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

An inmate at St. Clair Correctional Facility in Alabama brought suit under 42 U.S.C. § 1983 after he was assaulted by another prisoner in 2018. Previously, he had been attacked in 2016 and had requested transfer to segregation due to safety concerns but was denied by prison officials. Upon his return to St. Clair in 2017, he again sought protective housing, citing ongoing threats and hazardous conditions, including frequent violence, unauthorized inmate movement, and periods of absent supervision. Despite these requests, he remained in the general population and was ultimately assaulted, resulting in serious injuries.The United States District Court for the Northern District of Alabama first dismissed most of his claims, allowing only the Eighth Amendment deliberate-indifference claim based on a generalized risk of violence to proceed. After discovery, the district court granted summary judgment to the prison officials, finding that the plaintiff had failed to establish a genuine dispute of material fact as to whether he faced a substantial risk of serious harm. In an earlier appeal, the United States Court of Appeals for the Eleventh Circuit vacated the summary judgment due to improper denial of discovery, remanding for further proceedings. On remand, the district court again granted summary judgment, reasoning that the plaintiff had not sufficiently contextualized the violence statistics or provided adequate support for his allegations.Upon review, the United States Court of Appeals for the Eleventh Circuit held that the plaintiff had provided sufficient evidence—including statistical data on inmate assaults, contextual information about prison conditions, and sworn allegations of specific dangerous features—to create a genuine dispute of material fact regarding exposure to a substantial risk of serious harm. The court vacated the district court’s grant of summary judgment and remanded for further proceedings. View "Marbury v. Warden" on Justia Law

A man who was convicted of possessing child pornography in 2013 served his sentence and later married and had a son. Despite completing sex offender treatment and complying with supervised release conditions, he remained subject to Alabama’s Sex Offender Registration and Community Notification Act (“the Act”). This law prohibits him, for life, from residing with or conducting overnight visits with any minor—including his own child—because his conviction involved a child-related offense. The Act contains no mechanism for relief or individualized assessment, even for parents who have shown rehabilitation.After the birth of his son, the man sued the Sheriff and District Attorney of Tuscaloosa County and the Alabama Attorney General under 42 U.S.C. § 1983, seeking to enjoin enforcement of the Act’s prohibition against living with his child. The United States District Court for the Middle District of Alabama granted summary judgment in his favor, declaring the Act’s prohibition facially unconstitutional and issuing a universal injunction. On appeal, a panel of the United States Court of Appeals for the Eleventh Circuit affirmed in part, reversed in part, and vacated and remanded in part, finding the Act unconstitutional as applied to the plaintiff but vacating the universal injunction. The panel’s opinion was then vacated, and the case was reheard en banc.The United States Court of Appeals for the Eleventh Circuit held that all parents—including those with past convictions or “misconduct”—enjoy a fundamental right to live with their children under the Fourteenth Amendment. The court rejected Alabama’s argument that certain classes of parents lack this right due to prior offenses. The court remanded the case to the panel for further proceedings under strict scrutiny, requiring Alabama to show its law is narrowly tailored to serve a compelling state interest. The court affirmed in part and remanded in part. View "Henry v. Sheriff of Tuscaloosa County, Alabama" on Justia Law

