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

Articles Posted in Constitutional Law
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Smith, a Muslim serving a life sentence, sued the Georgia Department of Corrections (GDOC) under the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. 2000cc, claiming that GDOC’s grooming policy, which prohibits inmates from growing facial hair over a half-inch in length, placed a substantial burden on his religious exercise. The district court rejected Smith’s RLUIPA claim, finding that “GDOC ha[d] offered logical and persuasive reasons to show that allowing untrimmed beards would be unmanageable for GDOC” and that “it is plausible that allowing a close security inmate like Smith an untrimmed beard could be dangerous for prison security.” Rather than rule in favor of GDOC, the district court fashioned a remedy that neither party had requested: it held that RLUIPA entitled Smith to grow a three-inch beard.The Eleventh Circuit vacated. The district court’s determination that it was reasonable for GDOC to conclude that allowing Smith to grow an untrimmed beard would be both unmanageable and dangerous was not clearly erroneous but its ruling requiring GDOC to allow Smith to grow a three-inch beard was improper and contrary to the Supreme Court’s 2015 holding, Holt v. Hobbs, that courts should consider only the plaintiff’s proposed alternatives in deciding whether there is an available less restrictive means for the government to further its compelling interests under RLUIPA. View "Smith v. Dozier" on Justia Law

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Beach Blitz sued the City and individuals, asserting that the City’s enactment and enforcement of ordinances regulating the sale of liquor and requiring businesses selling liquor to obtain licenses violated its substantive and procedural due process rights and that the City’s closure of its store one day after it met with a City attorney constituted retaliation for Beach Blitz’s protected First Amendment conduct. The district court dismissed the due process claims on the merits, without prejudice, and without leave to amend, and the First Amendment retaliatory claim on the merits, without prejudice but with leave to amend. Beach Blitz did not amend its that claim by the stated deadline. The district court found the City to be the prevailing party on all five claims, determined that each of them was “frivolous, unreasonable, or without foundation,” and awarded attorney fees for each.The Eleventh Circuit upheld the prevailing party determination because the City rebuffed Beach Blitz’s efforts to effect a material alteration in the legal relationship between the parties and affirmed frivolity determination concerning the procedural and substantive due process claims. The court vacated in part. There was sufficient support in precedent for Beach Blitz’s position that its retaliation claim was not so groundless on causation as to be frivolous. View "Beach Blitz Co. v. City of Miami Beach" on Justia Law

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DeJesus claims that in 2016, he was sexually assaulted by a prison official, Lewis. DeJesus had an attorney to represent him in court, but shortly before trial, the district court allowed counsel to withdraw. DeJesus was ill-prepared for trial because he had not been provided discovery materials. He was not given transcripts of the depositions taken in discovery until the morning of his trial and tried to read through them—for the first time—during the morning break. Ultimately DeJesus presented only his own testimony. The jury ruled in favor of the defendants.The Eleventh Circuit affirmed. When a prisoner proves that a prison official, acting under color of law and without legitimate penological justification, engages in a sexual act with the prisoner, and that act was for the official’s own sexual gratification, or for the purpose of humiliating, degrading, or demeaning the prisoner, the prison official’s conduct amounts to a sexual assault in violation of the Eighth Amendment. Here, the jurors should have been instructed that the only fact they had to find was whether the sexual assault occurred. On the record, however, DeJesus has not established that any errors made during the trial were likely to have resulted in an incorrect verdict. View "DeJesus v. Lewis" on Justia Law

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Plaintiff filed a 42 U.S.C. 1983 action against the sheriff's department and deputies involved in plaintiff's second arrest based on mistaken identity. Plaintiff alleged that defendants violated his Fourth and Fourteenth Amendment rights by falsely arresting him, overdetaining him, and failing to institute policies and train deputies to prevent these things from happening.The Eleventh Circuit affirmed the district court's rulings on the false arrest and Monell claims. The court concluded that the mistaken arrest of plaintiff on the wanted warrant of someone by the same name was reasonable within the bounds of the Fourth Amendment, and the deputies are entitled to qualified immunity on the false arrest claim. However, the court vacated the district court's dismissal of the overdetention claim because plaintiff sufficiently alleged facts establishing that defendants failed to take any action for three days and nights after they learned of information that raised significant doubts about defendant's identity. The court remanded for further proceedings. View "Sosa v. Martin County" on Justia Law

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Plaintiff filed suit against prison officials, alleging that the delay in treatment of the cut on his hand amounted to deliberate indifference to a serious medical need. Captain Lewis asserted a qualified immunity defense, which the district court denied.The Eleventh Circuit reversed the district court's denial of qualified immunity to Lewis, concluding that Aldridge v. Montgomery, 753 F.2d 970 (11th Cir. 1985) (per curiam), did not place an objectively reasonable officer in Lewis's position on notice that his conduct was unconstitutional. In this case, although plaintiff's cut was bleeding while he was in Lewis's custody, nothing in the record supports the inference that, during Lewis's brief interaction with plaintiff, plaintiff's cut bled so continuously or profusely that it rose to the level of the circumstances in Aldridge. View "Wade v. Lewis" on Justia Law

