Katrina Reeves v. Howard Meddings

• Court: Court of Appeals for the Fourth Circuit
• Decided: May 14, 2025
• Docket: 23-1823
• Status: Unpublished

Opinion

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UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 23-1823

KATRINA REEVES,

Plaintiff – Appellee,

and

JAMES LEE REEVES,

Plaintiff,

v.

HOWARD MEDDINGS, Individually,

Defendant – Appellant,

DEPUTY HARRY SOWARDS, Individually,

Defendant.

Appeal from the United States District Court for the Southern District of West Virginia, at Huntington. Robert C. Chambers, District Judge. (3:20-cv-00423)

Submitted: February 24, 2025 Decided: May 14, 2025

Before KING, AGEE, and HARRIS, Circuit Judges. USCA4 Appeal: 23-1823 Doc: 111 Filed: 05/14/2025 Pg: 2 of 10

Dismissed in part and affirmed in part by unpublished per curiam opinion.

ON BRIEF: Perry W. Oxley, David E. Rich, Samantha J. Fields, OXLEY RICH SAMMONS, PLLC, Huntington, West Virginia, for Appellant. Hoyt Glazer, Abraham J. Saad, Eric B. Anderson, GLAZER SAAD ANDERSON L.C., Huntington, West Virginia, for Appellee.

Unpublished opinions are not binding precedent in this circuit.

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PER CURIAM:

Howard Meddings filed this interlocutory appeal to challenge the district court’s

denial of summary judgment based on its determination that he was not entitled to federal

qualified immunity. The fact-based arguments he raises on appeal fall outside our limited

jurisdiction at this state of the proceedings, and his remaining argument lacks merit.

Accordingly, we dismiss in part and affirm in part.

I.

Very little is undisputed about the underlying narrative leading up to this litigation.

Indeed, the district court observed that the parties disputed “the characterization of almost

all of the facts on the record.” Reeves v. Wayne Cnty. Bd. of Educ., No. 3:20-cv-0423, 2021

WL 5417396, at *3 (S.D.W. Va. Nov. 19, 2021) [Reeves I]; see also Reeves v. Meddings,

No. 3:20-cv-0423, 2023 WL 4378137, *7 (S.D.W. Va. July 6, 2023) [Reeves III]

(characterizing the “hotly contested disputes of fact”). Recounted at a broad level, however,

in the fall of 2019, after a reported theft of items from the Wayne County, West Virginia,

Board of Education’s bus garage, law enforcement investigated. Two employees at the

garage—Meddings and James Lee Reeves—had a contentious history, which had been

made more tense in the months before the theft after Mr. Reeves was promoted to a position

both men had sought. Meddings was friends with Deputy Harry Sowards, the lead

investigator into the theft, and they communicated throughout the investigation, though the

nature and extent of those interactions is contested. Regardless, Mr. Reeves was soon

implicated in the investigation, leading to a search of the property where he resided with

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his wife, Katrina Reeves. Meddings was present during that search, communicating with

law enforcement.

In February 2020, Mr. Reeves was charged in state court with embezzlement, and

both he and Mrs. Reeves were charged with conspiracy to embezzle. Their arrests and the

aftermath of the charges were the focus of news reports. They were both suspended from

their employment with the County. Mrs. Reeves was a bus driver, and declined the

County’s later offer to return to her position.

After the preliminary hearing several months later, the state magistrate dismissed

the conspiracy charges based on the determination that probable cause did not support

them. And although it did not happen until after this federal case was underway, the state

magistrate later dismissed the embezzlement charge against Mr. Reeves, writing that while

dismissal was required given his intervening death, it had been prepared to dismiss the

charges based on its finding that Deputy Sowards had made multiple misstatements that

had led to the charges in the first instance. The court deemed it unnecessary to determine

whether those misstatements had been made intentionally, noting instead that they were so

numerous as to be reckless at best, and that their number and nature had misled the grand

jury to indict Mr. Reeves.

Before all the state charges had been resolved and before Mr. Reeves’ death,

however, Mr. and Mrs. Reeves filed this federal complaint in the U.S. District Court for

the Southern District of West Virginia. It originally alleged multiple federal and state

claims against multiple defendants, all arising from the investigation, criminal charges, and

employment decisions surrounding the above-recounted events. The other claims have

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been resolved and all that matters for purposes of this appeal are the claims against

Meddings, which were: (1) civil conspiracy to violate civil rights, brought under 42 U.S.C.

