Justia Civil Rights Opinion Summaries

This appeal arose out of the district court's grant of summary judgment in favor of PCA on plaintiff's claims of sexual harassment in violation of Title VII. Because the court found that there were genuine issues of fact as to whether PCA took "tangible employment action" against plaintiff, the court reached neither the question of whether the district court erred by not determining whether Bobby Mills was a supervisor nor the question of whether the district court correctly applied the Faragher-Ellerth defense test. The court also held that there was uncertainty about whether there was a nexus between the harassment and plaintiff's alleged termination. Accordingly, the court vacated and remanded.

Plaintiff, who is deaf, appealed the district court's ruling of summary judgment for defendants, arguing that he was entitled to have the jury hear his argument that he was not reasonably accommodated by defendants during their investigation, in violation of his rights under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101, et seq., and the Rehabilitation Act, 29 U.S.C. 701 et seq. Plaintiff claimed he suffered "emotional issues" and "persistent anger" because the county "violated [his] right to communicate" by handcuffing him behind his back and failing to explain their presence. Having concluded that the ADA applied to the investigation of criminal conduct, the court next determined whether the deputies' conduct was reasonable under the circumstances. The court found that due to the exigencies inherent in responding to a domestic violence situation, no further accommodations were required than the ones made by the deputies. Accordingly, the court affirmed the judgment.

Plaintiffs brought an action under 18 U.S.C. 1983 against defendants after defendants asked plaintiffs to remove large, graphic signs depicting aborted fetuses that plaintiffs were using as part of a roadside demonstration. Plaintiffs and defendants subsequently cross-appealed different portions of the district court's opinion and order. The court affirmed the district court's grant of summary judgment on grounds of qualified immunity to defendants in their individual capacities where, at the time of the anti-abortion demonstration at issue, it was not clearly established that law enforcement officers could not proscribe the display of large, graphic photographs in a traditional public forum. The court held that plaintiff was indeed awarded summary judgment on its request for a declaratory judgment that defendants' actions were an unconstitutional infringement on its First Amendment rights. There was no abuse of discretion in the district court's denial of attorney's fees to plaintiffs. Finally, the court held that there was no abuse of discretion in the district court's decision to order defendants to safeguard plaintiff's First Amendment rights and refrain from impermissible content-based restrictions in the future. Therefore, the court affirmed the district court's grant of summary judgment to defendants on grounds of qualified immunity, the denial of an award of attorney's fees to plaintiff, and the grant of injunctive relief to plaintiff against defendants.

Plaintiff brought an action alleging that his dismissal from medical school for unprofessional behavior violated the Rehabilitation Act of 1973, 29 U.S.C. 794, and the Americans with Disabilities Act (ADA), 42 U.S.C. 12182. The district court granted summary judgment in favor of the medical school and plaintiff appealed. Because the court agreed with the district court that, with or without a reasonable accommodation of plaintiff's ADHD and anxiety disorder, plaintiff was not "otherwise qualified" to participate in the medical school's program, the court affirmed the judgment.

Plaintiff sued his employer under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., asserting that his inability to work more than eight hours per day and rotate day/night shifts as a result of physical impairments rendered him disabled under the ADA. The district court granted summary judgment to the employer and plaintiff subsequently appealed. The court held that an inability to work overtime did not constitute a "substantial" limitation on a major life activity under the ADA and the record contained no evidence indicating that plaintiff's inability to work overtime "significantly restricted" his ability to perform a class of jobs or a broad range of jobs in various classes. Therefore, the court affirmed the judgment of the district court.

Plaintiff appealed the district court's order granting summary judgment to the United States on her claim seeking money damages for alleged violations of the Privacy Protection Act (PPA), 42 U.S.C. 2000aa. Plaintiff, a photojournalist who claimed a special interest in covering protests, political demonstrations, and grassroots activism, was identified on a security camera as being present during a protest demonstration during the International Monetary Funds' annual spring meeting. Police officers executed a search warrant, believing it likely that plaintiff's residence contained evidence of suspected criminal activity that occurred during the protest. Plaintiff was never arrested or charged with any crimes relating to the incident. Plaintiff subsequently brought an action against the United States under the PPA and the district court granted summary judgment in favor of the United States. The court agreed with the district court that there was probable cause to believe plaintiff conspired with a group of vandals or aided and abetted the offenses committed by the group. Accordingly, the court concluded that the United States was entitled to summary judgment based on the "suspect exception" to the PPA and affirmed the judgment.

This appeal arose from an unsuccessful Title VII action brought by the Equal Employment Opportunity Commission (EEOC) against Great Steaks, Inc. The EEOC accused Great Steaks of subjecting female employees to a sexually hostile work environment. Although at the start of the case the EEOC asserted its claim on behalf of multiple claimants, that number diminished to one by trial. After a three-day trial, the jury rendered a verdict in Great Steaks' favor. Great Steaks subsequently moved for an award of attorneys' fees, maintaining it was entitled to such an award under three statutory provisions. The district court denied the motion for attorneys' fees in its entirety. On appeal, Great Steaks contended that the district court erred in doing so. Upon review of Great Steaks' claims of error and the laws it cited as grounds for relief, the Fourth Circuit found no abuse of discretion in the district court's decision. The Court affirmed the district court's decision.

Plaintiff filed a racial discrimination action under Title VII in a North Carolina state court, naming the Secretary as a defendant. The Secretary removed the case to federal court under 28 U.S.C. 1442(a) and then filed a motion to dismiss. The court concluded that because the United States and the Secretary did not consent to be sued in a North Carolina state court under Title VII, the state court lacked subject matter jurisdiction. Inasmuch as removal to the federal court, under the doctrine of derivative jurisdiction, did not cure that jurisdictional defect, the court affirmed the district court's order.

Defendant was indicted on the charge of possessing a firearm while being a felon in violation of 18 U.S.C. 922(g)(1). Defendant, an African American, moved to dismiss the indictment, claiming that the U.S. Attorney's Office selected him for prosecution under a federal-state law enforcement initiative known as Project Exile because of his race, in violation of the equal protection component of the Fifth Amendment's Due Process Clause. On appeal, defendant requested that the court reverse the district court's order denying his motion for discovery and remand the case for discovery and an evidentiary hearing. The court held that defendant failed to make a credible showing that a similarly situated defendant of another race had evaded prosecution under Project Exile in order to obtain discovery on his selective prosecution claim and that defendant had failed to carry his burden of producing some evidence to make a credible showing of both discriminatory effect and intent. Accordingly, the judgment of the district court was affirmed.

Plaintiff appealed the district court's order affirming the Commissioner's denial of her application for supplemental security income (SSI). The court found that substantial evidence supported the ALJ's conclusion that plaintiff was not disabled within the meaning of the Social Security Act, 42 U.S.C. 301 et seq. Accordingly, the court affirmed the district court's grant of judgment on the pleadings in favor of the Commissioner.