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

Law enforcement officers obtained and executed a search warrant for “4279 Violet Circle, Lake Worth, FL,” believing it to be a single-family home occupied by the defendant. In reality, the property included a main residence and three efficiency apartments at the back, one of which was occupied by the defendant. These apartments had no separate addresses, mailboxes, or exterior markings. During the search, officers were directed by other residents to the defendant’s apartment, where they found firearms and drugs. The defendant was subsequently charged with multiple firearm and drug offenses.The defendant moved to suppress the evidence, arguing that the warrant was defective under the Fourth Amendment because it listed only the main address and not his specific apartment. The United States District Court for the Southern District of Florida held an evidentiary hearing, credited the testimony of the investigating officer, and found that the officers reasonably believed the property was a single-family home based on surveillance, property records, and the lack of distinguishing features for the apartments. The magistrate judge recommended denying the motion to suppress, and the district court adopted this recommendation. The defendant was found guilty after a stipulated-facts bench trial and sentenced to 144 months’ imprisonment.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the denial of the motion to suppress. The court held that the search warrant satisfied the Fourth Amendment’s particularity requirement because the officers reasonably believed, after a diligent investigation, that the property was a single-family home. The court found no evidence that the officers knew or should have known about the separate apartments before executing the warrant. The court affirmed the denial of the motion to suppress and remanded for correction of a clerical error in the judgment. View "United States v. Schmitz" on Justia Law

A white man, after a dinner in Palm Harbor, Florida, targeted a Black man, his girlfriend, and his four-year-old daughter as they drove on a county-administered public road. The defendant, whom the victims did not know, repeatedly attempted to run their car off the road, shouted racial slurs, and made threatening gestures. At a red light, he exited his vehicle and physically confronted the Black man, continuing his racial abuse. Witnesses and police confirmed the defendant’s aggressive and racially charged conduct, and the defendant made further racist statements to law enforcement after his arrest. The defendant’s ex-girlfriend testified that such behavior was typical for him.A grand jury in the United States District Court for the Middle District of Florida indicted the defendant on two counts of violating 18 U.S.C. § 245(b)(2)(B), which prohibits racially motivated interference with the use of public facilities. The defendant moved to dismiss the indictment, arguing that the statute exceeded Congress’s authority under the Thirteenth Amendment and the Commerce Clause, and that the indictment violated the Double Jeopardy Clause. The district court denied these motions. At trial, the court instructed the jury that to convict, it must find the defendant acted “because of” the victim’s use of the public road, applying a “but-for” causation standard. The jury found the defendant guilty on one count and not guilty on the other. The district court denied the defendant’s motions for acquittal and a new trial, and sentenced him to 24 months in prison.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that 18 U.S.C. § 245(b)(2)(B) is a constitutional exercise of Congress’s power under the Thirteenth Amendment, as Congress may rationally prohibit racially motivated violence interfering with public facilities as a badge or incident of slavery. The court also found no error in the jury instructions, the handling of jury questions, or the sufficiency of the evidence. The conviction was affirmed. View "United States v. Leahy" on Justia Law

A business operating a strip club featuring nude dancing and alcohol sales entered into a settlement agreement with DeKalb County, Georgia, in 2001, which was later amended in 2007. The amended agreement granted the club non-conforming status, allowing it to continue its business model for fifteen years, with the possibility of renewal, and required annual licensing fees. In 2013, the City of Chamblee annexed the area containing the club and subsequently adopted ordinances restricting adult entertainment establishments, including bans on alcohol sales, stricter food sales requirements for alcohol licenses, and earlier closing times. The City initially issued alcohol licenses to the club but later denied renewal, citing failure to meet new requirements and the club’s status as an adult establishment.The United States District Court for the Northern District of Georgia dismissed some of the club’s claims for lack of standing and granted summary judgment to the City on the remaining claims. The district court found that the club lacked standing to challenge certain ordinances as it was not an alcohol licensee, and that the City’s ordinances regulating adult entertainment and alcohol sales were constitutional under the secondary-effects doctrine, applying intermediate scrutiny. The court also determined there was no valid contract between the club and the City, rejecting the Contract Clause claims, and found no equal protection violation, as the club failed to identify a similarly situated comparator.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s rulings. The Eleventh Circuit held that the club lacked standing for equitable relief due to its permanent closure, but had standing for damages for a limited period. The court upheld the application of intermediate scrutiny to the ordinances, found no impairment of contract, and agreed that the club failed to establish an equal protection violation. The district court’s judgment in favor of the City was affirmed. View "WBY, Inc. v. City of Chamblee, Georgia" on Justia Law

