Justia Civil Rights Opinion Summaries

Articles Posted in US Court of Appeals for the Fourth Circuit
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After plaintiff's murder conviction was vacated when another person confessed to the murder, plaintiff filed suit against the City of Baltimore, the Baltimore Police Department, and others, alleging violations of his federal and state civil rights which led to his wrongful imprisonment for the murder. After a ten-day trial, the jury returned a $15 million verdict in favor of plaintiff. Defendant Goldstein, one of the officers at the scene of the murder, appealed.The Fourth Circuit affirmed the district court's denial of motions for judgment as a matter of law or a new trial under Rules 50 and 59 of the Federal Rules of Civil Procedure, because there was evidence from which a reasonable jury could have found police misconduct. The court found no error in the district court's jury instructions, taken as a whole, because they complied with the law and the district court's earlier rulings. Finally, although the district court improperly admitted hearsay evidence, the error, in the context of the record as a whole, was harmless. Accordingly, the court affirmed the jury's verdict and the district court's denial of Rule 50 and 59 motions. However, the court reversed the district court's dismissal of plaintiff's claim against the Baltimore Police Department under Monell v. Department of Social Services of City of New York, 436 U.S. 658 (1978) where the district court did not explain why the allegations of the complaint that were sufficient earlier no longer were. Rather, the district court's dismissal seems to be based on the verdict issued against Defendant Goldstein. If the City does in fact indemnify Goldstein and the judgment is satisfied, the Monell claim would be moot. View "Burgess v. Goldstein" on Justia Law

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The Fourth Circuit held that the district court erred by dismissing under Federal Rule of Civil Procedure 12(b)(6) the Foundation's complaint against the executive director of the North Carolina State Board of Elections (the Board), alleging a violation of the disclosure provision in the National Voter Registration Act of 1993 (NVRA). The Foundation sought disclosure of broad categories of documents related to the identification of North Carolina voter registrants whom the Board had identified as potentially failing to satisfy the statutory citizenship requirement.The court vacated the district court's judgment and remanded, concluding that the district court erred in holding that the Foundation failed to state a claim under the NVRA's disclosure provision simply because the request implicated potential criminal conduct of registrants. The court explained that the disclosure provision does not contain such a blanket exemption and requires a more exacting and tailored analysis than what occurred in this case. Because discovery was not conducted, the court cannot discern on this record whether the Foundation may be entitled to disclosure of some of the documents requested. Therefore, the court remanded to the district court for further consideration of the documents subject to four restrictions excluding from disclosure: (1) information precluded from disclosure by the Privacy Act of 1974 and the Driver's Privacy Protection Act of 1994; (2) information obtained from confidential federal databases under the United States Department of Homeland Security's Systemic Alien Verification for Entitlements system (the SAVE system) that is otherwise protected from disclosure by statute or by the Board's agreement with the Department regarding confidentiality; (3) any requested voter registration applications, or the names affiliated with those applications, that are subject to protection as part of any prior or current criminal investigation; and (4) the identities and personal information of individuals who potentially committed criminal offenses, including those who later were determined to be United States citizens, which must be redacted from any documents ultimately released as sensitive information vulnerable to abuse. View "Public Interest Legal Foundation v. North Carolina State Board of Elections" on Justia Law

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In 2010, Lancaster was sentenced to 180 months’ imprisonment for conspiracy to traffic in crack cocaine and cocaine powder. In 2020 he sought a sentence reduction under the First Step Act of 2018, 132 Stat. 5194, to the sentence that would have been imposed, had the Fair Sentencing Act of 2010 been in effect at the time of his offense. The district court denied Lancaster’s motion, concluding on the merits that it would have imposed the same sentence on him had the Fair Sentencing Act been in effect. The court did not recalculate Lancaster’s Guidelines range and apparently did not consider the 18 U.S.C. 3553(a) factors in light of current circumstances. Lancaster argued that he no longer qualifies as a career offender for purposes of sentencing.The Fourth Circuit vacated. Additional analysis was required. Lancaster was convicted under 21 U.S.C. 846, a statute for which sentences were modified by the Fair Sentencing Act, and is eligible for discretionary relief under the First Step Act, which made the Fair Sentencing Act retroactive. The court was, therefore, required to consider that Lancaster no longer could be sentenced as a career offender and consider section 3553's factors. View "United States v. Lancaster" on Justia Law

