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

Plaintiff spent nearly three months in Middle River Regional Jail. And he alleges that Middle River’s practices during that time substantially burdened his Islamic faith while unconstitutionally favoring the practice of Christianity. He argues that he was kept from engaging in Friday Prayer.   Plaintiff’s claims regarding Friday Prayer implicate the Free Exercise Clause. Under that clause, prisons can impose burdens on inmates’ religious practice— even substantial burdens—so long as the prison rules that do so are “reasonably related to legitimate penological interests.” Middle River had three rules in place that kept Plaintiff from attending in-person Friday Prayer: no inmate led groups; no maximum-security prisoners allowed in any in-person groups; and prisoner services and classes by volunteer or donation only.   The Fourth Circuit affirmed the district court’s Free Exercise decision and remanded for further proceedings on the Establishment Clause. The court explained that Middle River’s policies do not violate the Free Exercise Clause. Each of the rules and regulations that combined to keep Plaintiff from engaging in communal Friday Prayer during his brief stay was reasonably related to a legitimate penological interest and, therefore, acceptable under Turner. Whether the challenged practices violate the Establishment Clause is a question best left to the district court to resolve in the first instance, with the benefit of intervening legal developments. View "David Firewalker-Fields v. Jack Lee" on Justia Law

Plaintiff a longtime employee of the Virginia Department of Environmental Quality (“DEQ”), commenced this action against DEQ, claiming that it paid her less than it paid a male employee with the same position doing equal work, in violation of the Equal Pay Act. The district court entered summary judgment against Plaintiff, concluding that she lacked evidence to demonstrate that any higher-paid male employee was doing work “virtually identical” to the work she was doing. Indeed, the court explained that the record showed that the male employee whom Plaintiff had identified as a comparator was doing different and more complex work than she was, such that she could not show that she was paid less for equal work.   The Fourth Circuit affirmed. The court explained that the district court did not err in concluding that Plaintiff could not establish that she and the male employee performed “equal work.” To be sure, Plaintiff and the male employee performed similar work. But the differences in the actual work performed and the level of complexity involved were significant enough that their work cannot be fairly described as “substantially equal” or “virtually identical,” as required to establish a claim under the Equal Pay Act. View "Elizabeth Polak v. Virginia Department of Environmental Quality" on Justia Law

Appellee a middle school teacher in Pender County, North Carolina, when she was physically attacked by a special education student in her language arts class. There is no dispute that the student was known to have been violent on prior occasions. At the time of the incident involving Appellee, Appellant was the principal of the school where the attack occurred.   Appellee asserted the following five 42 U.S.C. Section 1983 claims: (1) a substantive due process claim; (2) a deliberate indifference claim; (3) a supervisory liability claim against Superintendent Hill; (4) a claim seeking personal liability against Superintendent Hill; and (5) a claim seeking personal liability against Appellant. Relevant here, the personal liability claim against Appellant alleges that Appellant knew or should have known that her actions and inactions could have led to a violation of Appellee’s constitutional rights.   The Fourth Circuit reversed and remanded. The court held that Appellee failed to sufficiently allege that Appellant violated her constitutional rights, thus Appellant is entitled to qualified immunity. The court explained that here, Appellee’s state-created danger claim centers on a series of alleged choices or inactions by Appellant which are far removed from TB’s physical attack on Appellee. Specifically, Appellee attempts to recast Appellant’s knowledge of TB’s prior acts of violence and creation of the staffing schedule which required Appellant to teach TB on the day of the incident -- without a second teacher in her classroom -- as affirmative acts. But Appellee fails to point to any action by Appellant which created the danger that resulted in Appellee’s injuries. View "Kimberly Burns-Fisher v. Anna Romero-Lehrer" on Justia Law