§ 1983; (2) defamation; and (3) intentional infliction of emotional distress.

After discovery, both parties moved for summary judgment, and the district court

denied both motions after concluding genuine issue of material fact precluded it. Relatedly,

the district court denied Meddings’ assertion of federal qualified immunity and state

statutory immunity after (incorrectly) concluding that both could be overcome with

evidence of malicious conduct. See Reeves I, 2021 WL 5417396 at *2, *5.

Meddings sought interlocutory review of the denial of immunity. In the prior appeal,

we dismissed the part of his challenge that took issue with the district court’s finding that

a factual dispute precluded state statutory immunity. Reeves v. Meddings, No. 21-2391,

2022 WL 17091862, *1 (4th Cir. Nov. 21, 2022) [Reeves II]. “But we agree[d] with

Meddings that the district court did not consider his federal qualified immunity claim under

the proper legal standard,” and so vacated and remanded for the district court to undertake

that analysis. Id. We also took note that Mr. Reeves had died while the appeal was pending,

and left to the district court to determine what, if any, claims could survive so as to be

brought by his estate. Id. at *2 n.1.

On remand, the district court concluded that no claims brought by Mr. Reeves

survived his death, so the case was narrowed to Mrs. Reeves’ claim that Meddings

conspired to violate her civil rights under § 1983. Turning to the question of federal

immunity, the court left intact its prior determination of the existence of material fact

disputes, applied the proper federal qualified immunity analysis, and determined that

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Meddings was not entitled to that immunity at the summary judgment stage. Reeves III,

2023 WL 4378137 at *1–7.

Meddings noted another interlocutory appeal, and—as explored below—we have

limited jurisdiction under 28 U.S.C. § 1291 and the collateral order doctrine.

II.

Although couched in a variety of arguments, Meddings’s appeal rests almost

entirely on a version of events that ignores contradictory evidence and the district court’s

determination that genuine issues of material fact call his own version of events into sharp

dispute. And therein lies the rub, for we lack jurisdiction to consider such fact-based

underpinnings to arguments at this stage of proceedings.

As we have said many times before, in an interlocutory appeal from the denial of

qualified immunity, “we have jurisdiction to consider purely legal questions, but not over

the district court’s determination that the summary judgment record . . . raised a genuine

issue of material fact because that is not a final decision for purposes of 28 U.S.C. § 1291.”

Pegg v. Herrnberger, 845 F.3d 112, 117 (4th Cir. 2017) (internal quotation marks and

citation omitted). Relatedly, “[w]hether we agree or disagree with the district court’s

assessment of the record evidence on [an] issue is of no moment in the context of [an]

interlocutory appeal.” Culosi v. Bullock, 596 F.3d 195, 201 (4th Cir. 2010). “Instead, we

must take the facts as the district court ‘gives them to us,’ and determine whether, viewed

in the light most favorable to [Mrs. Reeves], they allow for a grant of immunity to

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[Meddings] as a matter of law.” Reeves II, 2022 WL 17091862, *4 (quoting Hicks v.

Ferreyra, 965 F.3d 302, 309 (4th Cir. 2020)).

Meddings’s brief almost exclusively argues matters outside our limited jurisdiction

on interlocutory appeal. For example, he claims a lack of evidence to support the district

court’s finding of a factual dispute over how involved he was in the investigation and

search of the Reeves property; he recounts at length deposition testimony supporting his

characterization of events; and he disputes the reasonableness of the inferences and

conclusions the district court determined a jury could make based on the record. These

challenges to the record cannot be considered at this juncture. Hensley ex rel N.C. v. Price,

876 F.3d 573, 579 (4th Cir. 2017) (“[On interlocutory appeal], we may not credit

defendant’s evidence, weigh the evidence, or resolve factual disputes in the defendant’s

favor.”). The rest of Meddings’ arguments flow from this initial reframing of his conduct

as purely innocuous good faith cooperation with a legitimate law enforcement

investigation. His resistance to “the facts as the district court ‘[gave] us’” permeates the

brief, precluding review of matters, such as the clearly established prong, that would

traditionally be viewed as raising pure questions of law. Reeves II, 2022 WL 17091862, *4

(quoting Hicks, 965 F.3d at 309); see also Thurston v. Frye, 99 F.4th 665, 672 (4th Cir.

2024) (“Whether particular conduct violates a constitutional right and whether that right is

clearly established are legal questions.”).

