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

An inmate at the Jefferson County Jail, who was on suicide watch and housed on the bottom floor of a two-story cell block, suffered a head injury and requested medical attention. A deputy, who was not previously familiar with the inmate, observed her distress and the visible injury. After consulting with a nurse, the deputy prepared to transport the inmate to the medical clinic and remotely unlocked her cell door from the control room. Upon release, the inmate ran upstairs and jumped from the second-story landing, sustaining additional injuries.The United States District Court for the Northern District of Alabama considered the inmate’s claim under 42 U.S.C. § 1983, alleging the deputy was deliberately indifferent to a strong likelihood of self-harm. The district court denied the deputy’s motion for summary judgment based on qualified immunity. It found that a reasonable juror could conclude the deputy violated the inmate's constitutional rights by disregarding the risk of harm in releasing her unsupervised and that the law regarding deliberate indifference to detainee safety was clearly established.The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s denial of qualified immunity de novo. The appellate court determined that, although the inmate suffered a serious deprivation, there was insufficient evidence that the deputy was subjectively aware that unlocking the cell presented a substantial suicide risk specific to this inmate. The court found the deputy acted to aid the inmate and did not knowingly disregard a substantial risk of harm. The Eleventh Circuit held the deputy did not violate the inmate’s constitutional rights and was entitled to qualified immunity. It vacated the district court’s order and remanded with instructions to enter summary judgment for the deputy. View "Gantt v. Everett" on Justia Law

On November 14, 2020, Officer David Collier and his partner arrived at a residence in Escambia County, Florida, to serve arrest warrants on Jacob Settle and his wife. Settle was in his truck parked closely alongside the house in a dark, debris-filled backyard. When the officers approached and identified themselves, Settle refused to exit the vehicle. After Collier threatened to break the truck’s windows, Settle started the engine and shifted the transmission into gear. Collier, believing he and his partner were in imminent danger due to his proximity to the truck, fired his gun into the vehicle, fatally wounding Settle. Settle’s estate sued Collier for excessive force under the Fourth Amendment and for battery under Florida law.The United States District Court for the Northern District of Florida considered Collier's motion for summary judgment, in which he asserted qualified immunity and state law immunity. The district court denied the motion, finding that a reasonable jury could conclude Collier violated Settle’s constitutional rights by using deadly force on a non-moving vehicle that did not pose a risk to the officers. The district court also denied state immunity for the battery claim, reasoning that a jury could find Collier acted with wanton disregard for Settle’s safety.The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s decision de novo. The appellate court held that Collier was entitled to qualified immunity, concluding that his use of deadly force was objectively reasonable because Settle’s actions—starting the engine and shifting the truck into gear while resisting arrest—could reasonably be perceived as an immediate threat. The court further held that Collier was entitled to state statutory immunity from the battery claim, as his conduct met the standards for justified use of force under Florida law. The Eleventh Circuit reversed the district court’s decision and remanded with instructions to enter judgment for Collier. View "Settle v. Collier" on Justia Law

A deputy sheriff of Arabic descent, employed by the Richmond County Sheriff’s Office, was assigned to an off-duty security position at a local business. During his assignment, he alleged that his supervisor subjected him to repeated racial harassment, including derogatory remarks about his ethnicity. Witnesses at the business supported these allegations, noting that the supervisor frequently made such comments. The deputy was also interested in joining the SWAT team, which the supervisor led, but after failing the SWAT entrance exam, the deputy filed a formal internal complaint about the harassment.Shortly thereafter, the deputy was investigated and ultimately terminated for allegedly violating departmental policy by making personal use of his patrol vehicle, specifically for visiting another county’s sheriff’s office to inquire about job opportunities. The deputy provided evidence that other officers regularly made similar personal use of patrol vehicles without being disciplined, and argued that his termination was in retaliation for his internal complaint. He filed suit under 42 U.S.C. § 1981, claiming retaliatory discharge.The United States District Court for the Southern District of Georgia granted summary judgment for the defendants, finding that the deputy had not shown that the employer’s stated reason for termination was a pretext for retaliation.On appeal, the United States Court of Appeals for the Eleventh Circuit concluded that the District Court erred by conflating the McDonnell Douglas pretext analysis with the “convincing mosaic” standard. The Eleventh Circuit held that a plaintiff may survive summary judgment by presenting circumstantial evidence that creates a triable issue regarding retaliatory intent, even if pretext is not conclusively shown. The court reversed and remanded for the District Court to apply the correct summary judgment standard. View "Ismael v. Roundtree" on Justia Law

