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

Early one morning, law enforcement officers went to the home of an individual whose son was suspected of assault and possibly being armed. The officers approached the house from different sides, announced their presence, and knocked on the front and side doors. The resident, believing his son was at the door, opened the back door—where no officer had knocked—and walked back inside without seeing or speaking to any officer. An officer then entered the home through the open back door without a warrant or exigent circumstances, only announcing his presence after passing through the kitchen. The resident, who was in his bedroom, was confronted, tased, handcuffed, and detained outside for a period of time.The resident filed suit in the United States District Court for the Northern District of Florida, alleging unlawful entry and unlawful seizure (including excessive force) in violation of the Fourth Amendment. After discovery, the officer moved for summary judgment on the basis of qualified immunity. The district court denied summary judgment on both the unlawful entry and unlawful seizure claims, finding that material factual disputes precluded qualified immunity. The officer appealed.The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo. The court held that, construing the facts in the light most favorable to the plaintiff, a reasonable jury could find that the officer entered the home without consent, in violation of clearly established Fourth Amendment law. The court affirmed the district court’s denial of summary judgment on the unlawful entry claim. However, the court found that the unlawful seizure and excessive force claims were entirely derivative of the unlawful entry claim, and therefore vacated the denial of summary judgment on those claims, remanding for the district court to treat them as subsumed within the unlawful entry claim. View "Dukes v. Gregory" on Justia Law

A city commissioner in Coffee County, Georgia, who was active in assisting voters, became involved in a heated exchange with the county’s Elections Supervisor at a polling site during early voting for the 2020 general election. After the confrontation, the police were called, and the commissioner left. Later that day, she returned to the polling site to assist another voter, prompting another police response. A City of Douglas police sergeant then issued her a criminal trespass warning, banning her from all county polling places for the remainder of the election period. When she refused to leave, she was arrested.The commissioner filed a lawsuit in the United States District Court for the Southern District of Georgia against the Elections Supervisor and Coffee County, alleging that the trespass warning violated her First Amendment rights and that her arrest violated the Fourth Amendment. The district court granted summary judgment to the defendants, finding that the police sergeant, not the Elections Supervisor or the County, had issued the trespass warning and made the arrest. The court concluded that the plaintiff failed to show that the defendants caused her alleged injuries, as required under 42 U.S.C. § 1983.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The Eleventh Circuit held that the plaintiff did not present sufficient evidence for a reasonable jury to conclude that the Elections Supervisor, rather than the police sergeant, caused her injuries. The court explained that the sergeant acted as a deliberative and autonomous decision-maker, conducting his own investigation and independently deciding to issue the trespass warning and make the arrest. Because causation is a necessary element of a § 1983 claim, and the plaintiff failed to establish it, summary judgment for the defendants was affirmed. View "Coley-Pearson v. Martin" on Justia Law

A woman was working late at her place of employment, a business located in a commercial cul-de-sac, when she was approached at night by two individuals carrying flashlights. Fearing for her safety, as she did not know they were police officers and they did not identify themselves, she attempted to drive away. The officers, who were investigating a report of a possible break-in at a different address in the same cul-de-sac, fired their weapons at her vehicle as she drove up the driveway. The woman was not physically harmed, but her car was struck by bullets and later declared a total loss. She was detained in a police cruiser for several hours before being released without charges.The United States District Court for the Northern District of Georgia reviewed the woman’s claims under 42 U.S.C. § 1983, alleging unlawful seizure, excessive force, and unlawful property seizure in violation of the Fourth Amendment. The district court granted summary judgment to the officers on state-law claims but denied summary judgment on the federal claims, finding that a reasonable jury could conclude the officers lacked reasonable suspicion or probable cause, and that their actions violated clearly established law. The officers appealed, arguing they were entitled to qualified immunity.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s denial of qualified immunity. The court held that the officers seized the plaintiff both by physical force (when they shot her car) and by a show of authority, that no reasonable officer could have believed there was reasonable suspicion or probable cause to seize or shoot at her, and that the warrantless seizure of her vehicle was not justified by exigent circumstances. The case was remanded for further proceedings. View "Watkins v. Davis" on Justia Law

