Justia Civil Rights Opinion Summaries

Plaintiff, a Georgia state prisoner proceeding pro se, appealed the district court's sua sponte dismissal, under 42 U.S.C. 1997e(a) and 28 U.S.C. 1915A, of his 42 U.S.C. 1983 civil rights action. On appeal, defendant argued that the district court erred in dismissing his claims. The court held, and the state conceded, that the district court erred in dismissing without prejudice defendant's dental treatment claim on the basis that it was "clear from the face of the complaint" that defendant had not exhausted his administrative remedies with regard to this claim. The court held, however, that there was no merit in defendant's remaining claims. Accordingly, the court affirmed in part, vacated in part, and remanded in part.

The United States appealed an award of attorney's fees and costs under the Hyde Amendment, Pub. L. No. 105-119, section 617, 111 Stat. 2440, 2519, and two attorneys, Sean Cronin and Andrea Hoffman, appeal public reprimands entered against them based on their work as Assistant United States Attorneys in an underlying criminal action marked by hard adversarial tactics. The court held that the district court abused its discretion when it imposed sanctions against the United States for a prosecution that was objectively reasonable, and the district court violated the constitutional right to due process of the two lead prosecutors, when it denied them notice of any charges of misconduct and an opportunity to be heard. Therefore, the court vacated the award of attorney's fees and costs against the United States and the public reprimand of Cronin and Hoffman, but the court denied the request of Cronin and Hoffman that the court reassign the case to a different district judge at this stage.

The city filed a complaint in admiralty against defendant, a vessel, claiming that defendant committed the maritime tort of trespass because it remained at the city marina after the city explicitly revoked its consent, and seeking to foreclose its maritime lien for necessaries (unpaid dockage provided to defendant by the city). Claimant, owner of the vessel, appealed from the district court's entry of an order of summary judgment and an order of final judgment for the city in an in rem proceeding against defendant. The court held that the district court did not err in concluding that it had federal admiralty jurisdiction over defendant where defendant was a "vessel" for purposes of admiralty jurisdiction; the district court's factual findings regarding the amount claimant owed under the city's maritime lien for necessaries were not clearly erroneous; the district court did not err in granting summary judgment to the city on claimant's affirmative defense of retaliation; the district court correctly concluded that the city was not estopped from bringing its action in admiralty against defendant; and the district court did not abuse its discretion in declining to apply collateral estoppel because the issues at stake were significantly different from those in dispute in the state court proceeding. Accordingly, the district court's orders were affirmed.

Plaintiffs brought this action challenging the constitutionality of the Patient Protection and Affordable Care Act, Pub. L. 111-148, 124 Stat. 119, amended by Health Care and Education Reconciliation Act of 2010 (HCERA), Pub. L. No. 111-152, 124 Stat. 1029 (Act). The government subsequently appealed the district court's ruling that the individual mandate was unconstitutional and the district court's severability holding. The state plaintiffs cross-appealed the district court's ruling on their Medicaid expansion claim. The court held that the Act's Medicaid expansion was constitutional. The court also held that the individual mandate was enacted as a regulatory penalty, not a revenue-raising tax, and could not be sustained as an exercise of Congress's power under the Taxing and Spending Clause; the individual mandate exceeded Congress's enumerated commerce power and was unconstitutional; and the individual mandate, however, could be severed from the remainder of the Act's myriad of reforms. Accordingly, the court affirmed in part and reversed in part the judgment of the district court.

Plaintiffs, Cindy Fils and Nemours Maurice, raised claims under 42 U.S.C. 1983, alleging that certain named police officers used excessive force to subdue plaintiffs at a club. The court denied the officers' motion for summary judgment based on qualified immunity and the officers appealed. The court affirmed the district court with respect to Maurice's excessive force claims against Officer Bergert and Williams; reversed the district court with respect to Fils' excessive force claims against Officer Bergert and Burns; affirmed the district court's decision to dismiss the remaining claims; and remanded the case to the district court for further proceedings.

Plaintiffs, visually or manually impaired Florida citizens who were registered to vote in Duval County, Florida and were represented by the American Association of People with Disabilities, filed a putative class action against defendants, alleging that defendants violated federal statutory and state constitutional provisions by failing to provide handicapped-accessible voting machines to visually or manually impaired Florida voters after the 2000 general election. The court vacated its prior opinion and in its revised opinion, held that the district court erroneously granted plaintiffs' requested declaratory judgment and injunction against purported violations of the American with Disabilities Act of 1990 (ADA), 42 U.S.C. 12101-12213, and the regulations promulgated thereunder. The opinion, however, based that outcome exclusively on the ground that voting machines were not "facilities" under 28 C.F.R. 35.151(b).

