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

by
In this case, Kenneth Kelley pled guilty to twenty-eight counts arising from a fatal car accident that resulted in the death of five people. The charges ranged from manslaughter by auto to driving with an expired license. Kelley later argued that his guilty plea was not knowing and voluntary because he wasn't informed of the nature and elements of the offenses to which he was pleading guilty. However, the United States Court of Appeals for the Fourth Circuit rejected this argument. The Court held that Kelley was informed of the offenses' elements as he testified at his plea hearing that he had read the indictment, his attorney had discussed the matter thoroughly with him, and he had signed a waiver acknowledging that he understood the charges and their elements. The Court also noted that the judge at the plea hearing had explained the charges to Kelley and that the prosecution had read its factual basis into the record at the plea hearing. The Court therefore concluded that Kelley's plea was knowing and voluntary. Consequently, the Court reversed the judgment of the district court and remanded with instructions to deny Kelley's habeas corpus petition. View "Kelley v. Bohrer" on Justia Law

Posted in: Criminal Law
by
In this case, the United States Court of Appeals for the Fourth Circuit was asked to determine the constitutionality of a process for selecting a student member of a county school board in Howard County, Maryland. Two parents sued the board, arguing that allowing public-school students to elect the student member diminishes adults’ voting power, violating the Equal Protection Clause, and that the selection process violates the Free Exercise Clause as it excludes students who opt not to attend public schools, including those who do so for religious reasons.The court affirmed the dismissal of both claims. It held that the selection process was "basically appointive rather than elective," therefore, the one-person, one-vote principle derived from the Equal Protection Clause was not applicable. The court also found that the selection process was neutral and generally applicable, thus it did not violate the Free Exercise Clause. The process excluded students who chose not to attend public school for any reason, not just those who did so for religious reasons. View "Kim v. Board of Education of Howard County" on Justia Law

by
In the case before the United States Court of Appeals for the Fourth Circuit, the plaintiff, Kristin Cosby, claimed that the South Carolina Probation, Parole & Pardon Services (SCPPP) had discriminated against her based on her gender and retaliated against her for filing discrimination complaints in violation of Title VII of the Civil Rights Act of 1964. Cosby had previously worked for SCPPP, left, and then reapplied in 2012. When she was not rehired, Cosby filed a discrimination charge with the Equal Employment Opportunity Commission (EEOC), which found in her favor. SCPPP rehired her, but Cosby alleged that she was subsequently subjected to gender discrimination and retaliation, including being denied a promotion, being investigated for inappropriate relationships with subordinates, and ultimately forced to resign.The court affirmed the district court's granting of summary judgment to SCPPP. The court held that Cosby had failed to establish her gender discrimination claim under both the disparate treatment and hostile work environment theories. For the disparate treatment claim, Cosby failed to identify a valid comparator — a similarly situated individual of a different gender who was treated more favorably. In her hostile work environment claim, Cosby's internal complaint did not constitute protected activity under Title VII because it did not oppose an unlawful employment practice. The court also found no causal connection between Cosby's 2012 EEOC charge and any adverse employment action taken by SCPPP in 2018, defeating her retaliation claim. View "Cosby v. South Carolina Probation, Parole & Pardon Services" on Justia Law

by
In this case, a South Carolina court-appointed receiver brought an action against Travelers Casualty and Surety Company and other insurers, alleging breaches of insurance policies issued to a defunct company within a state receivership. Travelers removed the action to federal court, asserting diversity jurisdiction. However, the district court granted the receiver’s motion to remand the case back to state court. The court held that it lacked subject-matter jurisdiction because the case involved property of a state receivership exclusively under the jurisdiction of the state court (based on the doctrine articulated in Barton v. Barbour), and the removal lacked unanimous consent of all defendants due to a forum selection clause in some of the insurance policies issued to the defunct company.Upon appeal, the United States Court of Appeals for the Fourth Circuit dismissed the appeal, holding that the district court's conclusions in support of remand were at least colorably supported. The court found that the district court's reliance on a lack of subject-matter jurisdiction and procedural defect as grounds for remand were colorably supported, and thus, not reviewable under 28 U.S.C. § 1447(d). The court also concluded that it lacked jurisdiction to review the district court's remand order and dismissed the appeal. View "Protopapas v. Travelers Casualty and Surety Co." on Justia Law

by
A former medical student at the University of Virginia School of Medicine, Kieran Bhattacharya, sued multiple university officials, alleging they reprimanded, suspended, and expelled him in violation of the First Amendment because of his views expressed during a faculty panel on microaggressions. The officials asserted that they took these actions due to Bhattacharya’s confrontational and threatening behavior.The United States District Court for the Western District of Virginia held that Bhattacharya could not provide evidence that the officials punished him due to his speech, siding with the officials. Bhattacharya appealed to the United States Court of Appeals for the Fourth Circuit.The Fourth Circuit affirmed the district court's decision. The court held that Bhattacharya failed to present evidence sufficient to create a triable issue as to whether his speech caused the actions taken against him. The court found that the university's administrators appropriately exercised their authority to ensure the safety of the school’s faculty and staff. The court also affirmed the district court's denial of Bhattacharya's request to amend his complaint to add a conspiracy claim and the dismissal of his due process claim. View "Bhattacharya v. Murray" on Justia Law

