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

The City filed suit against the Bank, alleging that the Bank engaged in a decade-long pattern of discriminatory lending in the residential housing market that caused the City economic harm. The City asserts a claim arising under the Fair Housing Act (FHA), 42 U.S.C. 3601 et seq., as well as an unjust enrichment claim under Florida law. The district court dismissed the City's FHA claim with prejudice. The court found that the City has constitutional standing to pursue its FHA claims; under controlling Supreme Court precedent, the “zone of interests” for the FHA extends as broadly as permitted under Article III of the Constitution, and therefore encompasses the City’s claim; while the court agreed with the district court that the FHA contains a proximate cause requirement, the court found that this analysis is based on principles drawn from the law of tort, and that the City has adequately alleged proximate cause; and the court concluded that the “continuing violation doctrine” can apply to the City’s claims, if they are adequately pled. The court concluded that the district court erred in dismissing the City’s federal claims with prejudice and in denying the City’s motion for leave to amend on the grounds of futility because the district court imposed too stringent a zone of interests test and wrongly applied the proximate cause analysis. The court affirmed the dismissal of the state law claim because the benefits the City allegedly conferred on the defendants were not sufficiently direct to plead an unjust enrichment claim under Florida law. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "City of Miami v. Bank of America Corp." on Justia Law

In this appeal, the court considered whether Florida’s Rental Tax and Florida’s Utility Tax, as applied to matters occurring on Seminole Tribe lands, violate the tenets of federal Indian law. The court held that Florida’s Rental Tax is expressly precluded by 25 U.S.C. 465, and, in the alternative, is preempted by the comprehensive federal regulation of Indian land leasing. Therefore, the court affirmed the district court's order as to this issue. The court concluded, however, that the district court erred in placing the legal incidence of the Utility Tax on the Tribe and find that, on this record, the Tribe has not demonstrated that the Utility Tax is generally preempted by federal law. Therefore, the court reversed as to this issue and remanded for further proceedings. View "Seminole Tribe v. Stranburg" on Justia Law

Jane Doe, an eighth-grade student, filed suit against the Board and officials because she was raped in a bathroom after school officials decided to use her as bait in a sting operation to catch another eighth-grade student in the act of sexual harassment. The court reversed the district court's grant of summary judgment to the Board on Doe's Title IX claim where, to prevail on a student-on-student sexual harassment claim, a plaintiff must prove the funding recipient had actual knowledge the sexual harassment was severe, pervasive, and objectively offensive. In this case, there is a genuine dispute of material fact as to whether Doe has satisfied all five elements necessary to succeed under Title IX. The court affirmed the district court's grant of summary judgment to the Board on Doe's 42 U.S.C. 1983 claim where the rape-bait scheme was not a known or obvious consequence of the "catch in the act" policy or the Board's allegedly inadequate training policies; reversed the grant of summary judgment to Defendant Blair on Doe's section 1983 equal protection claim where there is a genuine dispute of material fact as to whether Blair violated Doe’s constitutional right to equal protection by acting with deliberate indifference to the rape of Doe; reversed the district court's grant of summary judgment to Defendant Dunaway on Doe's section 1983 equal protection claim where Dunaway acquiesced to and ratified the sting operation; affirmed the grant of summary judgment to Defendant Terrell on Doe's section 1983 equal protection claim because Terrell is entitled to qualified immunity; and affirmed the grant of summary judgment to Defendant Simpson for the alleged section 1983 substantive due process violation where Simpson is entitled to qualified immunity. In regard to the state law claims, the court affirmed the grant of summary judgment to Blair for negligence/wantonness because he is entitled to state-agent immunity; affirmed the denial of summary judgment to Dunaway; and reversed the grant of summary judgment to Simpson for the tort of outrage. View "Hill v. Madison Cnty. Sch. Bd." on Justia Law

Plaintiffs, male inmates in the custody of the ADOC, filed suit against the ADOC and others challenging the ADOC's hair-length policy on various constitutional grounds and under the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA), 42 U.S.C. 2000cc et seq. Plaintiffs wish to wear their hair unshorn in accordance with the dictates of their Native American religion but the policy prohibits them from doing so. The United States intervened on plaintiffs’ behalf. The ADOC’s witnesses asserted that its policy is necessary to accomplish several compelling goals, including the prevention of contraband, facilitation of inmate identification, maintenance of good hygiene and health, and facilitation of prison discipline through uniformity. The court affirmed the district court's judgment in favor of the ADOC, because the ADOC carried its RLUIPA burden to demonstrate that its hair-length policy is the least restrictive means of furthering its compelling governmental interests. View "Knight v. Thompson" on Justia Law

