Reeves v. Meddings
| Decision Date | 21 November 2022 |
| Docket Number | 21-2391 |
| Parties | KATRINA REEVES, individually and as Executrix of the Estate of James Lee Reeves, Plaintiff-Appellee, v. HOWARD MEDDINGS, individually, Defendant-Appellant, and WAYNE COUNTY BOARD OF EDUCATION; WAYNE COUNTY; WAYNE COUNTY COMMISSION; WAYNE COUNTY SHERRIF RICHARD THOMPSON, individually; TODD ALEXANDER, individually; DEPUTY HARRY SOWARDS, individually, Defendants. |
| Court | U.S. Court of Appeals — Fourth Circuit |
Perry W. Oxley, OXLEY RICH SAMMONS, PLLC, Huntington, West Virginia, for Appellant.
Hoyt Eric Glazer, GLAZER SAAD ANDERSON L.C., Huntington, West Virginia, for Appellees.
ON BRIEF:
David E. Rich, Samantha J. Fields, OXLEY RICH SAMMONS, PLLC Huntington, West Virginia, for Appellant.
Abraham J. Saad, Eric B. Anderson, GLAZER SAAD ANDERSON L.C., Huntington, West Virginia, for Appellees.
Before AGEE and HARRIS, Circuit Judges, and MOTZ, Senior Circuit Judge
Dismissed in part, vacated in part, and remanded by unpublished opinion. Judge Harris wrote the opinion, in which Judge Agee and Senior Judge Motz joined.
Unpublished opinions are not binding precedent in this circuit.
The plaintiffs in this action, James and Katrina Reeves, allege that a supervisor at a school bus facility in Wayne County West Virginia, falsely accused them of stealing from the facility, and then conspired with other Wayne County officials to falsify evidence against them and cause their arrests. The defendant supervisor, Howard Meddings, moved for summary judgment, asserting federal qualified immunity and statutory immunity under West Virginia law. The district court denied summary judgment and Meddings filed an appeal.
Because Meddings's fact-based challenge to the denial of state statutory immunity falls outside our jurisdiction in this interlocutory posture, we must dismiss that part of his appeal. But we agree with Meddings that the district court did not consider his federal qualified immunity claim under the proper legal standard. Accordingly, we vacate the district court's judgment in part and remand so that the district court may undertake the correct qualified immunity analysis in the first instance.
In this interlocutory appeal of a denial of immunity, and except as otherwise noted, we recount the facts as the district court viewed them - that is, in the light most favorable to the plaintiffs, James and Katrina Reeves, drawing all justifiable inferences in their favor. See Hicks v. Ferreyra, 965 F.3d 302, 305 (4th Cir. 2020).
This case arises from an alleged break-in at the Wayne County Board of Education bus garage and the investigation that followed. Howard Meddings, a defendant in this action, is a Board of Education employee and a parts supervisor at the garage. He was involved in the investigation of the break-in, which centered around two of his Board of Education co-employees: plaintiff James Reeves, who worked alongside Meddings in the bus parts "barn," and his wife and co-plaintiff Katrina Reeves, who worked as a bus driver. The investigation was led by Wayne County Deputy Sherriff Harry Sowards - a longtime friend of Meddings's.
The gist of the plaintiffs' claim, as relevant here, is that Meddings and Sowards worked together, along with other WCBOE employees, to frame James and Katrina for theft and to effectuate their false arrests and other violations of their Fourth and First Amendment rights. According to the plaintiffs, Meddings had a long history of animus towards them and an especially fraught relationship with James Reeves: James and Meddings had once applied for the same job, with the position going to James, and Meddings had filed multiple grievances against James. But despite this history, the plaintiffs assert, Meddings was permitted to play a key role in the investigation of the break-in.
Throughout the investigation, Meddings allegedly spread information he knew to be false to implicate the plaintiffs. He also inserted himself centrally into the criminal inquiry led by his friend Sowards, texting and meeting with Sowards privately about the case. Meddings was on the scene with law enforcement during the search of the Reeveses' home, identifying items purportedly stolen from the garage. Through Deputy Sowards, the plaintiffs allege, he obtained pictures and texts gathered from a search of James Reeves's cell phone, which he planned to use against the Reeveses. And he further tainted the investigation by contacting other bus garage employees and discouraging them from cooperating in the Reeveses' private investigation to prepare for filing of this § 1983 action.
