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

Articles Posted in Civil Rights
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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

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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

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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

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The case concerns Tia Deyon Pugh, who was charged with impeding law enforcement during a civil disorder in violation of 18 U.S.C. § 231(a)(3) during a protest in Mobile, Alabama. She smashed a police car window with a baseball bat, thus obstructing law enforcement officers in their official duties during the civil disorder. Pugh challenged the constitutionality of Section 231(a)(3) on four grounds, arguing that it: (1) exceeds Congress’s power to legislate under the Commerce Clause, (2) is a substantially overbroad regulation of activities protected by the First Amendment, (3) is a content-based restriction of expressive activities in violation of the First Amendment, and (4) is vague in violation of the Fifth Amendment’s Due Process Clause. The district court rejected these arguments, and Pugh was found guilty by a jury.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed Pugh’s conviction. The court held that Section 231(a)(3) does not exceed Congress's power under the Commerce Clause as the statute's jurisdictional element is sufficient to limit its scope to constitutional applications. The court also found that the statute does not violate the First Amendment as it does not broadly prohibit protected speech and expressive conduct. Furthermore, the court ruled that the statute is not a content-based restriction and does not violate the Fifth Amendment's Due Process Clause due to vagueness. The court concluded that the statute constitutionally applies to Pugh's conduct, and she may not challenge the statute on vagueness grounds based on its application to others. View "USA v. Pugh" on Justia Law

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A decision from the United States Court of Appeals for the Eleventh Circuit concerned whether the Governor of Florida, Ron DeSantis, violated the First Amendment rights of Andrew Warren, a state attorney for Florida’s Thirteenth Judicial Circuit, when he suspended Warren from office. Warren, a vocal advocate for criminal justice reform, had been elected to his position twice. During his time in office, he implemented several policies and signed onto advocacy statements related to issues such as transgender health care and abortion rights. Governor DeSantis suspended Warren from his position, justifying the decision on the basis of these activities. Warren sued, claiming that the suspension was retaliation for his First Amendment-protected activities. The district court found that six factors motivated DeSantis to suspend Warren, two of which were protected by the First Amendment. However, the court concluded that DeSantis would have suspended Warren regardless of these protected activities, basing this conclusion on the other four factors. On appeal, the Eleventh Circuit found that the district court erred in not considering all of Warren's activities as protected by the First Amendment. The court emphasized that, as an elected official, Warren had a right to express his views on policy matters of public concern and that his suspension based on these expressions violated his First Amendment rights. The court vacated the district court's decision and remanded the case for further proceedings. View "Warren v. DeSantis" on Justia Law

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In the case before the United States Court of Appeals for the Eleventh Circuit, Young Israel of Tampa, Inc., an Orthodox Jewish synagogue, sued the Hillsborough Area Regional Transit Authority (HART) for rejecting its proposed advertisement for a Chanukah on Ice event. The synagogue argued that HART’s policy, which prohibited advertisements that “primarily promote a religious faith or religious organization,” violated the Free Speech Clause of the First Amendment. The district court granted summary judgment in favor of Young Israel on two grounds: 1) HART’s policy violated the First Amendment because it discriminated on the basis of viewpoint, and 2) even if the policy was viewpoint neutral, it was unreasonable because it lacked objective and workable standards and was inconsistently and haphazardly applied. The court subsequently issued a permanent injunction against HART, prohibiting it from rejecting any advertisement on the ground that it primarily promotes a religious faith or religious organization, including any future policies.On appeal, the Eleventh Circuit affirmed the district court’s decision, but on narrower grounds. The appellate court concluded that HART's policy was unreasonable under the Supreme Court's decision in Minnesota Voters Alliance v. Mansky because it failed to define key terms, lacked any official guidance, and vested too much discretion in those who applied it. The court declined to address the question of whether the policy constituted impermissible viewpoint discrimination. However, the court concluded that the permanent injunction issued by the district court needed to be revised to apply only to HART’s current policy, rather than any future policies, and remanded the case to the district court for that purpose. View "Young Israel of Tampa, Inc. v. Hillsborough Area Regional Transit Authority" on Justia Law

