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

Articles Posted in Civil Rights

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The Department of Justice filed suit against the State of Florida, seeking declaratory and injunctive relief under Title II of the Americans with Disabilities Act (ADA) and 28 C.F.R. 35.130(d). The Department alleged that Florida was failing to meet its obligations under Title II by unnecessarily institutionalizing hundreds of children with disabilities in nursing facilities. The Department also alleged that Florida's Medicaid policies and practices placed other children who have "medically complex" conditions, or who are "medically fragile," at risk of unnecessary institutionalization. The Eleventh Circuit held that the Attorney General has a cause of action to enforce Title II of the ADA. The court held that when Congress chose to designate the "remedies, procedures, and rights" in section 505 of the Rehabilitation Act, which in turn adopted Title VI, as the enforcement provision for Title II of the ADA, Congress created a system of federal enforcement. The court also held that the express statutory language in Title II adopts federal statutes that use a remedial structure based on investigation of complaints, compliance reviews, negotiation to achieve voluntary compliance, and ultimately enforcement through "any other means authorized by law" in the event of noncompliance. Therefore, courts have routinely concluded that Congress's decision to utilize the same enforcement mechanism for Title II as the Rehabilitation Act, and therefore Title VI, demonstrates that the Attorney General has the authority to act "by any other means authorized by law" to enforce Title II, including initiating a civil action. Accordingly, the court reversed the district court's judgment and remanded. View "United States v. State of Florida" on Justia Law

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This consolidated appeal arose after Massage Envy’s stated reason for the termination of intervenor was its fear that she might contract and later develop Ebola due to her trip to Ghana. EEOC and intervenor appealed the entry of judgment for Massage Envy on their employment discrimination claims under the Americans with Disabilities Act of 1990 (ADA), as amended by the ADA Amendments of 2009. The Eleventh Circuit held that, even construing the statute broadly, the terms of the ADA protect persons who experience discrimination because of a current, past, or perceived disability—not because of a potential future disability that a healthy person may experience later. Therefore, the court affirmed the district court's final judgment in favor of Massage Envy. View "Lowe v. STME, LLC" on Justia Law

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Plaintiff filed suit against three deputies and the county sheriff after she was shot five times during a routine wellness check. On appeal, the county sheriff challenged the judgment against him and the district court's denial of his motion for a new trial. The Eleventh Circuit held that controlling federal law did not preclude district court judges from accurately informing jurors of the effects of their findings—in either their instructions or their verdict forms. Therefore, the court held that it was not improper for the judge to provide an accurate statement of law explaining the legal effect of the jury's finding under Florida's alcohol defense. The court also held that plaintiff did not present a nonexistent negligent-use-of-force claim and that her negligent-wellness-check claim was not precluded; plaintiffs lawyer did not make a forbidden golden-rule argument; and any error that the district court committed in admitting testimony about the deputies' dismissals was harmless. View "Ermini v. Scott" on Justia Law

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The Eleventh Circuit affirmed the district court's denial of federal habeas relief to petitioner, who was sentenced to death for two murders. The court held that Hurst v. Florida, 136 S. Ct. 616 (2016), did not apply retroactively to petitioner and any challenge to his death sentence on this basis was beyond the court's reach on federal habeas review. The court also held that the Florida Supreme Court's rejection of petitioner's ineffective assistance claim was not an unreasonable application of Strickland v. Washington, 466 U.S. 668 (1984). In this case, counsel's decision not to call an equivocal expert, in part to preserve an advantage at closing, was reasonable trial strategy. Furthermore, petitioner failed to meet his burden of showing prejudice under Strickland because there was no reasonable probability the expert's testimony would have made a difference in the outcome of the trial, given the weight of the evidence against him. View "Knight v. Florida Department of Corrections" on Justia Law

