Justia Civil Rights Opinion SummariesArticles Posted in U.S. 11th Circuit Court of Appeals
Saunders v. Duke, et al.
Plaintiff filed suit against law enforcement officers under 42 U.S.C. 1983, alleging that officers used excessive force when his head was slammed against the pavement with extreme force after he had been handcuffed and was lying prone on the ground. The court held that plaintiff stated a valid Fourth Amendment claim for excessive force and that defendants were not entitled to qualified immunity. Accordingly, the court reversed the district court's dismissal of plaintiff's claim. View "Saunders v. Duke, et al." on Justia Law
West v. Davis
Plaintiff filed suit against defendant under 42 U.S.C. 1983, alleging that defendant subjected her to an unreasonable seizure and for using excessive force in the course of the seizure in violation of her Fourth Amendment rights. Plaintiff's claims arose from an incident where she was asked to remove her suit jacket at a security checkpoint in a courthouse. The district court granted summary judgment to defendant. The court concluded that the district court erred in applying the substantive due process/shock the conscience test rather than the well-established objective reasonableness standard under the Fourth Amendment. Therefore, the court reversed on this claim. The court concluded that the district court properly entered summary judgment in favor of defendant on plaintiff's state law claim on the ground of official immunity under the Georgia Constitution and affirmed on this claim. The court remanded for further proceedings. View "West v. Davis" on Justia Law
Connelly v. Metropolitan Atlanta Rapid Trans., et al.
Plaintiff appealed a judgment in favor of his former employer and against his complaint of racial discrimination and retaliation. At issue was whether the district court erred when it entered a judgment as a matter of law based on inconsistent jury verdicts. The court held that, to determine whether to grant a judgment as a matter of law, the district court should have considered only the sufficiency of the evidence in support of the verdict, not the consistency of that verdict with another. Accordingly, the court vacated and remanded for the district court to reinstate the jury verdict against the employer for retaliation. The court affirmed summary judgment against plaintiff's claim of discrimination against plaintiff's supervisor. View "Connelly v. Metropolitan Atlanta Rapid Trans., et al." on Justia Law
Bhogaita v. Altamonte Heights Condo Assoc.
Plaintiff filed suit against the Association under the Federal and Florida Fair Housing Acts (FHA), 42 U.S.C. 3604(f)(3)(b) and Fla. Stat. 760.23(9)(b). Plaintiff alleged that the Association violated these statutes when it enforced its pet weight policy and demanded that plaintiff remove his emotional support dog from his condominium. The jury awarded plaintiff damages and the district court awarded plaintiff attorneys' fees. The Association appealed. The court concluded that plaintiff was entitled to partial summary judgment on the refusal-to-accommodate element; plaintiff offered sufficient evidence to show he has a disability within the meaning of the FHA; plaintiff produced evidence supporting the conclusion that the requested accommodation was necessary; the jury instructions do not warrant reversal; in allowing the dog to remain in the courtroom, the district court did not abuse its discretion; and the district court did not err in awarding attorneys' fees. Because there was no merit to any of the arguments the Association made on appeal, the court affirmed the jury's verdict and the district court's order. View "Bhogaita v. Altamonte Heights Condo Assoc." on Justia Law
Evans v. Books-A-Million
Plaintiff filed suit against her employer, alleging violations of the Family Medical Leave Act (FMLA), 29 U.S.C. 2601; the Equal Pay Act, 29 U.S.C. 206; Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq.; and the Consolidated Omnibus Budget Reconciliation Act (COBRA), 29 U.S.C. 1161 et seq. Plaintiff's claims stemmed from her employer's denial of her request to take FMLA leave after the birth of her child. The court held that the district court correctly awarded summary judgment to the employer with respect to plaintiffs' claims under Title VII and the Equal Pay Act, and did not abuse its discretion by assessing a statutory COBRA penalty against the employer; the district court erred by dismissing plaintiff's FMLA claim and by refusing to consider her additional litigation-related expenses as part of an attorney's fee award; and, therefore, the court affirmed in part, vacated in part, and remanded in part. View "Evans v. Books-A-Million" on Justia Law
Pine, et al. v. City of West Palm Beach, FL
Plaintiffs, anti-abortion advocates, challenged Sections 34-38 of the Code of the City of West Palm Beach, which bans amplified sound within 100 feet of the property line of any health care facility. The court concluded that the district court did not abuse its discretion in denying a preliminary injunction when it found that the Ordinance is a valid time, place, or manner restriction on speech that is content-neutral, is narrowly tailored to advance the City's substantial interest in protecting patients, and leaves open ample alternative avenues of communication. The district court did not abuse its discretion in determining that plaintiffs failed to establish a substantial likelihood of success on their claims that the Ordinance is void for vagueness and is being applied discriminatorily against them. Accordingly, the court affirmed the judgment. View "Pine, et al. v. City of West Palm Beach, FL" on Justia Law
Wollschlaeger, et al. v. Governor State of FL, et al.
