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

Articles Posted in Government & Administrative Law
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The case involves Purpose Built Families Foundation, a Florida nonprofit that received federal grants from the Department of Veterans Affairs to serve veterans and their families. In 2022, the Department notified the Foundation that activities and payments under five grants would be terminated or withheld due to "major fiscal mismanagement activities". The Foundation sued the Secretary of Veterans Affairs under the Administrative Procedure Act and received a temporary restraining order. Subsequently, the Department withdrew the challenged notices and the Secretary moved to dismiss the action as moot. The district court granted the motion.The United States Court of Appeals for the Eleventh Circuit affirmed the decision of the district court. The court held that the case was moot, as the Department's withdrawal of the notices meant the Foundation's claims could not provide meaningful relief. It also ruled that neither the voluntary-cessation nor the capable-of-repetition-yet-evading-review exceptions to mootness applied. The court stated that the Department's subsequent actions, including a more robust process and new termination notices, were materially different from the original notices. Therefore, a lawsuit challenging the new termination notices would involve materially different allegations and answers. The court concluded that the Foundation would have ample opportunity for judicial review of the legality of the new terminations, once the administrative process was completed. View "Purpose Built Families Foundation, Inc. v. USA" on Justia Law

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In this case decided by the United States Court of Appeals for the Eleventh Circuit, Raquan Emahl Gray was convicted of conspiracy to commit a controlled-substances offense, after helping transport a car filled with drugs to a state prison. Gray appealed his conviction, arguing that the government failed to prove that he knowingly possessed a Schedule II controlled substance, namely methamphetamine, rather than a controlled substance generally. The appeals court affirmed Gray's conviction, holding that the government only needed to prove general knowledge to obtain a controlled-substances conviction, which it did. Gray also argued that the district court erred when it denied his renewed motion for judgment of acquittal due to his failure to timely renew the motion at the conclusion of the evidence. The appeals court acknowledged that Gray's renewed motion was timely, but deemed the district court's error as harmless because enough evidence supported Gray's conviction. View "United States v. Gray" on Justia Law

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Inmate Germaine Smart alleged that prison officials Ronald England, Gary Malone, and Larry Baker violated his First Amendment rights by retaliating against him for reporting an alleged sexual assault by England. Smart claimed that England sexually assaulted him during a pat-down search, but after an internal investigation, Smart's allegations were found to be unfounded and England charged Smart with lying. The United States Court of Appeals for the Eleventh Circuit ruled that the officials did not violate Smart's First Amendment rights. The court stated that a prisoner's violation of a prison regulation is not protected by the First Amendment, and in this case, the prison tribunal's finding that Smart lied, which was based on due process and some evidence, was conclusive. Therefore, the officials were entitled to qualified immunity. View "Smart v. England" on Justia Law

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In the case before the United States Court of Appeals for the Eleventh Circuit, the plaintiff, Taquila Monroe, was a former employee of Fort Valley State University's Head Start and Early Head Start department. She sued the Board of Regents of the University System of Georgia (the "Board") under the False Claims Act's (FCA) anti-retaliation provision, alleging that she was terminated for reporting mismanagement and misuse of federal and state funds meant for the Head Start programs. The district court granted the Board's motion to dismiss, citing the Board's sovereign immunity. The central issue on appeal was whether the FCA's anti-retaliation provision abrogates sovereign immunity for lawsuits against states, and whether the Board is an arm of the state entitled to the same immunity.The Eleventh Circuit affirmed the district court's decision. The court concluded that Congress did not unequivocally express its intent to subject states to suits under the FCA's anti-retaliation provision, and therefore did not abrogate sovereign immunity. The court also held that the Board is an arm of the state and thus entitled to sovereign immunity. In reaching these conclusions, the court considered how Georgia law defines the Board, the degree of control the state exercises over the Board, the Board's source of funding, and who would be responsible for a judgment against the Board. The court found that all of these factors pointed to the Board being an arm of the state that is entitled to sovereign immunity. View "Monroe v. Board of Regents of the University System of Georgia" on Justia Law

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In a case heard by the United States Court of Appeals for the Eleventh Circuit, plaintiffs Jennifer Dupree and Detrich Battle challenged the dismissal of their Title V claims under the Americans with Disabilities Act (ADA) on the basis of sovereign immunity. Dupree, who worked for the Georgia Department of Human Services, and Battle, an employee of the Georgia Department of Corrections, had requested accommodations at their respective workplaces due to their health conditions. After their requests were denied and their employment terminated, they filed claims under Title V, alleging retaliation.The court, however, found that sovereign immunity applies to Title V claims when brought in conjunction with Title I claims. This meant that the plaintiffs' claims could not proceed. Importantly, the court clarified that dismissals based on sovereign immunity, a jurisdictional issue, should be entered without prejudice. Not specifying this in the dismissal could lead to misunderstandings about the nature of the dismissal. Therefore, the court vacated and remanded the case for the limited purpose of allowing the district court to dismiss the case without prejudice. View "Dupree v. Owens" on Justia Law

