Justia U.S. 11th Circuit Court of Appeals Opinion Summaries
Articles Posted in Constitutional Law
Ault, et al. v. Walt Disney World Co., et al.
Objectors appealed the district court's approval of a class action settlement. The underlying case involved allegations that Disney violated Title III of the Americans with Disabilities Act, 42 U.S.C. 12182 et seq., by implementing a policy that banned the use of two-wheeled vehicles, including Segways, by customers within its park and hotels, without exception. The court held that the district court did not abuse its discretion in certifying the class and in approving the settlement. Accordingly, the court affirmed the settlement orders. View "Ault, et al. v. Walt Disney World Co., et al." on Justia Law
Countour Spa at the Hard Rock, v. Seminole Tribe of Florida, et al.
This case arose out of a leasing agreement between Contour and the Seminole Tribe. Contour appealed from a district court order dismissing its Amended Complaint for lack of subject matter jurisdiction on account of the Tribe's sovereign immunity. The district court rejected Contour's arguments and affirmed the judgment. Because the problems of inconsistency and unfairness that were inherent in the procedural posture of Lapides v. Bd. of Regents of the Univ. Sys. of Ga. were absent in this case, and because an Indian tribe's sovereign immunity was of a far different character than a state's Eleventh Amendment immunity, the court declined to extend Lapides. In regards to Contour's Indian Civil Rights Act, 25 U.S.C. 1301-1303, claim, it must fail because the Supreme Court had already held that Indian tribes were immune from suit under the statute. Finally, in regards to the equitable estoppel claim, that claim was unavailable because it was grounded on a waiver provision contained within a lease agreement that was wholly invalid as a matter of law. View "Countour Spa at the Hard Rock, v. Seminole Tribe of Florida, et al." on Justia Law
United States v. State of Alabama, et al.
This appeal involved challenges to ten provisions of Alabama's House Bill 56, the "Beason-Hammon Alabama Taxpayer and Citizen Protection Act" (H.B. 56). The stated purpose of the legislation was to discourage illegal immigration within the state and maximize enforcement of federal immigration laws through cooperation with federal authorities. The court found that the United States was likely to succeed on the merits of its challenges to sections 10, 11(a), 13(a), 16, 17, and 27 of H.B. 56. The court agreed with the United States that it was not likely to succeed on the merits of its challenge to section 12(a) or section 18 at this time. The court also found that the United States had not shown at this stage that it was likely to succeed on the merits of its challenge to section 30. Finally, the court dismissed the United States' appeal as to section 28 as moot, as the court's opinion in the private plaintiffs' companion case fully disposed of that issue. View "United States v. State of Alabama, et al." on Justia Law
Georgia Latino Alliance for Human Rights, et al. v. Governor of Georgia, et al.
Defendants appealed the district court's order granting plaintiffs' motion and preliminarily enjoined enforcement of sections 7 and 8 of House Bill 87, the Illegal Immigration Reform and Enforcement Act of 2011 (H.B. 87), on the ground that each was preempted by federal law. H.B. 87 was enacted to address the problem of illegal immigration within the state. The court held that section 7 could not be reconciled with the federal immigration scheme or the individual provisions of the Immigration and Nationality Act (INA), 8 U.S.C. 1101 et seq. Accordingly, the court affirmed in part the district court's order preliminarily enjoining enforcement of section 7. The court reversed in part the portion of that order enjoining section 8. View "Georgia Latino Alliance for Human Rights, et al. v. Governor of Georgia, et al." on Justia Law
Hispanic Interest Coalition of Alabama, et al. v. Governor of Alabama, et al.
