Articles Posted in US Court of Appeals for the Fourth Circuit

by
The EEOC filed suit on behalf of a Consol Energy employee, alleging that Consol violated Title VII by constructively discharging the employee instead of accommodating his religious beliefs. In this case, the employee was forced to resign because his religious beliefs prevented him from using a biometric hand scanner. Consol provided an alternative to employees who could not use the hand scanner for non-religious reasons, but refused to accommodate the employee here for his religious objection. A jury returned a verdict in favor of the EEOC. The district court subsequently denied Consol's post-verdict motions. The Fourth Circuit held that Consol was not entitled to summary judgment as a matter of law where the evidence presented at trial allowed the jury to conclude that Consol failed to make available to a sincere religious objector the same reasonable accommodation it offered other employees, in clear violation of Title VII. Furthermore, the court found no error in the numerous evidentiary challenges raised by Consol nor in the district court's determinations regarding lost wages and punitive damages. Accordingly, the court affirmed the district court's judgment. View "EEOC v. Consol Energy, Inc." on Justia Law

by
Plaintiff, who is civilly committed as a sexually dangerous person, filed suit against BOP employees challenging various conditions of his confinement at FCI Butner. The district court dismissed some of plaintiff's claims and then granted summary judgment as to the other claims. The Fourth Circuit held that the district court correctly dismissed BOP policies claims regarding double-bunking of civil detainees, forcing plaintiff to wear the same uniform as a prisoner, and limiting purchases at the commissary and his options on television to those of a prisoner; the commingling with prisoners claims where plaintiff was frequently in the presence of prisoners and that other prisoners taunted and harassed him; and the Fair Labor Standards Act (FLSA) claim where plaintiff did not qualify as an employee. The court also held that the district court correctly granted summary judgment as to the strip searches and mass shakedowns claims, the mail claims, and the educational and vocational programs claims. Accordingly, the court affirmed the judgment. View "Matherly v. Andrews" on Justia Law

by
Plaintiffs Eshow and Safar were arrested for an allegation of fraud that was mistakenly reported and almost immediately retracted. Safar was also briefly incarcerated. Plaintiffs filed suit under 42 U.S.C. 1983 and state law, against the police officer and prosecutor who, at different stages of the criminal process, learned that no crime had occurred and yet failed to take steps to withdraw an arrest warrant. Given the absence of an established duty to act, the Fourth Circuit affirmed the award of qualified immunity to the officer on the section 1983 claims. The court affirmed the grant of absolute immunity to the prosecutor because the prosecutor's decision whether to withdraw an arrest warrant was intimately associated with the judicial phase of the criminal process. However, the court reversed as to the state law claims, remanding to the district court to dismiss the state law claims without prejudice to plaintiffs' right to advance their case in state court. View "Safar v. Tingle" on Justia Law

by
Plaintiff filed suit against Cava, alleging a Title VII retaliation claim for reporting alleged sexual harassment between employees. Plaintiff's supervisor concluded, after an investigation, that plaintiff made up the allegations. The Fourth Circuit affirmed the district court's grant of summary judgment against plaintiff, holding that neither plaintiff nor amici have cited any case holding that the opposition clause protects employees' pretending to oppose Title VII violations by intentionally fabricating allegations, and the court was not aware of any; while the case law plaintiff and amici presented favor liberally interpreting the statute to further the goal of encouraging employees to come forward, they did not favor rewriting a statute that conditions liability on the existence of a retaliatory motive; and there was no genuine dispute of fact regarding the reasonableness of Cava's investigation into whether plaintiff fabricated her conversation with an employee. View "Villa v. Cavamezze Grill, LLC" on Justia Law