Justia U.S. 11th Circuit Court of Appeals Opinion Summaries

In this case, Amber Jackson filed a lawsuit against Atlanta police officers Cody Swanger and Jeremiah Brandt, alleging that they violated her constitutional rights by unlawfully seizing her without reasonable suspicion or probable cause and using excessive force. She also claimed that Brandt failed to intervene in Swanger's use of excessive force. The officers moved to dismiss the case, arguing that they were entitled to qualified immunity, but the district court denied their motion. The officers then appealed the decision.The United States Court of Appeals for the Eleventh Circuit found that it had jurisdiction to review the district court's denial of the officers' motion to dismiss Jackson's unlawful seizure claim. The court affirmed the district court's decision, agreeing that Jackson had plausibly alleged that the officers violated her clearly established right to be free from an unreasonable seizure.However, the court found that it did not have jurisdiction to review the district court's decision not to incorporate certain video footage into the pleadings. The court also declined to assert pendant appellate jurisdiction over that issue.As for Jackson's claim that Brandt failed to intervene in Swanger's use of excessive force, the court found that it had jurisdiction to review the district court's denial of Brandt's motion to dismiss this claim. However, the court vacated and remanded this part of the case, instructing the district court to dismiss the claim. The court reasoned that Brandt did not have a reasonable opportunity to intervene physically or verbally and stop Swanger's use of alleged excessive force against Jackson. Therefore, Brandt did not violate Jackson's Fourth Amendment rights. View "Jackson v. Swanger" on Justia Law

A Black woman, Erika Buckley, filed a lawsuit against the Secretary of the Army, alleging that her former colleagues at Martin Army Hospital engaged in conduct that was racially discriminatory. Buckley, a speech pathologist, claimed her colleagues diverted white patients from her care, encouraged white male patients to complain about her, and engaged in other race-based harassing conduct. The Secretary moved for summary judgment, which the district court granted on all counts. Buckley appealed this decision.The United States Court of Appeals for the Eleventh Circuit upheld the lower court's decision regarding Buckley's retaliation claims, but vacated the lower court's decision on her race-based disparate treatment claim and her race-based hostile work environment claim. The court found that Buckley had provided enough evidence to suggest that her race played a role in the decision-making process leading to her dismissal, even if her race was not the but-for cause of the dismissal. The court also concluded that Buckley had provided sufficient evidence to establish a hostile work environment claim. The case was sent back to the district court for further proceedings consistent with the appeals court's opinion. View "Buckley v. Secretary of the Army" on Justia Law

The case involves Maria Acosta, who sued six Miami-Dade officers involved in the arrest of her son, Maykel Barrera, who died after the encounter. Acosta alleged federal excessive-force claims and state wrongful-death claims. The district court granted summary judgment to the officers, and Acosta appealed. The United States Court of Appeals for the Eleventh Circuit held that the district court erred in granting summary judgment to five of the six officers on Acosta’s excessive-force claims and to all of the officers on Acosta’s wrongful-death claims.The Court of Appeals found that, viewing the facts in the light most favorable to Acosta, the officers used excessive force when they tased and kicked Barrera while he was subdued, on the ground, and no longer resisting arrest, violating clearly established Fourth Amendment rights.Furthermore, the court vacated the summary judgment on Acosta’s wrongful-death claim, concluding that there was enough evidence for the case to go to trial. The court ruled that the district court erred in emphasizing Acosta’s lack of expert evidence directed to the cause of Barrera’s death since she did not have to present expert testimony to show causation. View "Acosta v. Miami-Dade County" on Justia Law

