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

Khoury lives near the school’s baseball field and complained about parking, noise, lights, and the influx of people. Khoury took photos of cars that she believed were illegally parked. Khoury and a parent had a verbal confrontation. Williams, a Miami-Dade Public School police officer, told Khoury the cars were not illegally parked and told the parents there was nothing he could do about Khoury filming. Other residents told Williams that Khoury took photos of their children and that they were “afraid of her.” Khoury claims Williams “charged” her because she was recording him and twisted her arm behind her back. Williams and the parent claim that Khoury “pushed” Williams, then threw herself on the ground,” yelling “false arrest.” After handcuffing Khoury, Williams detained her under the Baker Act for mental health observation and took her to a hospital for treatment of her dislocated elbow. She was transferred to Miami Behavioral Health Center, which found no evidence of "psychosis.” Khoury was released two days later and filed suit under 42 U.S.C. 1983, alleging that the School Board had an unwritten policy of improperly detaining people under the Baker Act to reduce crime statistics.The Eleventh Circuit affirmed summary judgment in favor of the Board, noting the lack of evidence establishing a pervasive practice. The court reversed as to Williams, noting the many disputed facts. Williams concluded Khoury was “not mentally well” simply because she didn’t believe that the cars were parked legally; Khoury was not violating the law or harming anyone by filming, and other eyewitnesses testified that Khoury was not a threat—her response was simply irrational. That alone does not form a basis under which a reasonable officer would conclude that Khoury was a danger to herself or others View "Khoury v. Miami-Dade County School Board" on Justia Law

An abortion facility (RHS) and its owner filed suit against the Attorney General of Alabama and the District Attorney of Montgomery County, challenging some of the amendments to Alabama's Parental Consent Act, Ala. Code 26-21-4, which regulates an unemancipated minor's ability to obtain an abortion. Ruling on cross-motions for judgment on the pleadings, the district court held that some of the challenged provisions were unconstitutional, severed those provisions from the rest of the Act, and entered a declaratory judgment that rendered the severed provisions unenforceable.The Eleventh Circuit concluded that the district court correctly held that RHS had Article III standing to challenge Alabama's Parental Consent Act. In this case, plaintiffs have satisfied the injury-in-fact requirement and they have demonstrated causation and redressability. The court also concluded that the district court correctly held that the Attorney General and the District Attorney are proper defendants under Ex parte Young. The court explained that the criminal-enforcement link here establishes the necessary connection between defendants and the challenged provisions. The court stated that Ex parte Young provides an avenue for a civil lawsuit so plaintiffs do not need to subject themselves to criminal prosecution to challenge unconstitutional laws. That civil avenue is particularly important here, where the law involves the inherently serious time-sensitive issue of minors' access to abortion and violating the law could cause medical professionals to lose their licenses.On the merits, the court agreed with the district court that several provisions of the Act create an undue burden under Whole Woman's Health v. Hellerstedt, 136 S. Ct. 2292, 2309 (2016), and Planned Parenthood of S.E. Pa. v. Casey, 505 U.S. 833, 877 (1992). The court agreed with the district court that the Act constitutes an undue burden because it places a substantial obstacle on a "large fraction" of unemancipated minors who seek to obtain a court order authorizing an abortion without the consent of their parent or guardian. The court considered the benefits and burdens of the challenged regulation, concluding that although the state has an interest in providing guidance and assistance to minors who seek an abortion without parental consent, the challenged provisions provide, if anything, marginal benefit. Instead, the provisions created substantial obstacles and were therefore impermissible means of serving legitimate ends. The court was confident that the Act as amended creates an undue burden under Whole Woman's Health by placing a substantial obstacle each year for a handful of unemancipated minors who would seek to obtain a judicial bypass from the parental/guardian consent requirements of the Act. For these minors, the Act would either (a) unduly interfere with the minors' ability to demonstrate maturity or best interest by adding additional (and possibly adversarial parties) in the bypass proceeding, or (b) deter them from trying to obtain a court order through a judicial bypass proceeding. Accordingly, the court affirmed the district court's judgment. View "Reproductive Health Services v. Bailey" on Justia Law