Kevil Wingo, a pretrial detainee at the Cobb County Adult Detention Center, died from a perforated gastric ulcer after repeatedly complaining of severe abdominal pain, nausea, and vomiting. Jail nurses employed by WellStar Health Systems misdiagnosed his symptoms as drug withdrawal ("detox") and assured the sheriff’s deputies overseeing security that Wingo was medically stable. Despite Wingo’s persistent requests to be sent to a hospital and his deteriorating condition, the deputies deferred to the medical staff’s judgment, consistent with their training not to make independent medical decisions. Wingo was eventually moved to a padded cell for observation, where he died within hours.The United States District Court for the Northern District of Georgia granted summary judgment in favor of the sheriff’s deputies on the plaintiffs' 42 U.S.C. § 1983 claims, finding that they were protected by qualified immunity because they reasonably relied on medical professionals’ assessments. The district court also granted summary judgment to Deputy Wilkerson on a state law negligence claim, concluding that the plaintiffs’ expert could not establish causation with medical certainty regarding whether Wilkerson’s actions affected Wingo’s chance of survival.The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo and affirmed the district court’s judgment. The Eleventh Circuit held that nonmedical jail officers cannot be found liable for deliberate indifference to a detainee’s serious medical needs when they reasonably rely on the advice of medical professionals. The court further found that the absence of expert testimony establishing causation prevented the state law negligence claim against Deputy Wilkerson from surviving summary judgment. Thus, all claims against the defendant deputies were disposed of in their favor, and the district court’s rulings were affirmed. View "Wingo v. Harris" on Justia Law

An individual incarcerated in a county jail in Alabama died after several months in custody, during which his mother, acting as administrator of his estate, alleges he was denied adequate medical care. The county jail had contracted with a private company, Preemptive Forensic Health Solutions, to provide all inmate medical care, even though the company employed no physicians and was allegedly incompetent. Prior to the decedent's death, multiple inmates had died under this company's care, and concerns about inadequate medical treatment became a significant issue in a local sheriff’s election. Despite these concerns and the new sheriff’s efforts to terminate the contract, the county continued and even renewed the agreement with the company, retaining exclusive control over its continuation.The United States District Court for the Northern District of Alabama granted summary judgment to the county, holding that Alabama law limited the county's role to funding inmate healthcare, not providing it, and thus precluded liability under 42 U.S.C. § 1983. The district court determined that only the sheriff was responsible for administering medical care in the jail and that the county had fulfilled its statutory duty by paying for services.The United States Court of Appeals for the Eleventh Circuit reversed this decision. The appellate court held that, under Monell v. Department of Social Services of City of New York and Ancata v. Prison Health Services, Inc., a county can be liable under § 1983 if it adopts or maintains a policy or custom that results in deliberate indifference to inmates' constitutional rights. The court found sufficient evidence for a jury to conclude that the county’s policy of contracting with an incompetent provider—and preventing the sheriff from changing it—could have caused the decedent’s Eighth Amendment violation. The court ruled that Alabama law does not bar such liability and remanded the case for further proceedings. View "Smothers v. Childers" on Justia Law