In a case before the United States Court of Appeals for the Eleventh Circuit, Tyler Copeland, a transgender male, sued his employer, the Georgia Department of Corrections (GDOC), for workplace harassment. Copeland was a sergeant at a prison in Georgia and alleged that, after coming out as transgender at work, he endured constant and demeaning harassment from colleagues at various levels, despite repeated complaints to supervisors and HR personnel.He brought three claims under Title VII of the Civil Rights Act of 1964. The first was that his employer had created a hostile work environment. The district court granted summary judgment in favor of GDOC, concluding that the harassment Copeland experienced was not sufficiently severe or pervasive. However, the appellate court disagreed and vacated the summary judgment on this claim.The second claim was that Copeland had been denied promotion due to his transgender status. The district court also granted summary judgment on this count, as Copeland failed to provide evidence that those who decided not to promote him were aware of his protected conduct. The appellate court affirmed this decision.The third claim was that GDOC had retaliated against Copeland for engaging in a protected practice, namely opposing sex discrimination. The district court granted summary judgment on this count as well, and the appellate court affirmed the decision, citing lack of evidence of causation.In summary, the appellate court vacated the district court's grant of summary judgment on the hostile work environment claim but affirmed the summary judgments on the failure to promote and retaliation claims. The case was remanded for the district court to consider the fifth element of Copeland’s hostile work environment claim. View "Copeland v. Georgia Department of Corrections" on Justia Law

In this lawsuit, Keith Sylvester alleged that Detective James Barnett violated his Fourth Amendment rights by causing his arrest and detention without probable cause. Sylvester's parents were murdered and their house set on fire. Detective Barnett led the investigation and suspected Sylvester was the culprit, ultimately obtaining an arrest warrant for him. Sylvester spent over a year in jail until the charges were dropped. Sylvester claimed that Barnett lacked probable cause when he applied for the arrest warrant, arguing that key exonerating evidence was omitted from the affidavit.The district court granted Detective Barnett summary judgment, stating that the record did not establish that Barnett knew about the exonerating information when he wrote the warrant affidavit. The court concluded that, based on the totality of circumstances known to Barnett at the time of the arrest, his suspicion of Sylvester was reasonable.On appeal, the United States Court of Appeals for the Eleventh Circuit reversed the lower court's decision. The appellate court found that there were material facts omitted from the warrant affidavit. When those omissions were corrected, the affidavit failed to establish even arguable probable cause for Sylvester's arrest. The court further held that a reasonable jury could find that Barnett intentionally or recklessly left out information that exonerated Sylvester. If a jury finds such misconduct, qualified immunity would not shield Barnett from liability. Therefore, the case was remanded for further proceedings. View "Sylvester v. Barnett" on Justia Law

The United States Court of Appeals for the Eleventh Circuit reviewed an appeal by Dr. LeThenia Joy Baker against her former employer, Upson Regional Medical Center. Dr. Baker alleged that Upson violated the Equal Pay Act (“EPA”) and Title VII of the Civil Rights Act of 1964 by providing her a less favorable bonus compensation structure than that of her male colleague. Though Upson admitted that Dr. Baker was paid less than her male colleague, they argued that the pay disparity was due to the male doctor's greater experience, not his gender. The district court ruled in favor of Upson, stating that the EPA claim failed as Upson established a defense that the bonus structure, which paid Dr. Baker less than her comparator, was based on factors other than sex.The Eleventh Circuit upheld the district court's decision, stating that Upson had met its burden of proving that the difference in bonus compensation was based on factors other than sex. The court clarified that under the EPA, it only consists of a two-step analysis. First, the plaintiff must establish a prima facie case showing that she performed substantially similar work for less pay. Second, if the plaintiff establishes a prima facie case, the burden shifts to the employer to prove that the pay differential was justified under one of the Equal Pay Act’s statutory exceptions. If the employer fails, the plaintiff wins. The plaintiff is not required to prove discriminatory intent on the part of the defendant. The court concluded that no reasonable jury could find in favor of Dr. Baker on the question of whether her sex was considered in the different bonus structure she agreed to. View "Baker v. Upson Regional Medical Center" on Justia Law