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In the case before the United States Court of Appeals for the Eleventh Circuit, Young Israel of Tampa, Inc., an Orthodox Jewish synagogue, sued the Hillsborough Area Regional Transit Authority (HART) for rejecting its proposed advertisement for a Chanukah on Ice event. The synagogue argued that HART’s policy, which prohibited advertisements that “primarily promote a religious faith or religious organization,” violated the Free Speech Clause of the First Amendment. The district court granted summary judgment in favor of Young Israel on two grounds: 1) HART’s policy violated the First Amendment because it discriminated on the basis of viewpoint, and 2) even if the policy was viewpoint neutral, it was unreasonable because it lacked objective and workable standards and was inconsistently and haphazardly applied. The court subsequently issued a permanent injunction against HART, prohibiting it from rejecting any advertisement on the ground that it primarily promotes a religious faith or religious organization, including any future policies.On appeal, the Eleventh Circuit affirmed the district court’s decision, but on narrower grounds. The appellate court concluded that HART's policy was unreasonable under the Supreme Court's decision in Minnesota Voters Alliance v. Mansky because it failed to define key terms, lacked any official guidance, and vested too much discretion in those who applied it. The court declined to address the question of whether the policy constituted impermissible viewpoint discrimination. However, the court concluded that the permanent injunction issued by the district court needed to be revised to apply only to HART’s current policy, rather than any future policies, and remanded the case to the district court for that purpose. View "Young Israel of Tampa, Inc. v. Hillsborough Area Regional Transit Authority" on Justia Law

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In this case, the United States Court of Appeals for the Eleventh Circuit reviewed an appeal of a lower court's denial of qualified immunity to a jail intake officer, Keyvon Sellers. The case arose from an incident in which a black man, Jayvon Hatchett, attacked and killed his white cellmate, Eddie Nelson, in county jail. Before the attack, Hatchett had told Sellers that he had previously stabbed a white man after watching videos of white police officers shooting black men. Despite this admission, Sellers did not inform other jail staff of Hatchett's racially motivated violence. Nelson's survivors sued Sellers, alleging that his failure to share this information constituted deliberate indifference to a substantial risk of serious harm to Nelson, in violation of the Fourteenth Amendment.The Court of Appeals affirmed the district court's decision, finding that a reasonable jury could conclude that Sellers violated Nelson's clearly established constitutional right by failing to protect him from a known risk of harm. The court concluded that Sellers had fair warning that his inaction was unconstitutional. Therefore, he was not entitled to qualified immunity. View "Nelson v. Sellers" on Justia Law

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In this appeal, Marcus Raper contested the Social Security Administration’s (SSA) 2020 denial of his claim for disability insurance benefits. Raper raised three arguments: (1) that the administrative law judge's (ALJ) initial lack of constitutional appointment under the Appointments Clause tainted his later constitutionally appointed review of his case, (2) that the ALJ failed to clearly articulate good cause for not fully crediting his treating physician’s medical opinion, and (3) that the ALJ wrongly discredited his subjective complaints of pain by not properly considering evidence other than objective medical evidence.The United States Court of Appeals for the Eleventh Circuit affirmed the lower court’s decision. First, the court found no Appointments Clause violation as the ALJ's initial decision, made when he was unconstitutionally appointed, had been vacated on the merits and the case was remanded to the same ALJ who was then constitutionally appointed. Second, the court held that the ALJ articulated good cause for discounting Raper's treating physician’s opinion, finding the opinion inconsistent with the record. Lastly, the court found that the ALJ had properly considered Raper’s subjective complaints in light of the record as a whole and adequately explained his decision not to fully credit Raper’s alleged limitations on his ability to work. View "Raper v. Commissioner of Social Security" on Justia Law

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The U.S. Court of Appeals for the Eleventh Circuit considered an appeal by Mark Meadows, former White House chief of staff under President Donald Trump, who sought to move his state criminal prosecution to federal court. The state of Georgia had indicted Meadows for crimes related to alleged interference in the 2020 presidential election. Meadows argued that because these actions were taken in his official capacity, they should be heard in federal court according to the federal-officer removal statute (28 U.S.C. § 1442(a)(1)). The district court denied this request because Meadows' charged conduct was not performed under the color of his federal office. The court of appeals affirmed this decision. It ruled that the federal-officer removal statute does not apply to former federal officers and even if it did, the alleged actions leading to this criminal action were not related to Meadows’ official duties. The court concluded that the former chief of staff’s role does not include influencing state officials with allegations of election fraud or altering valid election results in favor of a particular candidate, regardless of the chief of staff's role with respect to state election administration. Therefore, Meadows was not entitled to invoke the federal-officer removal statute. View "The State of Georgia v. Meadows" on Justia Law

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The United States Court of Appeals for the Eleventh Circuit held that the United States District Court lacked subject matter jurisdiction to review the Drug Enforcement Administration's (DEA) denial of a church's petition for a religious exemption from the Controlled Substances Act (CSA). The Soul Quest Church of Mother Earth, Inc. petitioned the DEA for an exemption to the CSA so it could lawfully use and handle a sacramental tea known as ayahuasca, which contains a controlled substance, Dimethyltryptamine (DMT). The DEA denied the petition, concluding that the church had not met its burden under the Religious Freedom Restoration Act (RFRA) to show that its members' beliefs were sincerely held and that its use of ayahuasca was part of a religious exercise. The DEA also found compelling governmental interests in maintaining public safety and preventing diversion of the tea into improper channels. The DEA's denial of the petition was deemed a final decision made under the CSA, thereby triggering the jurisdictional bar of 21 U.S.C. § 877. The court ruled that because the DEA's decision was made under the CSA, the district court lacked subject matter jurisdiction to review the denial on the merits. The court also held that Soul Quest's additional constitutional, statutory, and procedural claims were "inescapably intertwined" with the DEA's final decision, making the CSA's jurisdictional bar applicable to those claims as well. View "Soul Quest Church of Mother Earth, Inc. v. Attorney General of the United States" on Justia Law