Justia Civil Rights Opinion Summaries

In June 2015, Dylann Roof shot and killed nine people at Mother Emanuel AME Church in Charleston, South Carolina, including M.P.'s father, Reverend Clementa Pinckney. M.P., a minor, filed a lawsuit against Meta Platforms, Inc. (formerly Facebook, Inc.) and its subsidiaries, alleging that Facebook's algorithm recommended harmful content that radicalized Roof, leading to the murders. M.P. asserted claims of strict products liability, negligence, and negligent infliction of emotional distress under South Carolina law, as well as a federal claim under 42 U.S.C. § 1985(3) for conspiracy to deprive her of her civil rights.The United States District Court for the District of South Carolina dismissed M.P.'s complaint under Federal Rule of Civil Procedure 12(b)(6), concluding that Section 230 of the Communications Decency Act barred her state law tort claims. The court also found that M.P. failed to plausibly allege a claim under 42 U.S.C. § 1985(3).The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that M.P.'s state law tort claims were barred by Section 230 because they sought to hold Facebook liable as a publisher of third-party content. The court also determined that M.P. failed to plausibly allege proximate causation under South Carolina law, as her complaint did not provide sufficient factual foundation linking Roof's Facebook use to his crimes. Additionally, the court found that M.P. forfeited her challenge to the dismissal of her Section 1985 claim by not adequately addressing it in her appellate brief. The court also concluded that any potential claim under 42 U.S.C. § 1986 was barred by the one-year statute of limitations. Thus, the Fourth Circuit affirmed the district court's judgment granting Facebook's motion to dismiss. View "M.P. v. Meta Platforms Inc." on Justia Law

Curtis Wells parked his car near Arlington Cemetery and was noticed by Officer Armstrong due to his animated gestures while on a phone call. Armstrong approached Wells and discovered that his car had an expired registration. Arlington County police were called, and they found that Wells did not have a driver's license and had weapons in his car. The police decided to tow Wells's car and conducted an inventory search, which revealed various weapons and tactical gear, including a ballistic plate carrier. Wells was sent home, but further investigation suggested that the plate might have been stolen from the Army. Nine days later, Wells was arrested for receiving stolen property.In the United States District Court for the Eastern District of Virginia, Wells brought state and federal claims against various officers and entities, alleging Fourth and Fifth Amendment violations, among other claims. The district court dismissed all his claims, reasoning that the officers were protected by qualified immunity and that Wells had not plausibly alleged the necessary elements for his state tort claims.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's dismissal. The court held that the officers' actions were protected by qualified immunity because Wells did not have a clearly established right against the officers' conduct. The court found that the initial approach by Officer Armstrong was justified under the community-caretaking exception, the inventory search of Wells's car was conducted according to standard procedures, and Wells had consented to the safekeeping of his property. Additionally, the court held that Wells's Second Amendment claims failed because the right to public carry was not clearly established in 2020. The court also dismissed Wells's state law claims, finding that he had not plausibly alleged the necessary elements for false imprisonment or malicious prosecution. View "Wells v. Fuentes" on Justia Law

In September 2018, police officers in Fayetteville, North Carolina, observed a car performing a U-turn and stopping in front of Allen Wendell McNeil's house. After a brief interaction with the car's occupants, the police conducted a traffic stop and found a small bag of marijuana on the passenger. Without a warrant, the officers then went to McNeil's house for a "knock and talk." When McNeil's children answered the door and said he was not home, the officers proceeded to the backyard, where they found McNeil in a shed and detected the smell of marijuana. This led to McNeil's detention and the subsequent search and seizure of marijuana, money, and guns from his property.McNeil was charged with marijuana distribution and firearm possession. He pleaded guilty without a plea agreement, and the district court sentenced him to 114 months in prison. McNeil's direct appeal was affirmed by the United States Court of Appeals for the Fourth Circuit.McNeil filed a pro se petition under 28 U.S.C. § 2255, claiming ineffective assistance of counsel for failing to file a motion to suppress evidence obtained from the warrantless search and for not pursuing a plea agreement despite his requests. The district court dismissed the petition without an evidentiary hearing, ruling that McNeil's Fourth Amendment claim was frivolous and that his statements during the Rule 11 hearing precluded his ineffective assistance claim regarding the plea agreement.The United States Court of Appeals for the Fourth Circuit reviewed the case and concluded that McNeil's ineffective assistance claims could not be resolved on the existing record. The court held that the district court erred in dismissing McNeil's claims without an evidentiary hearing, as the facts surrounding the police officers' entry into the backyard and the plea negotiations required further factual development. The Fourth Circuit vacated the district court's judgment and remanded the case for an evidentiary hearing. View "United States v. McNeil" on Justia Law

