Karen J. Williams

This case involves an EEOC lawsuit on behalf of an African-American female employee alleging that her employer, Central Wholesalers, created a hostile work environment through repeated racial and gender-based epithets and conduct by co-workers, and that she was constructively discharged. The district court granted summary judgment to the employer on the hostile environment and constructive discharge claims and denied its request for attorneys' fees. On appeal, the Fourth Circuit reversed the summary judgment, holding that a reasonable jury could find the employer's responses to the reported harassment insufficient to end it, and affirmed the denial of fees because the employer was no longer the prevailing party after reversal. The court remanded for further proceedings.

labor & employmentcivil rights

The case concerned Charles Kingrea's involvement in selling cockfighting supplies at an illegal cockfighting venue in Virginia, leading to federal charges including conspiracy to sponsor an animal fighting venture under 7 U.S.C. § 2156(a)(1), conspiracy to transport gaffs and similar instruments in interstate commerce under 7 U.S.C. § 2156(e), aiding and abetting the animal fighting venture, and aiding and abetting an illegal gambling business under 18 U.S.C. § 1955. After the district court dismissed one count and a jury convicted Kingrea on the remaining three, he was sentenced to six months' incarceration plus home confinement and supervised release; the court denied a sentencing reduction for acceptance of responsibility. On appeal, the Fourth Circuit vacated the conviction on the first conspiracy count because the indictment failed to allege that the animal fighting venture affected interstate commerce, remanded for resentencing on the remaining counts, and affirmed the convictions on the gaffs conspiracy and gambling counts, holding that the evidence showed Kingrea knowingly aided the illegal activities and that Virginia gambling statutes did not exempt the conduct. The court found sufficient proof that spectators' betting made the operation an illegal gambling business under federal law.

criminal law

Dr. Sherif Philips filed two lawsuits against Pitt County Memorial Hospital and several physicians after his hospital privileges were suspended, alleging violations of his Fourteenth Amendment due process rights under 42 U.S.C. § 1983 along with supplemental state claims. He argued that the hospital, though a nonprofit corporation, qualified as a state actor due to its prior public status and ongoing ties to Pitt County. The district court dismissed the actions, finding no state action, and the Fourth Circuit affirmed. The court reasoned that the 1998 conversion to a private nonprofit under the Municipal Hospital Act, the absence of eminent domain powers or other sovereign attributes, and the lack of creation by special law meant the hospital did not meet the tests for state action established in cases like Eaton or Lebron, despite some retained county oversight.

civil rightshealthcare