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

After the decedent died, Plaintiff, his surviving spouse, filed suit seeking relief under a provision of the Employee Retirement Income Security Act allowing “a participant or beneficiary” of an employee benefit plan “to recover benefits due” “under the terms of [the] plan.” The parties submitted a joint stipulation of facts and an administrative record and cross-moved for judgment based on those undisputed materials. The district court entered judgment for Prudential. The court concluded Prudential “reasonably denied Plaintiff’s request for benefits” because “decedent received timely notice of his conversion rights” and “did not convert his life insurance to an individual policy during the conversion period.” The district court also rejected Plaintiff’s request to “apply the doctrine of equitable tolling and find that Plaintiff is entitled to the life insurance benefits she seeks.”   The Fourth Circuit affirmed. The court wrote that it agreed with the district court that the plan administrator did not abuse its discretion in concluding Plaintiff was not entitled to benefits under the terms of the plan. The court explained that “Employers have large leeway to design [employee benefit] plans as they see fit,” but “once a plan is established, the administrator’s duty is to see that the plan is maintained pursuant to that written instrument.” Here, Prudential did not abuse its discretion by fulfilling its duty here, and the district court correctly resolved the single claim before it based on the agreed-on facts and consistent with well-established law. View "Kathy Hayes v. Prudential Insurance Company of America" on Justia Law

Plaintiffs—North Carolina Wildlife Federation and No Mid-Currituck Bridge-Concerned Citizens and Visitors Opposed to The Mid-Currituck Bridge (a community organization) sued the North Carolina Department of Transportation and the Federal Highway Administration (together, “the agencies”) —asserting that the agencies violated the National  Environmental Policy Act (“NEPA”) in approving a bridge project. Specifically, the NEPA provides that for an action “significantly affecting the quality of the human environment,” the Act requires an agency to prepare a detailed Environmental Impact Statement (“EIS”). The district court granted summary judgment for Defendants.   The Fourth Circuit affirmed. The court explained that Plaintiffs fault the agencies for glossing over the environmental impact of the extra 2,400 units that would be constructed under the bridge scenario. They claim that the EIS “made no attempt to evaluate the effect of the Toll Bridge’s additional development on the habitat, wildlife, and natural resources of the Outer Banks.” But the EIS does adequately account for this added development. The EIS noted that a bridge would likely lead to an increase in day visitors, which could lead to more beach driving. More beach driving may “increase the likelihood of collisions” with wild horses on the beaches, but would have “no effect on threatened and endangered species. The agencies also found no “appreciable improvement” in water quality under the no-build and existing roads scenarios. The agencies’ no-build baseline properly reflected the lower level of development that would result without the toll bridge. The agencies didn’t mislead the public about this fact. In sum, the agencies’ consideration of the no-build alternative did not violate the Act. View "No Mid-Currituck Bridge-Concerned Citizens v. North Carolina Department of Transportation" on Justia Law

People for the Ethical Treatment of Animals (PETA) wishes to conduct undercover animal-cruelty investigations and publicize what they uncover. But it faces a formidable obstacle: North Carolina’s Property Protection Act (the Act), passed to punish “any person who intentionally gains access to the non-public areas of another’s premises and engages in an act that exceeds the person’s authority to enter.” The Act goes on to explain what actions “exceed” authority. Some provisions appear more narrowly focused, prohibiting capturing, removing, or photographing employer data. Even these more specific provisions, however, potentially reach anything from stealing sensitive client information to ferreting out trade secrets in hopes of starting a competing business.   The Fourth Circuit enjoined North Carolina from applying the Act to PETA’s newsgathering activities but severed and reserved all other applications for future case-by-case adjudication. Here, the Act regulates at least some non-expressive, unprotected conduct. The court wrote these more general regulations of conduct do not insulate the Act from the First Amendment’s wringer when the Act bars speech. Absent any indication that the Act “as a whole” chills First Amendment freedoms, the court explained it follows the same principles under overbreadth. View "PETA v. NC Farm Bureau" on Justia Law

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