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

The Uniformed and Overseas Citizens Absentee Voting Act (UOCAVA), 52 U.S.C. 20302(a)(8)(A), includes a variety of measures that states are required to adopt in order to accommodate military voters when they administer federal elections. At issue is section 20302(a)(8)(A)'s requirement that, when a qualifying military or overseas voter requests an absentee ballot for a federal election, a state must transmit a ballot to that voter forty-five days before the federal election. The United States filed suit against Alabama seeking to enjoin the State from holding federal runoff elections forty-two days after federal primary elections. When the court looked at the text of section 20302(a)(9), the court found that it directs states only to "establish a written plan" in preparation for runoff elections, and makes no claim that it abrogates the mandatory forty-five day transmission timeline. In light of the plain language of this substantive command - and Congress's clear intent to prioritize the empowerment of military voters through clear and accessible absentee voting procedures - the court concluded that section 20302(a)(9) does not alter the court's interpretation. Therefore, the court held that the State must transmit validly requested absentee ballots to eligible UOCAVA voters forty-five days before each federal election, whether that election is primary, general, special, or runoff. Accordingly, the court affirmed the district court's grant of summary judgment to the United States. View "United States v. Alabama" on Justia Law

This appeal stemmed from five putative class actions filed against Wells Fargo and its predecessor, Wachovia Bank. At issue was whether Wells Fargo's waiver of its right to compel arbitration of the named plaintiffs' claims should be extended to preclude Wells Fargo from compelling arbitration of the unnamed putative class members' claims. The court concluded that because a class including the unnamed putative class members had not been certified, Article III's jurisdictional limitations precluded the district court from entertaining Wells Fargo's conditional motions to dismiss those members' claims as subject to arbitration; contrary to the position they take in this appeal, the named plaintiffs lack Article III standing to seek the court's affirmance of the district court's provision holding that if a class is certified, Wells Fargo will be estopped to assert its contractual rights to arbitration; and, therefore, the court vacated and remanded for further proceedings. View "Spears-Haymond v. Wells Fargo Bank" on Justia Law

These six consolidated appeals arose out of a Congressional exemption from taxation granted to the federal entities. Appellants contend that the state taxes normally imposed on real estate transfers apply when the federal entities transfer real property in their respective states. The federal entities have not paid the transfer taxes based on their Congressional charter exemptions from "all taxation." The district courts found that the statutory exemptions do apply to preclude taxation and are constitutional. The district court also found that statutory exceptions for taxation of real property contained in the federal statutes did not apply to allow appellants to impose the transfer tax. The court affirmed and agreed with its sister circuits, who have held that the charter exemptions do apply in this context, and are constitutional under the Commerce, Necessary and Proper, and Supremacy Clauses. View "Montgomery Cnty. Comm'n v. FHFA" on Justia Law

Plaintiff, a former deputy sheriff for the county, filed suit against the Sheriff, in his individual and official capacity, and the county, alleging that defendants violated her rights when they wrongfully terminated her. On appeal, the Sheriff challenged the district court's denial of his motion to dismiss. Balancing the three factors of Eleventh Amendment immunity in Manders v. Lee, the court concluded that the Sheriff enjoys Eleventh Amendment immunity against plaintiff's wrongful termination claims brought against him in his official capacity under 42 U.S.C. 1983 and the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq. Accordingly, the court reversed the district court's denial of the Sheriff's motion to dismiss and remanded for further proceedings. View "Pellitteri v. Prine" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983, alleging that the termination of her visitation privileges with her inmate husband was in retaliation for exercising her First Amendment free speech rights. Plaintiff had made public protests, alleging that the Department of Corrections violated the constitutional rights of her husband and other inmates when the inmates were engaged in a hunger strike. Corrections officials appealed the district court's ruling to the extent that it denied them summary judgment after the hunger strike ended. The court concluded that, based on the cross-appeal rule, it may not entertain plaintiff's arguments with respect to the district court's grant of qualified immunity to the Corrections officials during the hunger strike. In regards to the Corrections officials' appeal, the court concluded that the Corrections officials are entitled to qualified immunity for both the period during the hunger strike and for the period after the hunger strike ended where the record established that the decision to terminate plaintiff's visitation privileges was lawfully made during the time at issue. Accordingly, the court reversed and remanded. View "Jackson v. Humphrey" on Justia Law