Plaintiff pro se filed suit against defendant, a prison official, alleging that plaintiff's placement in segregation violated his constitutional rights to freedom from retaliation for filing a grievance, equal protection, and due process. The Fourth Circuit agreed with the district court that plaintiff failed to state a claim under the Equal Protection and Due Process clauses. The court held, however, that plaintiff pleaded sufficient facts to state a claim that defendant violated plaintiff's First Amendment rights by placing him in segregation as retaliation for filing a grievance. Furthermore, it was clearly established at the time that defendant placed plaintiff in segregation that retaliating against an inmate for filing a grievance violates the inmate's rights under the First Amendment. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Martin v. Duffy" on Justia Law

The Fourth Circuit affirmed in substantial part the district court's issuance of a nationwide injunction as to Section 2(c) of the challenged Second Executive Order (EO-2), holding that the reasonable observer would likely conclude EO-2's primary purpose was to exclude persons from the United States on the basis of their religious beliefs. Section 2(c) reinstated the ninety-day suspension of entry for nationals from six countries, eliminating Iraq from the list, but retaining Iran, Libya, Somalia, Sudan, Syria, and Yemen.Determining that the case was justiciable, the Fourth Circuit held that plaintiffs have more than plausibly alleged that EO-2's stated national security interest was provided in bad faith, as a pretext for its religious purpose. Because the facially legitimate reason offered by the government was not bona fide, the court no longer deferred to that reason and instead may look behind the challenged action. Applying the test in Lemon v. Kurtzman, the court held that the evidence in the record, viewed from the standpoint of the reasonable observer, created a compelling case that EO-2's primary purpose was religious. Then-candidate Trump's campaign statements revealed that on numerous occasions, he expressed anti-Muslim sentiment, as well as his intent, if elected, to ban Muslims from the United States. President Trump and his aides have made statements that suggest EO-2's purpose was to effectuate the promised Muslim ban, and that its changes from the first executive order reflect an effort to help it survive judicial scrutiny, rather than to avoid targeting Muslims for exclusion from the United States. These statements, taken together, provide direct, specific evidence of what motivated both executive orders: President Trump's desire to exclude Muslims from the United States and his intent to effectuate the ban by targeting majority-Muslim nations instead of Muslims explicitly. Because EO-2 likely fails Lemon's purpose prong in violation of the Establishment Clause, the district court did not err in concluding that plaintiffs are likely to succeed on the merits of their Establishment Clause claim. The court also held that plaintiffs will likely suffer irreparable harm; the Government's asserted national security interests do not outweigh the harm to plaintiffs; and the public interest counsels in favor of upholding the preliminary injunction. Finally, the district court did not abuse its discretion in concluding that a nationwide injunction was necessary to provide complete relief, but erred in issuing an injunction against the President himself. View "International Refugee Assistance Project v. Trump" on Justia Law