A 65-year-old homeless man was encountered by two Atlanta police officers near a highway on-ramp after he was observed receiving money from a driver. When approached, he fled on foot, and one officer pursued him across traffic. The man, unarmed and non-threatening, crossed a guardrail and began descending a steep embankment toward a highway. Without giving a verbal warning, the officer fired his taser in dart mode, striking the man in the back, causing him to fall down the embankment and suffer catastrophic injuries, including traumatic brain injury and quadriplegia.The man’s guardian filed suit in the United States District Court for the Northern District of Georgia against the officer and the City under 42 U.S.C. § 1983, alleging excessive force, as well as related state-law claims. The district court granted partial summary judgment on certain state claims and dismissed others by stipulation. At trial, the jury found in favor of the plaintiff, awarding $60 million against the City and $40 million against the officer (split between compensatory and punitive damages). The district court later set aside the verdict against the City, holding there was insufficient evidence of municipal liability, and reduced the punitive damages against the officer to $1 million.The United States Court of Appeals for the Eleventh Circuit reviewed these outcomes. It held that the officer was not entitled to qualified immunity, because tasing an unarmed, non-dangerous suspect fleeing on foot in a highly dangerous location, without warning, constituted excessive force under clearly established law. The appellate court affirmed setting aside the verdict against the City, finding insufficient evidence that any City policy or failure to enforce the body camera policy was the moving force behind the violation. The reduction of punitive damages to $1 million was upheld as constitutional. The court also affirmed the district court’s rulings on medical expenses and attorney’s fees. View "Edwards v. Grubbs" on Justia Law

Four individuals who regularly engage in panhandling in Daytona Beach, Florida, challenged the city’s 2019 ordinance that imposed wide-ranging restrictions on panhandling. They argued that the law, which defined panhandling as in-person requests for immediate donations, and which banned or restricted this conduct in various locations and circumstances, violated their First Amendment rights. Each plaintiff relied on panhandling for basic needs and had faced threats, arrests, or other enforcement actions as a result of the ordinance.The United States District Court for the Middle District of Florida reviewed the case and granted summary judgment in favor of the plaintiffs. The court found that the ordinance’s challenged provisions were content-based, failed strict scrutiny, and thus violated the First Amendment. It issued a declaratory judgment, a universal injunction against enforcement of the challenged provisions, and awarded damages as agreed by the parties. The City of Daytona Beach appealed these decisions.On appeal, the United States Court of Appeals for the Eleventh Circuit held that the ordinance imposed content-based restrictions on speech by targeting only in-person requests for immediate donations, distinguishing them from other types of solicitation. The court found that several provisions could not withstand strict scrutiny, as the city had less speech-restrictive means to achieve its public health and safety goals. However, the Eleventh Circuit determined that the plaintiffs had standing to challenge only some, not all, of the ordinance’s provisions and that the district court’s remedy was overbroad. The appellate court affirmed the district court’s ruling as to the provisions where at least one plaintiff had standing, vacated it in other respects, and remanded for further proceedings consistent with its opinion. The damages award was affirmed because at least one provision was found unconstitutional. View "Scott v. City of Daytona Beach" on Justia Law

A group of inmates incarcerated within Alabama’s state prison system filed a class action challenging the adequacy of mental health care provided by the Alabama Department of Corrections (ADOC). The plaintiffs, who suffer from serious mental illnesses, alleged that overcrowding, understaffing, and a series of systemic failures resulted in constitutionally deficient mental health services, contributing to a suicide rate far above the national average. Key alleged deficiencies included improper identification and classification of mental health needs, inadequate treatment plans, insufficient psychotherapy, lack of proper suicide risk management, improper use of segregation for mentally ill inmates, and the imposition of disciplinary sanctions for manifestations of mental illness.The United States District Court for the Middle District of Alabama managed the litigation in multiple phases. After a seven-week bench trial, the court found the ADOC liable under the Eighth Amendment for deliberate indifference to inmates’ serious mental health needs. The court then held extensive remedial proceedings, including further hearings and negotiations, and entered a comprehensive, system-wide remedial injunction. The court made detailed factual findings and, to comply with the Prison Litigation Reform Act (PLRA), issued particularized findings that the relief ordered was necessary, narrowly drawn, and the least intrusive means to remedy the constitutional violations. The court also adopted a monitoring plan to ensure compliance, involving external experts and a transition to internal oversight.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s liability findings and most aspects of the remedial and monitoring orders, holding that system-wide relief was appropriate given the systemic nature of the violations. However, the appellate court reversed certain remedial provisions where it found the relief exceeded what was necessary to correct the constitutional violations, particularly with respect to suicide-proofing cells and some staffing requirements, and as applied to a women’s facility where violations were not established. The case was remanded for modification in those limited respects. View "Braggs v. Commissioner, Alabama Department of Corrections" on Justia Law