A bankruptcy court imposed sanctions against Defendant. The sanctions arose from an adversary proceeding in the bankruptcy court brought by the United States Trustee against Defendant, UpRight Law LLC, Sperro LLC and other defendants. UpRight is a Chicago-based bankruptcy legal services company that operates through a nationwide network of “local partners.” After Defendant signed a partnership agreement with UpRight, he filed more than 30 bankruptcy cases as a partner. The bankruptcy court also found that Delafield violated Virginia Rules of Professional Conduct 5.1 and 5.3. After the district court affirmed sanctions, Defendant appealed, asserting the sanctions order violated his due process rights.   The court explained that to be sure, a lawyer facing suspension or disbarment is entitled to notice of the charges for which such discipline is sought and an opportunity to be heard on those issues. The court explained that the complaint did not cite to the Virginia Rules of Professional Conduct that Defendant was ultimately found to have violated. Identifying such rules is certainly preferred in an action seeking suspension or disbarment. But this omission did not violate Defendant’s due process rights. The complaint adequately notified Defendant of the conduct for which he was being accused and the sanctions that were being sought. View "U. S. Trustee v. Darren Delafield" on Justia Law

Defendant and another person were trespassing in a public park after it closed. When officers saw their car, they investigated the trespass. The officers found a gun abandoned in a nearby trash can, so they frisked Defendant and questioned him about the gun. After first denying the gun was his, Defendant admitted he was a felon and that he owned the gun. The officers arrested Defendant, who was then federally indicted for being a felon in possession of a firearm. He sought to suppress his incriminatory statements, arguing that his statements in the park were inadmissible because he was “in custody” under Miranda, and so the officers needed to read him his Miranda rights before questioning him about the gun. The district court disagreed, and Defendant pleaded guilty.   The Fourth Circuit affirmed. The court explained that Miranda warnings are not required every time an individual has their freedom of movement restrained by a police officer. Nor are they necessarily required every time “questioning imposes some sort of pressure on suspects to confess to their crimes.” Instead, they are required only when a suspect’s freedom of movement is restrained to the point where they do not feel free to terminate the encounter, and the circumstances reveal “the same inherently coercive pressures as the type of station house questioning at issue in Miranda.” The court found that, in this case, no such pressures existed. View "US v. Ervin Leggette" on Justia Law

Defendant filed a motion for compassionate release under 18 U.S.C. Section 3582(c)(1)(A)(i), relying primarily on his vulnerability to COVID-19 due to his advanced age and chronic lung-related health conditions. Although the government originally supported Defendant’s motion, it later changed its position, and the district court ultimately denied relief. Defendant appealed that denial, arguing in part that the district court, in weighing the sentencing factors outlined in 18 U.S.C. Section 3553(a), failed to address or consider his heightened risk of death or serious illness if infected with COVID-19.
The Fourth Circuit agreed with Defendant and vacated the district court’s denial of compassionate release and remand for reconsideration.  The court explained that it cannot say with any confidence that in denying Defendant’s motion, the district court properly “reconsidered the Section 3553(a) factors in view of” his age and health conditions, the COVID-19 outbreak at his correctional facility, and the “severe risks arising out of those circumstances.” Thus, the court wrote it cannot meaningfully review its denial of Defendant’s motion for compassionate release. View "US v. Michael Mangarella" on Justia Law

While participating in a TASER training session, Plaintiff, Virginia Beach Police Department Officer took a break in a designated safety area. Another participant, who was engaged in a role-playing exercise, fired his TASER. Unfortunately, he missed his intended target and hit Plainitff in the eye. Plaintiff sued R.N., who oversaw the session, for negligence and Axon Enterprise, Inc., the manufacturer of TASERs and sponsor of the training program, for vicarious liability. R.N. and Axon moved separately for summary judgment and the district court granted both motions.   It determined that R.N. could only be liable for the conduct of the participant who fired the TASER if what Virginia law calls a “special relationship” existed between R.N. and Plaintiff. But it found that no such special relationship existed. And since it held that R.N. was not liable, the court also granted Axon’s motion as to Plaintiff’ vicarious liability claim. On appeal, Plaintiff insists that he has two valid negligence claims.   The Fourth Circuit affirmed the district court’s decision to grant summary judgment on Plaintiff’s special relationship claim. As it noted, Virginia has not previously recognized a special relationship in the trainer and adult trainee context. The court saw no reversible error in the court’s interpretation of Virginia law on this issue or in its application of Rule 56 of the Federal Rules of Civil Procedure. But the court agreed with Plaintiff that Virginia law permits his general negligence claim against Nelson. Thus, the court vacated the order dismissing the case and remand for proceedings on Plaintiff’s general negligence claim. View "Shawn Curran v. Axon Enterprise, Inc." on Justia Law