Petitioner challenged the district court's denial of his 28 U.S.C. 2254 petition, alleging that his guilty plea to attempted murder and a related firearm offense resulted from his trial counsel's disabling conflict of interest. Determining that the appeal was not moot, the Fourth Circuit held that the petition was timely. In this case, petitioner's limitations period commenced on December 12, 2008, when the judgment entered upon his November 2008 resentencing became final. Because his postconviction proceedings statutorily tolled the limitations period from at least January 20, 2009 through October 21, 2013, his petition was timely. Furthermore, under the exceptional circumstances presented by petitioner's case, neither procedural bar at issue was adequate to preclude federal review of petitioner's ineffective assistance of counsel claim; the Court of Special Appeals' application of Md. Code Ann., Crim. Proc. 7-106(b)(1)(i)(6) was inadequate to bar federal review of petitioner's claim; and the circuit court's reliance on section 7-106(b)(1)(i)(4) was inadequate to bar consideration of his ineffective assistance claim on federal habeas review. The court vacated the district court's judgment and remanded for further proceedings. View "Woodfolk v. Maynard" on Justia Law

Wikimedia and eight other organizations filed suit challenging Upstream surveillance, an electronic surveillance program operated by the NSA. First, Wikimedia alleged that the sheer volume of its communications makes it virtually certain that the NSA has intercepted, copied, and reviewed at least some of its communications (Wikimedia Allegation). Second, all plaintiffs alleged that in the course of conducting Upstream surveillance the NSA was intercepting, copying, and reviewing substantially all text-based communications entering and leaving the United States, including their own (Dragnet Allegation). The district court dismissed the complaint based on lack of Article III standing. The Fourth Circuit held that the analysis of speculative injury in Clapper v. Amnesty International USA, 133 S. Ct. 1138 (2013), was not controlling in this case because the central allegations were not speculative. As to Wikimedia, the court vacated and remanded because Wikimedia made allegations sufficient to survive a facial challenge to standing. As to the other plaintiffs, the court affirmed because the complaint did not contain enough well-pleaded facts entitled to the presumption of truth to establish their standing. View "Wikimedia Foundation v. NSA/CSS" on Justia Law

Petitioner appealed the denial of his habeas corpus petition, alleging that his trial counsel was ineffective for failing to request an alibi instruction. The Fifth Circuit held that the post-conviction relief court's decision was a reasonable application of Strickland v. Washington. Although the parties accept for purposes of appeal that trial counsel's performance was deficient, even if the instruction had been given, there was no reasonable probability that the outcome of the proceedings would have been different. Therefore, because petitioner was not prejudiced by the error, the court affirmed the judgment. View "Maurice Hope v. Warden Cartledge" on Justia Law

Plaintiff filed suit against his former employer, Sotera, alleging that the company violated the Family and Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq. The Fourth Circuit affirmed the grant of summary judgment to Sotera, holding that the district court correctly rejected plaintiff's legal contention that Sotera interfered with plaintiff's FMLA rights by not restoring him to his pre-leave position; no reasonable factfinder could conclude that Sotera failed to place plaintiff in "an equivalent position" or that the differences between the two jobs at issue were more than merely de minimis; and plaintiff failed to create a genuine issue of material fact as to his termination-related claims. The court affirmed the district court's conclusion that Sotera was entitled to summary judgment on plaintiff's claim that Sotera interfered with his FMLA rights by reinstating him to a sham position and then firing him at the first opportunity. Finally, plaintiff failed to adduce sufficient evidence to create a genuine issue of material fact such that a reasonable factfinder could conclude that the adverse employment action was taken for an impermissible reason, such as retaliation. View "Waag v. Sotera Defense Solutions" on Justia Law

After BNT, a minority-owned television network, was granted and then denied an economic development loan from the City, BNT filed suit alleging, among other things, claims for racial discrimination under 42 U.S.C. 1981. The district court concluded that BNT's factual allegations were so insubstantial as to render its claim implausible, and therefore dismissed the complaint with prejudice. The Fourth Circuit held that the district court misinterpreted and misapplied the controlling pleading standard. In this case, the key issue was not whether the City would contract with a minority-owned business, but whether the City would contract with BNT on the same conditions and under substantially the same circumstances as it would with a nonminority-owned business. BNT has plausibly pled that the conditions under which the City was willing to grant it a loan were more stringent than those the City applied to similarly situated white-owned applicants. Therefore, the district court erred in dismissing BNT's claim of discrimination at the pleading stage. Accordingly, the Fourth Circuit reversed and remanded for further proceedings. View "Woods v. City of Greensboro" on Justia Law