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The United States Court of Appeals for the Eleventh Circuit partially affirmed and partially reversed a lower court's ruling in a case involving James McDonough, a citizen activist, who was banned from future meetings and arrested for disorderly conduct and cyberstalking by the City of Homestead, Florida. McDonough claimed these actions violated his First and Fourth Amendment rights.The court determined that the city council meetings were designated public forums, and the ban was not narrowly tailored to serve a significant government interest as required, thus violating McDonough's First Amendment rights.The court also found that the officers did not have probable cause to arrest McDonough for disorderly conduct, which involved swearing at officers and making obscene gestures. The court stated that such actions do not constitute disorderly conduct and are protected under the First Amendment. However, the court ruled that the City had probable cause to arrest McDonough for cyberstalking, as it was not unreasonable for the City to interpret Florida’s cyberstalking statute as barring McDonough from targeting one of its officers with his series of posts.The case was sent back to the lower court for further proceedings consistent with the appellate court’s opinion. View "McDonough v. Garcia" on Justia Law

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The United States Court of Appeals for the Eleventh Circuit vacated and remanded a decision by the United States District Court for the Northern District of Florida, which had ruled against Andrew Warren, a Florida State Attorney for the Thirteenth Judicial Circuit. Warren had filed a lawsuit against Governor Ron DeSantis, claiming that DeSantis had suspended him in retaliation for his First Amendment activity. The circuit court agreed with the district court that Warren had satisfied his initial burden of showing that he had engaged in protected activity, suffered an adverse action, and that DeSantis's actions were motivated by Warren's protected activity. However, the circuit court disagreed with the district court's conclusion that the First Amendment did not protect certain activities that motivated DeSantis's decision, and found that the district court erred in concluding that DeSantis would have suspended Warren based solely on unprotected activities. The case was remanded for the district court to reconsider whether DeSantis would have made the same decision based solely on the unprotected activities. View "Warren v. DeSantis" on Justia Law

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This case revolves around Kenneth Bailey's lawsuit against Deputy Shawn Swindell, claiming that Swindell violated his civil rights when he tackled Bailey through the door of Bailey's parents' home and arrested him without a warrant or exigent circumstances. Bailey's suit was filed under Section 1983. The United States District Court for the Northern District of Florida initially granted summary judgment in favor of Swindell based on qualified immunity. However, the United States Court of Appeals for the Eleventh Circuit reversed this decision, concluding that Swindell violated clearly established law when he entered Bailey's parents' home to arrest him without a warrant or exigent circumstances, and was therefore not entitled to qualified immunity.On remand, the case went to trial and the jury returned a verdict for Bailey, awarding him $625,000 for his injuries. However, the district court later granted Swindell's motion for judgment as a matter of law, setting aside the jury's verdict. Bailey appealed this decision.The Eleventh Circuit reversed the district court's grant of judgment as a matter of law. The appellate court found that the jury's factual findings, including that the arrest was initiated outside the home but no exigent circumstances existed allowing for a warrantless entry into the home, should have been used by the district court in making its legal conclusions about qualified immunity. The court emphasized that it was clearly established that an officer violates the Constitution by initiating an arrest outside of a home and then entering the home without a warrant to complete the arrest in the absence of exigent circumstances. Therefore, Swindell was not entitled to qualified immunity, and the jury's verdict in favor of Bailey should be reinstated. View "Bailey v. Swindell" on Justia Law

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In this case, the United States Court of Appeals for the Eleventh Circuit reviewed an appeal of a lower court's denial of qualified immunity to a jail intake officer, Keyvon Sellers. The case arose from an incident in which a black man, Jayvon Hatchett, attacked and killed his white cellmate, Eddie Nelson, in county jail. Before the attack, Hatchett had told Sellers that he had previously stabbed a white man after watching videos of white police officers shooting black men. Despite this admission, Sellers did not inform other jail staff of Hatchett's racially motivated violence. Nelson's survivors sued Sellers, alleging that his failure to share this information constituted deliberate indifference to a substantial risk of serious harm to Nelson, in violation of the Fourteenth Amendment.The Court of Appeals affirmed the district court's decision, finding that a reasonable jury could conclude that Sellers violated Nelson's clearly established constitutional right by failing to protect him from a known risk of harm. The court concluded that Sellers had fair warning that his inaction was unconstitutional. Therefore, he was not entitled to qualified immunity. View "Nelson v. Sellers" on Justia Law