A white man, after a dinner in Palm Harbor, Florida, targeted a Black man, his girlfriend, and his four-year-old daughter as they drove on a county-administered public road. The defendant, whom the victims did not know, repeatedly attempted to run their car off the road, shouted racial slurs, and made threatening gestures. At a red light, he exited his vehicle and physically confronted the Black man, continuing his racial abuse. Witnesses and police confirmed the defendant’s aggressive and racially charged conduct, and the defendant made further racist statements to law enforcement after his arrest. The defendant’s ex-girlfriend testified that such behavior was typical for him.A grand jury in the United States District Court for the Middle District of Florida indicted the defendant on two counts of violating 18 U.S.C. § 245(b)(2)(B), which prohibits racially motivated interference with the use of public facilities. The defendant moved to dismiss the indictment, arguing that the statute exceeded Congress’s authority under the Thirteenth Amendment and the Commerce Clause, and that the indictment violated the Double Jeopardy Clause. The district court denied these motions. At trial, the court instructed the jury that to convict, it must find the defendant acted “because of” the victim’s use of the public road, applying a “but-for” causation standard. The jury found the defendant guilty on one count and not guilty on the other. The district court denied the defendant’s motions for acquittal and a new trial, and sentenced him to 24 months in prison.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that 18 U.S.C. § 245(b)(2)(B) is a constitutional exercise of Congress’s power under the Thirteenth Amendment, as Congress may rationally prohibit racially motivated violence interfering with public facilities as a badge or incident of slavery. The court also found no error in the jury instructions, the handling of jury questions, or the sufficiency of the evidence. The conviction was affirmed. View "United States v. Leahy" on Justia Law

An athletic trainer employed by a rehabilitation services provider was assigned to work at a local high school under a contract between her employer and the school. Over several years, she reported concerns about the conduct and performance of other athletic trainers at the school, which led to personnel changes. In 2020, after a new head football coach was hired, the trainer was briefly given additional responsibilities but was soon told to return to her original role. Shortly thereafter, the school’s principal requested her removal, citing workplace issues unrelated to her sex. The trainer was then removed from her assignment at the school and offered several alternative positions by her employer, some with reduced pay or less desirable conditions. She ultimately accepted a new assignment but later resigned, alleging that her removal and reassignment were due to sex discrimination and retaliation for her complaints.The United States District Court for the Northern District of Alabama granted summary judgment in favor of the employer, finding that although there was a factual dispute about the employer’s control over the removal, the trainer failed to show that the employer discriminated or retaliated against her in violation of Title VII. The court concluded there was insufficient evidence that the employer knew or should have known the school’s removal request was based on sex, or that the reassignment options were offered for discriminatory reasons.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The appellate court held that the trainer’s discrimination claim failed because there was no evidence the employer knew or should have known the school’s request was sex-based, and no evidence that the reassignment was motivated by sex. The retaliation claim also failed, as there was no evidence the employer removed or reassigned her because she engaged in protected activity. The court affirmed summary judgment for the employer. View "Vincent v. ATI Holdings LLC" on Justia Law

The case centers on a Florida farm and its owner, who had supplied produce to a local school district for several years. In June 2020, the owner posted controversial statements on his personal Facebook page, describing the COVID-19 pandemic as a “hoax” and making disparaging remarks about the Black Lives Matter movement and George Floyd. The school district, concerned about food safety during the early, uncertain days of the pandemic, requested information about the farm’s COVID-19 protocols. The response provided protocols from a subsidiary, not the farm itself, which the district found inadequate. Shortly after, the superintendent terminated the farm’s contract, citing concerns about the farm’s approach to COVID-19 safety.The farm and its owner sued the school district and board members in the United States District Court for the Middle District of Florida, alleging First Amendment retaliation and raising state law claims. The district court granted summary judgment to the defendants, applying the Pickering balancing test (typically used for government employees and contractors) and finding that the school district’s interests in food safety outweighed the plaintiffs’ free speech rights. The court also granted qualified immunity to individual defendants and dismissed the state law claims without prejudice.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The Eleventh Circuit held that, although the owner’s speech addressed matters of public concern, the evidence showed the contract was terminated due to genuine food safety concerns, not as punishment for the owner’s views on COVID-19 or racial issues. The court found no genuine dispute of material fact regarding the school district’s motivation and concluded that the district’s interest in student safety justified its actions. The summary judgment in favor of the school district was affirmed. View "Oakes Farms Food & Distribution Services, LLC v. Adkins" on Justia Law

A man was arrested by city police officers in Rainsville, Alabama, after exhibiting erratic behavior and resisting arrest. The Chief of Police directed Officer White to transport the arrestee to the county jail in Fort Payne, which had better medical facilities. Upon arrival at the county jail, jailers became frustrated with the arrestee during booking and began to beat him. Officer White witnessed the beating from a few feet away but did not attempt to intervene or protest. The beating continued for several minutes after White left the room, resulting in significant injuries to the arrestee. The jailers involved were later criminally prosecuted and convicted for their conduct.The arrestee filed a lawsuit under 42 U.S.C. § 1983 against Officer White and others, alleging, among other claims, that White’s failure to intervene violated his Fourth Amendment rights. The United States District Court for the Northern District of Alabama granted summary judgment to the officers on the false arrest claim but denied summary judgment to White on the failure to intervene claim, rejecting his qualified immunity defense. White appealed the denial of qualified immunity.The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo. The court held that, under clearly established law as of March 2020, an arresting officer who delivers a helpless arrestee to jailers and witnesses those jailers immediately begin to beat the arrestee in his presence violates the Fourth Amendment if he remains silent and leaves the scene while the assault is ongoing. The court further held that the duty to intervene is not discharged by a phone call to a supervisor who is not in a position to stop the assault. The Eleventh Circuit affirmed the district court’s denial of summary judgment to Officer White on the failure to intervene claim. View "Nute v. White" on Justia Law