The case centers on a Florida farm and its owner, who had supplied produce to a local school district for several years. In June 2020, the owner posted controversial statements on his personal Facebook page, describing the COVID-19 pandemic as a “hoax” and making disparaging remarks about the Black Lives Matter movement and George Floyd. The school district, concerned about food safety during the early, uncertain days of the pandemic, requested information about the farm’s COVID-19 protocols. The response provided protocols from a subsidiary, not the farm itself, which the district found inadequate. Shortly after, the superintendent terminated the farm’s contract, citing concerns about the farm’s approach to COVID-19 safety.The farm and its owner sued the school district and board members in the United States District Court for the Middle District of Florida, alleging First Amendment retaliation and raising state law claims. The district court granted summary judgment to the defendants, applying the Pickering balancing test (typically used for government employees and contractors) and finding that the school district’s interests in food safety outweighed the plaintiffs’ free speech rights. The court also granted qualified immunity to individual defendants and dismissed the state law claims without prejudice.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The Eleventh Circuit held that, although the owner’s speech addressed matters of public concern, the evidence showed the contract was terminated due to genuine food safety concerns, not as punishment for the owner’s views on COVID-19 or racial issues. The court found no genuine dispute of material fact regarding the school district’s motivation and concluded that the district’s interest in student safety justified its actions. The summary judgment in favor of the school district was affirmed. View "Oakes Farms Food & Distribution Services, LLC v. Adkins" on Justia Law

A man was arrested by city police officers in Rainsville, Alabama, after exhibiting erratic behavior and resisting arrest. The Chief of Police directed Officer White to transport the arrestee to the county jail in Fort Payne, which had better medical facilities. Upon arrival at the county jail, jailers became frustrated with the arrestee during booking and began to beat him. Officer White witnessed the beating from a few feet away but did not attempt to intervene or protest. The beating continued for several minutes after White left the room, resulting in significant injuries to the arrestee. The jailers involved were later criminally prosecuted and convicted for their conduct.The arrestee filed a lawsuit under 42 U.S.C. § 1983 against Officer White and others, alleging, among other claims, that White’s failure to intervene violated his Fourth Amendment rights. The United States District Court for the Northern District of Alabama granted summary judgment to the officers on the false arrest claim but denied summary judgment to White on the failure to intervene claim, rejecting his qualified immunity defense. White appealed the denial of qualified immunity.The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo. The court held that, under clearly established law as of March 2020, an arresting officer who delivers a helpless arrestee to jailers and witnesses those jailers immediately begin to beat the arrestee in his presence violates the Fourth Amendment if he remains silent and leaves the scene while the assault is ongoing. The court further held that the duty to intervene is not discharged by a phone call to a supervisor who is not in a position to stop the assault. The Eleventh Circuit affirmed the district court’s denial of summary judgment to Officer White on the failure to intervene claim. View "Nute v. White" on Justia Law

A Florida minister and licensed clinical Christian psychologist, who had provided court-mandated batterers’ intervention program (BIP) services for decades, sought certification from the Florida Department of Children and Families (DCF) to continue offering these services to individuals ordered by courts to attend BIPs following domestic violence convictions. The DCF denied his application because his curriculum incorporated a faith-based approach and addressed issues such as substance abuse and anger management, which conflicted with state regulations prohibiting faith-based ideology and requiring a specific psychoeducational model. The provider had previously operated without proper certification and had been denied certification in the past for similar reasons.After the DCF’s 2022 denial, the provider filed suit in the United States District Court for the Northern District of Florida, alleging that the regulation violated his rights under the Free Speech and Free Exercise Clauses of the First Amendment. The District Court granted summary judgment in favor of DCF, holding that court-ordered BIPs constitute government speech, and thus the state could set their content without implicating the First Amendment.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the District Court’s decision de novo. The Eleventh Circuit affirmed, holding that the curriculum and presentation of court-ordered BIPs are government speech. The court found that the state has historically used BIPs to communicate its own message, that participants would reasonably associate the program’s content with the government, and that the state exercises substantial control over the content. Because the programs are government speech, the provider’s Free Speech and Free Exercise claims could not proceed. The court also rejected the facial challenge to the regulation and affirmed the District Court’s judgment. View "Nussbaumer v. Secretary, Florida Dept of Children and Families" on Justia Law

A woman who had a long history of calling her local sheriff’s office—often to complain about gunfire she believed was coming from private property near her home—called both the non-emergency number and 911 on Thanksgiving Day 2018 to report gunshots. Dispatchers informed her that deputies had previously investigated and determined the gunfire was lawful and that no further response would be made. Despite these explanations, she persisted, escalating her complaint to a 911 call. She declined offers to speak with deputies and refused contact when a deputy came to her home. Based on her repeated calls and refusal to accept the dispatchers’ explanations, two sheriff’s office employees initiated an investigation and swore out an affidavit for her arrest under a Georgia statute prohibiting disruptive or harassing conduct during 911 calls. The local district attorney later dismissed the charge.The woman then filed a civil suit in the United States District Court for the Southern District of Georgia, alleging violations of her First and Fourth Amendment rights, including claims of retaliatory arrest and malicious prosecution. The district court denied qualified immunity to the two officers on the First Amendment retaliation and malicious prosecution claims, finding genuine disputes of material fact regarding probable cause and the officers’ conduct in seeking the arrest warrant.On appeal, the United States Court of Appeals for the Eleventh Circuit considered whether the officers were entitled to qualified immunity. The court held that the officers were entitled to rely on the collective knowledge of the sheriff’s office dispatchers, who were aware of the plaintiff’s history of similar calls and the lawful nature of the gunfire. The court concluded that, given this collective knowledge, the officers had at least arguable probable cause to seek the plaintiff’s arrest under the relevant Georgia statute. As a result, the Eleventh Circuit reversed the district court’s denial of qualified immunity. View "Prospero v. Sullivan" on Justia Law

