The U.S. Court of Appeals for the Fourth Circuit issued a split decision Monday in *Wanda Johnson v. Baltimore City, Maryland*, partially reversing a district court ruling that had dismissed civil rights claims against the Baltimore Police Department. The January 6, 2026 ruling marks a partial victory for the plaintiff in her employment discrimination case.
Judge Amul Thacker wrote the majority opinion, joined by Judge Robert King, while Judge J. Harvie Wilkinson III dissented from portions of the decision. The three-judge panel affirmed some aspects of the lower court's ruling while reversing others, remanding the case for further proceedings in the U.S. District Court for the District of Maryland.
Wanda Johnson, a former Baltimore Police Department employee, brought claims under Title VII of the Civil Rights Act of 1964, alleging racial discrimination and retaliation by her former employer. Johnson also raised a civil rights claim under *Monell v. Department of Social Services*, which allows individuals to sue municipalities for constitutional violations when those violations result from official policy or custom.
The case originated in the U.S. District Court for the District of Maryland, where Senior District Judge Richard D. Bennett had granted the Baltimore Police Department's motion to dismiss. The district court concluded that Johnson failed to state plausible claims for which relief could be granted under federal civil rights law.
According to the Fourth Circuit opinion, Johnson alleged that multiple white or non-black comparators engaged in similar conduct to her own but received more favorable treatment from the department. This type of comparative evidence is central to establishing discrimination claims under Title VII, which prohibits employment discrimination based on race, color, religion, sex, or national origin.
The procedural history shows the case was argued before the Fourth Circuit on October 23, 2025, with oral arguments taking place nearly three months before the court issued its written decision. Johnson was represented by Dionna Maria Lewis and Stephen L. Fowler of District Legal Group, PLLC, based in Washington, D.C.
The City of Baltimore and its police department were represented by a team from the Baltimore City Law Department, including Christine Ellen White, who argued the case, along with Baltimore City Solicitor Ebony M. Thompson and several other attorneys specializing in appellate practice and consent decree matters.
The Fourth Circuit's decision to affirm in part and reverse in part suggests the court found merit in some but not all of Johnson's claims. While the specific details of which claims were affirmed or reversed are not fully detailed in the available portion of the opinion, the split decision indicates a nuanced legal analysis of the various civil rights theories presented.
Judge Wilkinson's dissenting opinion highlights disagreement within the panel about the proper application of civil rights law to Johnson's claims. Dissenting opinions in civil rights cases often focus on different interpretations of the evidence needed to establish discrimination or the appropriate legal standards for evaluating such claims.
The case returns to the district court for further proceedings on the claims that survived the Fourth Circuit's review. This remand allows Johnson to continue pursuing her discrimination and retaliation allegations against the Baltimore Police Department, potentially leading to discovery and trial on the surviving claims.
The ruling comes at a time when the Baltimore Police Department operates under a federal consent decree following a Department of Justice investigation into unconstitutional policing practices. The presence of attorneys specializing in consent decree matters on the city's legal team reflects the ongoing federal oversight of the department.
Title VII claims against municipal police departments have become increasingly common as employees and former employees seek redress for alleged discrimination in law enforcement workplaces. These cases often involve complex questions about municipal liability and the extent to which individual acts of discrimination reflect broader institutional policies or customs.
The Fourth Circuit's jurisdiction covers Maryland, Virginia, West Virginia, North Carolina, and South Carolina. The court's civil rights jurisprudence significantly impacts employment law throughout the region, making this decision potentially influential for similar cases involving municipal employers and police departments.
The partial reversal suggests that Johnson presented sufficient factual allegations to survive the initial motion to dismiss stage for at least some of her claims. Under federal civil procedure, courts must accept all factual allegations as true when evaluating motions to dismiss and determine whether those allegations state plausible claims for relief.
The case will now proceed in district court, where Johnson will have the opportunity to conduct discovery and develop her remaining claims. The defendants will continue to have opportunities to challenge the claims through subsequent motions and ultimately at trial if the case proceeds that far.
This decision adds to the Fourth Circuit's body of civil rights law and provides guidance for future employment discrimination cases involving municipal defendants in the region. The split nature of the decision and Judge Wilkinson's dissent may influence how lower courts interpret similar claims going forward.