Plaintiff appealed the district court’s dismissal of her putative class action against the West Virginia Parkways Authority, in which she alleges that the Parkways Authority improperly collected fees. And the Parkways Authority appeals the district court’s holding that it was not entitled to sovereign immunity under the United States or West Virginia Constitutions.   Plaintiff relied on the Class Action Fairness Act for jurisdiction. The Fourth Circuit vacated the district court’s judgment and remanded the case remanded to the district court with directions to dismiss without prejudice. The court concluded that here, Section 1332(d)(5)(A) bars jurisdiction under Section 1332(d)(2) of the Class Action Fairness Act. The court explained that the Parkways Authority is the only, and thus “primary,” defendant. And it is a “governmental entity.” The Parkways Authority’s sovereign-immunity claim is strong enough to conclude that the district court “may be foreclosed from ordering relief” against it. So Section 1332(d)(2)’s jurisdictional grant “shall not apply.” Since that is the only provision that Plaintiff relies on to establish jurisdiction over her putative class action, the district court lacked jurisdiction to hear it. View "Blazine Monaco v. WV Parkways Authority" on Justia Law

Defendant was sentenced to 330 months in federal prison for the use of a firearm to facilitate a drug offense and for a drug conspiracy. After serving eleven years in prison, Defendant filed his first motion for compassionate release pursuant to 18 U.S.C. Section 3582(c)(1)(A). Defendant argued that his significant health decline and advanced age justified his release. The district court denied his motion, relying solely upon a now in applicable policy statement, United States Sentencing Guidelines (“Sentencing Guidelines”). The following year, the Bureau of Prisons (“BOP”) deemed Defendant severely at risk of contracting COVID-19 and placed him in home confinement through authority granted by the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”). Defendant filed a subsequent motion for compassionate release reiterating his advanced age and severe health conditions. In addition, Defendant presented supplementary arguments that focused on the COVID-19 pandemic, relevant 18 U.S.C. Section 3553(a) factors, the “extreme” nature of his sentence, and his inability to receive government benefits while in home confinement. The district court again denied Defendant’s motion for compassionate release. 
The Fourth Circuit reversed and remanded the district court’s decision with instructions to grant Defendant’s motion for compassionate release. The court concluded that the district court abused its discretion by failing to properly assess the following factors which would warrant Defendant’s compassionate release: his ailing health, advanced age, and relevant 18 U.S.C. Section 3553(a) factors. Had it addressed that evidence, as more fully discussed below, its analysis of whether Defendant is entitled to compassionate release would have likely merited a different outcome. View "US v. Lonnie Malone" on Justia Law

These consolidated cases involve a dispute between Antero Resources Corporation (“Antero”) and a group of landowners (“Lessors”) over the payment of natural gas royalties under several oil and gas leases. The leases permit Antero to extract and sell natural gas owned by the Lessors in exchange for royalty payments. Antero appealed from the district court’s summary judgment order, which held that Antero breached the terms of the leases by deducting certain “post-production costs” from the royalties it paid Lessors and awarded damages. Lessors cross-appeal the district court’s earlier dismissal of their fraud and punitive damages claims against Antero.   The Fourth Circuit affirmed the district court’s summary judgment order in part and vacated in part. The court concluded that some of the leases prohibit Antero from deducting any post-production costs from Lessors’ royalties, but other leases—namely, those that contain a “Market Enhancement Clause”—do authorize deductions in certain circumstances. Separately, the court affirmed the dismissal of the fraud and punitive damages claims because Lessors did not plead them with sufficient particularity. View "Gerald Corder v. Antero Resources Corporation" on Justia Law