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

After G.G., a transgender boy, began to use the boys’ restrooms with the approval of the school administration, the local school board passed a policy banning G.G. from the boys’ restroom. G.G. filed suit alleging that the school board impermissibly discriminated against him in violation of Title IX, 20 U.S.C. 1681(a), and the Equal Protection Clause of the Constitution. The district court dismissed G.G.’s Title IX claim and denied his request for a preliminary injunction. The court reversed the dismissal of G.G.’s Title IX claim, concluding that the district court did not accord appropriate deference to the relevant Department of Education regulations. In this case, the Department’s interpretation of its own regulation, 34 C.F.R. 106.33, as it relates to restroom access by transgender individuals, is entitled to Auer v. Robbins deference and is to be accorded controlling weight. The court also concluded that the district court used the wrong evidentiary standard in assessing G.G.’s motion for a preliminary injunction. The district court evaluated G.G.’s proffered evidence against a stricter evidentiary standard than is warranted by the nature and purpose of preliminary injunction proceedings to prevent irreparable harm before a full trial on the merits. Therefore, the district court abused its discretion when it denied the preliminary injunction without considering G.G.’s proffered evidence. The court vacated the district court's denial of the preliminary injunction and remanded for consideration under the correct standard. View "G. G. v. Gloucester Cnty. Sch. Bd." on Justia Law

Because of an internal oversight, American Bank failed to respond to a summons and the state court entered a $98.5 million default judgment against it. Eight months after receipt of the summons, American Bank notified its insurer, St. Paul, of the lawsuit and St. Paul denied coverage due to late notice. American Bank was subsequently able to have the default judgment vacated and the suit dismissed, but at an expense of $1.8 million. St. Paul now seeks a declaratory judgment that it had no duty to pay for American Bank's defense, and American Bank counterclaims. The court affirmed the district court's entry of judgment for St. Paul where, among other things, American Bank did not provide St. Paul with notice as soon as practicable, as required by the terms of its insurance policy, and because the late notice caused St. Paul prejudice. Therefore, St. Paul was within its right to deny coverage. View "St. Paul Mercury Ins. Co. v. American Bank Holdings, Inc." on Justia Law

Defendant appealed his conviction for carjacking in violation of 18 U.S.C. 2119. The court held that, in light of Holloway v. United States, the evidence was insufficient to support a rational finding beyond a reasonable doubt that defendant possessed the specific intent, conditional or otherwise, to kill or seriously harm his victim when he took control of the vehicle. Applying Holloway, the court concluded that evidence of generalized recklessness and desperation, coupled with an unconsummated implied threat or “bluff” provided insufficient evidentiary support from which a jury could reasonably find beyond a reasonable doubt that defendant possessed the specific intent. Accordingly, the court vacated and remanded with instructions that a judgment of acquittal be entered. View "United States v. Bailey" on Justia Law

Defendant appealed his conviction for carjacking in violation of 18 U.S.C. 2119. The court held that, in light of Holloway v. United States, the evidence was insufficient to support a rational finding beyond a reasonable doubt that defendant possessed the specific intent, conditional or otherwise, to kill or seriously harm his victim when he took control of the vehicle. Applying Holloway, the court concluded that evidence of generalized recklessness and desperation, coupled with an unconsummated implied threat or “bluff” provided insufficient evidentiary support from which a jury could reasonably find beyond a reasonable doubt that defendant possessed the specific intent. Accordingly, the court vacated and remanded with instructions that a judgment of acquittal be entered. View "United States v. Bailey" on Justia Law

S.B., by and through his mother, filed suit against the Board, alleging primarily that by allowing other students to harass S.B. based on his disability, the Board violated section 504 of the Rehabilitation Act, 29 U.S.C. 701 et seq. S.B.'s father, a teacher and athletic director at the school, filed suit in his own right, claiming that the Board also violated section 504 by retaliating against him for advocating on S.B.’s behalf. The district court granted summary judgment for the Board. The court affirmed the judgment because no evidence support's the claims. In this case, S.B. has provided no evidence that the Board acted with the deliberate indifference necessary to hold it liable for student-on-student harassment. Nor does the record substantiate the father's allegation of a causal connection between his advocacy for S.B. and any adverse action taken by the Board. View "SB v. Board of Educ. of Harford" on Justia Law