An inmate in Georgia, who practices veganism as part of his religious beliefs, was enrolled in a prison program that provided vegan meals to accommodate religious diets. He was removed from this program twice after prison officials discovered he had purchased non-vegan food items from the prison store, such as chicken soup and Cheetos. The inmate claimed he bought these items to sell to other prisoners and would have stopped if he had known it could result in removal from the program. At the time of his removals, the prison’s policy did not explicitly list non-vegan purchases as grounds for removal, though this was later added. The inmate also alleged that only Black inmates were removed from the program, while similarly situated white inmates were not.The United States District Court for the Middle District of Georgia granted summary judgment to the prison officials on the inmate’s claims under the First, Eighth, and Fourteenth Amendments, as well as most of his claims under the Religious Land Use and Institutionalized Persons Act (RLUIPA). The court found that the officials were entitled to qualified immunity on the First Amendment and due process claims, that there was no evidence of discriminatory intent or similarly situated comparators for the equal protection claim, and that the non-vegan meals provided were nutritionally adequate. The court also dismissed the remaining RLUIPA claim as moot after the inmate was reenrolled in the vegan meal program.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that the officials were entitled to qualified immunity, that there was insufficient evidence to support the equal protection and Eighth Amendment claims, and that the RLUIPA claims either failed on the merits or were moot because the inmate had been reinstated in the vegan meal program. View "Sumrall v. Georgia Department of Corrections" on Justia Law

Arthur Huggins, a community member in Manatee County, Florida, regularly attended local school board meetings to criticize the School Board and Superintendent Cynthia Saunders for their decision to take control of Lincoln Memorial Academy, a Black-owned charter school, and remove its administration. Huggins was known for his outspoken opposition, including public comments and calls for investigations into the Board’s actions. At a November 2019 board meeting, after standing at the back of the room due to back pain, Huggins was ordered by the school district’s Chief of Security, at Saunders’s direction, to sit or leave. When Huggins explained his situation, he was removed from the meeting by a police officer and prevented from delivering his public comment. The incident was later publicized, and the Board and Saunders issued apologies.Huggins filed suit in state court against the School Board, Saunders, and several individuals, alleging violations of his First Amendment rights, among other claims. The case was removed to the United States District Court for the Middle District of Florida. The district court dismissed Huggins’s federal claims with prejudice, finding that the individual defendants were entitled to qualified immunity and that Huggins had not established municipal liability against the Board or the City of Bradenton. The court also denied Huggins’s request to amend his complaint a second time and declined to exercise supplemental jurisdiction over his state law claims.The United States Court of Appeals for the Eleventh Circuit reversed the district court’s dismissal of Huggins’s First Amendment claims against Saunders, holding that Saunders was not entitled to qualified immunity and that Huggins plausibly alleged both viewpoint discrimination and retaliation. The court affirmed the dismissal of claims against the other defendants and the denial of leave to amend, but vacated the district court’s decision declining supplemental jurisdiction over state claims, remanding for further proceedings. View "Huggins v. School District of Manatee County" on Justia Law

Two Black celebrities brought suit after being stopped by Clayton County, Georgia police officers on the jet bridge while boarding flights at Hartsfield-Jackson Atlanta International Airport. The officers, as part of a drug interdiction program, stopped passengers after they had cleared security and boarding checks, requested and retained their identification and boarding passes, questioned them about drugs, and asked to search their luggage. Both plaintiffs alleged they felt coerced, were not free to leave, and believed they had no choice but to comply. They further alleged that the program disproportionately targeted Black passengers and that the stops were neither random nor consensual.The United States District Court for the Northern District of Georgia dismissed all claims. It found the encounters were voluntary and not seizures under the Fourth Amendment, that any searches were consensual, and that the plaintiffs failed to plausibly allege racial discrimination or a policy supporting municipal liability. The court also granted qualified immunity to the individual officers.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that the plaintiffs plausibly alleged they were subjected to unreasonable seizures and, in one case, an unreasonable search, in violation of the Fourth Amendment. The court found that the circumstances—officers blocking the plaintiffs’ paths, retaining their documents, and questioning them in a confined space—amounted to seizures, and that the search was not voluntary. However, the court affirmed qualified immunity for the individual officers, as the law was not clearly established. The court also found that the plaintiffs plausibly alleged a policy or custom by Clayton County that could support municipal liability under Monell. The court affirmed dismissal of the equal protection claims, finding insufficient allegations of discriminatory intent. The court reversed in part, allowing the Fourth Amendment claims against Clayton County to proceed. View "Andre v. Clayton County" on Justia Law