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

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After a jury returned a verdict in plaintiff's favor on his claim of First Amendment retaliation, he was awarded only one dollar in nominal damages because the Eleventh Circuit has interpreted the Prison Litigation Reform Act (PLRA), 42 U.S.C. 1997e(e), as barring punitive damages for a prisoner's civil action where no physical injury is shown.The en banc court now recognizes that section 1997e(e) permits claims for punitive damages without a showing of physical injury. The en banc court explained that it did not conduct a textual interpretation of the statutory text and did not consider any non-physical injuries that were also not mental or emotional in nature. The en banc court misapprehended the text of the statute and the nature of the physical injury requirement when it comes to punitive damages. Therefore, in this case, plaintiff should be given an opportunity to obtain punitive damages too. In all other respects, the en banc court reinstated the panel opinion. View "Hoever v. Marks" on Justia Law

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The Eleventh Circuit sua sponte vacated its previous opinion and substituted the following opinion.In 2015, plaintiffs filed suit challenging Alabama's 2011 Photo Voter Identification Law passed by the Alabama legislature as House Bill 19 and codified at Ala. Code 17-9-30. The voter ID law took effect in June 2014 and requires all Alabama voters to present a photo ID when casting in-person or absentee votes. Plaintiffs sought declaratory and injunctive relief to prevent the enforcement of Alabama's voter ID law, alleging that the law violates the Fourteenth and Fifteenth Amendments of the Constitution; Section 2 of the Voting Rights Act (VRA), 52 U.S.C. 10301; and Section 201 of the VRA, 52 U.S.C. 10501.The Eleventh Circuit affirmed the district court's order granting summary judgment in favor of the Secretary, concluding that plaintiffs have failed to identify any genuine disputes of material facts and because no reasonable factfinder could find, based on the evidence presented, that Alabama's voter ID law is discriminatory. The court explained that the burden of providing a photo ID in order to vote is a minimal burden on Alabama's voters—especially when Alabama accepts so many different forms of photo ID and makes acquiring one simple and free for voters who lack a valid ID but wish to obtain one. Therefore, the Alabama voter ID law does not violate the Fourteenth and Fifteenth Amendments of the Constitution, nor does it violate the VRA. View "Greater Birmingham Ministries v. Secretary of State for the State of Alabama" on Justia Law

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The Eleventh Circuit affirmed defendant's conviction and sentence for possessing a firearm while being a felon, in violation of 18 U.S.C. 922(g)(1). The court concluded that the district court did not abuse its discretion in excluding out-of-court statements as hearsay when they were not offered to prove the truth of the matter asserted. In this case, the danger of unfair prejudice carried by a third party's confession was enormous and the confession would almost certainly precipitate a trial within a trial on the adequacy of the Task Force investigation.The court also concluded that, although defendant's indictment was insufficient under Rehaif v. United States, 139 S. Ct. 2191 (2019), the insufficiency did not affect his substantial rights; the district court did not abuse its discretion in admitting an unredacted copy of defendant's prior firearm conviction; and the Florida offense of armed robbery is a violent felony under the Armed Career Criminal Act (ACCA). View "United States v. Elysee" on Justia Law

Posted in: Criminal Law
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After a jury found that the manufacturer breached its duty to sell its products to certain customers exclusively through the distributor, the manufacturer appealed the denial of a directed verdict as to the status of two customers under the contract. The distributor cross-appealed a ruling that invalidated the contract's liquidated-damages clause and a ruling that prevented it from pursuing lost-profit damages.The Eleventh Circuit concluded that, under Federal Rule of Civil Procedure 6, the closure of the clerk's office renders the office inaccessible and tolls the filing deadline, which makes the motion timely. Therefore, the district court did not err in denying the manufacturer's Federal Rule of Civil Procedure 50 motions. The court also concluded that the district court did not err when it ruled that the liquidated-damages clause was unenforceable because $2 million a breach was grossly disproportionate to the foreseeable actual damages, and the disproportionality amounts to an unenforceable penalty. The court further concluded that the district court did not abuse its discretion by excluding lost-profit damages because Circuitronix failed to disclose its computation of those damages. View "Circuitronix, LLC v. Kinwong Electronic (Hong Kong) Co., Ltd." on Justia Law

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Plaintiff, a long-time customer with a visual disability who must access websites with screen reader software, filed suit against Winn-Dixie under Title III of the Americans with Disabilities Act (ADA) after he was unable to access Winn-Dixie's website with his software. The district court found that Winn-Dixie's website violated the ADA.The Eleventh Circuit vacated and remanded, concluding that plaintiff had Article III standing to bring the case where the difficulties caused by his inability to access much of the website constitute a concrete and particularized injury that is not conjectural or hypothetical and will continue if the website remains inaccessible; the websites are not places of public accommodation under Title III of the ADA because, pursuant to the language of Title III, public accommodations are limited to actual, physical places; and Winn-Dixie's limited use website, although inaccessible by individuals who are visually disabled, does not function as an intangible barrier to an individual with a visual disability accessing the goods, services, privileges, or advantages of Winn-Dixie's physical stores (the operative place of public accommodation). The court explained that, absent congressional action that broadens the definition of "places of public accommodation" to include websites, the court cannot extend ADA liability to the facts presented here, where there is no barrier to the access demanded by the statute. View "Gil v. Winn-Dixie Stores, Inc." on Justia Law

