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

Transgender residents of Alabama sought to change the sex designation on their driver’s licenses without undergoing sex-change surgery, as required by Alabama’s Policy Order 63. This policy mandates that individuals wishing to change the sex on their driver’s license must submit either an amended birth certificate or a letter from the physician who performed the reassignment surgery. Plaintiffs argued that this policy violated the Equal Protection and Due Process Clauses of the Fourteenth Amendment, as well as the Free Speech Clause of the First Amendment.The United States District Court for the Middle District of Alabama ruled in favor of the plaintiffs, declaring Policy Order 63 unconstitutional under the Equal Protection Clause. The district court found that the policy classified individuals by sex and applied intermediate scrutiny, concluding that Alabama had not provided an adequate justification for the policy.The United States Court of Appeals for the Eleventh Circuit reviewed the case and reversed the district court’s decision. The appellate court held that Policy Order 63 does not impose a sex-based classification and therefore does not trigger heightened scrutiny. Instead, the policy was subject to rational basis review, which it survived. The court found that the policy rationally advances Alabama’s legitimate interest in maintaining consistent requirements for amending sex designations on state documents.The appellate court also rejected the plaintiffs’ due process and First Amendment claims. It held that the policy does not violate the right to informational privacy or the right to refuse medical treatment, as it does not force individuals to undergo surgery to obtain a driver’s license. Additionally, the court determined that the policy does not compel speech, as the information on driver’s licenses constitutes government speech, not private speech. Thus, the Eleventh Circuit reversed the district court’s judgment and upheld the constitutionality of Policy Order 63. View "Corbitt v. Secretary of the Alabama Law Enforcement Agency" on Justia Law

Robert Turner, a property owner in Suwannee County, Florida, claimed that his homestead property was sold at an impermissibly low amount under Florida law, which deprived him of any surplus after back taxes and costs were deducted. Turner had a homestead exemption on his property, which was automatically renewed until 2015. After failing to pay property taxes, a tax certificate was issued, and a tax deed sale was conducted in 2015. Turner alleged that the sale was unlawful because it did not account for the homestead exemption, and he did not receive proper notice of the sale.Turner initially sought relief in state court, challenging the removal of his homestead exemption, but his complaint was dismissed as untimely. He then filed a federal lawsuit under 42 U.S.C. § 1983, claiming violations of his constitutional rights, including First Amendment retaliation, Fourth Amendment illegal seizure, and due process violations. The federal district court dismissed his complaint, finding that abstention was warranted under the comity doctrine, which prevents federal courts from interfering with state tax administration when state remedies are adequate.The United States Court of Appeals for the Eleventh Circuit reviewed the district court's decision. The court affirmed the dismissal, holding that the relief Turner sought would disrupt Florida's administration of its ad valorem property tax scheme. The court found that Florida provided plain, adequate, and complete state remedies, including the ability to challenge tax deed sales and homestead exemption removals in state court. The court concluded that the district court did not abuse its discretion in abstaining from exercising jurisdiction under the comity doctrine. View "Turner v. Jordan" on Justia Law

Amir Meshal, a professional truck driver, was stopped by Georgia State Police officers for a minor traffic infraction. During the stop, the officers discovered Meshal was on the FBI’s No Fly List. Despite instructions not to detain him based solely on this status, the officers handcuffed Meshal, placed him in a patrol car, and searched his truck. They questioned him about his religion and international travel while waiting for guidance from the FBI. After 91 minutes, the FBI cleared Meshal, and he was released with a warning citation for the traffic infraction.Meshal sued the officers in the United States District Court for the Southern District of Georgia, alleging violations of his Fourth Amendment rights due to the extended detention and the search of his truck. The officers moved to dismiss the complaint on qualified immunity grounds, arguing that Meshal failed to allege a violation of clearly established law. The district court denied the motion, finding that the complaint sufficiently alleged that the officers detained Meshal without arguable reasonable suspicion and searched his truck without arguable probable cause.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court agreed with the district court, holding that the officers were not entitled to qualified immunity at this stage. The court found that the officers lacked even arguable reasonable suspicion to justify prolonging the traffic stop beyond the time necessary to complete tasks related to the traffic infraction. Additionally, the court held that the search of Meshal’s truck was not supported by arguable probable cause. Therefore, the Eleventh Circuit affirmed the district court’s denial of qualified immunity. View "Meshal v. Commissioner, Georgia Department of Public Safety" on Justia Law