Plaintiff filed suit alleging that her former employer violated the Florida Civil Rights Act (FCRA) by discriminating against her because of her association with her son, who suffers from severe asthma. The district court dismissed plaintiff's associational discrimination claim and granted summary judgment to the employer on plaintiff's remaining claims under the FCRA and the federal Family and Medical Leave Act (FMLA).The Eleventh Circuit held, in light of the statute's plain language, that the FCRA does not support an associational-discrimination claim and no Florida court has concluded otherwise. The court also held that the district court correctly granted summary judgment in favor of the employer on plaintiff's claim for FCRA retaliation where she failed to show that any of the relevant decisionmakers knew of her protected activity or that other employees engineered her termination by manipulating the relevant decisionmakers; FMLA retaliation where plaintiff failed to show that the employer's reasons for taking adverse action were pretextual; and FMLA interference where she did not establish that she was entitled to FMLA leave. View "Matamoros v. Broward Sheriff's Office" on Justia Law

In 1994, SGV bought 547 acres in Alabaster for $1.65 million. The master development plan, approved in 1995, zoned the land as R-2 (90-foot wide single-family residences), R-4 (60-foot wide garden homes), and R-7 (townhomes). Most of the development was completed by 2008, except the 142-acre Sector 16, zoned predominantly for R-4 and R-7 with a small part as R-2. In 2011, the city rezoned Sector 16 for R-2 lots only. SGV filed suit under 42 U.S.C. 1983, 1985(3), and 1988, alleging that the rezoning “constitute[d] an unlawful taking” without just compensation and denials of procedural and substantive due process. The court rejected the due process claims. The city objected to evidence of the city’s motive and the “lot method” valuation and argued that the case was not ripe for adjudication, since SGV had not sought variances. The court found that a zoning ordinance was a final matter that could be adjudicated. A jury found that there was a regulatory taking without just compensation; that before the taking, the value of the property was $3,532,849.19; and after the taking, the value of the property was $500,000. The court added prejudgment interest and entered a final judgment of $3,505,030.65. The Eleventh Circuit affirmed, rejecting arguments that the just compensation claim was not ripe, that the district court improperly allowed evidence regarding the city’s motivation for enacting th ordinance, and concerning the admission and exclusion of certain other evidence. View "South Grand View Development Co., Inc. v. City of Alabaster" on Justia Law

Plaintiff filed suit against her former employer, Alfa, alleging disability discrimination in violation of the Americans with Disabilities Act (ADA). Plaintiff contends that, although Alfa claims she was terminated because of automation of some of her job responsibilities, she was actually terminated because of the high costs to Alfa in treating her multiple sclerosis (MS).The Eleventh Circuit reversed the district court's grant of summary judgment in favor of Alfa, concluding that plaintiff was denied full discovery. In this case, Alfa did not demonstrate a burden or abuse of process sufficient to justify such limitations on discovery, and especially in light of the relevant nature of the information sought by plaintiff. Therefore, the district court committed a clear error of judgment by denying plaintiff the opportunity to depose the then-Executive Vice President of Human Resources. View "Akridge v. Alfa Mutual Insurance Co." on Justia Law

In this appeal involving an alleged conspiracy by several state officials to violate a former physician's civil rights by pinning the blame for his patient's death on him, the district court dismissed the physician's claims involving actions taken within the scope of the receivership for lack of subject-matter jurisdiction. The district court dismissed the remaining claims for failure to state a claim upon which relief could be granted. In this case, a pre-med student began working in the physician's medical practice and then later moved into his home. The physician started prescribing the student hydrocodone and increasingly stronger medications for headaches and abdominal pains. The student later died of a drug overdose.The Eleventh Circuit concluded that the district court had jurisdiction to review the claims against the receiver for his acts taken within the scope of the receivership but that these claims fail because the receiver is entitled to judicial immunity. The court explained that, although the Barton Doctrine does not apply, Defendants Lambros, Ekonomou, and the Law Firms are entitled to judicial immunity. The court also concluded that the district court correctly dismissed the 42 U.S.C. 1985 claims for failure to allege racial or class-based animus; the physician's remaining allegations fail to state a claim upon which relief can be granted; and he is not entitled to amend his complaint. Accordingly, the court vacated in part and affirmed in part. View "Chua v. Ekonomou" on Justia Law