In 2002, Michael David Carruth was convicted and sentenced to death for four counts of first-degree murder, one count of attempted murder, first-degree burglary, and first-degree robbery in Alabama. Carruth appealed the denial of his habeas corpus petition, which raised six main issues. These included allegations of ineffective trial counsel for failing to investigate and present mitigating evidence during the penalty phase of his trial, and ineffective appellate counsel for failing to notify him of further available appellate proceedings and to argue that the prosecution engaged in prosecutorial misconduct. Carruth also argued that he was deprived of his right to an impartial jury and due process of law due to premature jury deliberations.The United States Court of Appeals for the Eleventh Circuit examined all the issues and affirmed the district court's denial of Carruth's habeas corpus petition. The circuit court determined that Carruth's claims did not survive deference under the Antiterrorism and Effective Death Penalty Act, as the state court's adjudications were not contrary to federal law, nor did they involve an unreasonable determination of the facts. The court also held that Carruth's claim of ineffective assistance of counsel was procedurally barred because it was not properly raised and preserved at the state level. The circuit court concluded that the nature of the crimes and the strength of the evidence against Carruth outweighed any potential mitigating evidence that may have been presented. View "Michael David Carruth v. Commissioner, Alabama Department of Corrections" on Justia Law

Inmate Germaine Smart alleged that prison officials Ronald England, Gary Malone, and Larry Baker violated his First Amendment rights by retaliating against him for reporting an alleged sexual assault by England. Smart claimed that England sexually assaulted him during a pat-down search, but after an internal investigation, Smart's allegations were found to be unfounded and England charged Smart with lying. The United States Court of Appeals for the Eleventh Circuit ruled that the officials did not violate Smart's First Amendment rights. The court stated that a prisoner's violation of a prison regulation is not protected by the First Amendment, and in this case, the prison tribunal's finding that Smart lied, which was based on due process and some evidence, was conclusive. Therefore, the officials were entitled to qualified immunity. View "Smart v. England" on Justia Law

In this case, Plaintiff Jennifer Akridge, a former employee of Alfa Mutual Insurance Company, appealed the entry of summary judgment in favor of Alfa on her claim under the Americans with Disabilities Act (ADA). Akridge had multiple sclerosis and severe migraines, and she alleged that the company wrongfully terminated her to avoid paying for her healthcare costs. Alfa argued that it eliminated her position because her duties were automated and no longer needed, and the company wanted to cut business expenses.The United States Court of Appeals for the Eleventh Circuit affirmed the summary judgment ruling. The court found that Akridge failed to establish a prima facie case of disability discrimination under the ADA. Even if she had, her evidence failed to show that Alfa’s reason for firing her (that her position was no longer needed and it wished to cut business expenses) was pretext for disability discrimination. The court also rejected Akridge's argument that she merely needs to show that her disability was a motivating factor, rather than a but-for cause, of her termination. The court clarified that, unlike Title VII, the ADA does not incorporate the motivating-factor causation standard, and an ADA plaintiff must show that a cause was outcome determinative. Therefore, it upheld the district court’s decision that Akridge did not produce sufficient evidence to suggest that her termination was a result of discrimination based on her disability.The court also affirmed the district court's award of $1,918 in discovery sanctions against Akridge. The lower court found that Akridge's motion to compel a certain deposition was not substantially justified, and the appeals court found no error or abuse of discretion in that ruling. View "Akridge v. Alfa Mutual Insurance Co." on Justia Law

In a case heard by the United States Court of Appeals for the Eleventh Circuit, plaintiffs Jennifer Dupree and Detrich Battle challenged the dismissal of their Title V claims under the Americans with Disabilities Act (ADA) on the basis of sovereign immunity. Dupree, who worked for the Georgia Department of Human Services, and Battle, an employee of the Georgia Department of Corrections, had requested accommodations at their respective workplaces due to their health conditions. After their requests were denied and their employment terminated, they filed claims under Title V, alleging retaliation.The court, however, found that sovereign immunity applies to Title V claims when brought in conjunction with Title I claims. This meant that the plaintiffs' claims could not proceed. Importantly, the court clarified that dismissals based on sovereign immunity, a jurisdictional issue, should be entered without prejudice. Not specifying this in the dismissal could lead to misunderstandings about the nature of the dismissal. Therefore, the court vacated and remanded the case for the limited purpose of allowing the district court to dismiss the case without prejudice. View "Dupree v. Owens" on Justia Law