Four registered voters and several non-profit organizations sued the Cobb County Board of Elections and Registration, alleging that the 2022 redistricting map for the Cobb County School Board was an unconstitutional racial gerrymander. They claimed the map packed Black and Latino voters into certain districts to dilute their political power and maintain a majority white School Board. The plaintiffs sought declaratory and injunctive relief to prevent the use of the 2022 map in future elections.The Cobb County School District intervened as a defendant and moved for judgment on the pleadings, arguing it was not liable for any constitutional violation because the Georgia General Assembly, not the School Board, enacted the map. The district court granted the School District’s motion based on Monell v. Department of Social Services of New York, but did not immediately enter judgment. The School District continued to participate in the case, prompting the court to formally terminate it as a party. The plaintiffs and the Election Defendants then entered a settlement, leading to a preliminary injunction against the 2022 map.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court dismissed the School District’s appeal for lack of jurisdiction, holding that the School District, as a nonparty, lacked standing to appeal the preliminary injunction. The court emphasized that only parties or those who properly become parties may appeal, and the School District had not sought to reintervene for purposes of appeal. The court also noted that the School District’s participation as an amicus did not grant it the right to appeal. View "Cobb County School District" on Justia Law

A federal prisoner, LaQuan Johnson, filed a complaint under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, seeking money damages from federal prison officials, doctors, a nurse, and a kitchen supervisor. Johnson alleged violations of his constitutional rights through excessive force, failure to protect him from other inmates, and deliberate indifference to his serious medical needs. The incidents occurred while Johnson was housed at the United States Penitentiary in Atlanta, Georgia, from September 2015 to April 2019. He claimed that prison officials failed to separate pretrial detainees from convicted inmates, leading to multiple attacks on him, and that medical staff provided inadequate treatment for his injuries.The United States District Court for the Northern District of Georgia initially denied the defendants' motion to dismiss for failure to exhaust administrative remedies, finding that Johnson was denied access to the Bureau of Prisons' (BOP) administrative remedy program. However, after further discovery, the district court granted the defendants' motions for summary judgment, concluding that Johnson's claims did not entitle him to a Bivens remedy because they would require recognizing new Bivens causes of action, which the court is generally forbidden to create.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's decision. The Eleventh Circuit held that Johnson's failure to protect and deliberate indifference claims presented new Bivens contexts, as they were meaningfully different from the three contexts previously recognized by the Supreme Court in Bivens, Davis v. Passman, and Carlson v. Green. The court also found that special factors, including the existence of the BOP's administrative remedy program, counseled against extending Bivens to these new contexts. The court emphasized that the existence of an alternative remedial structure alone is sufficient to preclude the creation of a new Bivens remedy. View "Johnson v. Terry" on Justia Law

Jesse Guardado confessed to the Walton County Sheriff’s Office that he had robbed and murdered Jackie Malone. He pleaded guilty without a plea agreement or counsel, and was later appointed counsel for the penalty phase. A jury recommended the death penalty, and the state trial court sentenced him to death. Guardado filed a habeas corpus petition, arguing ineffective assistance of counsel for failing to investigate and present mitigating evidence and for not challenging biased jurors.The Florida Supreme Court affirmed the trial court's decision, finding no prejudice from counsel's performance. The court determined that the additional mitigating evidence presented during postconviction proceedings was cumulative of the evidence presented at trial. It also found no actual bias in the jurors that Guardado claimed should have been challenged.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court found that the Florida Supreme Court unreasonably applied Strickland v. Washington by using a stricter "actual bias" standard instead of the reasonable probability standard for prejudice. However, upon de novo review, the Eleventh Circuit concluded that Guardado failed to show a substantial likelihood of a different outcome if the jurors had been challenged or if additional mitigating evidence had been presented. The court affirmed the denial of habeas relief. View "Guardado v. Secretary, Florida Department of Corrections" on Justia Law

The case involves several special education students who alleged that their teacher physically and emotionally abused them. The students, who have various disabilities affecting their communication abilities, were assigned to the same classroom at Elm Street Elementary School in Coweta County, Georgia. The teacher, Catherine Sprague, was hired by the principal, Dr. Christi Hildebrand, despite lacking special education certification. Throughout the fall of 2019, the students exhibited signs of distress, and their parents noticed behavioral changes and physical signs of mistreatment. A paraprofessional, Nicole Marshall, reported multiple instances of abuse by Sprague to Hildebrand, who delayed reporting these allegations to law enforcement and the students' parents.The United States District Court for the Northern District of Georgia dismissed the students' complaint. The court ruled that emotional distress damages are not recoverable under Title II of the Americans with Disabilities Act (ADA) following the Supreme Court's decision in Cummings v. Premier Rehab Keller, P.L.L.C. The court also found that the students failed to state a constitutional violation against Hildebrand and the school district, and that Hildebrand was entitled to qualified immunity. The court declined to exercise supplemental jurisdiction over the state law negligence claim.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court affirmed that emotional distress damages are not recoverable under Title II of the ADA, as Title II incorporates the remedies of the Rehabilitation Act, which the Supreme Court in Cummings ruled does not allow for emotional distress damages. However, the appellate court found that the district court erred by not considering whether the students might be entitled to other forms of relief under Title II, such as damages for physical harm or nominal damages. The appellate court also affirmed the dismissal of the section 1983 claims, ruling that the alleged abuse did not meet the "shock-the-conscience" standard required for a substantive due process violation. The case was remanded for further proceedings to consider other potential relief under Title II. View "A.W. v. Coweta County School District" on Justia Law

