Justia Constitutional Law Opinion Summaries

The Fourth Circuit vacated the district court's judgment holding that the statute of limitations barred plaintiff's 42 U.S.C. 1983 suit. The court explained that Congress did not provide fixed timing rules in section 1983 or its companion provision, section 1988. Rather, Congress specified that gaps in section 1983 should be filled by state law, as long as that law is not inconsistent with federal law. Because Virginia lacks a generally applicable statute that pauses limitations to accommodate administrative exhaustion requirements, plaintiff sought to borrow a tolling provision in the Virginia Tort Claims Act (VTCA).The court held that the VTCA did not save plaintiff's claims because it operates on a tighter schedule than section 1983 and does not govern suits against state employees. Furthermore, plaintiff could not invoke equitable estoppel under Virginia law. However, the court held that, with no Virginia rule available to toll the limitations period, refusal to do so during a prisoner's mandatory exhaustion period is inconsistent with federal law and the court could not apply it here. Therefore, the court applied federal equitable tolling principles and held that plaintiff's section 1983 complaint was timely because it was filed within two years of the date he exhausted his administrative remedies required by the Prison Litigation Reform Act. View "Battle v. Ledford" on Justia Law

The Fourth Circuit reversed the district court's determination that plaintiff was required to wait longer than 180 days to commence a civil action under Title VII and the Rehabilitation Act after amending his initial administrative complaint before the relevant agency. The court held that the text of Title VII, as well as the legislative context and purpose, plainly states that a claimant may commence a civil action 180 days from "the filing of the initial charge." Accordingly, the court remanded for further proceedings. View "Stewart v. Iancu" on Justia Law

The Fourth Circuit affirmed the district court's judgment concluding that defendant, chair of the Loudoun County Board of Supervisors, violated the First Amendment rights of one of her constituents, Brian Davison, when she banned Davison from the "Chair Phyllis J. Randall" Facebook page she administered. The court held that Davison had standing because she adduced facts establishing an injury in fact sufficient to justify the prospective declaratory relief awarded by the district court; considering the totality of these circumstances, the district court correctly held that defendant acted under color of state law in banning Davison from the Chair's Facebook Page; and the interactive component of the Chair's Facebook Page constituted a public forum, and defendant engaged in unconstitutional viewpoint discrimination when she banned Davison's page from that forum. In regard to Davison's cross-appeal, the court rejected his assertion that the district court reversely erred by dismissing his claim against defendant in her official capacity and by denying his motion to amend. View "Davison v. Randall" on Justia Law

Plaintiff appealed the district court's grant of summary judgment in favor of DOC officials in an 42 U.S.C. 1983 action alleging due process violations. Plaintiff claimed that, as a result of actions of defendants, he suffered in solitary confinement for three-and-a-half years while in pretrial detention, in violation of his Fourteenth Amendment rights.Determining that it had appellate jurisdiction and the due process claims were not moot, the Fourth Circuit held that Defendants Charlton and Miller were entitled to summary judgment on each of the due process claims because they lacked sufficient personal involvement in the alleged constitutional deprivations. The court held, however, that Director Stirling and Sheriff Carroll were not entitled to qualified immunity on plaintiff's substantive and procedural due process claims arising from plaintiff's solitary confinement as a safekeeper. Because neither the report or the summary judgment properly applied the legal principles that control substantive and procedural due process claims being pursued by a pretrial detainee, the court held that the district court erred in awarding summary judgment to Director Stirling and Sheriff Carroll on these claims. View "Williamson v. Stirling" on Justia Law

The Fourth Circuit affirmed the district court's denial of petitioner's successive 28 U.S.C. 2255 motion in this criminal proceeding stemming from murders committed four decades ago. The court rejected petitioner's prosecutorial misconduct claim based on the discovered evidence of a former Deputy U.S. Marshal that a threat from a prosecutor stopped another individual from confessing on the witness stand during petitioner's trial. The court also rejected petitioner's freestanding actual innocence claim premised on DNA testing. The court held that petitioner failed to overcome the procedural bar of section 2255(h)(1), because neither claim was based on newly discovered evidence that, if proven and viewed in light of the evidence as a whole, would be sufficient to establish by clear and convincing evidence that no reasonable factfinder would have found petitioner guilty of murdering his wife and daughters.In the alternative, the court held that the prosecutorial misconduct claim failed on the merits where the factual findings were well-supported by the evidence and not clearly erroneous. Furthermore, petitioner failed to meet his extraordinarily high burden of showing actual innocence. View "United States v. MacDonald" on Justia Law

