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

The case concerns Tia Deyon Pugh, who was charged with impeding law enforcement during a civil disorder in violation of 18 U.S.C. § 231(a)(3) during a protest in Mobile, Alabama. She smashed a police car window with a baseball bat, thus obstructing law enforcement officers in their official duties during the civil disorder. Pugh challenged the constitutionality of Section 231(a)(3) on four grounds, arguing that it: (1) exceeds Congress’s power to legislate under the Commerce Clause, (2) is a substantially overbroad regulation of activities protected by the First Amendment, (3) is a content-based restriction of expressive activities in violation of the First Amendment, and (4) is vague in violation of the Fifth Amendment’s Due Process Clause. The district court rejected these arguments, and Pugh was found guilty by a jury.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed Pugh’s conviction. The court held that Section 231(a)(3) does not exceed Congress's power under the Commerce Clause as the statute's jurisdictional element is sufficient to limit its scope to constitutional applications. The court also found that the statute does not violate the First Amendment as it does not broadly prohibit protected speech and expressive conduct. Furthermore, the court ruled that the statute is not a content-based restriction and does not violate the Fifth Amendment's Due Process Clause due to vagueness. The court concluded that the statute constitutionally applies to Pugh's conduct, and she may not challenge the statute on vagueness grounds based on its application to others. View "USA v. Pugh" on Justia Law

In this case heard by the United States Court of Appeals for the Eleventh Circuit, the appellant, Kai Hansjurgens, contested the revival of a bankruptcy judgment against him in favor of Donald Bailey. More than a decade earlier, Bailey had obtained a bankruptcy judgment against Hansjurgens for tortious interference with a contract, which Hansjurgens had not paid. To prevent the judgment from expiring under Georgia law, Bailey filed a motion to revive the judgment, which was granted by the bankruptcy court. Hansjurgens argued that the revival proceedings violated his due process rights and did not strictly comply with Georgia's scire facias procedures, which are used to revive dormant judgments.The court found that the Federal Rules of Civil Procedure, specifically Rule 69(a), only require the revival proceedings to "accord with" or substantially comply with state procedures, rather than strictly comply. The court further noted that the purpose of scire facias, providing notice to the party and an opportunity to present objections, had been served through mailed notices to Hansjurgens at several addresses. The court also observed that Georgia's scire facias procedures did not fit squarely within the federal court system, and requiring strict compliance would be impractical.Therefore, the court held that the bankruptcy court had properly revived the judgment and that the proceedings did not violate due process. It affirmed the district court's revival order. View "Hansjurgens v. Bailey" on Justia Law

The United States Court of Appeals for the Eleventh Circuit considered whether consumers can recover statutory damages under the Fair Credit Reporting Act (FCRA) without proving actual damages caused by a consumer reporting agency's willful violation of the Act. The case was brought by plaintiffs Omar Santos and Amanda Clements on behalf of a class of individuals, against Experian Information Solutions, Inc. The plaintiffs alleged that Experian willfully violated its obligation under the FCRA to ensure consumer credit reports were prepared with maximum possible accuracy, allowing credit reports to reflect inaccurately updated status dates. The district court denied class certification, holding that the FCRA required proof of actual damages.The Eleventh Circuit vacated and remanded the district court's decision, holding that consumers do not need to prove actual damages to recover statutory damages under the FCRA. The court found that the FCRA allows consumers to recover damages of not less than $100 and not more than $1,000 for a willful violation of the Act, regardless of whether they can prove actual damages. The court cited the plain language of the Act, the structure of the statute, and the Act's legislative history in reaching its decision. The court also noted that its interpretation was consistent with the holdings of other circuit courts that have addressed this issue. The case was remanded for further proceedings consistent with this interpretation. View "Santos v. Experian Information Solutions, Inc." on Justia Law

A decision from the United States Court of Appeals for the Eleventh Circuit concerned whether the Governor of Florida, Ron DeSantis, violated the First Amendment rights of Andrew Warren, a state attorney for Florida’s Thirteenth Judicial Circuit, when he suspended Warren from office. Warren, a vocal advocate for criminal justice reform, had been elected to his position twice. During his time in office, he implemented several policies and signed onto advocacy statements related to issues such as transgender health care and abortion rights. Governor DeSantis suspended Warren from his position, justifying the decision on the basis of these activities. Warren sued, claiming that the suspension was retaliation for his First Amendment-protected activities. The district court found that six factors motivated DeSantis to suspend Warren, two of which were protected by the First Amendment. However, the court concluded that DeSantis would have suspended Warren regardless of these protected activities, basing this conclusion on the other four factors. On appeal, the Eleventh Circuit found that the district court erred in not considering all of Warren's activities as protected by the First Amendment. The court emphasized that, as an elected official, Warren had a right to express his views on policy matters of public concern and that his suspension based on these expressions violated his First Amendment rights. The court vacated the district court's decision and remanded the case for further proceedings. View "Warren v. DeSantis" on Justia Law