Christopher Redding was wanted for parole violations related to robbery charges and was classified as a "Violent Felony Offender of Special Concern." On February 28, 2017, police officers, including Deputy Jason Popovich, attempted to arrest Redding at an apartment complex. Redding did not comply with the officers' commands and instead started shooting, injuring one officer. He fled, dropping his gun during the chase. Eventually, Redding was shot multiple times and fell to the ground. As officers, including Popovich, approached him, Redding made a sudden movement, prompting Popovich to shoot him twice in the head, resulting in Redding's death.The United States District Court for the Middle District of Florida granted summary judgment in favor of Popovich on qualified immunity grounds. The court found that while there was a genuine issue of fact regarding whether Popovich's use of force was objectively reasonable under the Fourth Amendment, Franklin, representing Redding's estate, failed to show that Popovich violated clearly established law. The court concluded that a reasonable officer could believe Redding's sudden movement was an attempt to fight back, distinguishing the case from precedents cited by Franklin.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's decision. The appellate court concluded that there was no genuine dispute of fact that Popovich did not know Redding was unarmed. Given the severity of Redding's crimes, his recent shootout with police, and his sudden movement, a reasonable officer could have believed Redding posed a threat. Therefore, Popovich's use of deadly force did not violate the Fourth Amendment, and Franklin failed to show that Popovich's actions violated clearly established law. Consequently, Popovich was entitled to qualified immunity. View "Franklin v. Popovich" on Justia Law

A high school football coach's contract was not renewed by the Valdosta Board of Education in 2020. The vote split along racial lines, with all white members voting to renew and all black members voting against renewal. The coach believed the decision was racially motivated.In 2020, the coach sued the five black board members individually under 42 U.S.C. §§ 1981 and 1983, seeking monetary damages. The district court denied the board members' motions to dismiss based on qualified immunity, but the Eleventh Circuit reversed, finding the coach failed to state a claim. The case was remanded for dismissal.In 2021, the coach filed a new lawsuit against the same board members and the Board itself, this time under Title VII of the Civil Rights Act of 1964. The new complaint included more detailed allegations but was based on the same core facts. The district court granted summary judgment for the Board, ruling that the new lawsuit was barred by res judicata because the Board was in privity with the individual board members and the two cases involved the same cause of action.The United States Court of Appeals for the Eleventh Circuit affirmed the district court's decision. The court held that the Board was in privity with the individual board members because they acted as the Board when they voted not to renew the coach's contract. The court also found that both lawsuits arose from the same nucleus of operative facts, thus meeting the criteria for res judicata. View "Rodemaker v. City of Valdosta Board of Education" on Justia Law

David Efron and Madeleine Candelario were involved in a divorce proceeding in Puerto Rico, during which Efron was ordered to pay Candelario $50,000 per month. After the divorce was finalized, Candelario began a relationship with Judge Cordero, and Efron alleges that Candelario, her attorney, and Judges Cordero and Aponte conspired to reinstate the payments through a corrupt scheme. Efron claims this resulted in Candelario receiving approximately $7 million. Efron filed a federal lawsuit against Candelario and her attorney, asserting claims for deprivation of procedural due process, conspiracy to deny civil rights, civil conspiracy, and unjust enrichment.The United States District Court for the Southern District of Florida dismissed Efron’s complaint for lack of subject matter jurisdiction, citing the Rooker-Feldman doctrine. The court found that Efron’s claims were inextricably intertwined with the Puerto Rico court’s judgment and that granting relief would effectively nullify that judgment. The district court also rejected Efron’s argument that his claims fell under a fraud exception to the Rooker-Feldman doctrine.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court’s dismissal. The Eleventh Circuit held that the Rooker-Feldman doctrine barred Efron’s claims because they essentially sought to challenge the state court’s judgment. The court concluded that Efron’s claims for damages were not independent of the state court’s decision but were directly related to it, as they required the federal court to review and reject the state court’s judgment. Therefore, the district court correctly dismissed the complaint for lack of subject matter jurisdiction. View "Efron v. Candelario" on Justia Law