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

Plaintiff brought suit against her former employer under the Age Discrimination in Employment Act, 29 U.S.C. 621 et seq., after she was terminated. The district court granted summary judgment in favor of the employer because plaintiff did not present sufficient evidence from which a jury could conclude that the employer's proffered nondiscriminatory reason for the termination - that plaintiff violated (or appeared to violate) the company's conduct policies - was pretextual. In this case, the corporate executive who terminated plaintiff later said that she was an exceptional employee who had done nothing wrong, had done everything right, and should not have been fired. The court held that such evidence, when combined with a prima facie case, created a jury question as to discrimination. Accordingly, the court reversed and remanded. View "Kragor v. Takeda Pharmaceuticals America" on Justia Law

The Board challenged the district court's determination affirming the validity of a Department of Education regulation that required state and local agencies to reimburse parents and guardians for an independent educational evaluation (IEE) of their children with disabilities. The court held that the Secretary of Education did not exceed its authority in promulgating 34 C.F.R. 300.502, providing parents the right to a publicly financed IEE and therefore, the district court did not err in requiring the Board to reimburse plaintiffs for the IEE that they obtained for their child. View "Phillip C., et al v. Jefferson County Board of Education" on Justia Law

Plaintiff sued defendant under 42 U.S.C. 1983, alleging that her termination was unconstitutional under the First Amendment because it was based on her candidacy. The court held that the First Amendment, as interpreted by the Supreme Court and the Eleventh Circuit, did not require defendant to retain her political opponent after becoming superior court clerk for the county. Accordingly, the court affirmed the district court's grant of summary judgment in favor of defendant. View "Underwood v. Harkins, et al" on Justia Law

In 2010, the Commissioner issued four summonses to third-party financial institutions to determine whether the Miccosukee Tribe had complied with its federal withholding requirements during the period from 2006-2009. The Tribe petitioned to quash the summonses on the grounds of sovereign immunity, improper purpose, relevance, bad faith, and overbreadth. The district court denied those petitions. Because the court concluded that tribal sovereign immunity did not bar the issuance of these third-party summonses, the district court did not clearly err when it found that the summonses were issued for a proper purpose, and the Tribe lacked standing to challenge the summonses for overbreadth, the court affirmed the judgment. View "Miccosukee Tribe of Indians v. United States" on Justia Law

Petitioner, a death row inmate, appealed the district court's denial of his petition for writ of habeas corpus brought pursuant to 28 U.S.C. 2254. Petitioner contended that he was denied a fair trial by an impartial judge and unbiased jury because the jury gave the judge and the bailiff inappropriate gag gifts at the conclusion of the trial. Specifically, some jurors gave the judge chocolate candy in the shape of a penis and a bailiff chocolate candy shaped as female breasts. Petitioner also contended that there was racial discrimination in the selection of the jury. The court held that it was not unreasonable for the Georgia Supreme Court to find that petitioner did not prove purposeful discrimination by the state in the selection of the jury. The court also held, without condoning the regrettable behavior of either, that both the jury and the judge remained impartial and unbiased throughout the trial. Accordingly, the court affirmed the district court's denial of habeas relief. View "Wellons v. Warden, Georgia Diagnostic and Classification Prison" on Justia Law

Plaintiffs, individually and on behalf of all others similarly situated, brought these actions against defendants for injunctive relief and damages under 42 U.S.C. 1983. Plaintiffs alleged that the FDOT promulgated a policy of "detaining" motorists in violation of the Fourth and Fourteenth Amendments. The court held that the complaint allegations did not state a constitutional violation; defendants were entitled to qualified immunity; and summary judgment of the district court denying qualified immunity to defendants was reversed and the case remanded with instructions to dismiss. View "Chandler v. Secretary, FL DOT, et al" on Justia Law

Plaintiff appealed summary judgment in favor of her former employer and against her complaint of discrimination in violation of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101, and Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e. At issue was whether the employer was entitled to sovereign immunity. The court held that the employer was a state agency immune from plaintiff's complaint of disability discrimination and that the district court correctly granted summary judgment against plaintiff's complaint of racial discrimination where plaintiff unequivocally answered "no" when she was asked if her termination had anything to do with her race. View "Ross v. Jefferson Co Dept of Health" on Justia Law

Petitioner, a Honduran national, appealed the denial of his petition for a writ of habeas corpus. This appeal involved the constitutional separation of powers and the limited judicial role in the extradition of a foreign national. On appeal, petitioner contended that the United Nations Convention Against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment barred his extradition by the Secretary of State, that the murder of the victim constituted a political offense for which he could not be extradited, and there was no valid extradition treaty in force between Honduras and the United States. The court held that petitioner's first argument was not ripe because the Secretary of State has not yet determined whether he was likely to be tortured nor decided whether to extradite him, and his other arguments lacked merit. Accordingly, the court vacated in part and affirmed in part the denial of petitioner's petition for a writ of habeas corpus, lifted the stay of the extradition proceedings, and remanded with instructions to dismiss petitioner's claim under the Convention Against Torture. View "Meza v. U.S. Attorney General, et al." on Justia Law

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

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