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

Several individuals affiliated with an organization headquartered in Florida, which advocates for the rights of African people worldwide, developed a close relationship with a Russian citizen who directed a Russian government-backed group. Over the course of several years, this Russian contact funded trips to Russia for organization leaders, sponsored events, and directed them to produce and disseminate pro-Russian statements and media. These individuals participated in activities at the direction of the Russian contact, including authoring petitions, organizing demonstrations, publishing statements, recording videos, and protesting at the request of their Russian counterpart. None of them notified the U.S. Attorney General as required by law for acting as agents of a foreign government.A federal grand jury indicted three organization members and one former member for acting as unregistered agents of a foreign government under 18 U.S.C. § 951(a), and for conspiracy to do so under 18 U.S.C. § 371. After a jury trial in the United States District Court for the Middle District of Florida, the defendants were found guilty of conspiracy but not of the substantive offense. The district court sentenced the former member to 60 months’ probation and the other three to 36 months’ probation. The defendants raised several arguments on appeal, including claims that the statute was unconstitutional as applied, that the evidence was insufficient, that evidentiary and jury instruction errors occurred, and that there was prosecutorial misconduct.The United States Court of Appeals for the Eleventh Circuit held that 18 U.S.C. §§ 951 and 371 are constitutional as applied, as they are content-neutral and survive intermediate scrutiny. The Court found sufficient evidence to support the conspiracy convictions, ruled that the district court did not abuse its discretion regarding jury instructions or evidentiary rulings, and found no prosecutorial misconduct. The convictions were affirmed. View "USA v. Romain" on Justia Law

A restaurant in Florida that hosts drag performances challenged the constitutionality of a state law known as the Protection of Children Act. The Act makes it a misdemeanor to knowingly admit a child to an “adult live performance,” defined as shows depicting nudity, sexual conduct, or lewd conduct, and meeting additional criteria based on prurient appeal, offensiveness to community standards for the age of the child present, and lack of serious value for that age. The restaurant argued that the Act’s use of the word “lewd” and its age-variable standards rendered the law unconstitutionally vague and overbroad, alleging harm to its business and chilling of its performances.The United States District Court for the Middle District of Florida granted a preliminary injunction, finding the Act unlikely to survive strict scrutiny and to be unconstitutionally vague and overbroad. The injunction barred the Secretary of the Florida Department of Business and Professional Regulation from enforcing the Act against anyone in the state. This decision was affirmed by a divided panel of the United States Court of Appeals for the Eleventh Circuit, but the full court granted rehearing en banc, stayed the injunction as to nonparties, and requested briefing on the scope and merits of the case.The United States Court of Appeals for the Eleventh Circuit, on en banc review, vacated the preliminary injunction in its entirety. The court held that the district court lacked authority to issue a universal injunction barring enforcement of the Act statewide, as such relief exceeds a federal court’s equitable power. Furthermore, the court found the Act’s language, as construed by Florida precedent, did not render it unconstitutionally vague or overbroad, and Hamburger Mary’s was not substantially likely to succeed on the merits. The matter was remanded for further proceedings consistent with this opinion. View "HM Florida-ORL, LLC v. Secretary of the Florida Department of Business" on Justia Law

A nonprofit organization in Florida, serving the Black community in St. Petersburg, applied twice for COVID-19 relief grants from funds distributed by Pinellas County. The group’s first grant application was initially approved, but after a newly seated Board member raised concerns about the group’s association with the “Uhuru Movement” and its perceived ties to Black empowerment and alleged antisemitic organizations, the Board revoked the grant. The group’s second application, for a backup generator, was later denied despite being highly ranked by an independent review foundation. The nonprofit alleged that similar grants were awarded to other organizations serving predominantly white communities for comparable purposes.After the denial, the nonprofit sued Pinellas County in the United States District Court for the Middle District of Florida, alleging violations of the First Amendment (retaliation for expressive association), the Equal Protection Clause (racial discrimination), and the Due Process Clause (lack of notice and opportunity to be heard). The district court dismissed all claims with prejudice, concluding there was no actionable First Amendment or equal protection violation and that the nonprofit did not have a property interest protected by due process.The United States Court of Appeals for the Eleventh Circuit reviewed the appeal. It held that the nonprofit plausibly alleged First Amendment retaliation, as the facts showed the county may have revoked and denied grants based on the group’s expressive association, and that the organization was entitled to full First Amendment protection as a grant applicant. The court also held that the nonprofit stated a plausible claim for intentional racial discrimination under the Equal Protection Clause. However, the panel affirmed dismissal of the due process claim, finding the nonprofit lacked a constitutionally protected property interest in the grants. The case was affirmed in part, reversed in part, and remanded for further proceedings. View "African People's Education and Defense Fund, Inc. v. Pinellas County" on Justia Law

