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

In this case, the plaintiffs filed a lawsuit against the United States under the Federal Tort Claims Act (FTCA) alleging negligence, wrongful death, and survival claims arising from the death of Eleusipa Van Emburgh who was treated at a Navy medical center. The United States District Court for the Eastern District of Virginia dismissed the plaintiffs' claims for lack of subject matter jurisdiction. The plaintiffs appealed this decision.The United States Court of Appeals for the Fourth Circuit held that regulations enacted under 28 U.S.C. § 2672 do not impose additional jurisdictional requirements beyond those listed in 28 U.S.C § 2675. As such, the court reversed the district court's decision for six of the plaintiffs and remanded the case for further proceedings. However, the court affirmed the dismissal of one plaintiff, Imelda Crovetto, who failed to satisfy one of the jurisdictional requirements listed in § 2675.The Court of Appeals held that the jurisdictional requirements laid out in 28 U.S.C. § 2675 were the sole source of jurisdictional requirements for the FTCA’s administrative exhaustion requirement. The court found that the implementing regulations did not impose additional jurisdictional requirements. The plaintiffs satisfied these jurisdictional requirements when they submitted their claims to the agency, included a specific valuation of their claims, and waited until after their claims were denied before filing suit. View "Estate of Eleusipa Van Emburgh v. US" on Justia Law

This case was brought before the United States Court of Appeals for the Fourth Circuit. The plaintiff, David Duvall, a white man, was terminated from his position as Senior Vice President of Marketing and Communications at Novant Health, Inc. Duvall filed a lawsuit claiming he was fired due to his race and sex, in violation of Title VII of the Civil Rights Act of 1964. A North Carolina jury found in favor of Duvall, awarding him $10 million in punitive damages. Novant Health appealed this decision, arguing that the evidence presented at trial was insufficient to support the jury’s verdict.The evidence presented at trial showed that Duvall performed exceptionally well in his role, receiving strong performance reviews. Despite his performance, Duvall was abruptly fired and replaced by two women, one of whom was a racial minority and rated a lower performer than Duvall. This occurred during a diversity and inclusion initiative at Novant Health, which aimed to achieve racial and gender diversity within its leadership.The Court of Appeals upheld the jury's verdict of liability against Novant Health, finding sufficient evidence to support the claim that Duvall's race, sex, or both were motivating factors in his termination. However, the court vacated the jury's award of punitive damages, concluding that Duvall failed to prove that Novant Health discriminated against him despite perceiving a risk that its actions would violate federal law.The court also upheld the district court's award of back pay and front pay to Duvall, rejecting Novant Health's claim that Duvall failed to reasonably mitigate his damages. The court found that Duvall exercised reasonable diligence in seeking new employment after his termination. The case was remanded for entry of an amended judgment as to punitive damages. View "Duvall v. Novant Health, Inc." on Justia Law

Edgardo Vasquez Castaneda, a citizen of El Salvador, filed a petition for a writ of habeas corpus under 28 U.S.C. § 2241, arguing that his ongoing civil detention during his ongoing withholding-only proceedings was unlawful. He had been ordered removed to El Salvador but had instigated withholding-only proceedings claiming a fear of torture if returned to El Salvador. The length of his detention, pending the resolution of those proceedings, had exceeded the six-month period deemed presumptively reasonable under Zadvydas v. Davis. The United States Court of Appeals for the Fourth Circuit affirmed the district court's dismissal of the petition.Vasquez Castaneda failed to show that his removal from the U.S. was not significantly likely to happen in the foreseeable future. The court reasoned that ongoing withholding-only proceedings, even lengthy ones, do not present the same risk of "indefinite and potentially permanent" detention at issue in Zadvydas. Furthermore, the court rejected Vasquez Castaneda's assertion that due process requires another bond hearing before an immigration judge given his circumstances. The court emphasized that Vasquez Castaneda's ongoing detention was directly tied to the proceedings he voluntarily initiated and that these proceedings would eventually conclude. The court also noted that Vasquez Castaneda had received ample process since his detention began, including a bond hearing, numerous custody reviews by ICE, and the very habeas proceedings in question. View "Castaneda v. Perry" on Justia Law