A male freshman football player at a public high school in Alabama was subjected to repeated acts of harassment by older teammates, including physical and verbal abuse with sexual overtones and an attempted sexual assault known as “keying,” where a car key is forced into a player’s anus. The harassment was meant to emasculate him and included slurs and other conduct suggesting hostility toward his perceived failure to conform to masculine stereotypes. The student reported these incidents to school officials, including the head coach, but the school’s response was minimal and did not stop the harassment. The student ultimately transferred to a different school as a result.Afterward, the student, through his representative, sued the school district and the head coach in the United States District Court for the Northern District of Alabama. He alleged violations of Title IX and the Equal Protection Clause, as well as state tort claims. The district court dismissed the federal claims, concluding that the harassment was motivated by anti-freshman bias rather than sex, that the conduct did not qualify as actionable same-sex sexual harassment under Title IX or the Equal Protection Clause, and that the coach was entitled to qualified immunity. The court declined to exercise supplemental jurisdiction over the state claims.The United States Court of Appeals for the Eleventh Circuit reviewed the dismissal de novo. It held that the student plausibly alleged sex-based harassment actionable under Title IX and the Equal Protection Clause because the alleged conduct targeted him for failing to conform to sex stereotypes and involved inherently sexual acts. The court concluded that the allegations supported a finding of deliberate indifference by the school district and the coach and that the coach was not entitled to qualified immunity. The Eleventh Circuit vacated the district court’s dismissal and remanded for further proceedings. View "C. W. v. Smith" on Justia Law

A candidate for the Republican nomination for Governor of Georgia, who was not the incumbent, challenged a unique provision of Georgia’s campaign finance law. This law allows only the incumbent Governor and Lieutenant Governor to establish and control so-called “leadership committees” with the ability to receive unlimited contributions and coordinate spending directly with their campaigns, advantages not available to challengers or other candidates. The challenger entered the 2026 gubernatorial primary and quickly discovered that his opponent, the sitting Lieutenant Governor, had amassed substantial campaign resources through such a leadership committee, while the challenger remained subject to standard contribution limits.After filing suit in the United States District Court for the Northern District of Georgia, the challenger sought a preliminary injunction to stop the Lieutenant Governor’s leadership committee from raising or spending further funds in support of his campaign. The district court initially issued a temporary restraining order, then, after further proceedings, granted a preliminary injunction, holding that the challenger was likely to succeed on his claim that the law violated the First Amendment’s guarantee of free speech and that the leadership committee’s actions could be fairly attributed to state action. The district court determined that the law’s favoritism toward select officials could not be justified and that the harm to the challenger was irreparable. However, the injunction was stayed pending appeal.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s grant of a preliminary injunction. The court held that the selective fundraising advantage granted to certain incumbents by the leadership committee statute was unconstitutional under the First Amendment, as it imposed different contribution limits on candidates for the same office without sufficient justification. The court also found that the leadership committee’s conduct constituted state action, making it subject to suit under 42 U.S.C. § 1983. The preliminary injunction was affirmed. View "Jackson v. Jones" on Justia Law

