Justia Civil Rights Opinion Summaries

Articles Posted in US Court of Appeals for the Fourth Circuit

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The Fourth Circuit reversed the district court's denial of habeas relief, holding that a juror's external communication with her pastor regarding the death penalty was not harmless. Given how Federal Rule of Evidence 606 limits the presentation of evidence in these circumstances, the court held that it was especially important for it to view the record practically and holistically when considering the effect that a juror's misconduct reasonably may be taken to have had upon the jury's decision. In this case, the juror shared the pastor's counsel with the other jurors in an apparent effort to convince someone it was okay to vote for the death penalty. The court remanded for further proceedings. View "Barnes v. Thomas" on Justia Law

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Plaintiff, a Virginia inmate, filed a 42 U.S.C. 1983 action against two Virginia Department of Corrections (VDOC) officials, alleging that defendants violated his Eighth Amendment rights by denying him treatment for his Hepatitis C virus (HCV). The Fourth Circuit vacated the district court's grant of summary judgment for defendants, holding that genuine disputes of material fact exist as to plaintiff's deliberate indifference claim against Defendant Schilling, the Health Services Director. In this case, there was sufficient evidence to establish a genuine issue of material fact as to Schilling's personal involvement in the denial of treatment for plaintiff's HCV. The court also held that genuine disputes of material fact exist as to plaintiff's deliberate indifference claim to Defendant Amonette, the Chief Physician, because a factfinder could determine that Amonette knew that HCV is a serious disease that affects a large percentage of those incarcerated in VDOC facilities. Furthermore, plaintiff presented evidence that Amonette knew that a lack of treatment for someone diagnosed with HCV, like plaintiff, creates a substantial risk of harm to that person. The court rejected defendants' alternative argument, which was based on a misreading of the opinion, and remanded for further proceedings. View "Gordon v. Schilling" on Justia Law

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Plaintiffs filed suit seeking to hold the United States liable for negligently performing a background check on Dylann Roof, the person who entered a church in Charleston, South Carolina and opened fire, killing nine worshippers. No one disputes that if the background check had been performed properly, it would have prevented Roof from purchasing the firearm he used. The district court dismissed plaintiffs' claims for lack of subject matter jurisdiction. The Fourth Circuit reversed and held that neither the discretionary function exception of the Federal Tort Claims Act nor the Brady Act's immunity provision in 18 U.S.C. 922(t)(6) affords the Government immunity in this case. In regard to the FTCA, the court held that this case turns on the NICS Examiner's alleged negligence in failing to follow a clear directive and the government could not claim immunity under these circumstances. The court held that the district court did not err by concluding that the government could not be held liable under the FTCA for declining to give Examiners access to the N-DEx, and the court rejected plaintiffs' claim that the government contravened a mandatory directive by failing to maintain data integrity during the NICS background check. In regard to the Brady Act, the court held that the district court erred in construing 18 U.S.C. 992(t)(6) to bar plaintiffs' claims where plaintiffs sued the government rather than any federal employee, and the federal employees whose conduct forms the basis of this suit were not responsible for providing information to the NICS system. View "Sanders v. United States" on Justia Law

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The Fourth Circuit affirmed the district court's grant of summary judgment for IPC in an action brought by plaintiff under Title VII of the Civil Rights Act of 1965 and the Equal Pay Act of 1963 (EPA), alleging gender and race discrimination. In regard to plaintiff's hostile work environment constructive discharge claims, without commenting on the district court's decision concerning the severe or pervasive requirement, the court held on an alternative ground that plaintiff failed to present sufficient evidence creating a genuine issue of material fact that her working conditions were so intolerable that a reasonable employee would be compelled to resign. The court also held that plaintiff failed to present evidence that created a genuine issue of material fact regarding her retaliation claim. Finally, the court held that plaintiff failed to offer evidence that created a genuine issue of material fact concerning her alleged EPA violation. View "Evans v. International Paper Co." on Justia Law

