Justia Civil Rights Opinion Summaries

Cybernet filed suit against three state officials under 42 U.S.C. 1983 for directing or participating in the unlawful destruction of its property in violation of the Fourth Amendment. Cybernet's claims stemmed from the execution of search warrants at two video sweepstakes stores owned and operated by Cybernet.The Fourth Circuit affirmed the district court's judgment and held that, taken as a whole, the items seized were within the parameters of the search warrant and any incidental damage that took place is not indicative of the kind of gratuitous damage that would exceed Fourth Amendment bounds. Therefore, the court held that there was no Fourth Amendment violation. Cybernet's motion to compel discovery failed for the same reason. View "Cybernet, LLC v. David" on Justia Law

Plaintiff filed suit against defendants under 42 U.S.C. 1983, alleging claims related to the demotion he suffered in 2012. Plaintiff alleged that defendants racially discriminated against him and seeks reinstatement of his prior position, the removal of negative materials from his personnel file, and reimbursement for his legal expenses. The district court granted summary judgment for defendants.The Fourth Circuit denied defendants' motion to dismiss plaintiff's appeal as moot based on plaintiff's retirement, because plaintiff has sworn that he would promptly return to work if reinstated to his prior position. The court affirmed the district court's grant of summary judgment to the Department, because its removal of this case did not constitute a waiver of sovereign immunity. Finally, the court vacated the district court's award of summary judgment to Defendant Hooks and remanded for further proceedings. In this case, plaintiff is seeking prospective, not retrospective, relief and thus his claim against Hooks falls under the sovereign-immunity exception articulated in Ex Parte Young, 209 U.S. 123 (1908). View "Biggs v. North Carolina Department of Public Safety" on Justia Law

The Fourth Circuit affirmed the district court's dismissal of a petition for habeas corpus relief based on two ineffective assistance of counsel claims previously rejected by the state post-conviction court. The court held that petitioner defaulted on his claims because he failed to raise them to the state court and thus they are unexhausted. Because the new evidence does not fundamentally alter the heart of the two ineffective assistance of counsel claims presented to the state court, the court held that the district court properly deferred to the state court rejection of these claims. Likewise, the court rejected petitioner's third ineffective assistance of counsel claim, holding that he defaulted on this claim by not presenting it to the state court and he failed to make a substantial showing that his trial counsel were ineffective. View "Moore v. Stirling" on Justia Law

The Fourth Circuit reversed the district court's dismissal of plaintiff's 42 U.S.C. 1983 claim, alleging that her Fourth Amendment rights were violated when an officer shot and killed her dog, Jax. The court held that the complaint plausibly stated a claim for an unconstitutional seizure of plaintiff's property for which the officer was not entitled to qualified immunity. Although the court acknowledged that there was evidence in the record on appeal that contradicted some of the allegations in the complaint, the complaint nonetheless alleged that the officer shot Jax when it was in plaintiff's yard, tethered, and incapable of reaching or harming the officer. Because the court must grant all reasonable inferences in favor of plaintiff, the court reversed and remanded for further proceedings. View "Ray v. Roane" on Justia Law

Petitioner appealed the district court's grant of summary judgment denying his 28 U.S.C. 2254 petition for habeas corpus relief. Petitioner alleged due process violations stemming from a prison disciplinary proceeding that resulted in the revocation of twenty days of his good-time credits.The Fourth Circuit affirmed the denial of petitioner's claim regarding the DHO's failure to review the requested surveillance video during his hearing, because there was no clearly established violation of petitioner's right at the time. Therefore, the North Carolina Supreme Court did not act unreasonably in denying petitioner's claim. However, the court vacated the district court's determination that petitioner's conviction was supported by "some evidence" in the record. The court held that this case presented the exceedingly rare circumstance where the record contained no probative evidence to support petitioner's conviction. Therefore, petitioner's disciplinary conviction amounted to a violation of his due process rights. Accordingly, the court remanded with instructions to grant habeas relief as to the good-time credits. View "Tyler v. Hooks" on Justia Law

A Maryland law requiring newspapers, among other platforms, to publish on their websites, as well as retain for state inspection, certain information about the political ads they decide to carry, violates the First amendment. The Fourth Circuit affirmed the preliminary injunctive relief awarded by the district court and explained that, while Maryland's law tries to serve important aims, the state has gone about this task in too circuitous and burdensome a manner to satisfy constitutional scrutiny. The court agreed with the district court that the law is a content-based law that targets political speech and compels newspapers, among other platforms, to carry certain messages on their websites. The court declined to decide whether strict or exacting scrutiny should apply to a disclosure law like the one at issue, and held that the law failed under the more forgiving exact scrutiny standard. View "The Washington Post v. McManus" on Justia Law

Plaintiff, an inmate at a state prison, filed suit against officials at the VDOC under the Religious Land Use and Institutionalized Persons Act (RLUIPA) and the Free Exercise Clause of the First Amendment, alleging that the VDOC was denying him the ability to practice central tenets of his Muslim religion. The district court granted summary judgment to the VDOC.The Fourth Circuit vacated and remanded, holding that the VDOC's stated justifications for denying plaintiff access to a Friday prayer service known as Jum'ah and interfering with his ability to maintain a four-inch beard were invalid under both RLUIPA and the First Amendment. The court commended for consideration by the VDOC in further proceedings the full practical effect of observations made by former correctional officials that providing robust support for inmates' genuine religious exercise would actually enhance prison security and inmate rehabilitation. View "Greenhill v. Clarke" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 against defendant, alleging unlawful entry and use of excessive force in violation of the Fourth Amendment. In this case, police officers used a battering ram to enter plaintiff's dwelling to execute a warrant. The officers did not announce their presence before using the battering ram, and plaintiff responded by pulling out a gun. Although plaintiff never discharged the gun, 29 shots were fired at him and he was struck nine times.The Fourth Circuit affirmed the district court's denial of qualified immunity with respect to the excessive force claim, holding that disputes of material fact preclude an award of summary judgment. The court held that a reasonable jury could find under the facts presented that plaintiff did not pose a threat to the officers justifying the use of deadly force. Furthermore, in light of Cooper v. Sheehan, 735 F.3d 153 (4th Cir. 2013), the court held that plaintiff's Fourth Amendment right to be free from the use of excessive force was clearly established at the time the incident occurred. View "Betton v. Belue" on Justia Law

Plaintiff filed suit challenging South Carolina's decision to terminate PPSAT's provider agreement because it offers abortion services. At issue was whether, and on what basis, the Medicaid Act's free-choice-of-provider provision affords a private right of action to challenge a state’s exclusion of a healthcare provider from its Medicaid roster.The Fourth Circuit affirmed the district court's grant of a preliminary injunction in favor of plaintiff and held that Congress's intent to create an individual right enforceable under 42 U.S.C. 1983 in the free-choice-provider provision is unambiguous. The court also held that a plain-language reading of the provision's mandate—that states "must" furnish Medicaid recipients the right to choose among providers "qualified to perform the service or services required"—bars states from excluding providers for reasons unrelated to professional competency. Because the individual plaintiff in this case has a private right of action to challenge South Carolina's denial of her right to the qualified and willing family-planning provider of her choice, the court agreed with the district court that she has demonstrated a substantial likelihood of success on her free-choice-of-provider claim. Furthermore, the district court did not abuse its discretion in enjoining South Carolina from terminating PPSAT's provider agreement; it was clear that plaintiff would suffer irreparable harm in the absence of a preliminary injunction; and the remaining preliminary injunction factors were satisfied. View "Planned Parenthood South Atlantic v. Baker" on Justia Law

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