Two inmates at Smith State Prison in Georgia, Miguel Jackson and Kelvin Stevenson, were involved in a prison riot on December 31, 2010, after officers discovered contraband in Jackson’s cell. The officers alleged that Jackson and Stevenson assaulted them, leading to both inmates being handcuffed and escorted away. Jackson and Stevenson claimed that, after being restrained, they were severely beaten by correctional officers. They filed suit in the United States District Court for the Southern District of Georgia against thirty-nine officers, asserting claims of excessive force and failure to intervene under the Eighth Amendment.Over the course of more than a decade, the plaintiffs voluntarily dismissed many defendants, and the district court granted partial summary judgment, leaving nine officers as defendants by the time of trial. Just before jury selection, plaintiffs moved to dismiss seven more defendants under Federal Rule of Civil Procedure 41(a)(2), which the district court granted, entering judgment in favor of those defendants and reserving the issue of costs and sanctions. The case proceeded to trial against Officers Catanzariti and Harrison. The jury found for Catanzariti on Jackson’s excessive force claim but found he failed to intervene when other officers used excessive force, awarding Jackson $1.00 in damages. Stevenson’s claims against both officers were rejected.On appeal to the United States Court of Appeals for the Eleventh Circuit, the plaintiffs challenged the district court’s grant of their Rule 41 motion and several evidentiary rulings. The Eleventh Circuit held that the district court did not abuse its discretion in granting the partial dismissal and entering judgment for the seven defendants, nor in admitting the challenged evidence. The court affirmed the district court’s final judgments. View "Jackson v. Catanzariti" on Justia Law

Three men were prosecuted for their roles in the fatal shooting of Ahmaud Arbery, a Black man, in the Satilla Shores neighborhood of Glynn County, Georgia. On February 23, 2020, Arbery was running through the neighborhood and stopped at a house under construction, which he had visited before. Gregory and Travis McMichael, who lived nearby, saw Arbery and, suspecting him of recent burglaries, armed themselves and pursued him in a truck. William Bryan, a neighbor, joined the chase in his own vehicle. The men used their trucks to block and pursue Arbery through public streets, ultimately leading to a confrontation in which Travis McMichael shot and killed Arbery.After being convicted of murder and other charges in Georgia state court and sentenced to life imprisonment, the defendants were tried in the United States District Court for the Southern District of Georgia. There, they were convicted of interference with rights under 18 U.S.C. § 245(b)(2)(B), attempted kidnapping under 18 U.S.C. § 1201(a)(1), and, for the McMichaels, firearm offenses under 18 U.S.C. § 924(c)(1)(A)(iii). The district court denied their motions for acquittal, finding sufficient evidence that the defendants acted because of Arbery’s race and his use of public streets, that the streets were provided or administered by the county, and that the attempted kidnapping was for a benefit and involved an instrumentality of interstate commerce.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the sufficiency of the evidence de novo. The court held that substantial evidence supported the jury’s findings on all challenged elements, including racial motivation, use of public facilities, and use of an automobile as an instrumentality of interstate commerce. The Eleventh Circuit affirmed all convictions. View "USA v. Bryan" on Justia Law

In 2004, Clemente Javier Aguirre-Jarquin was arrested and later convicted for the murders of his neighbors, Cheryl Williams and Carol Bareis, in Altamonte Springs, Florida. The investigation by Seminole County Sheriff’s Office (SCSO) focused on Aguirre after bloody clothing and a knife were found near his residence, and forensic analysis by Donna Birks, a latent print examiner, identified Aguirre’s palm print on the murder weapon. Aguirre was tried and sentenced to death in 2006. Over the next decade, new evidence emerged: a 2007 investigation revealed misconduct in the SCSO Latent Print Unit, undermining the reliability of the fingerprint identification, and post-conviction DNA testing failed to link Aguirre to the crime scene but implicated Samantha Williams, the victims’ daughter and granddaughter, who later confessed to involvement in the murders.The Seminole Circuit Court denied Aguirre’s initial motion for a new trial, finding the evidence against him overwhelming. The Supreme Court of Florida affirmed this denial. However, after further post-conviction investigation and new DNA evidence, the Supreme Court of Florida vacated Aguirre’s convictions and ordered a new trial. In 2018, the State dropped all charges against Aguirre.Aguirre then filed suit in the United States District Court for the Middle District of Florida against Birks, lead investigator Robert Hemmert, crime scene analyst Jacqueline Grossi, and the Seminole County Sheriff, alleging violations of his constitutional rights under 42 U.S.C. § 1983 and state law claims. The District Court denied qualified immunity to Birks, Hemmert, and Grossi on several counts and denied state-law immunity to Hemmert and Grossi.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the denial of qualified immunity to Birks on the fabrication of evidence claim and affirmed the denial of state-law immunity to Hemmert and Grossi for intentional infliction of emotional distress. However, the court reversed the denial of qualified immunity to Birks and Hemmert on the malicious prosecution claim and to Hemmert and Grossi on the claim of inadequate investigation, finding no clearly established law requiring the investigation to eliminate all doubts. The case was remanded for further proceedings. View "Aguirre-Jarquin v. Hemmert" on Justia Law

