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

A group called Moms for Liberty, along with several individual members, filed a lawsuit against Brevard Public Schools and members of the Brevard County School Board. The plaintiffs claimed that their speech was unconstitutionally restricted at school board meetings. They argued that the Board's policies prohibiting "abusive," "personally directed," and "obscene" speech were unconstitutional. The plaintiffs sought declaratory and injunctive relief, as well as nominal damages.The United States District Court for the Middle District of Florida granted summary judgment in favor of the Board. The district court concluded that the plaintiffs lacked standing because they could not show an actual or imminent injury. It also held that the Board's policies did not objectively chill the plaintiffs' protected speech. Despite finding no standing, the district court went on to rule that the Board's policies were constitutional.The United States Court of Appeals for the Eleventh Circuit reviewed the case and reversed the district court's decision. The Eleventh Circuit found that the plaintiffs had standing to seek both retrospective and prospective relief. The court held that the Board's policy on "abusive" speech was unconstitutional because it was viewpoint-based and prohibited offensive speech. The policy on "personally directed" speech was also found to be unreasonable and inconsistently enforced, making it unconstitutional. Lastly, the court ruled that the prohibition on "obscene" speech was unreasonably applied to restrict protected speech, particularly when it involved reading from books available in school libraries. The case was remanded for further proceedings consistent with the Eleventh Circuit's opinion. View "Moms for Liberty v. Brevard Public Schools" on Justia Law

The case involves Bradley Rodriguez, who applied for disability benefits and supplemental security income, claiming a disability due to a traumatic brain injury, bipolar disorder, and depression. His application was denied by an Administrative Law Judge (ALJ) with the Social Security Administration (SSA). The Appeals Council also denied his request for review. Rodriguez then filed a federal lawsuit challenging the denial of benefits, raising several constitutional issues regarding the appointment of SSA ALJs, Appeals Council members, and the Commissioner of the SSA. He also argued that the ALJ’s decision was not supported by substantial evidence.The United States District Court for the Southern District of Florida granted summary judgment in favor of the Commissioner of the SSA. The court found that the ALJ was properly appointed, the Appeals Council members were not principal officers requiring presidential appointment and Senate confirmation, and the for-cause removal provision for the Commissioner was unconstitutional but severable. The court also held that Rodriguez was not entitled to a new hearing because he did not show that the unconstitutional removal provision caused him any harm. Additionally, the court determined that the ALJ’s decision was supported by substantial evidence.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court’s decision. The court held that the Commissioner had the statutory authority to appoint SSA ALJs and properly exercised that authority through ratification in July 2018. The Appeals Council members were deemed inferior officers, not principal officers, and thus did not require presidential appointment and Senate confirmation. The court also agreed that the for-cause removal provision for the Commissioner was unconstitutional but severable, and Rodriguez did not demonstrate entitlement to retrospective relief. Finally, the court found that the ALJ’s decision was supported by substantial evidence, including medical records and vocational expert testimony. View "Rodriguez v. Social Security Administration" on Justia Law

Transgender residents of Alabama sought to change the sex designation on their driver’s licenses without undergoing sex-change surgery, as required by Alabama’s Policy Order 63. This policy mandates that individuals wishing to change the sex on their driver’s license must submit either an amended birth certificate or a letter from the physician who performed the reassignment surgery. Plaintiffs argued that this policy violated the Equal Protection and Due Process Clauses of the Fourteenth Amendment, as well as the Free Speech Clause of the First Amendment.The United States District Court for the Middle District of Alabama ruled in favor of the plaintiffs, declaring Policy Order 63 unconstitutional under the Equal Protection Clause. The district court found that the policy classified individuals by sex and applied intermediate scrutiny, concluding that Alabama had not provided an adequate justification for the policy.The United States Court of Appeals for the Eleventh Circuit reviewed the case and reversed the district court’s decision. The appellate court held that Policy Order 63 does not impose a sex-based classification and therefore does not trigger heightened scrutiny. Instead, the policy was subject to rational basis review, which it survived. The court found that the policy rationally advances Alabama’s legitimate interest in maintaining consistent requirements for amending sex designations on state documents.The appellate court also rejected the plaintiffs’ due process and First Amendment claims. It held that the policy does not violate the right to informational privacy or the right to refuse medical treatment, as it does not force individuals to undergo surgery to obtain a driver’s license. Additionally, the court determined that the policy does not compel speech, as the information on driver’s licenses constitutes government speech, not private speech. Thus, the Eleventh Circuit reversed the district court’s judgment and upheld the constitutionality of Policy Order 63. View "Corbitt v. Secretary of the Alabama Law Enforcement Agency" on Justia Law

