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

In 2002, Hayes, age 20, violently attacked his 60-year-old neighbor without provocation or apparent motive, causing her to lapse into a coma. Hayes was later seen burning items in his backyard. Clothing recovered from the burn pile contained the victim’s blood. Charged with attempted first-degree murder with a deadly weapon and armed trespassing, Hayes was found incompetent to proceed and transferred to a state mental health facility. After months of treatment, the psychology department and two court-appointed psychiatrists concluded that Hayes was competent to proceed Counsel filed a notice of intent to rely on an insanity defense and renewed his objection to the competence finding but never obtained an expert opinion regarding Hayes’ sanity at the time of the attack. On the first day of trial, defense counsel withdrew the insanity defense, allegedly at Hayes' request. Defense counsel did not call witnesses but attempted to present a misidentification defense through cross-examination. At sentencing, new defense counsel presented extensive evidence of Hayes’ mental illnesses. The court called Hayes “mentally disturbed” but sentenced him to life imprisonment.Hayes argued that trial counsel was ineffective for abandoning the insanity defense. The Eleventh Circuit reversed a grant of federal habeas relief. To establish prejudice, Hayes must show “that there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different. The district court instead relied on a prejudice test that was rejected by the Supreme Court. Under the clear and convincing standard required by Florida law, Hayes cannot show a reasonable probability that his insanity defense would have been successful if presented to the jury View "Hayes v. Secretary, Florida Department of Corrections" on Justia Law

After Jeffrey West died shortly after he was released from the prison where he was being held as a pre-trial detainee, West's estate filed suit under federal and Alabama law against Escambia County and the Escambia County Sheriff, as well as multiple fictitious defendants, initially identified only as prison guards, medical professionals, doctors, and nurses. In this case, West had a staph infection, and after inconsistent medical attention that did not address his underlying symptoms, he died from complications related to the infection. The district court ultimately entered an order pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(ii) and dismissed all claims with prejudice. After the Estate moved to reopen and the district court agreed, the district court found that it had jurisdiction over the Estate's claims because it could reopen the case under Federal Rule of Civil Procedure 60(a) but granted summary judgment to defendants because the Estate's claims were time-barred.The Eleventh Circuit vacated the district court's order purporting to reopen the case because the parties' filing of the stipulation of dismissal left the district court without jurisdiction over the Estate's claims pursuant to Rule 41(a)(1)(A)(ii). Furthermore, the district court could not reopen the case under Rule 60(a). View "Estate of Jeffrey West v. DeFrancisco" on Justia Law

Property owners filed suit after the Town of Redington Beach passed an ordinance that granted the public certain access to the dry sand beaches. After the lawsuit was filed, Plaintiff Fields was asked to resign from her position on the Board of Adjustment (which reviews requests for variances from the Town's zoning code), because she had filed this suit against the Town.The Eleventh Circuit vacated and remanded the district court's grant of summary judgment to the property owners on their claims that the ordinance violated Florida law and constituted an unlawful taking. The court concluded that the district court erred in declaring the ordinance void under Florida Statute 163.035; the district court erred in granting summary judgment to the property owners on the Town's customary use defense; and the district court erred in finding a facial and an as-applied taking. The court also vacated and remanded the district court's grant of summary judgment to Plaintiff Fields on the First Amendment retaliation claim. View "Buending v. Town of Redington Beach" on Justia Law

Coats, then a convicted felon, was arrested after making several (recorded) controlled drug sales to a confidential informant (CI). Coats was housed at the Wilkinson County jail, where the CI was also in custody. Coats gained access to the CI and punched him. That incident resulted in additional state charges for battery and influencing a witness, to which he pleaded guilty.Coats then pled guilty as a felon in possession of a firearm, 18 U.S.C. 922(g)(1). The district court sentenced Coats to serve 235 months' imprisonment under the Armed Career Criminal Act (ACCA), which applies when a defendant who is convicted under section 922(g) has three prior convictions for a “serious drug offense” or a “violent felony.” Coats had a 2003 Georgia burglary conviction, which the court determined was a violent felony under ACCA. The court denied an acceptance-of-responsibility reduction to his sentencing range, citing his obstructive conduct preceding his guilty plea.The Eleventh Circuit affirmed. Any Rehaif error was nonprejudicial; Coats was not informed of section922(g)’s essential "knowledge" requirement, but he made no attempt to show that he would not have pled guilty but for that error. Of the 12 criminal convictions identified in his PSR, at least four were for felonies. Coats did not dispute the PSR’s description of his criminal history. The burglary conviction qualifies as an ACCA violent felony and the district court did not clearly err in refusing to award an acceptance-of-responsibility reduction. View "United States v. Coats" on Justia Law

Plaintiffs, owners and operators of greyhound-racing businesses, filed suit against the Florida Attorney General, seeking a declaration that a newly enacted state law prohibiting gambling on greyhound racing is unlawful and an injunction to prevent her from enforcing it. The district court dismissed the complaint without prejudice based on lack of standing.The Eleventh Circuit affirmed the district court's dismissal of the complaint, holding that plaintiff's alleged injuries are not traceable to any conduct of the Attorney General—either in enforcing or threatening to enforce the law or otherwise—and that plaintiffs' injuries would not be redressable by relief from this court. Therefore, plaintiffs lack Article III standing to bring their claims against the Florida Attorney General. View "Support Working Animals, Inc. v. Governor of Florida" on Justia Law