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About a year after High was released from state prison, where he had served 20 years for murder, he began trafficking in illegal drugs. In 2017-2018, he distributed at least 168 grams of crack cocaine, 6.61 grams of marijuana, and 10,325 grams of cocaine powder. He pleaded guilty to distributing crack cocaine and possession of a firearm in furtherance of a drug-trafficking crime and was sentenced to 84 months’ imprisonment, which represented a downward departure under U.S.S.G. 5K1.1 of over 60 months based on "substantial assistance." In May 2020, 16 months after his sentencing, High (age 42) sought compassionate release under 18 U.S.C. 3582(c)(1)(A). He cited as “extraordinary and compelling reasons” the Covid-19 pandemic confronting the prison system and argued that he is not a danger to the community. High had been diagnosed with cardiovascular conditions. The government noted the absence of any infection at the institution where he was confined.The Fourth Circuit affirmed the denial of relief. The district court did not abuse its discretion in declining to reduce High’s term of imprisonment by approximately two-thirds, based on its consideration of the 18 U.S.C. 3553(a) factors. The court was aware of the arguments, considered the relevant sentencing factors, and had an “intuitive reason” for adhering to what was already a below-Guidelines sentence; its explanation for denying High’s motion for compassionate release was adequate. View "United States v. High" on Justia Law

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Officer Richardson stopped a car driven by Davis because he believed that the vehicle’s windows were tinted too dark. Davis had a history of felony drug charges and convictions. Other officers arrived. About three minutes into the stop, while Richardson talked with the other officers, Davis drove off without his license or proof of insurance, which were in Richardson’s possession. The officers gave chase. Davis raced through a residential neighborhood until he reached a dead-end, drove between houses and into someone’s backyard, got out of his vehicle carrying a backpack, ran into a swamp, and got stuck. Richardson drew his service weapon and ordered Davis to come out.Davis returned to dry land, dropping the backpack, and lying down on his stomach. Richardson patted Davis down and found a large amount of cash. Richardson handcuffed Davis, placed him under arrest, then unzipped the backpack and discovered large amounts of cash and plastic bags containing what appeared to be cocaine. A search of Davis’s vehicle revealed a digital scale and bundles of cash. The officers also received a report that Davis tossed a firearm out of his car window, then recovered a handgun from Davis’s path through the residential area. The district court denied Davis’s motion to suppress.The Fourth Circuit vacated. Incident to an arrest, a vehicle may be searched without a warrant if it was reasonable for the police to believe that the arrestee “could have accessed his car at the time of the search.” The court extended that holding to the search of the backpack. Davis was handcuffed and lying on his stomach during the search. View "United States v. Davis" on Justia Law

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Plaintiff filed suit against his former employer, the City of Newport News, alleging that it failed to accommodate his disability in violation of the Americans with Disabilities Act (ADA). Plaintiff alleged that the City concluded that he could not perform the essential functions of his job as a detective and then offered him the options of either retiring early or accepting reassignment to a civilian position he did not want. Plaintiff reluctantly retired.The Fourth Circuit vacated the district court's grant of summary judgment in favor of the City, concluding that it is generally inappropriate for an employer to unilaterally reassign a disabled employee to a position the employee does not want when another reasonable accommodation exists that would allow the disabled employee to remain in their current, preferred position. The court clarified that it did not hold that an employer can never reassign an employee when there exists a reasonable accommodation that will keep the employee in their current and preferred position. This broad question was not before the court. Nor should this opinion be read in any way to restrict the ability of employers and employees to agree to a voluntary transfer. Rather, the court simply reiterated that reassignment is strongly disfavored when an employee can still do their current job with the assistance of a reasonable accommodation, and that reassignment should therefore be held "in reserve for unusual circumstances." View "Wirtes v. City of Newport News" on Justia Law

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Plaintiff, the owner of a chain of pharmacies in Maryland and nearby states, was the subject of a Medicaid fraud prosecution. After the district court dismissed the charges against plaintiff, he filed suit seeking compensatory and punitive damages from multiple defendants. At issue on appeal are two of the district court's preliminary rulings.The Fourth Circuit affirmed the district court's dismissal of the federal constitutional claims, concluding that these claims would extend the Bivens remedy into a new context, and that special factors counsel against an extension to cover intertwined allegations of wrongdoing by prosecutors and criminal investigators in plaintiff's prosecution. However, the court reversed the district court's determination that the state-law claims can move forward against Prosecutor Pascale. Rather, the court found that absolute prosecutorial immunity bars the claims against her. Accordingly, the court affirmed in part and reversed in part, remanding for further proceedings. View "Annappareddy v. Pascale" on Justia Law