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Compensatory education is not an automatic remedy for a child-find violation under the Individuals with Disabilities Education Act (IDEA). Compensatory educational services are designed to counteract whatever educational setbacks a child encounters because of IDEA violations—to bring her back where she would have been but for those violations. At minimum, a parent must offer evidence that a procedural violation—like the child-find violation asserted here—caused a substantive educational harm, and that compensatory educational services can remedy that past harm.The Eleventh Circuit concluded that the district court was well within its "broad discretion and equitable authority" when it concluded that plaintiff had not shown that the school board's child-find violation resulted in educational deficits for the child that could be remediated with prospective compensatory relief. Furthermore, because the school began its special education referral process before plaintiff filed suit, she cannot show that she is entitled to attorney's fees. Accordingly, the court affirmed the district court's judgment. View "J.N. v. Jefferson County Board of Education" on Justia Law

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After Christian Redwine led officers from the Columbus Police Department on a high-speed chase across state lines before crashing into bushes on the side of a road, the driver of the police vehicle stopped behind and to the right of Redwine's car. Seconds after the officer stepped out to make an arrest, the car's reverse lights turned on, and the car started backing up. The officer fired 11 shots as the car passed near him, then he changed magazines and fired another 10 shots. The officer killed Redwine and injured two passengers. The district court granted the officer's motion for summary judgment based on qualified immunity as to the first round of shots but denied it as to the second.The Eleventh Circuit affirmed in part and reversed in part, concluding that the officer acted reasonably in firing both rounds of shots. The court concluded that the officer did not violate the Fourth Amendment and therefore he is entitled to qualified immunity. The court also concluded that the officer is entitled to state-law immunity and the police chief and the county are entitled to summary judgment for all claims against them as well. View "Tillis v. Brown" on Justia Law

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The Eleventh Circuit affirmed the district court's final judgment against plaintiff in an action brought against Koch for race and national origin discrimination under 42 U.S.C. 1981 and Title VII. In regard to plaintiff's Batson challenges, the court concluded that plaintiff failed to establish a prima facie case for Juror 9. Even assuming plaintiff established a prima facie case for Juror 32, Koch offered plausible non-discriminatory reasons for the strike; a company defending the decisions of a manager in a civil lawsuit would naturally not want a current union member and disgruntled worker's compensation claimant on the jury.The court rejected plaintiff's argument that Koch counsel's violation of the order in limine so prejudiced the jury that a new trial is warranted. Rather, considering the length of the trial, the shortness of the offending remarks, the context of the "prevailing party" comment as a response to a door plaintiff opened, and the curative instructions offered, the court could not find that the district court abused its discretion by denying plaintiff's motions for mistrial and a new trial. View "Vinson v. Koch Foods of Alabama, LLC" on Justia Law

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Plaintiff, a cheerleader at Kennesaw State University, filed suit alleging violations of 42 U.S.C. 1983 and 1985(3) after she and her teammates kneeled during the pre-game national anthem at one of the university's football games to protest police brutality against African Americans and to advance the cause of racial justice. Plaintiff claimed that there was a public and private conspiracy to deprive her and her teammates of their First Amendment rights. At issue on appeal is whether the district court erred by dismissing plaintiff's section 1985(3) claim against the sheriff.The Eleventh Circuit affirmed the district court's order dismissing plaintiff's claim against the sheriff, agreeing with the district court that plaintiff failed to surmount section 1985(3)'s class-based animus bar under the standard established by Supreme Court precedent. The court concluded that plaintiff's direct race-based theory cannot succeed because she failed to plead sufficient facts supporting it; plaintiff's indirect race-based claim failed to allege animus under Bray v. Alexandria Women's Health Clinic, 506 U.S. 263 (1993); and plaintiff's political class-based theory is also precluded by Bray. View "Dean v. Warren" on Justia Law

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The Eleventh Circuit affirmed the district court's grant of summary judgment in favor of defendants in an action alleging excessive force and municipal liability claims. Plaintiff claims that an officer stopped in front of his car, began shooting at him, and thus caused him to accelerate to drive away, and in doing so he hit another officer with his car.In regard to the excessive force claim, the court concluded that, although the officers violated plaintiff's Fourth Amendment rights when they shot him, the officers were entitled to qualified immunity because plaintiff has not demonstrated that his rights were clearly established at the time. In regard to the municipal liability claim, the court concluded that plaintiff has not demonstrated that the City failed to train the officers. Finally, the court concluded that there was no error in the district court's finding that the officers were entitled to immunity under Alabama law. View "Underwood v. City of Bessemer" on Justia Law