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

Plaintiff became a firefighter for the City of Sanford, Florida, in 1999. At the age of 47, Plaintiff took disability retirement on November 1, 2018. When Plaintiff retired, she continued to receive free health insurance through the City. Under a policy in effect when Plaintiff first joined the fire department, employees retiring for qualifying disability reasons, such as Plaintiff’s Parkinson’s disease, received free health insurance until the age of 65. But, unbeknownst to Plaintiff, the City changed its benefits plan in 2003. Under the new plan, disability retirees such as Plaintiff are entitled to the health insurance subsidy for only twenty-four months after retiring. Her complaint alleged various claims, including violations of Title I of the Americans with Disabilities Act, the Rehabilitation Act, and the Florida Civil Rights Act. The district court entered judgment for the City.   The Eleventh Circuit affirmed. The court explained that because Plaintiff cannot establish that the City committed any discriminatory acts against her while she could perform the essential functions of a job that she held or desired to hold, her Title I claim fails. For the same reason, so do her claims under the Rehab Act and the Florida Civil Rights Act. Further, the court held that the City’s s benefits plan does not run afoul of the Equal Protection Clause. Disabled persons are not a suspect class, and government-paid health insurance is not a recognized fundamental right. Thus under rational basis review, the City’s benefits plan advances the legitimate governmental purpose of conserving funds. View "Karyn D. Stanley v. City of Sanford, Florida" on Justia Law

Plaintiff is an inmate in the custody and care of the Georgia Department of Corrections (GDC). Plaintiff was diagnosed with Hepatitis C (HCV) in 2009 but did not receive medication for it until nine years later. By then, Plaintiff’s HCV had progressed to stage F4 cirrhosis with indications of severe liver inflammation. Plaintiff sued numerous prison doctors, three of whom are the subject of this appeal, alleging that they were deliberately indifferent to his serious medical needs in violation of the Eighth Amendment. The district court granted summary judgment in favor of the doctors and dismissed all claims against them. Plaintiff appealed both the district court’s grant of summary judgment and its denial of his motion to amend the complaint.   The Eleventh Circuit reversed the district court’s grant of summary judgment but affirmed its denial of the motion to amend. The court explained that the bar to proving an Eighth Amendment deliberate indifference claim is high, but it is not insurmountable. The court explained that Plaintiff has raised a number of factual disputes regarding the denial of his HCV treatment for over eight years. These disputes are sufficiently material to be decided by a jury. View "Ricky J. Johnson v. Dr. Sharon Lewis, et al" on Justia Law

After entering a conditional guilty plea, Defendant appealed his convictions on four counts related to child pornography. At the start of the COVID-19 global pandemic, Defendant was arrested on a criminal complaint on March 10, 2020. Thereafter, the district court entered a series of pandemic-related administrative orders that continued grand jury sessions five times at the ends of justice, spanning March 26, 2020, to November 16, 2020. Due to the pandemic, a grand jury did not formally indict Defendant until December 1, 2020. On appeal, Defendant argued that the district court erred in denying his motion to dismiss his indictment for failure to indict him within thirty days from his arrest, as required by the Speedy Trial Act. Defendant does not challenge the time between indictment and his guilty plea, but only between his arrest on March 10 and grand jury indictment on December 1, 2020.

The Eleventh Circuit affirmed the denial of Defendant’s motion to dismiss his indictment. The court concluded that the pandemic-related continuances in 2020 were not an abuse of discretion and were within the ends-of-justice exception to the Speedy Trial Act. The court explained that the magistrate judge was not required to expressly consider each statutory factor in its order or recite specific language from the statute. The court explained that not every statutory factor will be relevant to the circumstances warranting the continuance. Instead, it is sufficient if the record shows, as it does here, that the magistrate judge considered the pertinent factors. View "USA v. Robert Dunn" on Justia Law

