Scope of Discretionary Authority and Jurisdictional Limits in Qualified Immunity Interlocutory Appeals

Introduction

The Fourth Circuit’s unpublished per curiam decision in Katrina Reeves v. Howard Meddings (No. 23-1823, decided May 14, 2025) clarifies two critical points in the law of § 1983 qualified immunity: (1) the limits of this Court’s jurisdiction over interlocutory appeals from denials of summary judgment grounded in qualified immunity, and (2) the recognized exception to qualified immunity when a public official acts completely “beyond the scope of his authority.” The appeal arose from a factual dispute over the involvement of a school‐garage employee, Howard Meddings, in a criminal investigation that led to defamation and civil‐rights claims by Katrina and the late James Reeves. Meddings challenged the district court’s refusal to grant summary judgment on the basis of federal qualified immunity and state statutory immunity.

Background and Key Parties

Plaintiffs: Katrina Reeves (bus driver) and James Lee Reeves (deceased), former employees of the Wayne County Board of Education.
Defendant‐Appellant: Howard Meddings, a coworker at the Board of Education bus garage who allegedly conspired with law enforcement to wrongfully investigate and accuse the Reeveses of embezzlement.
Other Key Figure: Deputy Harry Sowards, the lead criminal investigator and friend of Meddings.
Procedural Posture: After the state magistrate dismissed the charges (including findings of numerous reckless or misleading statements by Sowards), the Reeveses brought federal § 1983, defamation, and intentional‐infliction‐of‐emotional‐distress claims. Meddings moved for summary judgment on immunity grounds, was denied, and filed this interlocutory appeal.

Summary of the Judgment

The Fourth Circuit dismissed in part and affirmed in part. It held:

It lacked jurisdiction under 28 U.S.C. § 1291 and the collateral‐order doctrine to review fact‐based challenges to the district court’s denial of qualified immunity. On interlocutory appeal, the Court must accept the district court’s view of the facts, taking them in the light most favorable to the non‐movant.
The only purely legal issue properly before the Court was whether the district court erred in sua sponte considering whether Meddings had acted “beyond the scope of his authority”—an exception that denies qualified immunity when an official’s conduct is entirely outside his discretionary authority. The Court held the district court acted within its discretion and did not err as a matter of law in raising and analyzing that exception.
Accordingly, all other challenges were dismissed for lack of jurisdiction and the ruling on scope‐of‐authority was affirmed.

Analysis

1. Precedents Cited

Pegg v. Herrnberger, 845 F.3d 112 (4th Cir. 2017): Jurisdictional limits of interlocutory appeals—only legal questions may be reviewed; fact disputes are off‐limits.
Hensley ex rel. N.C. v. Price, 876 F.3d 573 (4th Cir. 2017): On interlocutory appeal, courts may not weigh evidence or resolve factual disputes in the defendant’s favor.
Culosi v. Bullock, 596 F.3d 195 (4th Cir. 2010): Reinforces that appellate courts “take the facts as the district court gives them us” in immunity appeals.
Willingham v. Crooke, 412 F.3d 553 (4th Cir. 2005): Distinguishes pure legal questions (“entitled to qualified immunity under settled facts”) from fact‐intensive disputes.
In re Allen, 106 F.3d 582 (4th Cir. 1997): Establishes the “scope of authority” exception—an official is not entitled to qualified immunity if acting “entirely beyond [his] discretionary authority.”
Winfield v. Bass, 106 F.3d 525 (4th Cir. 1997): Illustrates that courts may address purely legal questions sua sponte when reviewing qualified‐immunity defenses.

2. Legal Reasoning

The Court’s reasoning unfolds in two major strands:

Jurisdictional Restraint: Because an interlocutory appeal of a denial of qualified immunity is authorized only to resolve pure questions of law, the Court must “take the facts as the district court gives them to us,” and cannot reassess or reinterpret evidence to resolve factual disputes (Pegg; Hensley; Culosi). Meddings’s extensive factual narrative—arguing that his interactions with law enforcement were wholly innocuous—clashed with the district court’s finding of genuine disputes. That framing is impermissible on interlocutory review and hence dismissed.
Scope‐of‐Authority Exception: Qualified immunity protects “all but the plainly incompetent or those who knowingly violate the law.” But when an official’s acts are “entirely beyond [his] discretionary authority,” immunity is unavailable. The Fourth Circuit had already instructed the district court to consider this possibility on remand. The district court did so, determining that a jury could find Meddings’s conduct to have exceeded any lawful authority he possessed, and thus the exception might apply. Since the district court had authority under Federal Rule 56 and prior Fourth Circuit guidance, its sua sponte consideration was proper, and the Court affirmed that legal determination.

3. Impact

This decision will influence future litigation in at least three ways:

It reinforces the sharp division between legal and factual issues in interlocutory appeals of immunity denials, curbing attempts by defendants to relitigate fact disputes before trial.
It highlights that district courts may—and in some circumstances must—examine whether a public official’s challenged actions fall outside the scope of job‐related discretion, even if that argument was not pressed by the plaintiff.
It clarifies that the “scope of authority” exception is a standalone bar to qualified immunity, ensuring truly ultra vires conduct does not escape judicial scrutiny under the guise of immunity.

Complex Concepts Simplified

Interlocutory Appeal: An appeal taken before the trial court enters a final judgment. Under 28 U.S.C. § 1291 and the “collateral‐order” doctrine, only certain non‐final orders—such as denials of qualified immunity—may be appealed, but only to resolve pure legal questions.
Qualified Immunity: A doctrine shielding government officials from liability for constitutional violations unless (a) the right was clearly established at the time, and (b) a reasonable official would have known his conduct was unlawful. Traditionally, this involves a two‐part inquiry (violation + clear establishment).
Scope‐of‐Authority Exception: When an official’s challenged conduct is “entirely beyond [his] discretionary authority” (i.e., ultra vires acts unrelated to any lawful duties), qualified immunity does not apply, irrespective of the two-part test.

Conclusion

The Fourth Circuit’s ruling in Reeves v. Meddings provides a clarified roadmap for both district and appellate courts: interlocutory immunity appeals must be confined to legal questions, accepting factual findings below; and district courts have the authority to scrutinize, sua sponte if necessary, whether a public official’s conduct falls completely outside his discretionary authority, thus negating any entitlement to qualified immunity. This decision strengthens the balance between protecting officials acting in good faith and holding those who act ultra vires accountable under § 1983.