Martin v. Duffy, No. 18-7122 (4th Cir. 2020)Annotate this Case
The Fourth Circuit held that Mt. Healthy City School District Board of Education v. Doyle, 429 U.S. 274 (1977), which applies a burden-shifting framework, provides the appropriate framework for reviewing inmates' First Amendment retaliation claims. However, the court held that the district court improperly resolved genuine disputes of material fact in defendant's favor. In this case, the district court erred in crediting defendant's reasons for segregating plaintiff because, at the summary judgment stage, a court must view all facts in the light most favorable to the non-moving party. Doing so here, a reasonable juror could find that defendant placed plaintiff in segregation and kept him segregated for impermissible reasons. The court took the opportunity to reemphasize the well-settled principle that an action motivated by retaliation for the exercise of a constitutionally protected right is actionable, even if the act, when taken for a different reason, might have been legitimate. The court reversed the district court's grant of summary judgment and remanded for further proceedings.