Justia Constitutional Law Opinion Summaries

Articles Posted in U.S. 4th Circuit Court of Appeals
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Plaintiffs, a class of Medicaid beneficiaries who suffered from severe developmental disabilities, sued the NCDHHS, PBH, and the director of PBH, alleging that defendants violated their rights under the Medicaid statute and the Due Process Clause of the Fourteenth Amendment by reducing their health care services without notice and an opportunity for a hearing. On appeal, PBH and the director challenged the district court's entry of a preliminary injunction. However, the NCDHHS did not join the appeal. Given that the NCDHHS had decided not to litigate the appeal, the court concluded that the Medicaid statute, 42 U.S.C. 1396a(a)(5), and accompanying regulations precluded PBH from appealing in the absence of the NCDHHS. Accordingly, the court dismissed the appeal. View "K.C. v. Shipman" on Justia Law

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Plaintiffs commenced this putative class action alleging that defendants participated in a global Internet conspiracy to sell illegal prescription drugs, in violation of the laws of the United States and Virginia. At issue on appeal was whether the district court erred in dismissing the complaint against four foreign banks for lack of personal jurisdiction. The court concluded that Rule 4(k)(2) did not justify the exercise of personal jurisdiction over the banks because exercising jurisdiction over them would not, in the circumstances here, be consistent with the United States Constitution and laws. Subjecting the banks to the coercive power of the court in the United States, in the absence of minimum contacts, would constitute a violation of the Due Process Clause. Accordingly, the court affirmed the district court's orders dismissing the complaint against the banks. View "Unspam Technologies v. Chernuk" on Justia Law

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South Carolina requested a waiver of its maintenance-of-effort condition under the Individuals with Disabilities Act (IDEA), 20 U.S.C. 1412(a)(18), for approximately $67.4 million for its fiscal year 2010. The Secretary granted the waiver in part, but denied it to the extent of the $36.2 million. South Carolina subsequently filed this petition for review, challenging the Secretary's denial of its request for a full waiver and its request for a hearing. The court concluded that the Secretary's action in partially denying the request for a waiver was a determination made with respect to the eligibility of the State for funding and that therefore the court had jurisdiction to consider the State's petition for review. The court also concluded that the Secretary's denial of the State's request for a full waiver was a determination that South Carolina was not eligible to receive a grant in the amount of $36.2 million and that therefore the Secretary was required to provide the State with notice and an opportunity for a hearing before he made a final determination with respect to the waiver request. Accordingly, the court granted the petition for review and remanded for further proceedings. View "SC Dept. of Educ. v. U.S. Sec. of Educ." on Justia Law

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Plaintiff, an employee of NGA with a top secret security clearance, informed the NGA of his marriage after the investigation for his security clearance had been completed but before he had begun work. The NGA conducted a reinvestigation into his security clearance and then revoked the security clearance. Plaintiff commenced this action under the Administrative Procedure Act (APA), 5 U.S.C. 500 et seq., against the NGA and its Director to reverse the NGA's decision, to reinstate his security clearance, and to award him back pay, benefits, and attorneys' fees. The district court dismissed the complaint, concluding that it did not have subject-matter jurisdiction to review a security clearance determination. The court concluded that plaintiff's speculative and conclusory allegations of constitutional violations were essentially recharacterizations of his challenge to the merits of the NGA's security clearance determination and that the court did not have jurisdiction to review such a determination. Accordingly, the court affirmed the judgment. View "Hegab v. Long" on Justia Law

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Plaintiff was convicted in 1993 of carnal knowledge of a minor without the use of force. In this appeal, plaintiff challenged Va. Code sections 9.1-900 et seq. and 18.2-370.5, which, together, classified her as a sexually violent offender and prevented her from entering the grounds of a school or daycare without first gaining permission from the Virginia circuit court and the school board or the owner of the daycare. Unless plaintiff gains such permission, she is not able to meet with her stepson's teachers at school, attend his school functions, or drop him off at or pick him up from school. Plaintiff's complaint included four counts: she alleged that defendants have violated her substantive due process, procedural due process, associational, and free exercise rights. The injuries she alleged with respect to the first, third, and fourth counts stemmed from impediments the Virginia statute and the school board policy placed on her ability to access school and church property. The court held that because she had not yet attempted to undertake the requisite steps to access these properties, she could not demonstrate that these claims were justiciable. While plaintiff's second count was justiciable, she failed to state a procedural due process claim upon which relief could be granted. Accordingly, the court affirmed the district court's dismissal of her claims. View "Doe v. Virginia Dept. of State Police" on Justia Law