The appellant, Terry George, was charged with being a felon in possession of a firearm and ammunition. The government's key witness, Prince Frazier, had given inconsistent accounts of who was in the car at the time of the traffic stop leading to George's arrest. This inconsistency was not disclosed to George prior to trial. After being convicted, George sought to have his conviction vacated or a new trial ordered, arguing that the government's failure to disclose this inconsistent testimony violated his due process rights under Brady v. Maryland, which requires the prosecution to disclose evidence favorable to an accused. The district court denied George's motion, finding that the government's failure to disclose was not material to George's defense.George was also serving a term of supervised release as a result of a separate criminal conviction at the time of his felon in possession conviction. The district court revoked George's supervised release based on his new conviction.George appealed both decisions. Upon review, the court affirmed the district court's decisions. The court held that while the government should have disclosed the inconsistent statement, it was not material to George's defense because George's conviction would stand independently of any question about Frazier's credibility. Furthermore, the court affirmed the revocation of George's supervised release, as it was based on a valid conviction. View "United States v. George" on Justia Law

A massage parlor, Elegant Massage LLC, filed a class action lawsuit against State Farm Mutual Automobile Insurance Company, asserting claims of breach of contract and other related claims. The suit stemmed from State Farm's denial of insurance coverage to businesses that had to shut down partially or fully due to Virginia executive orders during the COVID-19 pandemic. Elegant Massage claimed that the forced closure constituted a "direct physical loss" under its insurance policy. The district court certified the class and denied State Farm’s motion to dismiss. State Farm appealed.The United States Court of Appeals for the Fourth Circuit used its pendent appellate jurisdiction to review the district court's denial of State Farm’s motion to dismiss in conjunction with the appealable class certification order. The appellate court referred to the precedent set in Uncork & Create LLC v. Cincinnati Insurance Co., which held that a similar business closure during the pandemic did not constitute a "direct physical loss" requiring material destruction or harm to the property. The court found that this precedent was directly applicable to the case at hand.Consequently, the court of appeals held that the district court had erred in denying State Farm's motion to dismiss. It ruled that the temporary closures ordered by the executive did not result in a "direct physical loss" under the policy terms. As a result, the court also found no basis for class certification. The court reversed the district court’s decisions and instructed it to dismiss the entire case. View "Elegant Massage, LLC v. State Farm Mutual Automobile Insurance Co." on Justia Law

The case involved Martin William Luther Hamilton, who pleaded guilty to one count of possession with intent to distribute fentanyl and one count of unlawful possession of a firearm by a felon. The probation agent preparing Hamilton's presentence report determined that three of Hamilton’s prior North Carolina convictions qualified as violent felonies under the Armed Career Criminal Act (ACCA), which mandates a minimum of fifteen years for defendants who have three prior convictions for offenses that qualify as a “violent felony or a serious drug offense.”Hamilton objected to the ACCA classification, disputing that the third conviction for attempted robbery with a dangerous weapon met the requirements of the ACCA. The district court followed a previous court's unpublished decision which held that a North Carolina conviction for attempted robbery with a dangerous weapon qualifies as a crime of violence for purposes of the career-offender provisions of the Sentencing Guidelines. As a result, the court concluded that Hamilton qualified as an armed career criminal and sentenced him to 180 months’ imprisonment.Hamilton appealed, challenging only the district court’s determination that the attempted robbery conviction was a predicate offense under the ACCA. In response, the United States Court of Appeals for the Fourth Circuit affirmed the district court's decision, finding no error in the determination that Hamilton’s conviction under N.C. Gen. Stat. 14-87(a) qualifies as a violent felony for purposes of the ACCA. View "US v. Hamilton" on Justia Law

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

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

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

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