by
The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision to remand two lawsuits back to Maryland state court. The lawsuits were brought by the City of Annapolis and Anne Arundel County against more than 20 energy companies, including BP P.L.C. The local governments accused the companies of misrepresenting and concealing information about the environmental impact of their fossil fuel products in violation of Maryland's Consumer Protection Act and various state tort laws. The companies tried to remove the cases to federal court, arguing that because they had acted under federal authority in their operations, the court had federal question jurisdiction. However, the appeals court found that the company's activities related to fossil fuel production were not relevant to the claims brought by the local governments, which were based on alleged concealment or misrepresentation of information about fossil fuel products. The court also rejected the companies' argument that the First Amendment question related to their right to free speech provided a basis for federal jurisdiction, as this question was a defense rather than a necessary element of the plaintiffs' state-law claims. View "Anne Arundel County v. BP P.L.C." on Justia Law

by
In this case, a police officer, Michael Roane, shot and killed Tina Ray’s dog while attempting to serve an arrest warrant. The United States Court of Appeals for the Fourth Circuit vacated the district court's entry of summary judgment in favor of Roane and remanded the case for trial. The crux of the case was the dispute over Roane's perception of the threat posed by the dog. Roane asserted that he believed the dog was unrestrained and posed an immediate threat to his safety. However, Ray and other witnesses testified that Roane had stopped his retreat and took a step towards the dog before shooting, suggesting that he knew the dog could no longer reach him and did not pose an imminent threat. The Court of Appeals held that this dispute over material facts was for a jury to resolve, not a court, and could not be decided prior to trial. The court also held that if a jury credits Ray's allegations and draws permissible inferences in her favor, it could infer that Roane's shooting of the dog was an unreasonable seizure under the Fourth Amendment. The court also rejected Roane's claim to qualified immunity. View "Ray v. Roane" on Justia Law

by
In the case before the United States Court of Appeals for the Fourth Circuit, Bikachi Amisi, a contract nurse, sued Officer Lakeyta Brooks and Officer Roy Townsend for violating her Fourth Amendment rights when she was mistakenly strip searched on her first day of work at Riverside Regional Jail. Amisi also brought several tort claims under Virginia state law. The defendants moved for summary judgment, arguing they were entitled to qualified immunity and good-faith immunity under Virginia law. They also argued that the Virginia Workers’ Compensation Act’s exclusivity provision barred Amisi's claims. The district court denied their motions and the defendants appealed.The Court of Appeals affirmed the district court's decision. It held that both officers were not entitled to qualified immunity, a legal protection that shields officers who commit constitutional violations but who could reasonably believe their actions were lawful, because their actions were not reasonable and Amisi’s right to be free from unreasonable strip searches was clearly established. The court also held that the Virginia Workers' Compensation Act did not bar Amisi's state-law claims because her injuries did not arise out of her employment. The Court further held that Officer Townsend was not entitled to immunity under Virginia law as his belief that his conduct was lawful was not objectively reasonable. View "Amisi v. Brooks" on Justia Law

by
In a case before the United States Court of Appeals for the Fourth Circuit, the plaintiff, identified as Jane Doe, filed an appeal against two orders from the district court. The first order denied her request to compel the defendant, Cenk Sidar, to provide a DNA sample for a sexual assault case. The second order demanded that Doe disclose her real name in the proceedings following a default judgment against Sidar.The Court of Appeals dismissed the appeal regarding the DNA sample for lack of jurisdiction, ruling that orders denying requests for physical or mental examinations are not immediately appealable under the collateral order doctrine.However, the court did rule on the anonymity issue. The court found that the district court committed legal error in its order demanding Doe to disclose her real name. The district court had understated Doe's interest in anonymity, announced a general rule that fairness considerations invariably cut against allowing a plaintiff to be anonymous at trial unless the defendant is also anonymous, and failed to recognize the significance of its default judgment on liability. The Court of Appeals thus vacated the non-anonymity order and remanded for further proceedings, instructing the district court to reconsider its order in light of the appeals court's opinion. The court emphasized the importance of Doe's privacy interests, particularly given that the case involved allegations of sexual assault. View "Doe v. Sidar" on Justia Law

by
In the case before the United States Court of Appeals for the Fourth Circuit, the defendant, a registered sex offender, was convicted for knowingly failing to update his registration as required by the Sex Offender Registration and Notification Act (SORNA). The appellant argued that as he was mobile without a fixed abode, he was not required to register anywhere under SORNA. He also contested the district court's jury instruction on SORNA’s definition of “resides,” claiming it expanded the definition. Furthermore, he argued that SORNA, as applied to him, violated the Tenth Amendment. He also contested two aspects of his sentence: an eight-level enhancement for his third degree sexual abuse of a minor and possession of child pornography, and his lifetime term of supervised release.The court held that the district court correctly instructed the jury on the meaning of “resides” and “habitually lives” under SORNA and that SORNA, as applied to the appellant, did not violate the Tenth Amendment. The court also affirmed the district court’s sentence as procedurally and substantively reasonable. It concluded that the appellant, who was required to register as a sex offender due to a previous conviction, failed to update his registration while residing in West Virginia, thus violating SORNA. The court found that his argument of not having a fixed abode did not exempt him from the registration requirements of SORNA. View "United States v. Kokinda" on Justia Law