The court sua sponte vacated and reconsidered its original opinion on this matter and substituted in its place the following opinion. The State appealed the District Court’s grant of summary judgment and an injunction in favor of a plaintiffs, a group of physicians and physician advocacy groups, enjoining enforcement of Florida’s Firearm Owners Privacy Act, Fla. Stat. 381.026, 456.072, 790.338, on First and Fourteenth Amendment grounds. The Act seeks to protect patient privacy by restricting irrelevant inquiry and record-keeping by physicians on the sensitive issue of firearm ownership. The court concluded that the Act codifies the commonsense conclusion that good medical care does not require inquiry or record-keeping regarding firearms when unnecessary to a patient’s care - especially not when that inquiry or record-keeping constitutes such a substantial intrusion upon patient privacy. Given this understanding of the Act, and in light of the longstanding authority of States to define the boundaries of good medical practice, the court held that the Act is, on its face, a permissible restriction of physician speech. Accordingly, the court reversed the district court’s grant of summary judgment in favor of plaintiffs, and vacated the injunction against enforcement of the Act. View "Wollschlaeger v. Governor of the State of Florida" on Justia Law

Plaintiff, a Georgia death row inmate, filed suit under 42 U.S.C. 1983, alleging that her federal due process rights were violated when the warden of the prison where she was housed ordered the prison staff not to speak with her legal team as they were gathering evidence in support of her application for clemency. On appeal, plaintiff challenged the district court's dismissal of her complaint. The court concluded that plaintiff's argument is foreclosed by Wellons v. Comm'r, Ga. Dep't of Corr. Even if Wellons were distinguishable, the court rejected plaintiff's reading of the Supreme Court's decision in Ohio Adult Parole Authority v. Woodard, where nothing in Justice O’Connor’s concurring opinion suggests that a clemency board’s compliance with state laws or procedures is part of the “minimal procedural safeguards” protected by the Due Process Clause. View "Gissendaner v. Commissioner, GA DOC" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 against Palm Beach County Sheriff's Office deputies and the Sheriff's Office, alleging that deputies shot, tasered, and beat him in his own bedroom without warning or provocation during their response to a "Baker Act call." The court concluded that the district court abused its discretion when it dismissed plaintiff's count one and count three claims against the deputies on the ground that those counts did not comply with Federal Rules of Civil Procedure 8(a)(2) and 10(b) where these two counts are informative enough to permit a court to readily determine if they state a claim which relief can be granted. The court reversed the part of the district court’s judgment dismissing count one of plaintiff's third amended complaint; reversed the part of the judgment dismissing count three as to the deputies; and affirmed the dismissal of count three as to the Sheriff’s Office and the dismissal of counts two, four, six, and seven in their entirety. Finally, the court vacated the part of the district court's order remanding count five to state court and remanded for further proceedings. View "Weiland v. Palm Beach Cty. Sheriff's Office" on Justia Law

Plaintiffs, Florida public school teachers, filed suit challenging Florida’s Student Success Act, Fla. Stat. 1012.34, as well as the Florida State Board of Education’s and three school districts’ implementation of the Act. The district court granted summary judgment in favor of defendants. Plaintiff alleged that the Act resulted in teacher evaluation policies that violated the teachers’ rights to due process and equal protection under the Fourteenth Amendment. Determining that plaintiffs have standing and the case is not moot, the court concluded that, under rational basis review, the school district's evaluation policies are rationally related to the purpose of improving student academic performance. Therefore, plaintiffs substantive due process and equal protection claims failed. Accordingly, the court affirmed the judgment of the district court. View "Cook v. Chartrand" on Justia Law

Plaintiffs, parents of a child with autism and speech and language disabilities, filed suit under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400–1482, seeking payment for an independent educational evaluation (IEE) of the child to determine his educational needs. The district court dismissed the parents' complaint, holding that the parents' request in the state administrative proceeding was time-barred. Because a reevaluation of the child is due, the relief the parents seek - an order directing the District to pay for an IEE - will no longer redress the procedural injury they allege. Because the parents lack a legally cognizable interest in the outcome of the appeal, their appeal is moot. Accordingly, the court vacated for lack of subject matter jurisdiction and remanded. View "T.P. v. Bryan Cnty. Sch. Dist." on Justia Law

Joshua Salvato's estate filed an excessive force suit under 42 U.S.C. 1983 for damages against a law enforcement officer in her individual capacity and the sheriff in his official capacity after Salvato was shot and killed by the officer following an attempt to arrest Salvato. The court concluded that, viewing the facts in the light most favorable to Salvato, it is clearly established that the officer’s use of deadly force was excessive and that she should have intervened against the sheriff's use of excessive force. The court affirmed the denial of the officer's motion for qualified immunity and remanded for further proceedings. However, because the record contains no evidence that the officer’s violation of Salvato’s federal civil rights was attributable to the sheriff where a single failure to investigate an incident is insufficient to establish ratification, the court reversed the denial of the sheriff’s motion for judgment as a matter of law and rendered a judgment in his favor on the claim of excessive force. View "Salvato v. Miley" on Justia Law