Andrew Butler III was convicted by a jury of knowingly and intentionally possessing five grams or more of methamphetamine with the intent to distribute. The district court sentenced him to 84 months of imprisonment followed by five years of supervised release. Butler appealed, arguing that the district court wrongly revoked his Sixth Amendment right to self-representation and that the evidence was insufficient to support the jury’s verdict.Initially, the district court appointed Assistant Federal Public Defender Elizabeth Vallejo to represent Butler, but he expressed dissatisfaction, leading to her replacement by Robert A. Morris. Butler continued to file pro se motions disparaging Morris, resulting in Morris’s replacement by Richard A. Greenberg. Butler then requested to represent himself, and after a Faretta hearing, the court allowed it, appointing Greenberg as standby counsel. However, Butler’s disruptive behavior, including refusing to attend hearings and threatening not to attend the trial, led the court to revoke his self-representation right and appoint Mutaqee Akbar as his counsel.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that the district court did not err in revoking Butler’s right to self-representation due to his repeated and serious obstructionist misconduct, which spanned months and disrupted the trial schedule. The court emphasized that the right to self-representation is not a license to disrupt court proceedings and that the district court had given Butler multiple warnings and opportunities to comply.Regarding the sufficiency of the evidence, the Eleventh Circuit found that the evidence presented at trial, including the methamphetamine found in the safe in Butler’s hotel room and his incriminating post-arrest recorded call, was sufficient to support the conviction. The court affirmed the district court’s judgment, upholding Butler’s conviction and sentence. View "United States v. Butler" on Justia Law

Amir Meshal, a professional truck driver, was stopped by Georgia State Police officers for a minor traffic infraction. During the stop, the officers discovered Meshal was on the FBI’s No Fly List. Despite instructions not to detain him based solely on this status, the officers handcuffed Meshal, placed him in a patrol car, and searched his truck. They questioned him about his religion and international travel while waiting for guidance from the FBI. After 91 minutes, the FBI cleared Meshal, and he was released with a warning citation for the traffic infraction.Meshal sued the officers in the United States District Court for the Southern District of Georgia, alleging violations of his Fourth Amendment rights due to the extended detention and the search of his truck. The officers moved to dismiss the complaint on qualified immunity grounds, arguing that Meshal failed to allege a violation of clearly established law. The district court denied the motion, finding that the complaint sufficiently alleged that the officers detained Meshal without arguable reasonable suspicion and searched his truck without arguable probable cause.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court agreed with the district court, holding that the officers were not entitled to qualified immunity at this stage. The court found that the officers lacked even arguable reasonable suspicion to justify prolonging the traffic stop beyond the time necessary to complete tasks related to the traffic infraction. Additionally, the court held that the search of Meshal’s truck was not supported by arguable probable cause. Therefore, the Eleventh Circuit affirmed the district court’s denial of qualified immunity. View "Meshal v. Commissioner, Georgia Department of Public Safety" on Justia Law

A member of the Church of Christ, Stephen Jarrard, participated in a county jail's volunteer ministry program but was later dismissed and denied reentry. He sued, claiming his dismissal violated his free speech rights under the First Amendment. The district court granted summary judgment against Jarrard, rejecting his claims.The United States District Court for the Northern District of Georgia initially reviewed the case. The court applied the Pickering test, typically used for government employees, and concluded that Jarrard's speech was not constitutionally protected. The court also found that even if his speech were protected, the law was not clearly established, granting qualified immunity to the jail officials.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court determined that the Pickering test was not appropriate for Jarrard, who was not a de facto government employee. Instead, the court applied the usual forum analysis and found that the jail officials engaged in viewpoint discrimination by excluding Jarrard based on his beliefs about baptism. The court also held that the jail's policies violated the First Amendment by giving officials unbridled discretion in evaluating volunteer applications. The court concluded that these actions could not survive strict scrutiny and that the law was clearly established, denying qualified immunity to the officials.The Eleventh Circuit reversed the district court's decision granting summary judgment and remanded the case for further proceedings on Jarrard's claims. View "Jarrard v. Sheriff of Polk County" on Justia Law

In August of 2020, Matthew Ostrander, a homeless fugitive, was arrested in Gainesville, Florida, for failing to register as a sex offender following a 2007 child pornography conviction. At the time of his arrest, Ostrander possessed four electronic devices, three of which contained 480 computer-generated images (CGI) of children involved in sexual activity. These images did not depict real children. Ostrander was charged with knowing possession of an obscene visual depiction of a minor engaging in sexually explicit conduct in violation of 18 U.S.C. § 1466A(b)(1), (d)(4).The United States District Court for the Northern District of Florida denied Ostrander's motion to dismiss the possession charge, ruling it was untimely and without merit. After a two-day trial, a jury found Ostrander guilty. Ostrander appealed, challenging the constitutionality of the statute and the sufficiency of the evidence and alleging prosecutorial misconduct.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that the statute was not facially unconstitutional, as it was neither overbroad nor vague. The court found that the statute's legitimate sweep outweighed any potential unconstitutional applications. The court also determined that the evidence was sufficient to sustain Ostrander's conviction, as a reasonable jury could find him guilty beyond a reasonable doubt based on the evidence presented. Finally, the court found no prosecutorial misconduct that would have affected the jury's verdict. The Eleventh Circuit affirmed Ostrander's conviction. View "U.S. v. Ostrander" on Justia Law

