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

The Eleventh Circuit affirmed the district court's grant of summary judgment to defendants in an action alleging excessive force against Daniel Hammett. Hammett was shot and killed by an officer in a confrontation during the course of executing a warrant. The court held that plaintiff failed to produce evidence that suggested the "split-second judgments" of officers violated the Fourth Amendment as they responded to the "tense, uncertain, and rapidly evolving" events of the day. In this case, the actions of Defendant Horsley and Whitener were objectively reasonable and Defendant Mayfield was entitled to summary judgment because his bullet did not strike Hammett. View "Hammett v. Paulding County, Georgia" on Justia Law

The Eleventh Circuit withdrew its prior opinion and issued this opinion in its place. The court affirmed the district court's denial of petitioner's 28 U.S.C. 2254 habeas petition and held that the state court's denial of his Brady claim was entitled to deference under the Antiterrorism and Effective Death Penalty Act of 1996 and that the state court's denial was neither an unreasonable determination of the facts nor an unreasonable application of clearly established federal law. View "Rimmer v. Secretary, FL DOC" on Justia Law

The Eleventh Circuit affirmed the denial of a petition for habeas relief based on the ineffective assistance of counsel at the guilt phase of petitioner's trial. Petitioner alleged that she was denied effective assistance because a revolving door of trial attorneys, collectively, left her unable to muster an adequate defense. The state court deemed her challenge procedurally defaulted. Although the court did not rule out that an ineffective assistance of counsel claim could be based on the lack of continuity of counsel, and the court agreed that petitioner could show cause why she failed to raise her claim at the appropriate time in state court, the court concluded that petitioner could not demonstrate that the lack of continuity of counsel prejudiced her case. Therefore, petitioner could not overcome the procedural default and could not demonstrate a meritorious claim of ineffective assistance of counsel. View "Harris v. Commissioner, Alabama Department of Corrections" on Justia Law

The Eleventh Circuit affirmed the district court's denial of a 28 U.S.C. 2254 petition for writ of habeas corpus, alleging that defense counsel rendered ineffective assistance in the investigation and presentation of mitigation evidence during his penalty phase proceedings. The court held that the state court's denial of petitioner's ineffective trial counsel claim was not contrary to, or an unreasonable application of, clearly established federal law, nor was it based on an unreasonable determination of the facts. In this case, petitioner has not shown a reasonable probability that, had he presented all mitigating evidence, the outcome of the proceedings would have been different. The court explained that petitioner's claims about his counsel's investigation were immaterial and irrelevant to the prejudice analysis. View "Krawczuk v. Secretary, FL DOC" on Justia Law

The Eleventh Circuit reversed the district court's dismissal of a complaint alleging that prison staff were deliberately indifferent to Blair Mitchell's serious medical needs in violation of his Eighth Amendment rights. The court held that, because he alleged a total lack of hepatitis treatment and the resulting onset of cirrhosis, Mr. Mitchell's complaint falls within the imminent-danger exception to the three strikes provision. In the alternative, because the district court did not comply with the procedural requirements necessary for imposing sanctions, it abused its discretion in dismissing Mr. Mitchell's complaint as a sanction. The court held that the complaint stated a claim for a deliberate indifference and there was no alternative basis on which to affirm the district court's dismissal. Therefore, the court remanded for further proceedings. View "Mitchell v. Warden" on Justia Law

The Eleventh Circuit granted the State's motion to vacate the district court's certification of appealability and denied petitioner's stay of execution. Petitioner contended that his federal Due Process, Equal Protection, and Eighth Amendment rights were violated by the state court's failure to give retroactive effect to (1) Chapter 2017-1, a revised version of Florida Statute 921.141 (Florida's capital sentencing statute), and (2) the U.S. Supreme Court's decision in Hurst v. Florida. The court assumed without deciding that the current petition was not a second or successive one for purposes of 28 U.S.C. 2244(b) purposes, and held that the Florida Supreme Court's rejection of petitioner's constitutional-statutory claim was not contrary to, or an unreasonable application of, the holding of a Supreme Court decision. View "Lambrix v. Secretary, DOC" on Justia Law

Plaintiff filed suit challenging the school board's policy governing public comment at its meetings. The Eleventh Circuit affirmed in part the district court's grant of a permanent injunction based on plaintiff's facial claims and enjoined the school board's public comment policy. The court held that it had appellate jurisdiction under 28 U.S.C. 1292(a)(1); plaintiff had standing to pursue his facial unbridled-discretion claim; the court vacated the district court's entry of summary judgment in favor of plaintiff on all claims other than the facial unbridled-discretion claim; the court held that the lack of a time limit for scheduling an initial meeting effectively granted the Superintendent unbridled discretion in contravention of the First Amendment; and the district court did not abuse its discretion in granting a permanent injunction. Because the court affirmed the district court's entry of summary judgment with respect to only the facial unbridled-discretion claim, the district court must alter the scope of the injunction on remand so that the injunction remedies only the harm created by the unconstitutional grant of unbridled discretion. The court affirmed the district court's denial of defendants' motion for extension of time and remanded. View "Barrett v. Walker County School District" on Justia Law

After the Florida Supreme Court rejected petitioner's appeal from the denial of his guilt stage ineffective assistance claim on remand, he filed in federal district court a 28 U.S.C. 2254 petition for writ of habeas corpus. The Eleventh Circuit reversed the district court's grant of relief, holding that the district court relied on evidence that had not even been before the Florida Supreme Court in the first appeal from the denial of state collateral relief. In this case, petitioner did not raise a cumulative error claim, but the district court granted relief based on the cumulative effect or combined impact, of defense counsel's errors at the penalty phase and sentencing phase. The court held that the Florida Supreme Court did not unreasonably deny petitioner relief and the district court erred in granting habeas relief. View "Reaves v. Secretary, Florida DOC" on Justia Law

The Eleventh Circuit reversed and remanded for an evidentiary hearing on an ineffective assistance of counsel claim involving the failure to challenge the quantity of methamphetamine attributed to petitioner. Because there was nothing in the trial record to contradict petitioner's allegations, at this stage of the proceedings, the court must accept that unusable liquids were counted in calculating the drug quantities that determined his mandatory minimum sentence and his advisory guidelines base offense level. The court also must accept that the liquids could not have produced any more than 2.4 grams of methamphetamine. The court held that counsel's failure to challenge the weight calculations amounted to deficient performance, particularly because the drug quantities were the basis of petitioner's mandatory minimum sentence and higher guidelines range. Furthermore, counsel's deficient performance prejudiced petitioner. View "Griffith v. United States" on Justia Law

The Eleventh Circuit affirmed the dismissal of plaintiff's 42 U.S.C. 1983 action against five ADOC officials. Plaintiff alleged that the Alabama Sex Offender Registration and Community Notification Act (ASORCNA) and the ADOC classification manual violated his procedural due process, substantive due process, and ex post facto rights. The court held that the district court did not err in dismissing the procedural due process claim because he was convicted of a crime that constituted a sex offense under Alabama law at the time of his conviction and thus was not entitled to any additional process before being classified as a sex offender by prison officials. Furthermore, plaintiff failed to raise a cognizable substantive due process claim and ex post facto claim. View "Waldman v. Alabama Prison Commissioner" on Justia Law