In 2023, the Florida Legislature enacted Senate Bill 264, which, among other provisions, imposed restrictions on real property transactions involving persons domiciled in China who are not U.S. citizens or lawful permanent residents. The law included three key requirements: a purchase restriction barring certain Chinese domiciliaries from acquiring Florida real estate, a registration requirement mandating such individuals to register their existing property interests, and an affidavit requirement obligating all purchasers of Florida real estate to attest compliance with the law. Four Chinese citizens residing in Florida on various nonimmigrant visas and a real estate brokerage firm serving Chinese-speaking clients challenged these provisions, alleging violations of the Equal Protection Clause, the Fair Housing Act, the Due Process Clause, and federal preemption.The plaintiffs filed suit in the United States District Court for the Northern District of Florida against several state officials responsible for enforcing SB 264. They sought a preliminary injunction to halt enforcement of the purchase restriction, registration requirement, and affidavit requirement. The district court found that the plaintiffs had standing to challenge all three provisions but denied the preliminary injunction, concluding that the plaintiffs were not substantially likely to succeed on the merits of their claims.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s decision. The Eleventh Circuit held that the plaintiffs lacked standing to challenge the purchase restriction because none had shown an imminent injury from that provision. However, at least one plaintiff had standing to challenge the registration and affidavit requirements. The court affirmed the denial of the preliminary injunction as to the registration and affidavit requirements, finding no substantial likelihood of success on the merits of the constitutional, statutory, or preemption claims. The court reversed and remanded the denial of the preliminary injunction as to the purchase restriction, instructing the district court to deny it without prejudice for lack of standing. View "Shen v. Commissioner, Florida Department of Agriculture and Consumer Services" on Justia Law

Six women who were formerly incarcerated at the Jasper City Jail in Alabama alleged that they suffered repeated sexual abuse by jailers, primarily by one officer, while serving as inmates. The plaintiffs described a range of sexual assaults and harassment, with one plaintiff also alleging abuse by a second jailer. The jail operated under the authority of the City of Jasper’s police chief, with a chief jailer and other supervisory staff responsible for daily operations. Jail policies expressly prohibited sexual contact between staff and inmates, and there were procedures for reporting grievances, but the plaintiffs claimed these mechanisms were ineffective or inaccessible.After the alleged abuse, the Alabama State Bureau of Investigation began an inquiry, leading to the resignation of the primary alleged abuser and, later, his indictment on state charges. The plaintiffs filed six separate lawsuits, later consolidated, asserting claims under 42 U.S.C. § 1983 for Eighth Amendment violations against the police chief, chief jailer, and the City, as well as claims under the Trafficking Victims Protection Reauthorization Act (TVPRA). One plaintiff also brought claims against a second jailer. The United States District Court for the Northern District of Alabama granted summary judgment to all defendants, finding insufficient evidence that the supervisory officials or the City had knowledge of, or were deliberately indifferent to, the alleged abuse, and that the claims against one jailer failed for lack of proper service.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The court held that the plaintiffs failed to establish a causal link between the actions or inactions of the supervisory officials or the City and the alleged constitutional violations, as there was no evidence of a widespread custom or policy of tolerating sexual abuse, nor of deliberate indifference or failure to train. The court also found that certain claims were time-barred and that the TVPRA claims failed due to lack of evidence that the City knowingly benefited from or had knowledge of the alleged trafficking. View "Bridges v. Poe" on Justia Law