Plaintiffs appealed the district court's dismissal of their civil rights actions under Title IX of the Education Amendments of 1972 and 42 U.S.C. 1983, seeking the reinstatement of three claims: a Title IX sex discrimination claim against the University of Mary Washington; a Title IX retaliation claim against UMW; and a section 1983 claim against UMW's former president, Dr. Richard Hurley, for violating the Equal Protection Clause of the Fourteenth Amendment.The Fourth Circuit affirmed the dismissal of the section 1983 claim and held that, at the time of President Hurley's challenged conduct, the equal protection right to be free from a university administrator's deliberate indifference to student-on-student sexual harassment was not clearly established by either controlling authority or by a robust consensus of persuasive authority. The court vacated the dismissal of the retaliation claim insofar as it is premised on UMW’s deliberate indifference to student-on-student retaliatory harassment. The court affirmed the dismissal of the aspect of the retaliation claim that relied exclusively on President Hurley's June 2015 letter. Finally, the panel vacated the dismissal of the Title IX sex discrimination claim against UMW where plaintiffs have sufficiently alleged a sex discrimination claim under Title IX, predicated on UMW's deliberate indifference to the specified student-on-student harassment. View "Feminist Majority Foundation v. Hurley" on Justia Law

Plaintiff and her daughter filed suit against the county, challenging an in-school Bible lesson program for public elementary and middle school students as violating the Establishment Clause. The Fourth Circuit reversed the district court's dismissal of the complaint, holding that plaintiffs have standing because they alleged two actual, ongoing injuries: (1) near-daily avoidance of contact with an alleged state-sponsored religious exercise, and (2) enduring feelings of marginalization and exclusion resulting therefrom. The court also held that plaintiffs' claims were redressable because an injunction would meaningfully redress their injuries. The court also held that the district court erred in treating the temporary suspension of the program as raising ripeness concerns, and plaintiffs' claims were not moot. View "Deal v. Mercer County Board of Education" on Justia Law

Nursing Homes, on behalf of eleven residents, filed suit against the Secretaries, alleging that the Secretaries wrongfully denied the residents Medicaid benefits in violation of the Fourteenth Amendment and several federal statutes.The Fourth Circuit affirmed the district court's dismissal of the complaint for lack of subject matter jurisdiction and failure to state a claim. The court held that the Eleventh Amendment barred the Nursing Homes' constitutional and Medicaid Act claims for damages or other relief based on past actions; the Nursing Homes' claims for declaratory and injunctive relief were moot and required dismissal because the court lacked subject matter jurisdiction; and, because the Nursing Homes failed to state a viable Americans with Disabilities Act claim, they failed to state a cognizable Rehabilitation Act claim. View "Wicomico Nursing Home v. Padilla" on Justia Law

In 2004, after pleading guilty to selling crack cocaine to a government informant, Lester was sentenced to almost 22 years in prison because he was designated a career offender under the then-mandatory Sentencing Guidelines. This enhancement depended on a past conviction for a “crime of violence,” Lester’s 1990 Georgia conviction for walkaway escape. In 2005, the Supreme Court stripped the Sentencing Guidelines of legal force and made them purely advisory; in 2009, the Court ruled that the generic crime of failing to report to a prison was not a crime of violence. Lester’s sentence should have been up to 11 years shorter. Lester sought habeas corpus relief. The district court denied his petition. The Fourth Circuit vacated, noting that its 2018 decision in United States v. Wheeler permits Lester’s challenge although Lester had already filed a petition under 28 U.S.C. 2255. In limited circumstances, courts, including the Fourth Circuit, allow a prisoner otherwise unable to file a second or successive section 2255 petition to seek relief under 28 U.S.C. 2241. A sentencing error “need not result in a sentence that exceeds statutory limits in order to be a fundamental defect.” Lester’s case must be considered on the merits. View "Lester v. Flournoy" on Justia Law

MDENT, a Charleston drug task force, investigated Terry after an officer found remnants of drugs in trash outside of a residence associated with Terry. An MDENT agent acquired a search warrant for Terry’s residence. Agents followed Terry to a store. Once Terry had parked, Corporal Johnson approached the car and smelled marijuana. Terry turned over a small amount of marijuana. Johnson searched the car. Nothing more was found. Meanwhile, another MDENT agent surreptitiously placed a GPS tracker onto the car. No contraband or incriminating evidence was found in the residence. Afterwards, Johnson obtained a warrant to “ping” Terry’s cell phone and to place a GPS tracker on the car. Two days later, agents relied solely on the GPS data to track the car to Ohio, where they suspected Terry obtained drugs. After the car returned, the officers followed it and determined that it was speeding at five miles above the posted speed limit of 45 MPH. Officers pulled the car over. Tamara, the car’s owner, was driving. Terry was a passenger. Johnson wrote Tamara a warning citation while another officer spoke with Terry and informed Johnson that he smelled marijuana, Johnson ordered Terry out of the car and performed a pat-down. Officers discovered 195.5 grams of methamphetamine and 2.9 grams of marijuana. Although the district court found that MDENT’s conduct constituted a flagrant constitutional violation, it denied Terry’s motion to suppress on the basis of standing. The Fourth Circuit vacated. Terry had standing and the discovery of the evidence seized during the traffic stop was not sufficiently attenuated from the unlawful GPS search to purge the taint. View "United States v. Terry" on Justia Law