Plaintiff filed suit against Santander, seeking damages for breach of contract and alleging a violation of the Maryland Credit Grantor Closed End Credit Provisions (CLEC), Md. Code, Comm. Law 12-1001, et seq. The dispute stemmed from plaintiff's use of a loan she obtained through a retail installment contract (RISC) to finance the purchase of a vehicle. The court concluded that the district court correctly enforced the parties' arbitration agreement because the district court properly concluded that the arbitration agreement was a term of a contract that the parties entered into, and that the arbitration agreement was enforceable under the Federal Arbitration Act, 9 U.S.C. 2. Accordingly, the court affirmed the judgment. View "Galloway v. Santander Consumer USA, Inc." on Justia Law

Plaintiff filed suit against Defendant Terry and others after he was pulled over, tased three times, and arrested. Plaintiff was charged with an excessive noise violation, no license in possession, and disorderly conduct, all of which were nol prossed. The parties filed a stipulation of dismissal as to all claims except for the 42 U.S.C. 1983 claim for excessive force against Terry in his individual capacity. The district court denied Terry summary judgment based on qualified immunity. The court's analysis of the Graham v. Connor factors when measured against the level of force used by Terry against plaintiff leads the court to conclude that such force was not objectively reasonable in light of the totality of the circumstances in this case. Therefore, plaintiff has established that Terry's use of his taser constituted excessive force in violation of plaintiff's Fourth Amendment rights. Further, no reasonable officer would have believed that Terry’s use of the taser was justifiable at all and certainly not on three occasions. Accordingly, the court affirmed the district court’s denial of Terry’s motion for summary judgment based on qualified immunity. View "Yates v. Terry" on Justia Law

Plaintiff filed suit against Defendant Terry and others after he was pulled over, tased three times, and arrested. Plaintiff was charged with an excessive noise violation, no license in possession, and disorderly conduct, all of which were nol prossed. The parties filed a stipulation of dismissal as to all claims except for the 42 U.S.C. 1983 claim for excessive force against Terry in his individual capacity. The district court denied Terry summary judgment based on qualified immunity. The court's analysis of the Graham v. Connor factors when measured against the level of force used by Terry against plaintiff leads the court to conclude that such force was not objectively reasonable in light of the totality of the circumstances in this case. Therefore, plaintiff has established that Terry's use of his taser constituted excessive force in violation of plaintiff's Fourth Amendment rights. Further, no reasonable officer would have believed that Terry’s use of the taser was justifiable at all and certainly not on three occasions. Accordingly, the court affirmed the district court’s denial of Terry’s motion for summary judgment based on qualified immunity. View "Yates v. Terry" on Justia Law

The Government filed a motion to transfer defendant, under 18 U.S.C. 5032, for prosecution as an adult for murder in aid of racketeering. Defendant was a juvenile at the time of the alleged offense. The district court denied the Government’s motion after concluding that the prosecution would be unconstitutional given that recent Supreme Court decisions have held that the United States Constitution prohibits sentencing juvenile offenders to either death or life imprisonment. The court agreed with the district court that defendant cannot be prosecuted for murder in aid of racketeering because his conviction would require the district court to impose an unconstitutional sentence. Because the district court did not err in denying the Government’s motion to transfer defendant for prosecution as an adult, the court affirmed the judgment. View "United States v. Under Seal" on Justia Law

This appeal stems from Roger and Mary Jo Carlson's attempt to arbitrate class action claims against Pulte under a sales agreement that contained an arbitration clause, and Pulte's efforts to limit arbitration to the claims between the three parties. Because the primary goal in enforcing an arbitration agreement is to discern and honor party intent, and because of the fundamental differences between bilateral and class arbitration - which change the nature of arbitration altogether - the court held that whether parties agree to class arbitration is a gateway question for the court. In this case, the parties did not unmistakably provide that the arbitrator would decide whether their agreement authorizes class arbitration. In fact, the sales agreement says nothing at all about the subject. Therefore, the district court erred in concluding that the question was a procedural one for the arbitrator. Accordingly, the court reversed the order denying Pulte's motion for partial summary judgment, vacated the judgment dismissing the petition, and remanded for further proceedings. View "Del Webb Communities, Inc. v. Carlson" on Justia Law