Articles Posted in Constitutional Law

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The Eleventh Circuit reversed the district court's dismissal of a complaint alleging that prison staff were deliberately indifferent to Blair Mitchell's serious medical needs in violation of his Eighth Amendment rights. The court held that, because he alleged a total lack of hepatitis treatment and the resulting onset of cirrhosis, Mr. Mitchell's complaint falls within the imminent-danger exception to the three strikes provision. In the alternative, because the district court did not comply with the procedural requirements necessary for imposing sanctions, it abused its discretion in dismissing Mr. Mitchell's complaint as a sanction. The court held that the complaint stated a claim for a deliberate indifference and there was no alternative basis on which to affirm the district court's dismissal. Therefore, the court remanded for further proceedings. View "Mitchell v. Warden" on Justia Law

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The Eleventh Circuit granted the State's motion to vacate the district court's certification of appealability and denied petitioner's stay of execution. Petitioner contended that his federal Due Process, Equal Protection, and Eighth Amendment rights were violated by the state court's failure to give retroactive effect to (1) Chapter 2017-1, a revised version of Florida Statute 921.141 (Florida's capital sentencing statute), and (2) the U.S. Supreme Court's decision in Hurst v. Florida. The court assumed without deciding that the current petition was not a second or successive one for purposes of 28 U.S.C. 2244(b) purposes, and held that the Florida Supreme Court's rejection of petitioner's constitutional-statutory claim was not contrary to, or an unreasonable application of, the holding of a Supreme Court decision. View "Lambrix v. Secretary, DOC" on Justia Law

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Plaintiff filed suit challenging the school board's policy governing public comment at its meetings. The Eleventh Circuit affirmed in part the district court's grant of a permanent injunction based on plaintiff's facial claims and enjoined the school board's public comment policy. The court held that it had appellate jurisdiction under 28 U.S.C. 1292(a)(1); plaintiff had standing to pursue his facial unbridled-discretion claim; the court vacated the district court's entry of summary judgment in favor of plaintiff on all claims other than the facial unbridled-discretion claim; the court held that the lack of a time limit for scheduling an initial meeting effectively granted the Superintendent unbridled discretion in contravention of the First Amendment; and the district court did not abuse its discretion in granting a permanent injunction. Because the court affirmed the district court's entry of summary judgment with respect to only the facial unbridled-discretion claim, the district court must alter the scope of the injunction on remand so that the injunction remedies only the harm created by the unconstitutional grant of unbridled discretion. The court affirmed the district court's denial of defendants' motion for extension of time and remanded. View "Barrett v. Walker County School District" on Justia Law

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After the Florida Supreme Court rejected petitioner's appeal from the denial of his guilt stage ineffective assistance claim on remand, he filed in federal district court a 28 U.S.C. 2254 petition for writ of habeas corpus. The Eleventh Circuit reversed the district court's grant of relief, holding that the district court relied on evidence that had not even been before the Florida Supreme Court in the first appeal from the denial of state collateral relief. In this case, petitioner did not raise a cumulative error claim, but the district court granted relief based on the cumulative effect or combined impact, of defense counsel's errors at the penalty phase and sentencing phase. The court held that the Florida Supreme Court did not unreasonably deny petitioner relief and the district court erred in granting habeas relief. View "Reaves v. Secretary, Florida DOC" on Justia Law

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The Eleventh Circuit reversed and remanded for an evidentiary hearing on an ineffective assistance of counsel claim involving the failure to challenge the quantity of methamphetamine attributed to petitioner. Because there was nothing in the trial record to contradict petitioner's allegations, at this stage of the proceedings, the court must accept that unusable liquids were counted in calculating the drug quantities that determined his mandatory minimum sentence and his advisory guidelines base offense level. The court also must accept that the liquids could not have produced any more than 2.4 grams of methamphetamine. The court held that counsel's failure to challenge the weight calculations amounted to deficient performance, particularly because the drug quantities were the basis of petitioner's mandatory minimum sentence and higher guidelines range. Furthermore, counsel's deficient performance prejudiced petitioner. View "Griffith v. United States" on Justia Law

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The Eleventh Circuit affirmed the dismissal of plaintiff's 42 U.S.C. 1983 action against five ADOC officials. Plaintiff alleged that the Alabama Sex Offender Registration and Community Notification Act (ASORCNA) and the ADOC classification manual violated his procedural due process, substantive due process, and ex post facto rights. The court held that the district court did not err in dismissing the procedural due process claim because he was convicted of a crime that constituted a sex offense under Alabama law at the time of his conviction and thus was not entitled to any additional process before being classified as a sex offender by prison officials. Furthermore, plaintiff failed to raise a cognizable substantive due process claim and ex post facto claim. View "Waldman v. Alabama Prison Commissioner" on Justia Law

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The money that a homosexual man paid to father children through in vitro fertilization—and in particular, to identify, retain, compensate, and care for the women who served as an egg donor and a gestational surrogate—was not spent "for the purpose of affecting" his body's reproductive "function" within the meaning of I.R.C. 213. In this case, the Eleventh Circuit held that it was constrained by I.R.C. 213's plain language where taxpayer's own function within the human reproductive process was to produce and provide healthy sperm, and because taxpayer was and remained capable of performing that function without the aid of IVF-related treatments, those treatments did not affect any function of his body and did not qualify as deductible "medical care" within the meaning of Section 213(a). The court also held that the IRS's disallowance of taxpayer's claimed deduction neither violated any fundamental right nor discriminated on the basis of any suspect (or quasi-suspect) characteristic. View "Morrissey v. United States" on Justia Law

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The Eleventh Circuit affirmed the district court's denial of habeas relief in a capital case where petitioner was convicted of three murders. The court held that the Florida Supreme Court's decision to exclude evidence related to an alternative perpetrator was neither contrary to nor an unreasonable application of clearly established law and the district court correctly denied relief. In this case, petitioner sought to admit into evidence testimony from a death row inmate who claimed to have received and then destroyed a letter in which the lynchpin witness who put him on death row allegedly confessed to the triple homicide petitioner was accused of. The court explained that it was not hard to understand why the trial court was skeptical of this story. The court also rejected petitioner's claim that counsel was ineffective during the penalty phase of trial. View "Pittman v. Secretary, FL DOC" on Justia Law

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Petitioner appealed the district court's denial of his 28 U.S.C. 2255 motion to vacate his 210-month sentence, arguing that he was entitled to resentencing pursuant to Johnson v. United States. The Eleventh Circuit affirmed the portion of the district court's judgment determining that petitioner's section 2255 motion was untimely because it raised only a claim pursuant to Descamps v. United States. The court held, however, that the district court's conclusion that petitioner's section 2255 motion also did not assert a Johnson claim was erroneous. On the merits of the Johnson claim, the court held that petitioner failed to prove that but for the residual clause he would have received a different sentence. Accordingly, the court affirmed the denial of the motion. View "Beeman v. United States" on Justia Law

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Plaintiff, a public school teacher, filed suit under 42 U.S.C. 1983, alleging that she was denied a promotion in violation of her First Amendment right to free speech and intimate association. The Fifth Circuit reversed the district court's denial of qualified immunity to the school superintendent, holding that the district court defined "clearly established law" at too high a level of generality. In this case, the case law that plaintiff relied upon was not particularized to the facts of the case, but rather it merely set out First Amendment principles at a high level of generality, it was not "apparent" that passing her over for promotion based on things her father said would violate her constitutional rights. Accordingly, the court remanded with instructions to grant the superintendent summary judgment based on qualified immunity as to the section 1983 claims against him. View "Gaines v. Wardynski" on Justia Law