Lucious Boyd, a Florida prisoner sentenced to death for first-degree murder, sexual battery, and armed kidnapping, filed a federal habeas corpus petition under 28 U.S.C. § 2254 after a series of unsuccessful state collateral attacks. The district court held an evidentiary hearing on Boyd's claim that his Sixth and Fourteenth Amendment rights were violated due to a juror's undisclosed criminal history. The juror, Tonja Striggles, admitted her criminal history and disclosed additional information, but Boyd did not amend his petition to include these new disclosures. The district court denied Boyd's habeas petition on the merits and granted a certificate of appealability, leading Boyd to appeal.While his appeal was pending, Boyd moved in the district court to amend his habeas petition under Rule 15(a)(2) or, alternatively, to reopen his habeas proceedings under Rule 60(b)(6), citing new evidence from Striggles's testimony. The district court characterized Boyd's motion as a second or successive habeas petition, requiring preauthorization from the Eleventh Circuit Court of Appeals, which Boyd had not obtained. Consequently, the district court dismissed his motion.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's decision. The court held that once a district court has entered a final judgment on a habeas petition, any new filing seeking to relitigate the same claims is considered a second or successive petition under 28 U.S.C. § 2244(b). The court also noted that an appeal transfers jurisdiction to the appellate court, preventing the district court from amending the petition or reopening the case. Boyd's failure to obtain the necessary preauthorization from the appellate court meant that the district court correctly dismissed his motion. View "Boyd v. Secretary, Department of Corrections" on Justia Law

In 2007, Luis Fernandez and others conspired to rob a fictional cocaine stash house set up by law enforcement. They were arrested en route to the stash house with loaded firearms. Fernandez was indicted on multiple charges, including conspiracy and attempt to possess cocaine, conspiracy and attempt to commit Hobbs Act robbery, and carrying a firearm in furtherance of a crime of violence or drug trafficking crime under 18 U.S.C. § 924(c). The jury found him guilty of the Hobbs Act charges and the § 924(c) charge but acquitted him of the drug-related charges. He was sentenced to 360 months in prison.Fernandez's direct appeal was unsuccessful. In 2016, he filed a motion under 28 U.S.C. § 2255 to vacate his sentence, arguing that his § 924(c) conviction was invalid under Johnson v. United States, which invalidated the residual clause of the Armed Career Criminal Act (ACCA). The district court denied the motion as untimely and procedurally defaulted. In 2020, Fernandez sought to file a second § 2255 motion based on United States v. Davis, which invalidated § 924(c)’s residual clause. The Eleventh Circuit granted his motion, acknowledging that his conviction might be unconstitutional under Davis.The United States Court of Appeals for the Eleventh Circuit reviewed Fernandez's appeal. The court held that Fernandez could not prove that his § 924(c) conviction rested solely on the residual clause, as required by Beeman v. United States. The court noted that the jury's general verdict did not specify which predicate offense supported the § 924(c) conviction. Additionally, the court found that the legal landscape at the time of Fernandez's conviction did not clearly establish that only the residual clause could support his conviction. Consequently, the court affirmed the district court's denial of Fernandez's § 2255 motion. View "Fernandez v. United States" on Justia Law

Jesse Guardado confessed to the Walton County Sheriff’s Office that he had robbed and murdered Jackie Malone. He pleaded guilty without a plea agreement or counsel, and was later appointed counsel for the penalty phase. A jury recommended the death penalty, and the state trial court sentenced him to death. Guardado filed a habeas corpus petition, arguing ineffective assistance of counsel for failing to investigate and present mitigating evidence and for not challenging biased jurors.The Florida Supreme Court affirmed the trial court's decision, finding no prejudice from counsel's performance. The court determined that the additional mitigating evidence presented during postconviction proceedings was cumulative of the evidence presented at trial. It also found no actual bias in the jurors that Guardado claimed should have been challenged.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court found that the Florida Supreme Court unreasonably applied Strickland v. Washington by using a stricter "actual bias" standard instead of the reasonable probability standard for prejudice. However, upon de novo review, the Eleventh Circuit concluded that Guardado failed to show a substantial likelihood of a different outcome if the jurors had been challenged or if additional mitigating evidence had been presented. The court affirmed the denial of habeas relief. View "Guardado v. Secretary, Florida Department of Corrections" on Justia Law