Raymond Carrin was a federal detainee diagnosed with Hepatitis C who sought medical treatment while in custody at the Federal Detention Center in Tallahassee, Florida. Despite Carrin’s repeated requests and visible deterioration over more than a year—including emergency hospitalizations and symptoms consistent with advanced liver disease—medical staff did not provide him with the direct-acting antiviral treatment prescribed for his condition. The facility’s staff indicated that treatment would only begin once Carrin was transferred to his designated institution, a transfer that was delayed for various reasons. Carrin eventually died from hepatic cirrhosis without receiving the necessary medication. He did not file a formal grievance or seek relief under the prison’s Administrative Remedy Program (ARP) before his death.Carrin’s estate brought suit in the United States District Court for the Northern District of Florida against two federal prison officials, alleging violations of Carrin’s Fifth and Eighth Amendment rights and seeking damages under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 (1971). The district court initially denied the defendants’ motions to dismiss and for summary judgment. However, after the Eleventh Circuit’s decision in Johnson v. Terry, 119 F.4th 840 (11th Cir. 2024), the court granted judgment on the pleadings for the defendants, holding that the presence of the ARP constituted a special factor counseling against extending Bivens to these claims, and that Carrin’s case differed meaningfully from prior Supreme Court Bivens precedents.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s dismissal. The court held that both the Eighth and Fifth Amendment claims arose in a new context distinct from Carlson v. Green, 446 U.S. 14 (1980), and that the existence of the ARP—regardless of its adequacy or accessibility to the estate—was a special factor precluding the extension of Bivens remedies. View "Carrin v. Smiledge" on Justia Law

A man was investigated after Google and Yahoo flagged several of his email accounts for sending and storing what appeared to be child pornography. Both companies identified the user through information like a shared recovery phone number, birthdate, and selfies associated with the accounts. Yahoo manually reviewed and confirmed the images as child pornography before reporting them to the National Center for Missing and Exploited Children (NCMEC). Google used both human review and a hash-value matching protocol, whereby a file’s unique digital fingerprint was compared against a database of previously identified illegal images. One of the files in the defendant’s account matched the hash of a known child pornography image. Law enforcement, after receiving tips from NCMEC, conducted warrantless searches and confirmed the illicit nature of the files, leading to search warrants for the defendant’s residence and devices, which yielded more incriminating evidence.The United States District Court for the Middle District of Florida denied the defendant’s motions to suppress the evidence (arguing a Fourth Amendment violation), to dismiss one of the charges on double jeopardy grounds, and to exclude certain evidence. The court also rejected his arguments concerning the admissibility of defense evidence, the sufficiency of the evidence, and the jury instructions. The defendant was convicted by a jury on both distribution and possession charges and given an enhanced sentence based on a finding of a pattern of activity involving abuse or exploitation. His subsequent motions for psychological evaluation and sentencing continuance were also denied.On appeal, the United States Court of Appeals for the Eleventh Circuit held that Google’s use of hash-value matching constituted a valid private search under the Fourth Amendment, so the government’s warrantless review did not violate the defendant’s rights. The court also held that possession and distribution of child pornography are separate offenses for double jeopardy purposes. The appellate court affirmed all district court decisions except for the application of a pattern-of-activity sentencing enhancement, which it found improper; it vacated the sentence and remanded for resentencing. View "USA v. Brillhart" on Justia Law

Florida enacted a law prohibiting public university professors from endorsing or promoting certain ideas related to race, color, sex, and national origin in classroom instruction. The law, known as the Individual Freedom Act, identifies eight specific concepts that professors are barred from espousing, such as claims of moral superiority based on race or sex, inherent racism or oppression, and the idea that virtues like merit or colorblindness are themselves racist or sexist. The law allows professors to discuss these concepts in a neutral way, but not to advocate for them, and imposes severe penalties on both individual professors and universities for violations, including the loss of significant funding and potential termination of employment.Groups of professors and students from several Florida public universities filed lawsuits in the United States District Court for the Northern District of Florida, arguing that the Act violated their First Amendment rights by restricting viewpoint-based expression and was unconstitutionally vague. The district court granted preliminary injunctions in both cases, enjoining enforcement of the Act’s classroom restrictions against the plaintiffs, finding that at least one plaintiff had standing to challenge each prohibited concept. The court concluded the Act was likely unconstitutional as applied to public university professors.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s grant of a preliminary injunction. The Eleventh Circuit affirmed, holding that the Act’s restrictions amount to unconstitutional viewpoint discrimination in violation of the First Amendment. The court distinguished between permissible curricular control by universities and the broad, legislative ban imposed by the state’s political branches. It concluded that neither public-employee speech doctrine nor government speech doctrine justified the law’s suppression of disfavored ideas in the university classroom, and that the Act impermissibly infringed on academic freedom and open inquiry. The preliminary injunction was affirmed. View "Pernell v. Commissioner of the FL State Board of Education" on Justia Law

The dispute centers on whether the U.S. Department of Education may constitutionally rely on private educational accreditors in disbursing federal education funds. Under the Higher Education Act, colleges and universities must be accredited by a recognized accreditor for their students to be eligible for federal financial aid. Accreditors are private, voluntary organizations funded by the schools they accredit. Florida challenged this arrangement, alleging that it unconstitutionally delegates government power to private accreditors and violates both the Appointments Clause and the Spending Clause, claiming the accreditation requirement is an unascertainable condition for federal funds.The United States District Court for the Southern District of Florida reviewed the suit after Florida brought four claims: a private nondelegation doctrine challenge, an Appointments Clause challenge, a Spending Clause challenge, and a now-abandoned Administrative Procedure Act challenge. The federal government moved to dismiss, and the district court granted the motion. The district court found no unlawful delegation of government power, noted that Title IV funds are directed to students and not institutions, determined the accreditation requirement is unambiguous, and dismissed the Appointments Clause claim because accreditors do not determine eligibility for federal funds.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s dismissal de novo. The Court held that private accreditors do not exercise government authority that could violate the Vesting Clauses or the Appointments Clause. The Court also determined that the accreditation requirement is an ascertainable condition for federal funds, as it is a well-understood, longstanding practice and does not amount to an ambiguous or novel restriction. The Eleventh Circuit affirmed the district court’s dismissal of Florida’s suit. View "State of Florida v. Secretary, US Department of Education" 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

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