By Nick McCauslin and Tristan Meagher
Equal Employment Opportunity Commission v. McLeod Health, Inc.
In this civil case, the EEOC brought suit against McLeod Health, Inc. (“McLeod”) alleging that McLeod violated the Americans with Disabilities Act (“ADA”) by having an employee undergo a work-related medical exam and by discharging her on the basis of her disability. The district court granted summary judgment in favor of McLeod on both claims. The Fourth Circuit reversed finding that enough evidence existed suggesting that the employee’s disability did not prevent her from performing essential job functions, and, therefore, McLeod was not entitled to summary judgment.
In this civil case, David McClure brought suit against Maryland Department of Transportation officials for violating the First and Fourteenth Amendment rights of the union McClure represented by denying him, and the union, access to restricted Maryland Transportation Authority (“MTA”) property in response to McClure’s criticism of the MTA. The district court granted summary judgment in favor of the transportation officials. The Fourth Circuit affirmed, finding that the retaliation against McClure and the union was justified because the legitimate countervailing government interest in regulating its restricted property was sufficiently strong and outweighed McClure’s interest in accessing the property to interact and support union members.
United States v. Azua-Rinconada
In this criminal case, Ismael Azua-Rinconada was convicted for illegally entering the United States in violation of 8 U.S.C. § 1326(a). Azua-Riconada appealed claiming the district court erroneously denied his motion to suppress statements and evidence obtained prior to his arrest. The basis of the motion was that officers gained access to his residence through coercion in violation of the Fourth Amendment and subjected him to custodial interrogation without providing his Miranda rights in violation of the Fifth Amendment. The Fourth Circuit affirmed, finding that the police obtained consent before entering the defendant’s home and that Azua-Rinconada was not in custody when he made statements to the police.
This civil case considered 8 U.S.C. § 1101(a)(27)(J), a statute that allows for citizenship for immigrant children if they meet the special immigrant juvenile requirements. Specifically, the court considered whether an ex parte emergency order, presented on behalf of Felipe Perez, qualified as a predicate state court custody order necessary for the citizenship application. The district court concluded it did not. The Fourth Circuit affirmed. The district court found, and the Fourth Circuit agreed, there was a requirement of deference to the administrative agency, and without the evidence the decision was arbitrary and capricious, that the agency acted appropriately.
In this criminal case, South Carolina appealed the district court’s ruling. After having been found guilty and sentenced to death for killing his ex-girlfriend, Charles Williams petitioned the district court for a writ of habeas corpus. The district court found, and the Fourth Circuit affirmed, that defense counsel’s failure to investigate Fetal Alcohol Syndrome, potentially mitigating evidence, was unacceptable. The Fourth Circuit concluded that had there been evidence presented on Fetal Alcohol Syndrome it would have probably resulted in a different sentence; thus, the district court’s finding was affirmed.
