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

Plaintiff, an Alabama prisoner, brought this 42 U.S.C. Sec. 1983 action alleging long delays in his receipt of treatment for hernias and for post-surgery complications. In his pro se third amended complaint, Plaintiff asserted claims of deliberate indifference to his serious medical needs against: (1) Wexford Health Sources, Inc. (“Wexford”), a private contractor that provides health care services for Alabama inmates; (2) Kay Ivey, the Governor of Alabama; and (3) Jefferson Dunn, the Commissioner of the Alabama Department of Corrections.The district court (1) granted summary judgment in favor of Wexford and (2) dismissed Roy’s complaint against Governor Ivey and Commissioner Dunn for failure to state a claim.The Eleventh Circuit affirmed, finding that only one of several statements from other inmates that Plaintiff presented satisfied the requirements of 28 U.S.C. Sec. 1746 because the other statements were only presented as "affidavits" and did not mention the statement was “true and correct” and was made “under penalty of perjury." Considering Plaintiff's remaining evidence, the Eleventh Circuit held that the district court did not err in entering judgment in favor of Defendants. View "Larry Roy v. Kay Ivy, et al." on Justia Law

Plaintiffs (the Estate) appealed the district court’s grant of summary judgment for the named Defendants. This appeal stems from the circumstances surrounding Plaintiff’s son's detention and death at the Charlotte County Jail.  The Estate brought a seven-count complaint against the named Defendants. The district court granted each of the summary judgment motions in full, finding that the Estate failed to present evidence sufficient to raise a genuine issue of material fact on any of the claims, and entered final judgment for the Defendants.   The Eleventh Circuit affirmed the grant of summary judgment for the Sherriff of Charlotte County, the jail’s health care provider, and the jail’s medical personnel. The court also affirmed the grant of summary judgment for the jail’s corrections officers. The court agreed with the district court’s conclusion that the Estate failed to carry its burden of establishing a reasonable dispute of material fact regarding whether either the prison or the Sheriff advanced an unconstitutional policy or custom. Specifically, the district court found that Ireland’s Estate presented “no evidence” of an unconstitutional policy or custom and, at most, that the  Estate pointed to isolated incidents by the prison and the Sherriff.   Further, because there is no evidence in the record from which the court can infer that the officers were aware of the man’s need for medical aid at any time during the encounter before he ultimately lost consciousness, the deliberate indifference to medical treatment claims against the officers fail and summary judgment in their favor was proper. View "Thomas B. Ireland v. Bill Prummell, et al." on Justia Law

Representative Marjorie Taylor Greene, a member of the U.S. House of Representatives for Georgia’s 14th Congressional District, appeals the district court’s denial of her Motion for Preliminary Injunctive Relief. In her motion, Rep. Greene asked the district court to enjoin the state court’s application of O.C.G.A. Section 21-2-5 (“Challenge Statute”) against her to prevent her from being disqualified as a candidate for Congress under Section 3 of the Fourteenth Amendment to the United States Constitution.   The Eleventh Circuit remanded the case to the district court with instructions to dismiss the case as moot. The court explained that Rep. Greene sought to enjoin the application of the Challenge Statute against her in the state proceedings to prevent her from being disqualified as a candidate for Congress under Section 3 of the Fourteenth Amendment. However, the state proceedings under the Challenge Statute have concluded, and Rep. Greene has prevailed at each stage: the ALJ ruled in Rep. Greene’s favor, Secretary Raffensperger adopted the ALJ’s conclusions, the Superior Court of Fulton County affirmed the Secretary’s decision, and the Supreme Court of Georgia denied the Challengers’ application for discretionary review. Ultimately, Rep. Greene was not disqualified from being a candidate for Congress and is presently on the ballot for the upcoming election. Accordingly, the court no longer has the ability to accord Rep. Greene meaningful relief. Therefore the court held that the case is moot. View "Marjorie Taylor Greene v. Secretary of State for the State of Georgia, et al" on Justia Law