In this reverse discrimination case under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., and 42 U.S.C. 1981, plaintiff, a white male, claimed that his former employer discriminated against him on account of his race in terminating his employment. At issue was whether the district court misapplied the summary judgment standard to the evidence presented. Based on the totality of the circumstances, the court held that the record contained sufficient circumstantial evidence from which a jury could infer that the employer displayed a racially discriminatory animus toward plaintiff when it fired him in May 2005. Consequently, plaintiff presented a case sufficient to withstand the employer's motion for summary judgment. Therefore, the judgment of the district court was vacated and remanded for further proceedings.

Petitioner, currently on death row, filed a civil rights action under 42 U.S.C. 1983, contending that the Alabama Department of Corrections' ("ADOC") recent change from sodium thipoental to pentobarbitol as the first three drugs used in the lethal injection protocol constituted cruel and unusual punishment in violation of the Eighth Amendment and violated his rights protected by the Due Process Clause of the Fourteenth Amendment. At issue was whether the district court erred in granting the motion to dismiss on statute of limitations grounds because, in rejecting petitioner's claim that the ADOC's lethal injection protocol violated the Eight Amendment, the district court relied on external evidence and dicta, and the change in lethal injection protocol was significant; and petitioner's claim regarding Alabama's secrecy and arbitrary changes also accrued when the ADOC changed the first drug in the protocol. The court held that the district court did not err in basing its conclusion on the binding precedent in Powell v. Thomas, and, in light of the binding precedent, the court rejected petitioner's attempt to relitigate the issue of whether the ADOC's action in changing the first drug in the lethal injection protocol was a "significant" change for purposes of McNair v. Allen. Therefore, the district court did not err in determining that petitioner's claim was barred by the statute of limitations. The court also held that petitioner failed to show how his claim about the secrecy surrounding the ADOC's recent change in lethal injection protocol was revived by the ADOC's 2011 switch in drugs and therefore, the district court did not err in finding petitioner's second claim for relief barred by the statute of limitations.

Plaintiff sued defendant, a deputy with the sheriff's office, under 42 U.S.C. 1983, alleging that the deputy violated her right to be free from unreasonable searches and seizures under the Fourth and Fourteenth Amendments. At issue was whether the district court erred in concluding that the deputy was not entitled to qualified immunity because he was acting outside the scope of his discretionary authority. The court held that the deputy's actions were undertaken pursuant to the performance of his duties and were within the scope of his authority. The court also held that, under the particular circumstances of the case, the deputy's conduct did not violate the Fourth Amendment and he was therefore, entitled to qualified immunity. Furthermore, assuming arguendo a constitutional violation, a reasonable officer in the deputy's shoes would not have known that his conduct was unlawful. Plaintiff had no binding precedent that clearly established that probable cause and exigent circumstances immediately evaporated once an officer performing a welfare check for a possibly suicidal person and saw that the person was merely alive. Accordingly, the district court's order denying the deputy's motion for summary judgment was reversed and remanded.

Plaintiffs, a husband and wife, sued defendants, two sheriff's deputies, seeking damages under 42 U.S.C. 1983 on the grounds that the deputies' warrantless entry into their garage, and wife's subsequent arrest for obstruction of justice, violated their Fourth Amendment rights. Wife attempted to shut her open garage door to prevent the deputies from serving a court order on her husband, as the garage door closed, one of the deputies stepped into the threshold, breaking the electronic-eye safety beam on the garage door and caused the door to retreat to its open position. At issue was whether the warrantless seizure inside plaintiffs' garage violated their Fourth Amendment rights and, if so, whether those rights were clearly established when the incident occurred, such that the deputies should be stripped of qualified immunity. The court held that although the deputies' entrance into the garage did violate plaintiffs' Fourth Amendment rights, the boundaries of the right violated were not clearly established and therefore, the deputies were entitled to qualified immunity. Accordingly, the district court properly granted summary judgment in favor of the deputies both on plaintiffs' arrest claim and on plaintiffs' challenge of the entrance of the garage.