The United States Court of Appeals for the Eleventh Circuit considered two petitions for review brought by Hunt Refining Company against decisions made by the U.S. Environmental Protection Agency (EPA). The EPA had denied Hunt's petitions for hardship exemptions under the Renewable Fuel Standard (RFS) program, part of the Clean Air Act that mandates most oil refineries in the U.S. to blend a certain quantity of renewable fuels into their transportation fuels each year. Small refineries can petition for exemption from these requirements if compliance would cause them "disproportionate economic hardship." The EPA's denial of Hunt's petitions was based on a new interpretation of the statutory provision and a new economic theory applicable to all small refineries, regardless of their location or market.The Eleventh Circuit held that Hunt's petitions for review should have been filed in the United States Court of Appeals for the District of Columbia because the EPA actions challenged were "nationally applicable." In other words, they applied a consistent statutory interpretation and economic analysis to small refineries across the country. The court dismissed Hunt's petitions, given that Hunt had already filed protective petitions for review of the same EPA decisions in the D.C. Circuit, which were currently being briefed on the merits. View "Hunt Refining Company v. U.S. Environmental Protection Agency" on Justia Law

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

The United States Court of Appeals for the Eleventh Circuit partially affirmed and partially reversed a lower court's ruling in a case involving James McDonough, a citizen activist, who was banned from future meetings and arrested for disorderly conduct and cyberstalking by the City of Homestead, Florida. McDonough claimed these actions violated his First and Fourth Amendment rights.The court determined that the city council meetings were designated public forums, and the ban was not narrowly tailored to serve a significant government interest as required, thus violating McDonough's First Amendment rights.The court also found that the officers did not have probable cause to arrest McDonough for disorderly conduct, which involved swearing at officers and making obscene gestures. The court stated that such actions do not constitute disorderly conduct and are protected under the First Amendment. However, the court ruled that the City had probable cause to arrest McDonough for cyberstalking, as it was not unreasonable for the City to interpret Florida’s cyberstalking statute as barring McDonough from targeting one of its officers with his series of posts.The case was sent back to the lower court for further proceedings consistent with the appellate court’s opinion. View "McDonough v. Garcia" on Justia Law

The United States Court of Appeals for the Eleventh Circuit vacated and remanded a decision by the United States District Court for the Northern District of Florida, which had ruled against Andrew Warren, a Florida State Attorney for the Thirteenth Judicial Circuit. Warren had filed a lawsuit against Governor Ron DeSantis, claiming that DeSantis had suspended him in retaliation for his First Amendment activity. The circuit court agreed with the district court that Warren had satisfied his initial burden of showing that he had engaged in protected activity, suffered an adverse action, and that DeSantis's actions were motivated by Warren's protected activity. However, the circuit court disagreed with the district court's conclusion that the First Amendment did not protect certain activities that motivated DeSantis's decision, and found that the district court erred in concluding that DeSantis would have suspended Warren based solely on unprotected activities. The case was remanded for the district court to reconsider whether DeSantis would have made the same decision based solely on the unprotected activities. View "Warren v. DeSantis" on Justia Law

This case revolves around Kenneth Bailey's lawsuit against Deputy Shawn Swindell, claiming that Swindell violated his civil rights when he tackled Bailey through the door of Bailey's parents' home and arrested him without a warrant or exigent circumstances. Bailey's suit was filed under Section 1983. The United States District Court for the Northern District of Florida initially granted summary judgment in favor of Swindell based on qualified immunity. However, the United States Court of Appeals for the Eleventh Circuit reversed this decision, concluding that Swindell violated clearly established law when he entered Bailey's parents' home to arrest him without a warrant or exigent circumstances, and was therefore not entitled to qualified immunity.On remand, the case went to trial and the jury returned a verdict for Bailey, awarding him $625,000 for his injuries. However, the district court later granted Swindell's motion for judgment as a matter of law, setting aside the jury's verdict. Bailey appealed this decision.The Eleventh Circuit reversed the district court's grant of judgment as a matter of law. The appellate court found that the jury's factual findings, including that the arrest was initiated outside the home but no exigent circumstances existed allowing for a warrantless entry into the home, should have been used by the district court in making its legal conclusions about qualified immunity. The court emphasized that it was clearly established that an officer violates the Constitution by initiating an arrest outside of a home and then entering the home without a warrant to complete the arrest in the absence of exigent circumstances. Therefore, Swindell was not entitled to qualified immunity, and the jury's verdict in favor of Bailey should be reinstated. View "Bailey v. Swindell" on Justia Law

In 1993, Anthony Mungin was convicted of first-degree murder and sentenced to death. Mungin argued that his lawyer was ineffective during the guilt phase of his trial. In the United States Court of Appeals for the Eleventh Circuit, Mungin presented four claims of ineffective assistance of counsel. Two were initially raised in his federal habeas petition, while the other two were added later. The court found that the first two claims failed under Strickland v. Washington, 466 U.S. 668 (1984), and habeas caselaw. The other two claims were deemed inadmissible in federal court because they did not relate back to the initial habeas petition and were therefore barred by the statute of limitations. The court corrected its precedent on the standard of review, stating that under Krupski v. Costa Crociere S.p.A, 560 U.S. 538 (2010), they review those decisions de novo. The district court's denial of Mungin’s petition for a writ of habeas corpus was affirmed. View "Mungin v. Secretary, Florida Department of Corrections" on Justia Law