Defendant appealed his sentence of 20 years of imprisonment following the revocation of his probation pursuant to 18 U.S.C. Section 3565. Defendant argued that, where the Sentencing Guidelines recommended a sentence of 12 to 18 months of imprisonment, his sentence is procedurally and substantively unreasonable. One of his arguments is that the district court failed to give a specific reason for imposing an upward variance to the statutory maximum.   The Eleventh Circuit vacated and remanded for resentencing. The court wrote that upon finding that a defendant violated a condition of probation, a district court may revoke the term of probation and impose a term of imprisonment as long as the court considers the factors set forth in 18 U.S.C. Section 3553(a), such as the need for the sentence imposed to reflect the “seriousness of the offense” and “afford adequate deterrence,” among others. The court noted that a district court commits a “significant procedural error” in imposing a sentence if it calculates the guidelines incorrectly, fails to consider the Section 3553(a) factors, bases the sentence on clearly erroneous facts, or, of particular relevance here, “fail[s] to adequately explain the chosen sentence—including an explanation for any deviation from the Guidelines range.” The court explained that the record reflects that the district court did not give any reason for why it was imposing an above-guideline sentence. The court explained that the district court’s statements at the conclusion of the revocation proceeding were not sufficiently specific to allow the court to understand why the district court imposed an above-guideline sentence. View "USA v. Henry Martin Steiger" on Justia Law

Defendant is a Pasco County, Florida, Sherriff’s Office deputy. Chris Nocco, the Pasco County Sheriff, is a codefendant. Plaintiff’s initial complaint in this case consisted of twelve counts. Plaintiff's first amended complaint, the complaint at hand, contains ten counts. Count I of the amended complaint, which replicates verbatim Count I of the initial complaint, was brought against Defendant in his individual capacity and is the only count before the Eleventh Circuit in this appeal. The district court denied Defendant’s motion to dismiss Plaintiff’s claims pursuant to the doctrine of qualified immunity.   At issue on appeal is whether the Fourth Amendment precluded a law enforcement officer—who had stopped a vehicle for a traffic violation—from asking a passenger in the vehicle to identify himself unless the officer had reason to suspect that the passenger had committed, was in the process of committing, or was likely to commit a criminal offense. The second question is whether binding precedent clearly established, at the time relevant here, that an officer could not ask a passenger to identify himself absent this reasonable suspicion.   The Eleventh Circuit reversed. The court explained that it doubts that the Florida Supreme Court would hold that a passenger is free to resist an officer’s request for identification in the setting this case presents. At the very least, it is arguable that the court would uphold the request and find the officer had at least arguable cause to arrest the passenger for resisting an officer without violence in violation of Section 843.02. View "Marques A. Johnson v. James Dunn" on Justia Law

TASER International, Inc., obtained an injunction against “Phazzer [Electronics] and its officers, agents, servants, employees, and attorneys; and any other persons who are in active concert or participation with Phazzer Electronics or its officers, agents, servants, employees, or attorneys” (the “2017 injunction”). The injunction prohibited Phazzer Electronics from distributing or causing to be distributed certain stun guns and accompanying cartridges that infringed on TASER’s intellectual property. At the time of the TASER-Phazzer Electronics litigation, Steven Abboud controlled Phazzer Electronics, and Phazzer Electronics employed, among others, Defendant. In 2018, after the district court found Abboud in contempt for violating the 2017 injunction, Abboud and Defendant went to work for other entities with “Phazzer” in their names. Based on that activity, the district court found Defendant (and others) in contempt of the 2017 injunction. At issue on appeal is whether the 2017 injunction extended broadly enough to bind Defendant and prohibit her conduct under the theories of liability that the government has pressed and the district court decided   The Eleventh Circuit vacated Defendant’s conviction. The court concluded that the record cannot sustain Defendant’s conviction.  The court explained that the district court did not make factual findings about whether Defendant was a key employee. Nor did it determine whether she so controlled Phazzer Electronics and the litigation that resulted in the 2017 injunction that it would be fair to say she had her day in court on that injunction. View "USA v. Diana Robinson" on Justia Law

Plaintiff brought both a Section 1983 false arrest claim and a state law false arrest claim against two Huntsville, Alabama, police officers and the City itself. The district court concluded that the officers were entitled to qualified immunity, and Plaintiff appealed.   The Eleventh Circuit reversed the district court’s grant of qualified immunity. The court explained that, in general, when government officials are performing discretionary duties, as all parties concede they were in this case, they are entitled to qualified immunity. A plaintiff may rebut this entitlement by showing that the government officials (1) committed a constitutional violation; and (2) that this violation was “clearly established” in law at the time of the alleged misconduct.   The court explained that it has been clearly established for decades that the police are free to ask questions, and the public is free to ignore them. It has been clearly established prior to Plaintiff’s arrest that any legal obligation to speak to the police and answer their questions arises as a matter of state law. And the state statute itself, in this case, is clear and requires no additional construction: police are empowered to demand from an individual three things: “name, address and an explanation of his actions.” It was thus clearly established at the time of Plaintiff’s arrest that Defendant could not demand he produce physical identification. Thus, no reasonable officer could have believed there was probable cause to arrest Plaintiff for obstructing governmental operations. And this theory cannot support the grant of qualified immunity to the officers. View "Roland Edger v. Krista McCabe, et al" on Justia Law

