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

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

On remand from the Supreme Court for further proceedings regarding a sovereign immunity issue, the court reviewed the district court's conclusion that plaintiff's official-capacity claim against the former president of CACC for equitable relief was barred by the Eleventh Amendment. In this case, plaintiff seeks equitable relief in the form of reinstatement of his employment and such relief falls within the scope of the Ex parte Young exception and is not barred by the Eleventh Amendment. In light of the court's reinstatement precedents, the court concluded that the district court erred in dismissing plaintiff's official-capacity claim against the president as barred by the Eleventh Amendment. View "Lane v. Central Alabama Community College, et al." on Justia Law

Plaintiff filed suit seeking declaratory and injunctive relief against a Georgia post-judgment garnishment statute. Plaintiff obtained funds from a workers' compensation settlement after suffering a permanent disability on the job. Plaintiff also received Social Security disability payments. One of plaintiff's creditors issued a garnishment summons that resulted in the freezing of plaintiff's worker's compensation funds for four months before plaintiff's creditor finally conceded that plaintiff's funds were exempt from garnishment and agreed to the dissolution of the hold on his funds. The court concluded that plaintiff had Article III standing and that his claim is not moot. The court declined to pass on the constitutionality of Georgia's post-judgment garnishment statute before ensuring that all interested parties have had notice and a chance to present all evidence and argument, and the district court has had an opportunity to examine and consider that evidence and argument on the merits. Accordingly, the court reversed the district court's sua sponte dismissal of plaintiff's suit for lack of standing and remanded, because it was substantially likely that plaintiff and his wife's exempt funds will soon be the subject of a garnishment summons again. View "Strickland v. Alexander, et al." on Justia Law