Plaintiff filed suit against his employer, the Sheriff of Broward County, under 42 U.S.C. 1983 for declaratory and injunctive relief, alleging that the Sheriff retaliated against him for exercising his First Amendment rights by suspending him with pay pending an investigation into his conduct.The Eleventh Circuit affirmed the district court's dismissal under Federal Rule of Civil Procedure 12(b)(6), because plaintiff failed to allege that he suffered an adverse employment action. In this case, plaintiff filed suit against the Sheriff only five days after he was suspended with pay in accordance with the governing collective bargaining agreement. The court agreed with the district court that a five-day suspension with pay does not constitute adverse action for purposes of a First Amendment retaliation claim. The court explained that such a temporally-limited suspension pending an investigation into alleged misconduct would not deter a reasonable person from exercising his First Amendment rights. View "Bell v. Sheriff of Broward County" on Justia Law

The Eleventh Circuit affirmed the district court's dismissal of Coral Ridge's complaint alleging a defamation claim against SPLC and a religious discrimination claim against Amazon. Coral Ridge alleged that SPLC is an Alabama-based nonprofit organization that publishes a "Hate Map,"—a list of entities the organization has characterized as hate groups—on its website. After Coral Ridge applied to be an eligible charity for the AmazonSmile program, Amazon denied its application because Coral Ridge is listed on the Hate Map as being anti-LGBTQ.The court found that Coral Ridge has not adequately alleged a state law defamation claim and that its proposed interpretation of Title II would violate the First Amendment. The court concluded that the district court correctly dismissed the defamation claim on the ground that Coral Ridge did not sufficiently plead actual malice. The court explained that Coral Ridge did not sufficiently plead facts that give rise to a reasonable inference that SPLC actually entertained serious doubts as to the veracity of its hate group definition and that definition's application to Coral Ridge, or that SPLC was highly aware that the definition and its application was probably false. The court also concluded that the district court correctly found that Coral Ridge's interpretation of Title II would violate the First Amendment by essentially forcing Amazon to donate to organizations it does not support. In this case, Coral Ridge's proposed interpretation of Title II would infringe on Amazon's First Amendment right to engage in expressive conduct and would not further Title II's purpose. View "Coral Ridge Ministries Media, Inc. v. Amazon.com, Inc." on Justia Law

The Eleventh Circuit affirmed the district court's denial of a petition for writ of habeas corpus under 28 U.S.C. 2254 brought by petitioner, alleging that the district court erred when it held that he was not prejudiced by his attorney's failure to object to the introduction of hearsay evidence and it erred when it denied his Confrontation Clause claim.The court agreed with the district court that the conclusion of the Rule 3.850 state court that petitioner could not show prejudice under the Strickland standard was neither an unreasonable application of Supreme Court precedent nor an unreasonable determination of the facts. Undertaking the section 2254(d)(2) inquiry first, and applying that deferential standard of review, the court cannot conclude that the Rule 3.850 court's statement that the witness identified petitioner as the perpetrator was an unreasonable determination of fact in light of the evidence presented in state court. In regard to the Confrontation Clause claim, the court could not conclude that petitioner has met his burden under Harrington v. Richter, 562 U.S. 86, 103, 135 S. Ct. 770, 786-87 (2011), to show that there was no reasonable basis for the state court to deny relief. Finally, the court rejected claims of cumulative error, because the court could not conclude that petitioner can satisfy his burden of avoiding the preemptive effect of the state court decisions and of establishing prejudice. View "Tarleton v. Secretary, Florida Department of Corrections" on Justia Law

The Eleventh Circuit held that sexual harassment—both hostile housing environment and quid pro quo sexual harassment—is actionable under the Fair Housing Act of 1968, provided the plaintiff demonstrates that she would not have been harassed but for her sex.In this case, plaintiff filed suit against the property manager and the property's owner, alleging sexual harassment claims under the Act and state law. The district court found no guidance from the court on this question and therefore dismissed the complaint based on the ground that plaintiff's claims were not actionable under the Act. The court vacated the district court's order dismissing plaintiff's complaint and remanded for reconsideration. View "Fox v. Gaines" on Justia Law

Spencer sued Sheriff Benison under 42 U.S.C. 1983, alleging that Benison violated his Fifth and Fourteenth Amendment rights by ordering him to remove cones and vehicles that were preventing Spencer’s neighbor from completing construction that Spencer claimed encroached on his property. The district court found that Benison acted outside the scope of his discretionary authority and was not entitled to qualified immunity on Spencer’s individual capacity claims and that Spencer had presented adequate evidence of a constitutional violation to sustain his section 1983 claims against Benison in both his individual and official capacities.The Eleventh Circuit reversed. Benison was acting within the scope of his discretionary authority when he ordered Spencer to remove the cones and vehicles. It was a legitimate job-related function for Benison, an Alabama sheriff, to seek the removal of cones and vehicles for the purposes of achieving public safety, given that traffic was backing up and customers were unable to access a business. Benison properly carried out his duties by verbally commanding Spencer to remove the cones and vehicles and by threatening arrest should he fail to comply. Spencer failed to present adequate evidence of a constitutional violation; he did not demonstrate that Benison’s actions caused him to be deprived of a constitutionally-protected property interest. View "Spencer v. Benison" on Justia Law