Plaintiffs worked as detention officers for Glynn County under Sheriff Jump’s supervision. Although it is unclear from the record whether the Officers are formally deputy sheriffs, it is undisputed that they are, at minimum, direct employees of Sheriff Jump, in his official capacity, akin to deputies. The Officers brought a Fair Labor Standards Act (FLSA) collective action alleging that the County “illegally calculated their and other detention officers’ overtime wages.” The County moved to dismiss for failure to state a claim. In response, the Officers amended their complaint to include Sheriff Jump in his individual capacity. The County and Sheriff Jump then moved to dismiss the amended complaint for lack of subject-matter jurisdiction and for failure to state a claim, arguing that neither defendant was the Officers’ employer under the FLSA.   The Eleventh Circuit affirmed both the district court’s denial of the Officers’ motion for leave to amend and its ultimate dismissal of the amended complaint. The court held that the district court correctly dismissed the Officers’ complaint against Sheriff Jump in his individual capacity because he is not an “employer” under the FLSA. Further, the court agreed with the district court that Sheriff Jump would be entitled to Eleventh Amendment immunity when making compensation decisions for his employees. Further, the court held that Georgia “retained its Eleventh Amendment immunity” from suits in federal court for breach-of-contract claims because no statute or constitutional provision “expressly consents to suits in federal court. View "Langston Austin, et al. v. Glynn County, Georgia, et al." on Justia Law

In 2002, the grand jury indicted Petitioner for (1) armed bank robbery, (2) knowingly carrying, using, possessing, and discharging a firearm during and in relation to a crime of violence, and (3) possessing a firearm as a felon. The government then filed a notice that Petitioner qualified for the enhanced sentence under section 3559. Petitioner appealed his convictions and sentences, and the Eleventh Circuit affirmed. Petitioner then filed in the district court a second section 2255 motion. The issue here is whether the Supreme Court has announced a “new rule of constitutional law” that applies to the residual clause in 18 U.S.C. section 3559.   The Eleventh Circuit vacated the district court’s order and remanded for Petitioner’s motion to be dismissed for lack of jurisdiction. The court noted that its decision is narrow, and it has not decided whether the three-strikes law’s residual clause is unconstitutionally vague. The court wrote that it has not decided whether the three-strikes law’s residual clause is unconstitutionally vague. Further, the court explained that it has not decided whether Petitioner met his burden under Beeman. Instead, the court’s review was limited to the threshold question of whether Petitioner has met the jurisdictional requirements of section 2255(h)(2).   The court reasoned that the district court had jurisdiction to consider Petitioner's second section 2255 motion only if he could establish that a new constitutional rule supported his claim. But no decision from the Supreme Court has announced the new rule that Petitioner needs. The district court therefore lacked jurisdiction to decide whether Petitioner’s motion had any merit. View "Charles Edward Jones v. USA" on Justia Law

Zen Group, Inc., is “a Florida Medicaid provider of services to developmentally-disabled minors.” Zen Group alleges that beginning in 2018, the Florida Agency for Health Care Administration wrongfully attempted to recoup payments rendered under the Agency’s “Behavior Analysis Services Program.” Zen Group asserts that the officials made baseless referrals for investigation of fraud and suspended payments to Zen Group in retaliation for the previous exercise of its constitutional rights in an administrative proceeding. Zen Group complained that the officials’ retaliation violated its due-process rights under the Fourteenth Amendment and its speech and petition rights under the First Amendment. The district court dismissed the complaint.   The Eleventh Circuit affirmed. The court held that Zen Group’s due process and First Amendment claims for damages are both barred by qualified immunity. And Zen Group lacks standing to seek injunctive relief. The court explained that Zen Group alleged that it had “completely ceased operations” in June 2020. It did not allege that it had resumed providing services to Medicaid recipients. The court explained that in that context, the most it can fairly infer from the assertion that Zen Group “remains a Florida Medicaid provider” is that Zen Group remains an active corporation authorized by the state to provide Medicaid services, even though it is not currently doing so. The allegations in the amended complaint do not support the inference that Zen Group faces anything more than a speculative risk of future injury if it resumes providing services or the officials decide to engage in retaliatory fraud referrals against an inactive provider with respect to services rendered in the past. View "Zen Group, Inc., et al v. State of Florida Agency for Health Care Administra, et al" on Justia Law