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

South Carolina law makes it a crime for elementary and secondary school students to act “disorderly” or in a “boisterous manner,”; use “obscene or profane language”; or “interfere with,” “loiter about,” or “act in an obnoxious manner” in (or sometimes near) a school. Four students who had been referred or charged under the disorderly conduct or disturbing schools laws, and a nonprofit organization that advocates for at-risk youth filed a putative class action challenging both laws as unconstitutionally vague. After denying a motion to dismiss, the district court certified one main class and two subclasses under the Federal Rule of Civil Procedure 23(b)(2). The court held that both laws were unconstitutionally vague as applied to elementary and secondary school students, and it permanently enjoined future enforcement of the disorderly conduct law against those students. South Carolina’s Attorney General—appealed, lodging multiple challenges to the district court’s rulings.   The Fourth Circuit affirmed. The court reasoned that the district court committed no abuse of discretion here—not just because the challenged laws are facially invalid as applied to elementary and secondary school students but also because the subclasses demonstrated ongoing injury by the retention of existing records. A delinquency adjudication under South Carolina law may impair a minor’s future practice of law, application for military service, use of a driver’s license, and educational opportunities. Having concluded the laws may not be constitutionally enforced against South Carolina’s elementary and secondary students, the court saw no reason for allowing such continuing injuries to stand. View "Carolina Youth Action Project v. Alan Wilson" on Justia Law

Plaintiff sued numerous media organizations and individual journalists, alleging defamation, false light invasion of privacy, and civil conspiracy. Plaintiff’s claims arise from misstatements of his criminal record: he was convicted and served one year in prison for a federal conspiracy offense, but Defendants made statements describing him as a “felon.” The sixteen Defendants moved for summary judgment in their respective cases. The district court granted summary judgment to all sixteen Defendants after concluding they did not make the statements with actual malice. At issue are two appeals: a consolidated appeal from the district court’s decisions granting summary judgment to fifteen Defendants and a separate appeal from the district court’s grant of summary judgment to the Boston Globe.   The Fourth Circuit affirmed. The court held that the cumulative record simply does not permit a finding, by clear and convincing evidence, that any Defendant “in fact entertained serious doubts as to the truth” of the statements it published. Some of the statements may have been the product of carelessness and substandard journalistic methods. But at the end of the day, the record does not contain evidence that the commentators and journalists responsible for the statements were anything more than confused about how to describe a person who served a year in prison for a federal offense. Further, the court wrote that Plaintiff has not offered sufficient evidence of actual malice to support his defamation or false light claims against Fox News, he cannot establish an underlying tort, and his conspiracy claims fail as a matter of law. View "Don Blankenship v. NBCUniversal, LLC" on Justia Law

Plaintiff appealed the district court’s order affirming the Social Security Administration’s (“SSA”) denial of her application for Social Security Disability Insurance (“SSDI”). In her application, she alleged major depressive disorder (“MDD”), anxiety disorder, and attention deficit disorder (“ADHD”). Following a formal hearing, the Administrative Law Judge (“ALJ”) determined that Plaintiff suffered from severe depression with suicidal ideations, anxiety features and ADHD, but he nonetheless denied her claim based on his finding that she could perform other simple, routine jobs and was, therefore, not disabled. Plaintiff contends that the ALJ erred by (1) according to only little weight to the opinion of her long-time treating psychiatrist (“Dr. B”) and (2) disregarding her subjective complaints based on their alleged inconsistency with the objective medical evidence in the record.   The Fourth Circuit reversed and remanded with instructions to grant disability benefits. The court agreed with Plaintiff that the ALJ failed to sufficiently consider the requisite factors and record evidence by extending little weight to Dr. B’s opinion. The ALJ also erred by improperly disregarding Plaintiff’s subjective statements. Finally, the court found that the ALJ’s analysis did not account for the unique nature of the relevant mental health impairments, specifically chronic depression. The court explained that because substantial evidence in the record clearly establishes Plaintiff’s disability, remanding for a rehearing would only “delay justice.” View "Shelley C. v. Commissioner of Social Security Administration" on Justia Law