A physician licensed in Florida worked at a weight management clinic, where he was responsible for maintaining a federal registration to dispense controlled substances. After a report of missing controlled substances at the clinic, local police and the Drug Enforcement Administration (DEA) began investigating. The investigation revealed that the physician had issued numerous prescriptions for controlled substances without proper documentation of a doctor-patient relationship, failed to maintain required records, did not properly report or store controlled substances, and dispensed medication in violation of labeling requirements. The physician claimed that another clinic employee had forged his signature on some prescriptions and denied personal wrongdoing.The DEA issued an Order to Show Cause, notifying the physician of its intent to revoke his registration and deny pending applications, citing violations of federal and state law. The physician submitted a Corrective Action Plan but did not request a hearing. The DEA Administrator reviewed the evidence, including expert testimony and the physician’s admissions, and found that the physician’s continued registration would be inconsistent with the public interest. The Administrator revoked the registration and denied all pending applications, emphasizing the physician’s failure to accept responsibility and the inadequacy of his proposed corrective measures.The United States Court of Appeals for the Eleventh Circuit reviewed the DEA’s final order under an abuse of discretion standard, deferring to the agency’s factual findings if supported by substantial evidence. The court held that the physician received adequate procedural due process, as he was given notice and an opportunity for a hearing, which he declined. The court also rejected the argument that the DEA was required to find knowing or intentional misconduct under Ruan v. United States, holding that such a mens rea requirement does not apply to administrative revocation proceedings under 21 U.S.C. § 824. The petition for review was denied. View "Ashraf v. Drug Enforcement Administration" on Justia Law

Two Florida residents who use medical marijuana in compliance with state law sought to purchase firearms but were denied after disclosing their marijuana use on a federal form. A third individual, a lawful gun owner, wished to participate in Florida’s medical marijuana program but refrained due to concerns about federal prosecution. All three, along with the Florida Commissioner of Agriculture, challenged the constitutionality of federal statutes and regulations that prohibit “unlawful users” of controlled substances—including marijuana—from possessing or purchasing firearms. The complaint did not allege that the plaintiffs had been convicted of any crimes or that their marijuana use rendered them dangerous.The United States District Court for the Northern District of Florida assumed the plaintiffs were protected by the Second Amendment but dismissed the complaint. The court applied the historical analysis required by District of Columbia v. Heller and New York State Rifle & Pistol Association v. Bruen, concluding that the federal prohibitions were consistent with the nation’s tradition of disarming individuals engaged in criminal conduct or deemed dangerous, such as felons, the mentally ill, or habitual drug users.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the case de novo. The court held that, at the motion to dismiss stage, the government failed to show that the plaintiffs—state-law-compliant medical marijuana users—were relevantly similar to either felons or dangerous individuals, the two historical analogues offered to justify the federal restrictions. The court emphasized that the complaint did not allege facts showing the plaintiffs were dangerous or had committed felonies. Accordingly, the Eleventh Circuit vacated the district court’s dismissal and remanded the case for further proceedings, holding that the plaintiffs had plausibly alleged a violation of their Second Amendment rights as applied to them. View "Florida Commissioner of Agriculture v. Attorney General of the United States" on Justia Law

A tenured English professor at a public university objected to the administration’s decision to resume in-person instruction during the Covid-19 pandemic. The professor, who had health concerns and was partially vaccinated, communicated his opposition by emailing students about his forced return to the classroom, attaching correspondence with his department chair, and using an unconventional email signature. The university responded by reassigning his courses, placing him on paid leave, and proposing a five-day suspension without pay, along with requirements for improved email professionalism. The professor then filed a lawsuit alleging violations of his First Amendment and procedural due process rights.The United States District Court for the Northern District of Florida dismissed the complaint. The court found that the professor’s email did not constitute protected speech under the First Amendment, as it was gratuitous information in a logistical message sent in his professional capacity. The court also rejected the procedural due process claim for failure to exhaust state-law remedies. The court’s dismissal order allowed the professor until July 3 to amend his complaint, instructing the clerk to enter judgment if no amendment was filed. The professor did not amend, and the clerk did not immediately enter judgment. On July 14, the court issued another order directing entry of judgment, which the clerk entered that day. The professor filed his notice of appeal on August 10.The United States Court of Appeals for the Eleventh Circuit reviewed whether the appeal was timely. Applying its precedent from Schuurman v. Motor Vessel Betty K V, the court held that the thirty-day appeal period began on the last day set for amending the complaint, not the later date when judgment was entered. Because the notice of appeal was filed more than thirty days after the amendment deadline, the court dismissed the appeal for lack of jurisdiction. View "Burt v. President of University of Florida" on Justia Law