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Southern Walk, a homeowners association, brought this action seeking a declaratory judgment against OpenBand, the corporation with which it had contracted in 2001 for wire-based video services. Southern Walk alleged that the 2007 Exclusivity Order issued by the FCC rendered "null and void" OpenBand's exclusive rights under the 2001 contracts to provide such wire-based video services to Southern Walk homeowners. The court affirmed the judgment of the district court to the extent that it held that Southern Walk failed to allege facts supporting standing in this case, but vacated that judgment to the extent that it dismissed the case with prejudice, and remanded with instructions to dismiss without prejudice. The court affirmed the district court's denial of attorney's fees to OpenBand. View "Southern Walk at Broadlands v. Openband at Broadlands, LLC" on Justia Law

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This case arose when Calvary's application to the City for a special use permit was denied. On appeal, Calvary challenged the district court's procedural rulings, contending that the district court abused its discretion in denying Calvary's motion for leave to amend its complaint, which was filed after the district court had dismissed its original complaint, and in denying its motion for reconsideration. The court concluded that Calvary failed to take account of the fact that it filed its motion to amend after its complaint had been dismissed, and there was simply no longer any complaint pending to amend. Calvary never made an effort to open or vacate the judgment under Rule 60(b), and the court rejected its argument that the district court should have construed its motion for reconsideration as a motion to vacate under Rule 60(b). Accordingly, the court affirmed the judgment. View "Calvary Christian Center v. City of Fredericksburg, VA" on Justia Law

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Plaintiff appealed the district court's denial of relief on her claims of discrimination, retaliation, and hostile work environment, brought under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e, as well as wrongful discharge, assault, and battery, brought under Virginia law, against Huntington Ingalls, the successor to her former employer. According to plaintiff, Huntington Ingalls subjected her to an ongoing sexually hostile work environment and her claims centered on the actions of her supervisor. The court held that the district court properly declined to consider those allegations not included in plaintiff's EEOC charge; because the district court correctly determined that amending her complaint would be futile, it did not abuse its discretion in denying her leave to do so; because the department manager did not know of the protected activity, and because the supervisor, who allegedly influenced him, was not principally responsible for the decision to terminate plaintiff's employment, the court affirmed the district court's grant of summary judgment to Huntington Ingalls on the retaliatory discharge claim; and the court affirmed the district court's grant of summary judgment as to the assault and battery claims. View "Balas v. Huntington Ingalls Industries" on Justia Law

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Plaintiffs, thirteenth North Carolina residents who lost access to in-home personal care services (PCS) due to a statutory change, brought suit challenging the new PCS program. The district court granted plaintiffs' motions for a preliminary injunction and class certification. Defendants appealed, raising several points of error. The court agreed with the district court's conclusion that a preliminary injunction was appropriate in this case. The court held, however, that the district court's order failed to comply with Federal Rule of Civil Procedure 65 because it lacked specificity and because the district court neglected to address the issue of security. Accordingly, the court remanded the case. View "Pashby v. Delia" on Justia Law

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Defendant appealed the district court's decision allowing him to represent himself at trial in light of the Supreme Court's decision in Indiana v. Edwards. The heightened standard discussed in Edwards, which applied when the district court considered whether to force counsel on a severely mentally ill defendant competent to stand trial who wished to represent himself, did not control. The court held that this case was more akin to Godinez v. Moran because the district court granted defendant's request to represent himself. Because the court rejected defendant's interpretation of Edwards and was satisfied that the district court applied the correct legal standard, the court affirmed the judgment. View "United States v. Bernard" on Justia Law