A Black resident of the Middle District of Florida, descended from enslaved individuals, brought suit against the Mayor of Jacksonville and the Governor of Florida in their official capacities. He alleged that the continued presence and maintenance of nearly fifty Confederate memorials, monuments, and naming tributes on public land, funded by city or state tax dollars, caused him to feel “deeply repulsed, disheartened, and intimidated.” He asserted that these symbols were governmental celebrations of White supremacy, and sought a declaratory judgment that their presence violated his rights under Title II of the Civil Rights Act, the Thirteenth Amendment, the Equal Protection and Due Process Clauses of the Fourteenth Amendment, and 42 U.S.C. § 1981.The United States District Court for the Middle District of Florida dismissed the complaint. The magistrate judge had recommended dismissal, finding that the plaintiff failed to allege facts showing a particularized injury, and thus lacked Article III standing. The magistrate also found that the plaintiff did not have taxpayer standing, as he failed to allege a direct injury or that taxpayer funds were specifically used to maintain the memorials. The district court adopted the recommendation, concluding that the plaintiff’s objections were not sufficiently specific, but nonetheless conducted a de novo review and agreed that standing was lacking.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s dismissal. The court held that the plaintiff’s alleged psychological harm—feelings of repulsion and intimidation—did not constitute a concrete or particularized injury for Article III standing. It further found he did not demonstrate municipal taxpayer standing, as he failed to allege facts indicating that taxpayer funds were used for the memorials. The Eleventh Circuit concluded that the plaintiff lacked standing and affirmed the dismissal. View "Johnson v. Mayor, City of Jacksonville" on Justia Law

A woman became unconscious after riding home with her mother, who suspected a drug overdose and called 911. When police officers and emergency medical personnel arrived, the woman regained consciousness but refused medical assistance, adamantly stating she wished to go inside to use the restroom. As she attempted to pass one of the officers, a physical altercation ensued involving four officers. During the struggle, she sustained a fractured arm, resulting in lasting injury. She later sued the officers, alleging unlawful detention and excessive force in violation of her Fourth Amendment rights.The United States District Court for the Northern District of Georgia granted summary judgment for the officers, finding they were entitled to qualified immunity. The court determined that the officers had probable cause to execute a mental-health seizure and that their use of force was objectively reasonable under the circumstances. It also concluded that there was no duty for the other officers to intervene because no excessive force had occurred.The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo. It held that the officers did not violate the woman’s clearly established Fourth Amendment rights. The court found two independent grounds for affirming qualified immunity: first, the officers had an objectively reasonable basis to seize her under the emergency-aid doctrine, as clarified by Case v. Montana, which requires only objective reasonableness and not probable cause in emergency situations; second, they had probable cause to believe she had committed a crime due to suspected GHB possession. The court also held that the force used was not excessive, as it was proportionate and fell within established standards for physical restraint, even though injury resulted. Finally, since no excessive force occurred, the other officers had no obligation to intervene. The Eleventh Circuit affirmed the summary judgment in favor of the officers. View "Marbut v. Phillips" on Justia Law

A man was sitting in the backseat of his vehicle in a shopping center parking lot when sheriff’s deputies approached and asked for identification, suspecting loitering. The man repeatedly questioned the request, moved to the driver’s seat without complying, and started the vehicle. He drove away after deputies drew their weapons and commanded him to stop, nearly striking one deputy. The deputies pursued him, during which he drove through stop signs and on the wrong side of the road. A pursuit intervention technique caused his vehicle to spin and become pinned between police cars. Despite being boxed in, the man continued to press the accelerator, causing his tires to squeal and the car to push against a deputy’s vehicle. At this point, a deputy fired one shot, hitting the man in the eye. The man was then removed from the vehicle, handcuffed on the ground, and a deputy briefly placed a knee on his back.The United States District Court for the Northern District of Georgia granted summary judgment to the sheriff and deputies. It found that the shooting was a reasonable use of force in response to the perceived threat and that no clearly established law made the force unconstitutional. It held that the force used to arrest the man after the shooting was de minimis and not excessive. The court also determined the sheriff was entitled to sovereign immunity and the deputies to official immunity on state law claims because there was no showing of malice.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s judgment. It held that the deputies did not violate the man’s constitutional rights or act with malice, and that the sheriff was immune from suit. The court found the shooting objectively reasonable under the circumstances, the force used during the arrest minimal, and no duty for a deputy to intervene. It also affirmed immunity for state law claims. View "Bolton v. Sheriff of Coweta County" on Justia Law