedy Trial Act rights, considered his motion to dismiss the indictment on Sixth Amendment speedy trial grounds. The motion argued that the government’s delay in seeking his extradition and prosecution in the U.S. violated his constitutional rights. The district court denied the motion, finding that, although the length of the delay was significant, the government made reasonably diligent and good-faith efforts to secure his return, and the remaining factors weighed against finding a violation. The defendant entered a conditional guilty plea, reserving his right to appeal the speedy trial ruling.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s decision, applying the four-factor balancing test from Barker v. Wingo. The appellate court agreed that only the length of the delay favored the defendant, but reasoned that the government’s efforts, the defendant’s own conduct in resisting extradition, and the absence of actual prejudice outweighed that factor. The court held there was no Sixth Amendment speedy trial violation and affirmed the conviction. View "US v. Chaudhry" on Justia Law

Crystal Hultz, a woman born in 1987, stopped working full-time in December 2013 due to multiple health conditions, including lupus, fibromyalgia, spinal disorders, and depression. Although some of her conditions improved with treatment and surgery, she continued to experience severe, persistent symptoms of fibromyalgia, leading to fatigue and periods of being bedridden. Her daily functioning depended heavily on support from her family. Based on these ongoing symptoms, Hultz applied for Social Security disability benefits, asserting that her fibromyalgia and related health problems rendered her unable to work.Her claims for benefits were initially denied by the Social Security Administration (SSA) and again after reconsideration. Following a hearing, an Administrative Law Judge (ALJ) denied her applications, a decision upheld by the SSA's Appeals Council. Hultz sought review in the United States District Court for the District of Maryland, which remanded the case to the ALJ for further consideration of certain impairments. On remand, another ALJ again denied benefits, finding that Hultz's subjective reports of her symptoms were not fully supported by objective medical evidence. The District Court affirmed this denial.The United States Court of Appeals for the Fourth Circuit reviewed the case and found that the ALJ erred by discounting Hultz’s subjective testimony about her fibromyalgia symptoms based on a lack of objective medical evidence. The Fourth Circuit emphasized its precedent that, for conditions like fibromyalgia—which cannot be measured by objective tests—ALJs may not use the absence of such evidence to discredit claimants’ subjective accounts. The court also held that the ALJ improperly gave little weight to the opinion of Hultz’s treating physician. The Fourth Circuit reversed the denial of benefits and remanded the case for a calculation of benefits. View "Hultz v. Bisignano" on Justia Law