Plaintiff appealed from the 2021 opinion of the district court affirming the final decision of Defendant Kijakazi, as the Acting Commissioner of Social Security, which denied Plaintiff’s claim for disability benefits.   The Fourth Circuit, without resolving the merits, vacated the judgment of the district court and directed a remand to the Commissioner for a new and plenary hearing on Plaintiff’s disability benefits claim, to be conducted before a different and properly appointed administrative law judge (ALJ). The court agreed with Plaintiff’s appellate contention that, pursuant to the Supreme Court’s 2018 decision in Lucia v. SEC, 138 S. Ct. 2044 (2018), the (“ALJ Bright”) who rendered the Commissioner’s final decision did so in contravention of the Constitution’s Appointments Clause.   The court explained that the Supreme Court made clear that if an ALJ makes a ruling absent a proper constitutional appointment, and if the claimant interposes a timely Appointments Clause challenge, the appropriate remedy is for the claim to be reheard before a new decisionmaker. Plaintiff did not receive that remedy. The Appointments Clause violation as to Plaintiff was thus not cured, and the 2019 ALJ Decision was likewise rendered in contravention of that Clause. View "Camille Brooks v. Kilolo Kijakazi" on Justia Law

Appellant American Federation of State, County and Municipal Employees, Council 3 (“Appellant”) filed suit against the State of Maryland alleging that the State breached a statutorily formed contract with current state employees to provide them with certain prescription drug benefits upon retirement. The district court agreed that Maryland law created a contract, it held that the contract was unilateral in nature and that the promised benefits do not vest until an employee retires with sufficient years of service. The district court determined that the current employees represented by Appellant had no vested contractual right to the retirement prescription drug benefits and dismissed the complaint.   The Fourth Circuit affirmed. However, the court did so because it found that the statutory language does not create a contract with state employees. The court explained that in reviewing the language of the statutes at issue, it concluded that they do not create a contract binding upon the State. While Section 2-508 does “entitle” retirees to a subsidy, it does not include any unmistakable contract language. Rather, it only “entitles” a retiree to the “same State subsidy allowed a State employee.” The court explained that nothing in Sections 2-508 or 2-509.1 leaves the court with an unmistakably “clear indication that the legislature intended to bind itself contractually.” Therefore, “all doubts must be resolved in favor of the continuance of the power” of the state legislature to modify or repeal enactments of a previous legislature. View "AFSCME Maryland Council 3 v. State of Maryland" on Justia Law

Plaintiff appealed the dismissal of his claim against TrustedID, Inc. under South Carolina’s Financial Identity Fraud and Identity Theft Protection Act (the “Act”), S.C. Code Ann. Section 37-20-180. The district court held that Plaintiff alleged an Article III injury in fact but failed to state a claim under the Act. Plaintiff agrees with the district court’s decision on standing but appeals its Rule 12(b)(6) dismissal.   The Fourth Circuit vacated and remanded with instructions to remand this case to state court where it originated. The court conceded that it is odd that TrustedID failed to comply with the five-digit SSN cutoff, which doesn’t appear to be unique to South Carolina’s Act. But federal courts can’t entertain a case without a concrete injury in fact. The court offered no opinion about whether the alleged facts state a claim under the Act. Absent Article III jurisdiction, that’s a question for Plaintiff to take up in state court. View "Brady O'Leary v. TrustedID, Inc." on Justia Law

Defendant pled guilty to possession with intent to distribute fifty or more grams of methamphetamine. The offense carried a ten-year mandatory minimum sentence of imprisonment. At sentencing, Defendant argued that she was eligible for relief from that mandatory minimum under the First Step Act’s safety valve provision. The sole issue on appeal is whether the word “and” in Section 3553(f)(1) connecting the criminal history characteristics applies conjunctively or disjunctively.   The Fourth Circuit affirmed and concluded that “and” is conjunctive. The court wrote that it is persuaded that the plain text of Section 3553(f)(1) requires a sentencing court to find that a defendant has all three of the listed criminal history characteristics before excluding a defendant from safety valve eligibility. View "US v. Cassity Jones" on Justia Law