Plaintiffs challenged various provisions of Alabama's House Bill 56, the "Beason-Hammon Alabama Taxpayer and Citizen Protection Act" (H.B. 56). Because the court found that the United States was likely to succeed on its claims that sections 10 and 27 of H.B. 56 were preempted, the court dismissed the HICA plaintiffs' appeal as to those sections as moot. The court vacated as moot the district court's injunction of section 8 and remanded for the dismissal of the challenge to that section, as the statutory amendment had removed the challenged language. In light of the court's decision on the substantive provisions of sections 10, 11, and 13, the court vacated as moot the district court's order insofar as it preliminarily enjoined the last sentence of sections 10(e), 11(e), and 13(h). The court found that at least one of the HICA plaintiffs had standing to challenge section 28 and that it violated the Equal Protection Clause. Therefore, the court reversed the district court's decision and remanded for the entry of a preliminary injunction. Finally, the court concluded, for reasons stated in the United State's companion cases, Nos. 11-14532, 11-14674, that the HICA plaintiffs could not succeed on the merits of their facial challenges to sections 12, 18, and 30 at this time. View "Hispanic Interest Coalition of Alabama, et al. v. Governor of Alabama, et al." on Justia Law
Seff v. Broward County, Florida
Plaintiff appealed the district court's grant of summary judgment in a class action suit alleging that Broward County's employee wellness program violated the Americans with Disabilities Act of 1990 (ADA), 42 U.S.C. 12101 et seq. Plaintiff alleged that the wellness program's biometric screening and online Health Risk Assessment questionnaire violated the ADA's prohibition on non-voluntary medical examinations and disability-related inquiries. The court held that the district court did not err in finding as a matter of law that the wellness program was a "term" of Broward County's group health insurance plan, such that the wellness program fell within the ADA's safe harbor provision. View "Seff v. Broward County, Florida" on Justia Law
Kuenzel v. Ala. Dept. of Correct.
Petitioner William Ernest Kuenzel, a state prisoner, appealed the district court’s dismissal of his habeas corpus petition under 28 U.S.C. section 2254. Because Petitioner’s claims are procedurally barred under state law and he has made no attempt to demonstrate cause for (or prejudice from) his default, Petitioner could not obtain relief without properly supporting a claim of actual innocence. Petitioner was unable to carry this burden; so the Eleventh Circuit affirmed the dismissal of his petition. View "Kuenzel v. Ala. Dept. of Correct. " on Justia Law
Ponticelli v. Florida Dept. of Corrections
Petitioner-Appellant Anthony Ponticelli, a death row inmate in the Florida Department of Corrections, raised two issues about the denial of his petition for the writ of habeas corpus: (1) the prosecution violated his right to due process when it allegedly suppressed evidence of and failed to correct false testimony about an agreement to provide immunity for a witness for the state and about Petitioner's use of cocaine shortly before the murders; (2) his trial counsel provided ineffective assistance of counsel by failing to present evidence of his incompetence to stand trial and by failing to present mitigating evidence of drug use and mental health problems during the penalty phase. Upon review, the Eleventh Circuit concluded both of Petitioner's arguments failed: the Florida Supreme Court reasonably determined the underlying facts as to the first issue; and on both issues, neither contravened nor unreasonably applied clearly established federal law. Accordingly, the Court affirmed the denial of Petitioner's petition for the writ. View "Ponticelli v. Florida Dept. of Corrections" on Justia Law
Dormescar v. Holder, Jr.
Petitioner Odulene Dormescar, a native and citizen of Haiti, appealed a removal order issued by an immigration judge because he had been convicted of an aggravated felony. The Board of Immigration Appeals dismissed his appeal of that order. He has petitioned the Eleventh Circuit for review. His petition presented three issues: (1) whether the Eleventh Circuit had subject matter jurisdiction; if it did, then the second (2) issue was whether res judicata barred the Department of Homeland Security’s proceedings against Petitioner based on the aggravated felony conviction. If it did not, the third (3) issue was whether the Department had the authority to amend the notice to appear to charge Petitioner as "admitted to the United States, but . . . removable" when he was originally charged as an inadmissible "arriving alien." Upon review, the Eleventh Circuit concluded that it had jurisdiction over this case, res judicata did not apply, and that the Department had the authority to amend the notice to appear to charge Petitioner as admitted but removable. View "Dormescar v. Holder, Jr." on Justia Law
United States v. Mathurin
Defendant-Appellant James Mathurin was convicted of a number of armed robbery and weapons charges. These convictions resulted from a five-month-long crime spree in Miami-Dade County that took place when Defendant was seventeen-years-old. On appeal, Defendant challenged his convictions on a number of grounds, one of which is that the government violated his rights under the Speedy Trial Act. The narrow question on appeal before the Eleventh Circuit was whether the time during which plea negotiations are conducted is automatically excludable from the Speedy Trial Act’s thirty-day window for filing an information or indictment. After review, the Court concluded that the time during which plea negotiations are conducted are not automatically excludable. Therefore, the Court reversed the District Court’s denial of Defendant's motion to dismiss, vacated his convictions, and remanded the case to the District Court with instructions to determine whether dismissal of the charges should be with or without prejudice. View "United States v. Mathurin" on Justia Law