In particular, Meddings argues that the district court erred in concluding that his

conduct violated Mrs. Reeves’s clearly established rights. Although he purports to

challenge the district court’s articulation of what rights are clearly established and whether

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it viewed the question at the right level of generality, those arguments hinge on first

rejecting the district court’s assessment of the underlying factual record. As but one

example, he argues that no case law clearly establishes liability on the part of a

“government official cooperating with law enforcement” during a criminal investigation.

Opening Br. 40. Perhaps, but that argument necessarily contradicts the district court’s

factual assessment that the record could also allow a factfinder to conclude that Meddings

was not “cooperating with law enforcement,” but rather maliciously “directing the criminal

investigation, causing process to be issued against Ms. Reeves without probable cause,

searching the Reeves home and Mr. Reeves’s phone records, instructing coworkers not to

cooperate with the investigation to Ms. Reeves’s detriment, providing false or misleading

statements to Deputy Sowards, etc.” Reeves III, 2023 WL 4378137 at *7. A purely legal

challenge to this prong’s inquiry would consider whether Meddings’s conduct violated

Mrs. Reeves’s clearly established rights through the lens of the district court’s assessment

of what the record may allow a factfinder to determine. Cf., e.g., Willingham v. Crooke,

412 F.3d 553, 559 (4th Cir. 2005) (explaining that whether someone “was entitled to

qualified immunity under” settled facts is a legal question). It would not—as Meddings’s

brief does—first reframe what he did before engaging with whether that conduct violated

Mrs. Reeves’s clearly established rights. And, notably, Meddings does not challenge the

district court’s determination that, if a factfinder found against him in terms of what he did,

then his conduct could have violated Mrs. Reeves’ clearly established rights. So,

Meddings’ arguments on this prong of the inquiry are not properly before us.

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In sum, Meddings’ arguments predominantly conflict with the district court’s

assessment of the record evidence and its conclusion that a genuine issue of material fact

existed on core matters relating to Mrs. Reeves’s claim. So, as explained above, we lack

jurisdiction to consider that part of Meddings’s appeal and therefore dismiss it in part.

Having scoured Meddings’s brief for any purely legal issue over which we would

have jurisdiction, we located one such possible question, and so briefly address it. See

Winfield v. Bass, 106 F.3d 525, 528–29 (4th Cir. 1997). Meddings challenges the district

court’s sua sponte determination that a factfinder could find that he was not acting within

the scope of his authority during the events in question such that he may not be entitled to

assert qualified immunity on that basis. In his view, because that was not a ground that

Mrs. Reeves had pursued as a basis for denying immunity, the court erred by undertaking

that review. Although the district court’s ultimate determination that a question of fact

existed on this issue is not properly before us at this time, we can consider the legal question

of whether it erred in sua sponte considering it. We readily conclude that it did not so err.

As we observed in the first interlocutory appeal, when a “public official engages in

conduct ‘that is entirely beyond [his] discretionary authority,’ then he is not protected by

this immunity” even apart from considering the two-prong qualified immunity inquiry that

otherwise applies. Reeves II, 2022 WL 17091862, at *5 (quoting In re Allen, 106 F.3d 582,

594 (4th Cir. 1997)) (alteration in original). And we observed that, “[b]ecause of its

truncated analysis, the district court . . . failed to consider whether this might be the ‘rare[]’

case in which a defendant’s conduct is so ‘totally beyond the scope of his authority’ that

he is not protected by qualified immunity.” Id. at *6 (quoting In re Allen, 106 F.3d at 594)

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(alteration in original). We then remanded the case “to the district court to address in the

first instance whether, under the correct standard, Meddings is entitled to federal qualified

immunity as a matter of law.” Id.

Once Meddings invoked qualified immunity as a defense, the district court was free

to consider all aspects of that defense in deciding whether to grant or deny judgment. Cf.

Fed. R. Civ. P. 56(f) (permitting the court to grant summary judgment “on grounds not

raised by a party”). And, here, our prior decision teed up the issue of the scope of authority

as an issue the district court could consider as part of its determination of qualified

immunity. There’s no support for Meddings’ suggestion—and it would make little sense

to say—that the court then erred as a matter of law in doing something that it had authority

to do under the governing rules and that we had specifically suggested that it consider on

remand. Accordingly, we affirm that part of the district court’s decision.

III.

For the reasons set out above, the appeal is dismissed in part and the decision of the

district court to deny summary judgment on the basis of qualified immunity is affirmed in

part.

DISMISSED IN PART AND AFFIRMED IN PART