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Petitioner, a Cuban citizen, petitioned for review of the BIA's order affirming the denial of his applications for asylum and withholding of removal under the Immigration and Nationality Act (INA), and relief under the United Nations Convention Against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment (CAT).The Eleventh Circuit granted the petition in part because the IJ and the BIA failed to provide reasoned consideration of petitioner's evidence of his well-founded fear of future persecution based on a pattern or practice of persecution toward dissident journalists in Cuba. However, the court denied the petition for review of petitioner's asylum claim based on past persecution because substantial evidence supports the BIA's conclusion that petitioner did not demonstrate that he suffered past persecution. View "Cabrera Martinez v. U.S. Attorney General" on Justia Law

Posted in: Immigration Law
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After an ATF reverse sting operation caught petitioner in the midst of an effort to commit armed robbery of a house he believed held the cocaine stash of a Colombian cartel, a jury convicted petitioner of both conspiring to use and using a firearm during a crime of violence or drug trafficking offense in violation of 18 U.S.C. 924(o) and 924(c). The Eleventh Circuit affirmed his conviction and sentence. Petitioner now appeals the district court's rejection of his section 2255 collateral attack on these convictions.The Eleventh Circuit affirmed the district court's judgment because petitioner cannot overcome the procedural default of his claim and because even if he could, he suffered no harm from the inclusion of an invalid predicate offense, Hobbs Act conspiracy, in his indictment and jury instructions. The court explained that both conclusions follow from the same feature of petitioner's case: the Hobbs Act conspiracy was inextricably intertwined with petitioner's conspiracy and attempt to possess with intent to distribute cocaine (Counts 2 and 3), convictions petitioner does not dispute are valid drug trafficking predicates for his Count 4 and Count 5 convictions. View "Parker v. United States" on Justia Law

Posted in: Criminal Law
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The Eleventh Circuit affirmed the district court's order granting summary judgment to AMR in a Title VII action brought by plaintiff, alleging failure to accommodate his religious requirement, discrimination on the basis of religion, and retaliation for filing a discrimination claim. Plaintiff's action stemmed from AMR's refusal to allow him to work emergency transports with his goatee, which he grew as part of his practice of Rastafarianism.In regard to plaintiff's disparate-treatment claims based on religion, the court concluded that plaintiff forfeited any "convincing mosaic" argument in support of his traditional religious disparate-treatment discrimination claim. Furthermore, plaintiff made no other argument to support that version of his disparate-treatment discrimination claim. In regard to plaintiff's religious-discrimination claim based on AMR's alleged failure to provide plaintiff with a reasonable accommodation of his religious practice of wearing a beard, the court concluded that AMR offered plaintiff a reasonable accommodation by providing him with an opportunity to maintain his beard and to work on the non-emergency-transport side of its operations, for which DeKalb County's facial-hair policy did not apply. The panel explained that his terms and conditions of employment would not have been affected by the accommodation AMR offered. In regard to the retaliation claim, the record indicates that the but-for cause of plaintiff's termination was AMR's belief that he had given an untrue answer on his employment application. Therefore, his retaliation claim necessarily fails. View "Bailey v. Metro Ambulance Services, Inc." on Justia Law

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The Eleventh Circuit held that the Employment Retirement Income Security Act's (ERISA) fee-shifting provision, 29 U.S.C. 1132(g)(1), cannot support a fee award against a party's counsel. The court explained that the function of this statute is not to sanction attorney misconduct. Rather, that role belongs to other provisions, such as 28 U.S.C. 1927 and Federal Rule of Civil Procedure 11(c).In this case, the district court relied exclusively on Section 1132(g)(1) when awarding fees. Therefore, the court reversed and vacated the district court's fee award. The court did not address Liberty Life's argument that the district court should have imposed fees against Theresa E. Peer's counsel, Paul Sullivan. On remand, the district court may consider whether a fee award is appropriate against Peer under ERISA or against Peer or Sullivan under another statute, rule, or the district court's inherent authority. View "Sullivan v. Liberty Life Assurance Company of Boston" on Justia Law

Posted in: ERISA
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Plaintiff filed suit against defendant, a police officer, under 42 U.S.C. 1983 and Georgia state laws, alleging claims for unlawful entry, false arrest, excessive force, malicious prosecution, false imprisonment, assault, and battery. Plaintiff's claim arose from an August 4, 2016, interaction with defendant and other officers at his mobile home where defendant deployed his taser on plaintiff and plaintiff was arrested and charged with disorderly conduct, obstruction, and simple battery, which were eventually dismissed.The Eleventh Circuit concluded that the facts of this case are heavily disputed and there are genuine issues of material fact as to whether defendant lawfully entered plaintiff's home. Therefore, summary judgment was improper and the court reversed the district court's grant of summary judgment to plaintiff on the unlawful entry claim. The court also concluded that disputed facts exist as to the remaining claims. Therefore, because genuine issues of material fact prevent finding for defendant as a matter of law, the court affirmed the district court's denial of summary judgment, qualified immunity, and official immunity on all other claims. View "Hardigree v. Lofton" on Justia Law