2021 Case Summaries

Select Week:

Week of January 4, 2021 through January 11, 2021

Dean v. Jones (Harris 1/4/2021): The Fourth Circuit held that the district court misapplied the summary judgment standard and agreed with the appellant that the record would support a jury finding that correctional officers, of Central Prison in Raleigh, violated the Eighth Amendment by using force in retaliation for the appellant’s instigations. The court rejected the correctional officers’ claim that use of force was necessary to ensure officer safety. The court reversed the district court’s grant of summary judgment in favor of the correctional officers. Full Opinion.

JTH Tax, Inc. v. Aime (Gregory 1/4/2021): The Fourth Circuit held that disgorgement damages were unavailable because Aime failed to raise the theory during litigation and because the mandate rule precluded the disgorgement theory. The court further held that the district court erred by concluding that Aime met its burden to show that evidence qualified as newly discovered under Rule 59(e). Finally, the Fourth Circuit held that the district court erred by awarding additional nominal damages because Aime was previously awarded compensatory damages. Therefore, the court affirmed the district court’s order denying litigant’s motion for reconsideration, reversed the district court’s order granting litigant’s motion to amend the judgment based on newly discovered evidence and its award of nominal damages. Accordingly, the Fourth Circuit vacated the district court’s post-judgment increase of damages and remanded for recalculation. Full Opinion.

Sesay v. United States (Wilkinson 1/5/2021): The Fourth Circuit held that the doctrine of consular nonreviewability was properly applied to dismiss the plaintiff’s complaint challenging the denial of a visa. The court affirmed the district court’s order dismissing the plaintiff’s complaint. Full Opinion.

Knight v. Boehringer Ingelheim Pharm., Inc. (Quattlebaum 1/6/2021): The Fourth Circuit held that the plaintiff’s state law fraud claim was preempted because the defendant’s post FDA approval analysis on its drug did not offer “newly acquired information.” The court reversed the district court’s order denying the defendant’s post-trial motion for judgment as a matter of law. Full Opinion.

Mann v. United States (Niemeyer 1/6/2021): The Fourth Circuit held that the plaintiffs were not entitled to a charitable deduction for the value of a house because the plaintiffs failed to donate their entire interest in the house and the plaintiff’s appraisal used to claim the charitable deduction was not a qualified appraisal. The court affirmed the district court’s judgment, which affirmed the IRS’s disallowance of the charitable deduction. Full Opinion.

Zachary Randolph