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

In Georgia, in-person voters can vote on election day or during advance voting. Absentee voters, after applying for and receiving an absentee ballot, are responsible for returning their ballots directly to the county election office, depositing them into a ballot drop box, or mailing them to that office. The statute requires neither the state of Georgia nor county governments to cover the cost of postage for mailing ballots. Plaintiffs alleged that the Twenty-Fourth Amendment or the Equal Protection Clause required Georgia to pay for postage for voters who choose to return their absentee ballots by mail; by not covering the cost of postage, Georgia is imposing an unconstitutional “poll tax” or fee on some absentee voters.The Eleventh Circuit affirmed the dismissal of the suit. Requiring the payment of postage is not a “tax” or unconstitutional fee on voting. Georgia voters, without paying any money, have several options; even those voters who choose to mail in their absentee ballots buy postage from the U.S. Postal Service and the proceeds from postage sales are paid to USPS—not the state of Georgia— to account for the costs associated with delivering the mail. These voters are buying services from USPS. Georgia does not receive any money from those sales. View "Black Voters Matter Fund v. Secretary of State for the State of Georgia" on Justia Law

Troy Robinson's family filed suit under federal and state law after a traffic stop that resulted in Robinson's death. Robinson, a passenger in the stopped vehicle, fled the scene on foot, ran across a busy road and through a parking lot before attempting to scale an eight-foot wall. The pursuing officer fired his taser at Robinson while he was on top of the wall and the shock from the taser incapacitated Robinson, causing him to fall, break his neck, and die.The Eleventh Circuit concluded that the officer cannot be held liable for conducting the initial traffic stop or pursuing Robinson when he fled on foot. Therefore, the court reversed the district court's judgment as to these two issues. However, the court held that the officer's decision to tase Robinson at an elevated height violated Robinson's clearly established right to be free from excessive force. The court explained that the officer used deadly force to stop an unarmed man who was not suspected of committing a violent crime from fleeing on foot, and that Tennessee v. Garner, 471 U.S. 1 (1985), establishes that this level of force is excessive in that circumstance. Accordingly, the court affirmed the district court's denial of summary judgment on qualified immunity grounds to the officer and remanded so that plaintiffs' claims against the officer relating to the tasing may proceed to trial. View "Bradley v. Benton" on Justia Law

Mitchell was a Duval County Jail pretrial detainee. Detective Simpson told a jail official to “obtain,” “seize,” and “confiscate and review” all of Mitchell’s incoming and outgoing mail. A mail clerk, Perkins, delivered a letter from Mitchell’s attorney marked “Legal Mail” that had already been opened. When Perkins later asked Mitchell specific questions about his case, Mitchell concluded that she had read at least part of the letter. During the next year, Mitchell continued to experience issues with his mail. Perkins switched an outgoing letter to Mitchell’s family with another inmate’s letter. Sergeant Clark, the mailroom supervisor, tried to “intimidate” Mitchell, intercepting his grievances and warning him to stop filing complaints.Mitchell filed a pro se complaint alleging that Simpson, Perkins, and Clark, violated his constitutional rights. The district court denied the defendants’ motion to dismiss on qualified immunity grounds. The Eleventh Circuit affirmed, noting that: A simple rule has governed prison mail procedures in our Circuit for nearly 50 years: a prison official may not open an inmate’s properly marked legal mail outside of his presence. The defendants’ conduct violated Mitchell’s First Amendment right to free speech; it was clearly established that the officials’ conduct was unlawful. View "Mitchell v. Smith" on Justia Law

In 2002, Hayes, age 20, violently attacked his 60-year-old neighbor without provocation or apparent motive, causing her to lapse into a coma. Hayes was later seen burning items in his backyard. Clothing recovered from the burn pile contained the victim’s blood. Charged with attempted first-degree murder with a deadly weapon and armed trespassing, Hayes was found incompetent to proceed and transferred to a state mental health facility. After months of treatment, the psychology department and two court-appointed psychiatrists concluded that Hayes was competent to proceed Counsel filed a notice of intent to rely on an insanity defense and renewed his objection to the competence finding but never obtained an expert opinion regarding Hayes’ sanity at the time of the attack. On the first day of trial, defense counsel withdrew the insanity defense, allegedly at Hayes' request. Defense counsel did not call witnesses but attempted to present a misidentification defense through cross-examination. At sentencing, new defense counsel presented extensive evidence of Hayes’ mental illnesses. The court called Hayes “mentally disturbed” but sentenced him to life imprisonment.Hayes argued that trial counsel was ineffective for abandoning the insanity defense. The Eleventh Circuit reversed a grant of federal habeas relief. To establish prejudice, Hayes must show “that there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different. The district court instead relied on a prejudice test that was rejected by the Supreme Court. Under the clear and convincing standard required by Florida law, Hayes cannot show a reasonable probability that his insanity defense would have been successful if presented to the jury View "Hayes v. Secretary, Florida Department of Corrections" on Justia Law