After a series of prolonged airport security screenings, Plaintiff filed Bivens claims against the Customs and Border Protection officers who detained him. The district court found that the officers had qualified immunity and dismissed the complaint. Plaintiff then filed a new complaint, under the Federal Tort Claims Act. The district court dismissed the new complaint for failure to state a claim, and Plaintiff appealed.The Eleventh Circuit affirmed the dismissal of Plaintiff's claims on grounds of collateral estoppel. Applying the four elements of collateral estoppel from Miller’s Ale House, Inc. v. Boynton Carolina Ale House, LLC, 702 F.3d 1312, 1318 (11th Cir. 2012), the court held that Plainitff's claims against the federal officers were barred due to the determinations made in the prior Bivens action. View "Daniel Kordash v. USA" on Justia Law

Over the past 25 years, Florida lawmakers have amended the state's sex-offender registration law dozens of times, making them increasingly more burdensome. Following the state's 2018 amendments to the law, Plaintiffs, a group of men who were subject to the law based on convictions occurring before the amendment, challenged the constitutionality of the law. Finding that Plaintiffs' injuries all accrued in 2018, the district court dismissed all of Plaintiffs' claims as untimely under the applicable four-year statute of limitations.The Eleventh Circuit reversed in part. Reviewing each of Plaintiffs' claims individually, the court found that while Plaintiff's injuries originated in 2018; they were ongoing. Thus, applying the continuing violation doctrine, the court reversed the district court's holding on several of Plaintiffs' claims, dismissing the remaining claims as untimely. View "Jane Doe, et al. v. Richard L. Swearingen" on Justia Law

Norwegian Cruise Line Holdings Ltd., a corporation headquartered in Florida, operates cruise ships that travel around the world. Norwegian requires everyone on board its ships to be vaccinated against COVID-19. To enforce that policy, Norwegian requires its customers to provide proof of vaccination. Florida sought to protect its residents from that kind of discrimination by enacting a statute that prohibits businesses from “requiring patrons or customers to provide any documentation certifying COVID-19 vaccination or post-infection recovery to gain access to, entry upon, or service from the business operations in Florida.” Norwegian sued Florida’s Surgeon General and moved for a preliminary injunction. The district court entered a preliminary injunction on the grounds that the statute likely violates Norwegian’s right to speak freely.The Eleventh Circuit vacated the preliminary injunction. The court explained that Florida’s statute is a regulation of economic conduct that only incidentally burdens speech, which does not implicate the First Amendment. And its burdens on interstate commerce do not exceed the benefits of furthering Florida’s substantial interests in protecting its residents from discrimination and invasions of privacy. View "Norwegian Cruise Line Holdings Ltd, et al. v. State Surgeon General" on Justia Law

After the representative from Georgia’s Sixth Congressional District was appointed to serve as a cabinet secretary, the State held an out-of-cycle election to fill the seat. Plaintiffs, The Coalition for Good Governance did not trust the results. It organized several lawsuits targeting Georgia elections, including the one here: an action contending that the “precise outcome” of the runoff for the Sixth District seat was unknowable because the State’s electronic voting system was vulnerable to hacking. The Coalition (along with several individual plaintiffs) asked for a declaration that the runoff election was void and for an injunction against the system’s future use. Georgia began using new machines allowing voters to select their choices electronically.   Plaintiffs amended their complaint and moved to enjoin the use of the new election equipment. The district court entered its partial relief, and the Eleventh Circuit stayed the district court’s judgment. The Eleventh Circuit vacated the district court’s preliminary injunction on the state’s paper backup check-in list, as well as its related directives on provisional and emergency ballots, and dismissed the appeal with respect to the scanner order.   The court explained that the Coalition has not demonstrated a severe burden on the right to vote attributable to the State’s print date for the paper backup. The district court erred in treating that print date as such and abused its discretion when it reviewed the State’s backup practices under strict scrutiny. The court wrote that federal courts must resist the temptation to step into the role of elected representatives. View "Donna Curling, et al. v. Brad Raffensperger, et al." on Justia Law