Defendant Deputy Sheriff cited Plaintiff for a parking violation. In response, Plaintiff complained about Defendant on social media for issuing the citation. Listening to her police radio, Defendant heard about another Deputy’s encounter with Plaintiff. She then called that Deputy and offered to buy him lunch if he cited Plaintiff. After the Deputy cited her, Plaintiff learned of Defendant’s lunch offer. So she sued Defendant in her personal capacity under 42 U.S.C. Section 1983. Plaintiff alleged that Defendant’s lunch offer violated her First Amendment rights. Defendant made this offer, Plaintiff asserted, to retaliate against Plaintiff for her earlier complaints about Defendant. But the jury found Defendant not liable, leading to Plaintiff’s appeal. She now claims that the district court erred in instructing the jury on the applicable standard for First Amendment retaliation and in excluding certain witness testimony during the trial’s liability phase.   The Fourth Circuit affirmed the district court’s ruling. The court explained that Plaintiff would have preferred to call additional witnesses to bolster her testimony. But the district court had to balance that interest with the fact that, under the court’s precedent, the inquiry into the second element of the test set forth in Constantine—“whether a person of ordinary firmness in the plaintiff’s position would likely be deterred by the defendant’s retaliatory conduct”—is an objective analysis. Thus, the court affirmed the jury’s verdict and the judgment of the district court in favor of Defendant. View "Rebecca Snoeyenbos v. Marcia Curtis" on Justia Law

Habeas Petitioner was sentenced to life without the possibility of parole for thirty years in South Carolina state court for a number of crimes he committed in 1987, including two murders. But in 2004, the South Carolina Department of Probation, Parole and Pardon Services (“Department”) notified Petitioner that he would never be eligible to seek parole because of an earlier armed-robbery conviction. Petitioner contends that, in reaching this conclusion, the Department violated his federal due-process rights because, in his view, a temporary change in South Carolina parole-eligibility law in 1994 permanently “vested” his parole eligibility, such that the Department could not legally determine him ineligible to ever seek parole. The district court rejected Petitioner’s contention.   The Fourth Circuit granted a certificate of appealability and affirmed the district court’s decision. The court explained that there is no dispute that Petitioner received a statement of reasons why he was not eligible for parole. The 2004 letter from the Department makes clear that Petitioner is ineligible because his 1992 murder convictions followed a 1979 armed-robbery conviction, and pursuant to S.C. Code Section 24-21-640, a defendant convicted of a violent crime who has previously been convicted of another violent crime is not eligible for parole. Accordingly, Petitioner received the limited process required by the Federal Constitution for a parole-eligibility determination. View "Thomas Torrence v. Scott Lewis" on Justia Law

Defendant pleaded guilty to transporting child pornography. The district court sentenced him to twelve years in prison and lifetime supervised release, subject to certain conditions. Defendant has struggled to comply with the conditions, returning to prison three times for violating them. Defendant challenged the sentence imposed after his third revocation of supervised release. He argued that the court erred in reimposing a special condition limiting his access to pornography (broadly defined), and in imposing a plainly unreasonable 24-month prison term.   The Fourth Circuit reversed the district court’s order rejecting Defendant’s objection to the condition, vacated the judgment, and remanded for resentencing. The district court based the revocation sentence on three special-condition violations: Defendant’s possession of a smartphone, his possession of five adult pornographic movies, and his unapproved contact with two minors. The court noted its fear that Defendant’s “getting a smartphone and accessing adult pornography” would soon “lapse into something else.” It also emphasized that Special Condition Nine, “[n]ot viewing pornography,” was “all part of the same thing that brought you here, the child pornography.” In other words, the district court based its sentence in large part on the violation of a condition that the court now vacates as not reasonably related and overbroad. The court, therefore, held that the district court didn’t state a “proper basis” for imposing the statutory maximum, rendering the revocation sentence substantively unreasonable. View "US v. Joseph Castellano" on Justia Law