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

Articles Posted in Civil Rights
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The Eleventh Circuit sua sponte vacated its previous opinion and substituted the following option. The court affirmed the denial of habeas relief to petitioner, rejecting petitioner's claims of ineffective assistance of counsel and that he is intellectually disabled and therefore ineligible for the death penalty. 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 for failing to present mitigation evidence. Even if petitioner had demonstrated that counsel's performance was deficient, he failed to demonstrate prejudice. The court also held that the state court did not unreasonably determine the facts or unreasonably apply Atkins v. Virginia, 536 U.S. 304 (2002), with respect to the intellectual component of intellectual disability; the record supports the state court's conclusion that petitioner does not have substantial deficits in adaptive behaviors; and the ample record of petitioner's childhood does not point to intellectual disability before age 18. View "Jenkins v. Commissioner, Alabama Department of Corrections" on Justia Law

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This appeal arose from an action brought by plaintiffs who object to the City of Lakeland's decision to relocate a Confederate monument from one city park to another, contending that the relocation violates their rights under the First Amendment's Free Speech Clause and the Fourteenth Amendment's Due Process Clause. The Eleventh Circuit held that plaintiffs lack standing to pursue either their First Amendment claim or their due process claim. Plaintiffs have not shown that they have suffered a particularized Article III injury of the sort that distinguishes them from other interested observers and thus qualifies them, specifically, to invoke federal-court jurisdiction. Rather, plaintiffs' allegations implicate only the generalized desires to promote Southern history and to honor Confederate soldiers. Therefore, the court vacated and remanded the with-prejudice dismissal of plaintiffs' First Amendment claim, with instructions that the district court should dismiss without prejudice for lack of jurisdiction. The court affirmed the district court's without-prejudice dismissal of the due process claim. View "Gardner v. Mutz" on Justia Law

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After a pretrial detainee, Kenneth Grochowski, was killed by his cellmate, William Alexander Brooks, while both men were detained at the Clayton County Jail, Grochowski's surviving adult children filed a civil rights action against the County and four supervisors at the jail. Plaintiffs alleged that the conditions at the jail violated Grochowski's due process rights under the Fourteenth Amendment and that those conditions caused his death. The Eleventh Circuit affirmed the district court's grant of the jail supervisors' motion for summary judgment based on qualified immunity. The court held that plaintiffs have failed to show that the jail supervisors violated a constitutionally protected right because they failed to show that the Constitution requires in-person security screenings or consideration of violent misdemeanors and that the Constitution requires jail officials to conduct rounds more frequently than once per hour. The court also affirmed the district court's grant of summary judgment in favor of the County, holding that plaintiffs failed to show that either the jail design or its funding and staffing levels violated Grochowski's Fourteenth Amendment rights. Finally, the court granted the district court's order granting the County's motion for a protective order regarding the decision-making process with respect to the design and funding of the jail. View "Grochowski v. Clayton County, Georgia" on Justia Law

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The Eleventh Circuit held that the district court erred in issuing an injunction against the County and the Director of the Miami-Dade Corrections and Rehabilitations Department (MDCR), requiring defendants to employ numerous safety measures to prevent the spread of COVID-19 and imposing extensive reporting requirements. Metro West inmates had filed a class action challenging the conditions of their confinement under 42 U.S.C. 1983 and seeking habeas relief under 28 U.S.C. 2241 for the named plaintiffs with a "medically vulnerable" subclass of inmates. The court held that plaintiffs failed to show a substantial likelihood of success on the merits of their constitutional claim for deliberate indifference. The court explained that the district court erred in relying on the increased rate of infection, and in concluding that defendants' inability to ensure adequate social distancing constituted deliberate indifference. In this case, the court simply could not conclude that, when faced with a perfect storm of a contagious virus and the space constraints inherent in a correctional facility, defendants acted unreasonably by "doing their best." The court also agreed with defendants that the district court erred in its likelihood-of-success-on-the-merits analysis because it failed to consider "two threshold issues": (1) the heightened standard for municipal liability under Monell v. Department of Social Services, 436 U.S. 658 (1978), and (2) exhaustion under the Prison Litigation Reform Act. Finally, the court held that the district court erred in holding, without any meaningful analysis, that plaintiffs would suffer irreparable injury absent an injunction. Furthermore, the district court erred in its determination of the balance-of-the-harms and public-interest factors. View "Swain v. Junior" on Justia Law

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Plaintiff appealed the district court's grant of summary judgment in Trees's favor on his hostile work environment and national origin discrimination claims under Title VII of the Civil Rights Act of 1964 and the Florida Civil Rights Act (FCRA). The Eleventh Circuit affirmed the district court's grant of summary judgment for Trees on plaintiff's national origin discrimination claim, holding that the claim fails as a matter of law where the supervisor's statement, although reprehensible, was not direct evidence that plaintiff was fired because of his national origin. The court reversed the district court's grant of summary judgment for Trees on the hostile work environment claim, holding that plaintiff provided evidence sufficient to raise a material issue of fact as to whether the harassment was objectively severe or pervasive. In this case, plaintiff provided ample evidence that the harassment he faced was frequent; a reasonable jury could conclude that the harassment was sufficiently severe; the supervisor's conduct was sufficiently humiliating to support a hostile work environment claim; and, although more attenuated than typical interference-with-job-performance arguments, the court could not say on this record that plaintiff's on-the-job suicide attempt was wholly unrelated to his job performance. View "Soto Fernandez v. Trees, Inc." on Justia Law