Plaintiff, a federal prisoner and a Santeria priest, filed suit against prison employees, alleging violations of the First Amendment and the Religious Freedom Restoration Act (RFRA), 42 U.S.C. 2000bb. Plaintiff sought injunctive and monetary relief, claiming that defendants violated his rights by refusing to allow him to receive his Santeria beads and shells. The court concluded that the district court erred in granting summary judgment on plaintiff's claim for injunctive relief under RFRA where the prison has offered no evidence to justify its cost and safety concerns. Defendants' generalized statement of interests, unsupported by specific and reliable evidence, is not sufficient to show that the prison restriction furthered a compelling governmental interest. The court affirmed the district court's dismissal of plaintiff's claims for money damages under RFRA and grant of summary judgment to defendants on the First Amendment claims. View "Davila v. Gladden" on Justia Law

Plaintiffs filed suit claiming that Fayette County's at-large election system violated Section 2 of the Voting Rights Act, 52 U.S.C. 10301, by effectively guaranteeing that no African-American would be able to participate in the political process through election to the Board of Commissioners (BOC) and the Board of Education (BOE), nor would African-American voters be able to elect representatives of their choice to either entity. The district court granted summary judgment in plaintiffs' favor, finding that the at-large election method used by both the BOC and BOE resulted in impermissible vote dilution. However, the court concluded that the district court failed to notice the BOE that it was considering awarding summary judgment against it; the district court weighed the evidence submitted by the moving parties, accepting the support proffered by plaintiffs and rejecting the contrary evidence presented by the BOC; and, therefore, without opining as to the correctness of the district court's substantive conclusions, the district court erred in its Section 2 determination on summary judgment. Accordingly, the court vacated and remanded for further proceedings. View "Georgia State Conference of the NAACP v. Fayette Cnty. Bd. of Comm'rs" on Justia Law

Plaintiffs filed suit under 42 U.S.C. 1983, alleging that Alabama's ballot access statute violates their First and Fourteenth Amendment rights. The court concluded that the district court properly granted summary judgment to the Secretary and adopted much of the district court's reasoning contained in its memorandum opinion and order. The court held that plaintiffs' constitutional claims failed where plaintiffs did not present evidence showing that the legitimate, nondiscriminatory reasons for the State's restrictions on petition-based ballot access unconstitutionally burdens their associational rights. Rather, the burden on plaintiffs was slight, and the State's interests in treating all political parties fairly and in setting a deadline that provides sufficient time to verify the petition signatures outweigh the burden to plaintiffs' associational rights. Accordingly, the court affirmed the district court's judgment. View "Stein v. AL Secretary of State" on Justia Law

Plaintiff filed suit against the State, challenging the constitutionality of Fla. Stat. 414.0652, which requires suspicionless drug testing of all applicants seeking Temporary Assistance for Needy Families (TANF). The court granted a preliminary injunction barring the application of the statute against plaintiff and the State stopped the drug-testing program. Then the district court granted final summary judgment to plaintiff, declaring the statute unconstitutional and permanently enjoined its enforcement. The court concluded that the State failed to meet its burden of establishing a substantial special need to drug test all TANF applicants without any suspicion; even viewing the facts in the light most favorable to the nonmoving party, the State has not demonstrated a more prevalent, unique, or different drug problem among TANF applicants than in the general population; the ordinary government interests claimed in this case are nothing like the narrow category of special needs that justify blanket drug testing of railroad workers, certain federal Customs employees involved in drug interdiction or who carry firearms, or involve surpassing safety interests; and the State cannot circumvent constitutional concerns by requiring that applicants consent to a drug test to receive TANF payments. Accordingly, the court affirmed the judgment. View "Lebron v. Secretary of the FL Dept. of Children and Families" on Justia Law

Kawa filed suit challenging the Treasury's decision to postpone the enforcement of the employer mandate provisions of the Patient Protection and Affordable Care Act (ACA), 26 U.S.C. 4980H, and sought a declaratory judgment and injunction setting aside the Treasury's transition relief. Kawa had expended time and money to determine how to comply with the employer mandate between early 2013 and the end of June 2013. After Kawa incurred these expenses, the Treasury announced it would not enforce the mandate for a transition period of one year - until the end of 2014. The Treasury then extended the transition relief for certain employers, including Kawa, for a second year. The court affirmed the district court's dismissal of the complaint because Kawa lacked Article III standing where Kawa failed to allege an injury in fact, a causal connection, and a likelihood of success. View "Kawa Orthodontics, LLP v. Secretary, U.S. Dept. of the Treasury, et al." on Justia Law