The State appealed the district court's grant of summary judgment and an injunction in favor of plaintiffs, enjoining enforcement of Florida's Firearm Owners Privacy Act, Fla. Stat. 381.026, 456.072, 790.338, on First and Fourteenth Amendment grounds. The Act seeks to protect patients' privacy by restricting irrelevant inquiry and record-keeping by physicians regarding firearms. The court concluded that plaintiffs have standing to challenge the Act and plaintiffs' claims are ripe for adjudication; the Act is a legitimate regulation of professional conduct where the Act simply codifies that good medical care does not require inquiry or record-keeping regarding firearms when unnecessary to a patient's care, and any burden the Act places on physician speech is incidental; and the Act is not unconstitutionally vague when the Act is properly understood as a regulation of physician conduct intended to protect patient privacy and curtail abuses of the physician-patient relationship, and it is readily apparent from the language of the Act the type of conduct the Act prohibits. Accordyingly, the court reversed the district court's grant of summary judgment and vacated the injunction. View "Wollschlaeger, et al. v. Governor State of FL, et al." on Justia Law
Cummings v. Dept. of Corrections, et al.
Plaintiff filed suit against four prison officials under 42 U.S.C. 1983, alleging violations of his constitutional rights and seeking money damages. The jury returned a verdict for the defense and plaintiff filed a motion for a new trial, arguing that a sleeping juror should have been removed from the jury. The Magistrate Judge granted the motion and defendants moved for reconsideration. The Magistrate Judge then granted the motion for reconsideration and denied plaintiff's motion for a new trial. The court affirmed, concluding that plaintiff could not get a "second bite of the apple" after the jury returned an unfavorable verdict when he was aware of the juror's purported misconduct and declined to object to her retention on the jury at trial. View "Cummings v. Dept. of Corrections, et al." on Justia Law
Booth, et al. v. Pasco Cty., FL, et al.
Plaintiffs filed suit against the County and Union, alleging violations of federal and state civil rights statutes. The jury found that the County subjected plaintiffs to fitness-for-duty examinations because of their grievances and charges against the County. The district court held that there was insufficient evidence to support this finding. The court disagreed, concluding that the jury was permitted to find that the desire to retaliate was a "but-for" cause of the County's decision; the district court did not abuse its discretion in rejecting plaintiffs' proposed jury instructions; and, even assuming that the restriction on the Union's speech was content-based, the court nevertheless rejected the Union's argument that the First Amendment immunizes it under the facts of this case. The court reversed the entry of judgment in favor of the County and ordered that judgment be entered against the County on the verdicts as returned. The court affirmed the judgment in all other respects. View "Booth, et al. v. Pasco Cty., FL, et al." on Justia Law
R.L., et al. v. Miami-Dade Cty. Sch. Bd.
The Board challenged the district court's decision to award O.L.'s parents reimbursement for one-on-one instruction outside the school setting as well as some of their attorney's fees. The parents cross-appealed the district court's decision not to award O.L. compensatory education. The court concluded that the parents were eligible for reimbursement; the district court was right to find that the alternative program was proper under the standard set forth in Bd. of Educ. of Hendrick Hudson Centr. Sch. Dist., Westchester Cnty. v. Rowley; even if the alternative program has its shortcomings, it was reasonably calculated to permit the child to obtain some educational benefit; the district court's reimbursement award was appropriate; the district court did not abuse its discretion when it took the quality of the chosen alternative into consideration; it was clear on the record that the district court properly weighed the evidence and did not abuse its considerable discretion when it denied the request for compensatory education; and there was no need to reverse the attorney's fee award since the court affirmed the district court's decision in all respects. View "R.L., et al. v. Miami-Dade Cty. Sch. Bd." on Justia Law