Petitioner was convicted by a Georgia jury of kidnapping, robbery, gang rape, and murder. The jury recommended that Petitioner be sentenced to death for his crimes. Having exhausted his state post-conviction remedies, Petitioner filed a federal habeas corpus petition, arguing, as relevant here, that his trial counsel rendered him constitutionally ineffective assistance in connection with the sentencing phase of his trial. The district court denied relief, but a panel of the Eleventh Circuit reversed and vacated Petitioner’s death sentence, holding that the state court’s rejection of his ineffective-assistance-of-counsel claim was based on an unreasonable determination of the facts and involved an unreasonable application of clearly established federal law.   The Eleventh Circuit granted rehearing en banc to decide whether the state court’s decision that Petitioner is not entitled to relief on his ineffective assistance claim warrants deference under the Antiterrorism and Effective Death Penalty Act (AEDPA). The court affirmed the district court’s denial of Petitioner’s petition and remanded it to the panel. The court held that the state court reasonably concluded that Petitioner was not prejudiced by any of his counsel’s alleged deficiencies in connection with his sentencing proceeding.   The court explained that while Petitioner argues that the background evidence that Mostiler should have presented parallels the evidence in Williams v. Taylor, 529 U.S. 362 (2000), and Rompilla v. Beard, 545 U.S. 374 (2005), those cases “offer no guidance with respect to whether a state court has unreasonably determined that prejudice is lacking” because the Supreme Court “did not apply AEDPA deference to the question of prejudice in those cases.” View "Willie James Pye v. Warden, Georgia Diagnostic Prison" on Justia Law

Plaintiff s required to register as a sex offender under the Alabama Sex Offender Registration and Community Notification Act (“ASORCNA” or the “Act”). Plaintiff sued the Alabama Attorney General and others, claiming that some provisions of ASORCNA impose retroactive punishment in violation of the Constitution’s Ex Post Facto Clause. After a bench trial, the district court entered judgment against Plaintiff, concluding that the retroactive application of these provisions did not amount to punishment.   The Eleventh Circuit affirmed in part and vacated and remanded in part. The court vacated the district court’s judgment insofar as it involves Plaintiff’s claims that it is unconstitutional to apply retroactively the following provisions of the ASORCNA, and remanded with instructions that it dismiss those claims as moot: (1) the identification-labeling requirement and (2) the dual registration requirements for homeless registrants and for registrants providing travel notification.   The court affirmed the district court’s judgment insofar as it rejects Plaintiff’s claims that it is unconstitutional to apply retroactively the following provisions of ASORCNA: (1) the residency and employment restrictions, (2) the homeless registration requirement, (3) the travel notification requirement, and (4) the community notification requirement. View "Michael A. McGuire v. Steven T. Marshall, et al" on Justia Law

In Plaintiff’s malicious prosecution claim against Defendant, a detective with the Albany Police Department, the Eleventh Circuit previously vacated an order dismissing Plaintiff’s complaint for failure to allege a favorable termination on a charge of felony murder. Plaintiff appealed the summary judgment in favor of Defendant based on qualified immunity. The district court ruled that, even though Defendant’s affidavit was insufficient to provide probable cause to support the warrant to arrest Plaintiff, the detective had at least arguable probable cause to arrest Plaintiff.   The Eleventh Circuit again vacated the order granting summary judgment in the detective’s favor and remanded. The court concluded that because Plaintiff established that the legal process underlying his seizure was constitutionally infirm and it would not have been otherwise justified, the detective does not enjoy immunity from suit. The court explained that under longstanding Supreme Court precedent, an officer must provide particular information to support an arrest warrant. Here, no “reasonably competent officer” could have concluded that a warrant should issue based on the glaring deficiencies in the affidavit. As a result, the unlawfulness of the detective’s conduct was clearly established when he acted and he was not entitled to qualified immunity. View "Demetrius Rashard Luke v. Jameel H. Gulley" on Justia Law