As a result of the investigation, the plaintiffs were arrested. James Reeves was charged with three counts of felony embezzlement, and both Reeveses were charged with conspiracy to embezzle. The conspiracy charges were soon dropped, but James Reeves was indicted for embezzlement by a grand jury after Deputy Sowards presented the case against him.
James Reeves moved to dismiss the indictment, arguing that Sowards had testified falsely before the grand jury. The state court agreed and issued an order explaining that it was prepared to dismiss the case on that ground. Sowards, the court found, had indeed presented false and material evidence to the grand jury, and his confessed "mistakes" were so frequent that they were "reckless at best" and warranted dismissal of the indictment "as misleading to the jury." J.A. 663. But because James Reeves passed away before the court could issue its decision, the court dismissed the charges against Reeves on that basis, instead, and dismissed his motion as moot.[1] Because of the criminal charges brought against them, the Reeveses were terminated from their jobs. Their arrests and termination were covered by local news publications and media, humiliating the Reeveses and allegedly damaging their reputations.
B.
In August 2020, the Reeveses filed an eleven-count complaint against Meddings, Sowards, and several other county entities and officials. Relevant to this appeal are the three counts against Meddings: one for conspiracy to violate the plaintiffs' civil rights under 42 U.S.C. § 1983; and two alleging state-law claims, for defamation and intentional infliction of emotional distress.[2] After discovery, both parties moved for summary judgment. The plaintiffs sought summary judgment on their defamation claim alone, while Meddings sought summary judgment on the merits of all three claims against him. Meddings also argued that he was entitled to federal qualified immunity and to statutory immunity under § 29-12A-5(b) of the West Virginia Code, which protects employees of the state's political subdivisions. See W.Va. Code § 29-12A-5(b) (2022).
The district court denied summary judgment to both parties on the merits, finding that genuine disputes of material fact precluded an award of judgment as a matter of law. Reeves v. Wayne Cnty. Bd. of Educ., No. 3:20-0423, 2021 WL 5417396, at *3-5 (S.D. W.Va. Nov. 19, 2021). Although that part of the court's ruling is not directly before us now, we describe it briefly here because it bears on the immunity issues in the case.
The court began with the § 1983 conspiracy claim, which, as the court recognized, would require the plaintiffs to establish that Meddings acted in concert with Deputy Sowards, and that some overt action was taken which led to a deprivation of the Reeveses' constitutional rights. Id. at *3 (quoting Penly v. McDowell Cnty. Bd. of Educ., 876 F.3d 646, 658 (4th Cir. 2017)). The court acknowledged Meddings's deposition testimony -corroborated by Sowards - purporting to establish that his actions in assisting Sowards had been well within the scope of his employment at the bus garage, and that he had been only "tangentially" involved in the criminal investigation. Id. But the deposition testimony offered by the plaintiffs, the court explained, "establishe[d] the exact opposite." Id. A reasonable jury, the court concluded, could credit that evidence and find that Meddings in fact was "personally very involved in the [] police investigation" and had conspired with Sowards to "falsely accuse the Reeves[es] and subject them to arrest." Id.
In particular, the court determined, the record evidence would support a finding that Meddings engaged in private communications with Deputy Sowards about the investigation; that Sowards forwarded him records recovered from a search of Mr. Reeves's cell phone; and that Meddings had contacted multiple other garage employees about the Reeveses' private investigation preparing for this lawsuit, instructing them not to cooperate with the private investigator. Id. And it was undisputed that Meddings was on the scene when the Reeveses' home was searched, with his level of involvement in the search subject to dispute. Id. In sum, the court concluded, the record evidence regarding Meddings's role in the investigation "conflicts greatly and could lead to a reasonable inference in favor of either party's version of events," making summary judgment inappropriate. Id.
The court reached a similar determination with respect to the record evidence on the defamation and intentional infliction of emotional distress ("IIED") claims. As to both Meddings's principal defense was that he had acted not from any animus against the Reeveses but only in good faith, believing his accusations to be true - which would entitle him to a qualified privilege as to the plaintiffs' defamation claim, id. at *4, and preclude a finding that he acted intentionally...
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