After Jeffrey West died shortly after he was released from the prison where he was being held as a pre-trial detainee, West's estate filed suit under federal and Alabama law against Escambia County and the Escambia County Sheriff, as well as multiple fictitious defendants, initially identified only as prison guards, medical professionals, doctors, and nurses. In this case, West had a staph infection, and after inconsistent medical attention that did not address his underlying symptoms, he died from complications related to the infection. The district court ultimately entered an order pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(ii) and dismissed all claims with prejudice. After the Estate moved to reopen and the district court agreed, the district court found that it had jurisdiction over the Estate's claims because it could reopen the case under Federal Rule of Civil Procedure 60(a) but granted summary judgment to defendants because the Estate's claims were time-barred.The Eleventh Circuit vacated the district court's order purporting to reopen the case because the parties' filing of the stipulation of dismissal left the district court without jurisdiction over the Estate's claims pursuant to Rule 41(a)(1)(A)(ii). Furthermore, the district court could not reopen the case under Rule 60(a). View "Estate of Jeffrey West v. DeFrancisco" on Justia Law

Property owners filed suit after the Town of Redington Beach passed an ordinance that granted the public certain access to the dry sand beaches. After the lawsuit was filed, Plaintiff Fields was asked to resign from her position on the Board of Adjustment (which reviews requests for variances from the Town's zoning code), because she had filed this suit against the Town.The Eleventh Circuit vacated and remanded the district court's grant of summary judgment to the property owners on their claims that the ordinance violated Florida law and constituted an unlawful taking. The court concluded that the district court erred in declaring the ordinance void under Florida Statute 163.035; the district court erred in granting summary judgment to the property owners on the Town's customary use defense; and the district court erred in finding a facial and an as-applied taking. The court also vacated and remanded the district court's grant of summary judgment to Plaintiff Fields on the First Amendment retaliation claim. View "Buending v. Town of Redington Beach" on Justia Law

Coats, then a convicted felon, was arrested after making several (recorded) controlled drug sales to a confidential informant (CI). Coats was housed at the Wilkinson County jail, where the CI was also in custody. Coats gained access to the CI and punched him. That incident resulted in additional state charges for battery and influencing a witness, to which he pleaded guilty.Coats then pled guilty as a felon in possession of a firearm, 18 U.S.C. 922(g)(1). The district court sentenced Coats to serve 235 months' imprisonment under the Armed Career Criminal Act (ACCA), which applies when a defendant who is convicted under section 922(g) has three prior convictions for a “serious drug offense” or a “violent felony.” Coats had a 2003 Georgia burglary conviction, which the court determined was a violent felony under ACCA. The court denied an acceptance-of-responsibility reduction to his sentencing range, citing his obstructive conduct preceding his guilty plea.The Eleventh Circuit affirmed. Any Rehaif error was nonprejudicial; Coats was not informed of section922(g)’s essential "knowledge" requirement, but he made no attempt to show that he would not have pled guilty but for that error. Of the 12 criminal convictions identified in his PSR, at least four were for felonies. Coats did not dispute the PSR’s description of his criminal history. The burglary conviction qualifies as an ACCA violent felony and the district court did not clearly err in refusing to award an acceptance-of-responsibility reduction. View "United States v. Coats" on Justia Law

Bradshaw was a designated pilot examiner for the Federal Aviation Administration (FAA), with the authority to issue an applicant an airman certificate, 49 U.S.C. 44703(a). In 2018, the FAA discovered that Bradshaw had certified a pilot applicant without conducting a complete flight test and terminated Bradshaw’s designation. A three-member FAA appeal panel affirmed.The Eleventh Circuit denied a petition for review. The FAA did not fall short of its own requirements and did not violate Bradshaw’s constitutional right to due process. FAA-designated pilot examiners do not have a property or liberty interest in their designation. Bradshaw’s other constitutional claim—that the FAA violated his right to equal protection because other categories of FAA designees are afforded a hearing before their designation can be terminated—was also without merit. View "Bradshaw v. Federal Aviation Administration" on Justia Law

Plaintiff and two of his children filed a 30-count pro se complaint in federal district court asserting a wide variety of constitutional, statutory, and tort claims against 18 named defendants. The district court dismissed the entire complaint on Rooker-Feldman grounds.The Eleventh Circuit vacated the district court's dismissal of the complaint, concluding that the court's own review of the complaint shows that several of the claims plaintiffs raised do not fall within that doctrine's narrow bounds. The court clarified that Rooker-Feldman is a limited doctrine that applies only when litigants try to appeal state court losses in the lower federal courts. In this case, the district court erred by dismissing plaintiffs' complaint in one fell swoop without considering whether each individual claim sought "review and rejection" of a state court judgment. The court also concluded that the Rooker-Feldman doctrine does not apply to three federal claims plaintiffs raised before this court, seeking damages for issues collateral to a state court judgment rather than relief from that judgment itself. Accordingly, the court remanded for further proceedings. View "Behr v. Campbell" on Justia Law

Plaintiffs, owners and operators of greyhound-racing businesses, filed suit against the Florida Attorney General, seeking a declaration that a newly enacted state law prohibiting gambling on greyhound racing is unlawful and an injunction to prevent her from enforcing it. The district court dismissed the complaint without prejudice based on lack of standing.The Eleventh Circuit affirmed the district court's dismissal of the complaint, holding that plaintiff's alleged injuries are not traceable to any conduct of the Attorney General—either in enforcing or threatening to enforce the law or otherwise—and that plaintiffs' injuries would not be redressable by relief from this court. Therefore, plaintiffs lack Article III standing to bring their claims against the Florida Attorney General. View "Support Working Animals, Inc. v. Governor of Florida" on Justia Law