After plaintiff was attacked by his cellmate, he filed suit against the United States under the Federal Tort Claims Act (FTCA) and five prison employees under Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics, 403 U.S. 388, 91 S. Ct. 1999 (1971). Plaintiff alleged that prison officials negligently assigned the cellmate to plaintiff's cell and that their conduct also violated his Eighth Amendment rights.The Eleventh Circuit affirmed the district court's dismissal of plaintiff's FTCA claim against the United States based on the discretionary function exception to the FTCA's waiver of sovereign immunity. The court explained that inmate-classification and housing-placement decisions fall squarely within the discretionary function exception. The court also affirmed the district court's dismissal without prejudice of plaintiff's Bivens claim against the prison employees for failure to exhaust his administrative remedies. View "Shivers v. United States" on Justia Law

Plaintiff, who seeks to knock down his beachfront mansion and to build a new one, filed suit against the town, claiming that the criteria the town's architectural review commission used to deny his building permit violated his First Amendment free speech rights and his Fourteenth Amendment rights to due process and equal protection. In this case, plaintiff wants to knock down his "traditional" beachfront mansion and to build a new one, almost twice its size, in the midcentury modern style. The district court granted summary judgment in favor of the town.The Eleventh Circuit concluded that summary judgment was not granted too early and affirmed on the First Amendment claim because there was no great likelihood that some sort of message would be understood by those who viewed plaintiff's new beachfront mansion. The court also affirmed the district court's summary judgment on the Fourteenth Amendment claims because the commission's criteria were not unconstitutionally vague and plaintiff has not presented evidence that the commission applied its criteria differently for him than for other similarly situated mansion-builders. View "Burns v. Town of Palm Beach" on Justia Law

The Eleventh Circuit affirmed the district court's dismissal without prejudice of plaintiff's 42 U.S.C. 1983 action against the State of Georgia, the Georgia Department of Corrections (GDC), and about 42 correctional officials.The court agreed with its sister circuits that a plaintiff's duplicative complaint is an abuse of the judicial process and is properly dismissed without prejudice as malicious under the Prison Litigation Reform Act (PLRA). The court explained that, given plaintiff knowingly filed the third complaint at issue here containing claims duplicative of claims he had already asserted in two other pending civil actions, and in light of his history as a prolific serial filer, the district court did not abuse its discretion by dismissing this third complaint without prejudice as malicious under 28 U.S.C. 1915A(b)(1). The court also concluded that the district court did not err in alternatively dismissing plaintiff's complaint as barred by the three strikes provision of the PLRA where the complaint as a whole does not sufficiently allege that plaintiff was under imminent danger of serious physical injury. View "Daker v. Ward" on Justia Law

Plaintiff appealed the district court's dismissal of her complaint against Floridian, in an action alleging that Floridian violated Title III of the Americans with Disabilities Act (ADA) based on barriers to access she encountered at the hotel property (Count I) and deficiencies in its online reservation system (Count II). The district court dismissed Count II for improper claim splitting, given that plaintiff had made a claim in her first lawsuit about Floridian's online reservation system. The district court subsequently dismissed Count I with prejudice for lack of subject matter jurisdiction, concluding that plaintiff did not have standing to seek injunctive relief.The Eleventh Circuit affirmed the district court's dismissal of Count I for lack of standing, except to the extent that the district court dismissed the claim with prejudice. In this case, the totality of relevant facts simply do not support the conclusion that plaintiff faced a real and immediate threat of future discrimination at the Hotel. Therefore, the court remanded for the district court to amend its judgment as to Count I. The court affirmed the district court's dismissal of Count II for claim splitting because Count II and Floridian I arise from the same transaction and are based on facts that are sufficiently related in time, space, origin, and motivation. View "Kennedy v. Floridian Hotel, Inc." on Justia Law