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The Fourth Circuit affirmed the district court's grant of summary judgment for IPC in plaintiff's action under Title VII of the Civil Rights Act of 1965, alleging race-based discrimination claims. In regard to the disparate treatment claim, the court held that plaintiff's claims of disparate treatment for being denied positions, overtime, additional educational benefits and training were time-barred. As for plaintiff's timely claim that he was denied annual reviews, the court held that plaintiff offered no evidence demonstrating IPC's failure to give him annual reviews affected the terms, benefits and conditions of his employment. Furthermore, even if hostile treatment could qualify as an adverse employment action, plaintiff's claim that the hostile treatment he received at IPC constitutes an adverse employment action would fail as a matter of law. In regard to the race-based hostile work environment claim, the court held that the totality of the circumstances did not sufficiently demonstrate a severe or pervasive hostile work environment. Finally, plaintiff failed to create a genuine issue of material fact as to his constructive discharge claim. View "Perkins v. International Paper Co." on Justia Law

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Under the Supreme Court's decision in Wolff v. McDonnell, 418 U.S. 539 (1974), inmates at risk of being deprived of a liberty interest, like good time credits, have a qualified right to obtain and present video surveillance evidence. The Fourth Circuit vacated the district court's judgment in this case because the district court failed to make several factual critical determinations bearing on whether petitioner's disciplinary proceeding failed to comply with that right. Accordingly, the panel remanded for further proceedings. View "Lennear v. Wilson" on Justia Law

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Plaintiff, a former special agent with the Virginia State Police, filed suit under the Americans with Disabilities Act (ADA) and Title VII of the Civil Rights Act against the Commonwealth, seeking relief that includes compensatory damages, reinstatement, and back pay. The Fourth Circuit affirmed the district court's dismissal of the ADA claim, because the Commonwealth has not waived its sovereign immunity from that claim. However, the court reversed the district court's decision that claim preclusion barred the Title VII claims, because the initial forum did not have the power to award the full measure of relief sought in this litigation. Accordingly, the court remanded for further proceedings. View "Passaro v. Commonwealth of Virginia" on Justia Law

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This case stemmed from the wrongful conviction of two brothers, teenage boys with severe intellectual disabilities, for the rape and murder of an 11 year old girl in 1983. The brothers spent 31 years in prison and on death row before they were exonerated based on DNA evidence linking another individual to the crime. The brothers filed a 42 U.S.C. 1983 action alleging that the state and county law enforcement officers investigating the crime violated their Fourth Amendment and due process rights. The Fourth Circuit held that the district court did not improperly apply the test for qualified immunity by waiting to parse the liability of each individual defendant as it relates to each claim until the facts were determined; defendants did not have probable cause to arrest the brothers as a matter of law; and the brothers' right not to be arrested without probable cause based on a coerced and fabricated confession was clearly established. Therefore, the district court did not err by denying summary judgment to defendants on the false arrest and malicious prosecution claims based on qualified immunity. The court also held that the district court properly denied summary judgment as to the due process claims where it was beyond debate at the time that the brothers' constitutional rights not to be imprisoned and convicted based on coerced, falsified, and fabricated evidence or confessions, or to have material exculpatory evidence suppressed, were clearly established. View "Gilliam v. Sealey" on Justia Law

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Plaintiff, her minor son, and her father-in-law filed a 42 U.S.C. 1983 action against a state trooper, asserting various violations of the Fourth Amendment. Plaintiff's claims arose from her arrest for obstruction when she attempted to stop the trooper from shooting her family's dog. The district court granted summary judgment for the trooper. The Fourth Circuit held that there were genuine disputes of fact underlying the false arrest, excessive force, and malicious prosecution claims. The court also held that the district court properly denied plaintiff's motion for summary judgment on the search and seizure claims. Accordingly, the court affirmed the district court's order denying plaintiff partial summary judgment and reversed the order granting summary judgment to the trooper. The court remanded for further proceedings. View "Hupp v. Cook" on Justia Law

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The Fourth Circuit reversed the district court's denial of a petition for habeas relief under 28 U.S.C. 2241 and remanded with instructions to grant the writ. The court held that petitioner's current sentence stems from faulty arithmetic based on a now-obsolete scheme of statutory interpretation, and thus his petition met the requirements of section 2255(e), the savings clause. In this case, petitioner's conviction on Count IV—the second of his 18 U.S.C. 924(c) convictions—could not stand because it was not supported by an independent firearm possession under recent Tenth Circuit precedent. View "Hahn v. Moseley" on Justia Law