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Petitioner filed an application for a writ of habeas corpus under 28 U.S.C. 2254, seeking relief from his convictions in Maryland state court for attempted first degree murder, first degree assault, use of a handgun in the commission of a crime of violence, and second degree assault. Petitioner's conviction stemmed from domestic abuse incidents involving his ex-wife where he ultimately shot her.Petitioner claims that he is entitled to habeas relief because (1) he did not knowingly and voluntarily waive his right to a jury trial, in violation of Patton v. United States, 281 U.S. 276 (1930); (2) the prosecution suppressed material evidence, in violation of Brady v. Maryland, 373 U.S. 83 (1963); and (3) he received ineffective assistance from his legal counsel, in violation of Strickland v. Washington, 466 U.S. 668 (1984). The district court granted relief in part on the Patton and Brady claims, dismissing the Strickland claims without prejudice.The Fourth Circuit held that the district court's decision to grant petitioner habeas relief runs contrary to the deference that federal courts are required to afford state court adjudications of federal constitutional claims. In regard to the Patton claim, the court concluded that the state court's adjudication of petitioner's challenge to his waiver was not unreasonable under the standards of the Antiterrorism and Effective Death Penalty Act (AEDPA). The court explained that petitioner failed to make a plain showing that his waiver was not knowing and voluntary.In regard to the Brady claims, the court concluded that petitioner was not entitled to relief in regard to his paid informant claim, more lenient treatment claim, claims arising out of the government witness and the ex-wife's affidavit, as well as petitioner's claim regarding the alleged confession of other deaths. Finally, because the district court declined to consider petitioner's claims of ineffective assistance of counsel under Strickland, and dismissed them without prejudice, the court also vacated this judgment. Accordingly, the court vacated and remanded for further proceedings. View "Horner v. Nines" on Justia Law

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The Fourth Circuit affirmed the district court's denial of habeas relief under 28 U.S.C. 2241. Petitioner claims that, pursuant to United States v. Wheeler, 886 F.3d 415 (4th Cir. 2018), the district court was permitted to address the merits of his petition.The court declined to hold that the explanation in Mathis v. United States, 136 S. Ct. 2243 (2016), about how to determine whether parts of a statute are "elements or means" changed this circuit's substantive law applying the modified categorical approach to South Carolina third degree burglary. The court explained that, to the extent petitioner contends Mathis changed settled substantive Supreme Court law, Mathis itself made clear that it was not changing, but rather clarifying, the law. To the extent petitioner contends Mathis changed settled Fourth Circuit law, the court rejected such contentions. Furthermore, petitioner's arguments relying on three other circuit cases failed because these cases do not utilize a test like Wheeler. Therefore, petitioner cannot satisfy prong two of the Wheeler test. View "Ham v. Breckon" on Justia Law

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After the DEA terminated Darek and Lisa Kitlinski's employment based on their refusal to participate in an internal investigation into their own allegations of misconduct by the DEA, the Kitlinskis alleged that the DEA terminated Darek in violation of the Uniformed Services Employment and Reemployment Rights Act of 1994 (USERRA), and that the DEA terminated Lisa in retaliation for her support of Darek’s USERRA claims against the DEA. The Kitlinskis also claim that the DEA retaliated against them for their prior protected activity in violation of Title VII of the Civil Rights Act of 1964.The Fourth Circuit affirmed the district court's grant of summary judgment in favor of the DEA, concluding that the Kitlinskis offer no evidence that Darek's military service or his prior USERRA-protected activity was a motivating factor in his termination. Furthermore, even assuming that Armstrong v. Index Journal Co., 647 F.2d 441, 448 (4th Cir. 1981), applies here, the court has little difficulty concluding that the DEA's interest in ensuring its employees' full participation in internal investigations outweighs any interest Lisa had in promoting USERRA's nondiscriminatory purpose. The court also concluded that no reasonable factfinder could conclude that the DEA terminated the Kitlinskis' employment in retaliation for engaging in protected activity. The court explained that the Kitlinskis offer no evidence showing that the DEA terminated their employment for any reason other than their conduct during the OPR investigation. The court rejected the Kitlinskis' remaining claims. View "Kitlinski v. Department of Justice" on Justia Law