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The Eleventh Circuit affirmed the district court's denial of habeas relief to petitioner, who was sentenced to death for murder. The court held that the state court did not unreasonably determine that petitioner failed to establish objectively incompetent performance by his counsel during the penalty phase of his trial. Furthermore, even if petitioner had demonstrated that his counsel performed as no reasonable lawyer could have, the court did not find that the state court's decision -- that a different result was not substantially likely -- was an unreasonable application of Strickland v. Washington. The court also held that the state court did not unreasonably determine the facts or unreasonably apply Atkins v. Virginia with respect to the intellectual component of intellectual disability; the record supported the state court's conclusion that petitioner did not have substantial deficits in adaptive behavior; the Alabama Court of Criminal Appeals' determination that petitioner did not have intellectual disability was not contrary to or an unreasonable application of Atkins; and the district court did not abuse its discretion by denying an evidentiary hearing on the Atkins claim. View "Jenkins v. Commissioner, Alabama Department of Corrections" on Justia Law

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The Eleventh Circuit affirmed the district court's grant of summary judgment to a correctional facility officer and warden in a 42 U.S.C. 1983 action brought by plaintiff, alleging that defendants were deliberately indifferent to his substantial risk of safety. The court held that the evidence plaintiff presented regarding a general risk of inmate-on-inmate violence did not rise to the level necessary to show deliberate indifference to a substantial risk. In this case, plaintiff failed to produce evidence that he was in an environment so beset by violence that confinement, by its nature, threatened him with the substantial risk of serious harm. Likewise, plaintiff's claim that defendants were deliberately indifferent to the more specific threat he warned them about in April 2016 -- that he had heard from a friend that someone intended to harm him -- failed because he did not have enough evidence to establish a genuine issue of fact that the warden was put on notice that plaintiff faced a substantial risk of serious harm. Finally, plaintiff failed to establish that defendants were deliberately indifferent in failing to investigate his report that someone was out to harm him or in otherwise failing to abide by prison policy. View "Marbury v. Warden" on Justia Law

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The ACRU filed suit alleging that defendant, the former Broward County Supervisor of Elections, failed to satisfy her list-maintenance obligations under the National Voter Registration Act (NVRA). The Eleventh Circuit held that, under the NVRA, the states and their subsidiaries are required to conduct a general program of list maintenance that makes a reasonable effort to remove voters who become ineligible on account of death or change of residence, and only on those two accounts. The court also held that nothing in the Help America Vote Act (HAVA) changes what is required by the NVRA. Finally, the court held that the NVRA sets forth an explicit safe-harbor procedure by which the states may fulfill their list-maintenance obligations as to voters who move. In this case, the district court did not clearly err by finding that defendant's Election Supervisor conducted a program reasonably designed to accomplish these tasks required under the NVRA. Accordingly, the court affirmed the judgment of the district court. View "American Civil Rights Union v. Snipes" on Justia Law

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The Eleventh Circuit denied petitioner's application seeking an order authorizing the district court to consider a second or successive petition for a writ of habeas corpus. Petitioner claimed that he is intellectually disabled and thus ineligible for the death penalty. The court held that petitioner failed to make a prima facie showing that his claim satisfied the requirements of 28 U.S.C. 2244(b)(2), because petitioner failed to rely on a new rule of constitutional law, made retroactive to cases on collateral review by the Supreme Court, that was previously unavailable, because all the cases he relies on were either previously available to him or were not made retroactive to cases on collateral review. The court also denied petitioner's emergency motion to stay his execution. View "In re: Gary Ray Bowles" on Justia Law

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After plaintiff was arrested for simple battery following an altercation with her sister, she filed suit against Deputy McDonough, alleging the violation of her Fourth Amendment rights. The district court granted summary judgment for the deputy. The Eleventh Circuit affirmed and held that the deputy had ample probable cause to arrest plaintiff where the underlying information indicating that she had battered her sister was credible and his investigation was sufficient. The court also held that the deputy did not use excessive force in making the arrest by pulling plaintiff's arms, cinching the handcuffs too tight, or tugging on her fingers and arms to remove her rings. View "Huebner v. Bradshaw" on Justia Law

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The Eleventh Circuit denied the motion for stay of execution pending appeal, holding that the district court rightly dismissed petitioner's current petition as second or successive under 28 U.S.C. 2244(b)(3)(A). In this case, petitioner failed to obtain authorization from this court before filing the petition. The court rejected petitioner's remaining three claims as to why his petition should not be dismissed, and held that petitioner failed to show a substantial likelihood of success on the merits of his appeal. View "Bowles v. Secretary, Florida Department of Corrections" on Justia Law