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Plaintiff filed a 42 U.S.C. 1983 action against three police officers after plaintiff was shot and seriously injured while he was assisting the police apprehend a fugitive. Plaintiff alleged a section 1983 claim for involuntary servitude under the Thirteenth Amendment to the U.S. Constitution and a violation of substantive due process under the Fourteenth Amendment, as well as claims for negligence, wantonness, failure to train/supervise, and false imprisonment under Alabama state law. In this case, the officers told plaintiff that they would "throw some charges on [him]" if he did not agree to participate in a ruse to capture the fugitive. Plaintiff claimed that the threat of physical violence is what ultimately overcame his will and forced him to participate in the ruse. The Eleventh Circuit affirmed the district court's grant of summary judgment in favor of the officers based on qualified immunity, holding that the officers did not violate the Thirteenth or Fourteenth Amendment. Even assuming that there was a constitutional violation, the court held that it was not clearly established at the time that all objectively reasonable officers in their position would have known that what they said to plaintiff violated the Constitution's prohibition against involuntary servitude or its "nebulous" doctrine of substantive due process. Likewise, the court held that the officers are entitled to discretionary-function immunity on the state law claims. View "King v. Pridmore" on Justia Law

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The Libertarian Party filed suit against the Secretary of State of Georgia, alleging that Georgia's ballot-access requirements for third-party and independent candidates violated their associational rights under the First and Fourteenth Amendments and their Equal Protection rights under the Fourteenth Amendment. The Eleventh Circuit vacated the district court's grant of summary judgment to the Secretary, holding that the district court's failure to apply the Supreme Court's test for the constitutionality of ballot-access requirements, as articulated in Anderson v. Celebreeze, 460 U.S. 780 (1983), constitutes reversible error. Accordingly, the court remanded to the district court with instructions to conduct in the first instance the Anderson test and to consider the Party's Equal Protection claim. View "Cowen v. Georgia Secretary of State" on Justia Law

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Plaintiff filed a 42 U.S.C. 1983 action against the city and a police officer, alleging claims for illegal seizure, unlawful search, and excessive force in violation of the Fourth and Fourteenth Amendments to the United States Constitution. Plaintiff also alleged claims under Alabama law for illegal search, false arrest, battery, and excessive force. The Eleventh Circuit affirmed the district court's denial of summary judgment to the officer based on qualified immunity, holding that genuine issues of material fact exist as to whether the use of force was unconstitutional. In this case, the seriousness and permanence of plaintiff's injuries and the unusual alacrity and horsepower of the officer's leg sweep preclude his force from being characterized as de minimis. Furthermore, the court held that the law had clearly established that plaintiff's force was unconstitutional where no reasonable officer could have thought that sweeping plaintiff's legs out from under him and throwing him to the ground headfirst was a reasonable use of force. Plaintiff was somewhat frail and was not resisting or attempting to flee, and thus the law clearly forbade the officer's forceful takedown under the circumstances. Finally, the court held that the officer is not entitled to immunity under Alabama's immunity doctrine. View "Patel v. City of Madison" on Justia Law

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Plaintiff filed suit against her employer and its CEO for interference and retaliation under the Family Medical Leave Act (FMLA), and for retaliation under Title VII of the Civil Rights Act and 42 U.S.C. 1981. The Eleventh Circuit affirmed the district court's grant of summary judgment to the employer on the FMLA claim, holding that plaintiff's visit to her counselor did not count as treatment by a health care provider under the statute. In regard to the Title VII claim against the employer, the court held that plaintiff failed to offer any evidence that the CEO knew she had complained about race or sex discrimination, and thus she cannot show a relationship between her firing and that protected activity. Furthermore, plaintiff failed to impeach the CEO's testimony or present circumstantial evidence of his knowledge beyond temporal proximity. Therefore, summary judgment was appropriate on this claim because a jury could find discrimination only based on speculation, rather than on evidence. Finally, plaintiff's section 1981 claims were abandoned on appeal. View "Martin v. Financial Asset Management Systems, Inc." on Justia Law

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Harbourside filed suit against the town, moving for a pre-enforcement preliminary injunction against Ordinance 1-16. The ordinance, among other things, established a two-tiered scheme for the use of amplified sound at non-residential properties and contains a separate section relating to outdoor live musical performances. The district court denied injunctive relief. The Eleventh Circuit applied limited review, without definitively addressing the merits, and affirmed the district court's judgment. The court held that the district court did not abuse its discretion in ruling that Harbourside failed to establish a likelihood of success on its claims that it qualifies as an outdoor venue and that the challenged sections of the Jupiter Code are content-based. View "Harbourside Place, LLC v. Town of Jupiter" on Justia Law