Justia Civil Rights Opinion Summaries

On June 1, 2018, Officer Jonathan Guzman of the City of Miami Police Department identified a speeding driver in a black Jeep Compass. The driver crashed into another vehicle and fled on foot. During an inventory search of the Jeep, Guzman found a firearm, ammunition, and marijuana. Shortly after, a radio dispatch reported the vehicle as stolen. Officer Michael Bloom arrived at the scene of the reported theft, where Samuel Scott Jr. claimed his Jeep had been stolen. Guzman arrived and recognized Scott as the driver who fled the crash. Scott was arrested for multiple charges, including reckless driving and falsely reporting a crime. The charges were later dropped.Scott filed federal and state law claims in the Southern District of Florida against the officers and the City of Miami, alleging unreasonable search and seizure, false arrest, false imprisonment, and malicious prosecution. The district court granted summary judgment for the defendants, citing qualified and sovereign immunity, and found that the officers had probable cause to arrest Scott based on Guzman’s eyewitness identification.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court’s decision. The court held that Guzman’s eyewitness identification provided sufficient probable cause for Scott’s arrest. The court also found that the officers were entitled to qualified immunity on the federal claims and that the City of Miami was not liable under state law due to the presence of probable cause. Consequently, all of Scott’s claims were dismissed. View "Scott v. City of Miami" on Justia Law

The defendants in this case challenged the constitutionality of 8 U.S.C. § 1326, which criminalizes unlawfully reentering the United States after a prior removal. They argued that the statute violates the equal protection component of the Fifth Amendment’s Due Process Clause by discriminating against Mexican and other Latin American immigrants. Their theory was that the statute’s predecessor, the Undesirable Aliens Act of 1929, was enacted with discriminatory intent, and that § 1326, first codified in 1952 and amended several times thereafter, perpetuates that taint.The United States District Court for the Middle District of Florida denied the defendants’ motions to dismiss their indictments. The court assumed without deciding that the Arlington Heights framework applied but concluded that the defendants had failed to establish a discriminatory purpose behind § 1326’s enactment. The court also concluded that the statute easily satisfied rational-basis review. The defendants then entered conditional guilty pleas or proceeded to a stipulated bench trial, reserving their rights to appeal the constitutional issue. The District Court sentenced the defendants to varying terms of imprisonment and supervised release.The United States Court of Appeals for the Eleventh Circuit reviewed the case and upheld the District Court’s decision. The court found no clear error in the District Court’s conclusion that the defendants had not shown that § 1326 was enacted or maintained for a discriminatory purpose. The court noted that the defendants’ evidence, including historical context, statements by public officials, and statistical disparities, was insufficient to establish that the 1952 Congress acted with discriminatory intent. The court also emphasized that laws do not carry forward “taint” through reenactment unless the later legislature acted with the same constitutionally impermissible purpose. The judgments of the District Court were affirmed. View "USA v. Ferretiz-Hernandez" on Justia Law

DeShawn Gervin was on probation in Georgia with the sole condition that he not return to the South Georgia Judicial Circuit. He moved to North Carolina but was later imprisoned there for various crimes. A Georgia probation officer, Pamela Florence, learned of his North Carolina offenses and sought a warrant for his arrest in Georgia, falsely claiming he had violated probation by failing to report. Gervin was arrested in North Carolina and extradited to Georgia, where he spent 104 days in jail before a court found he had not violated his probation and ordered his release.Gervin sued Florence and another probation officer, Tandria Milton, under 42 U.S.C. § 1983, alleging violations of his Fourth, Eighth, and Fourteenth Amendment rights. The United States District Court for the Middle District of Georgia granted summary judgment for the defendants on the Eighth and Fourteenth Amendment claims but denied it on the Fourth Amendment claim, characterizing it as a malicious-prosecution claim.The United States Court of Appeals for the Eleventh Circuit affirmed the district court's ruling. The court held that Gervin presented enough evidence to support his Fourth Amendment malicious-prosecution claim. The court found that Florence and Milton recklessly made false statements and omissions that led to Gervin's arrest and prolonged detention, violating his Fourth and Fourteenth Amendment rights. The court also concluded that the probation officers were not entitled to qualified immunity because the constitutional violations were clearly established at the time of their actions. View "Gervin v. Florence" on Justia Law

Jeremy Jones was stopped by Officer David Ceinski for a traffic infraction. Jones complied with Ceinski’s instructions to exit his car and provide his driver’s license and vehicle registration. Jones also informed Ceinski that he had a firearm in the car. After seeing the firearm under the driver’s seat, Ceinski grabbed Jones’s wrist, twisted his arm, and pushed him against the car. While Jones was subdued, Ceinski choked him until he could not breathe and punched him on the top of his head. Jones filed a complaint against Ceinski under 42 U.S.C. § 1983, alleging excessive force in violation of the Fourth Amendment.The magistrate judge in the United States District Court for the Middle District of Florida granted Ceinski’s motion for summary judgment based on qualified immunity, ruling that Ceinski’s conduct did not violate any clearly established federal right.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that a reasonable jury could find that Ceinski used excessive force when he choked and punched Jones after he was subdued and could not access his firearm. The court noted that Jones’s right to be free from excessive force was clearly established, since controlling case law placed the illegality of Ceinski’s actions beyond debate. Consequently, the court reversed the summary judgment in favor of Ceinski and remanded the case for further proceedings. View "Jones v. Ceinski" on Justia Law

On Thanksgiving night in 2018, Officer David Alexander, a policeman with the City of Hoover, was on foot patrol at the Galleria Mall in Birmingham, Alabama. During a suspected active shooting situation, Officer Alexander saw Emantic "E.J." Fitzgerald Bradford moving towards two men with a gun in his hand. Without issuing a verbal warning, Officer Alexander shot and killed Mr. Bradford, who was legally authorized to carry his gun and was attempting to provide assistance.April Pipkins, Mr. Bradford's mother and representative of his estate, filed a lawsuit against Officer Alexander, the City of Hoover, and other defendants, asserting Fourth Amendment claims under 42 U.S.C. § 1983 and state law claims for negligence and wantonness. The United States District Court for the Northern District of Alabama dismissed the state law claims and granted summary judgment on the § 1983 claims, ruling that Officer Alexander's use of deadly force was reasonable under the Fourth Amendment and that a verbal warning was not feasible under the circumstances.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's decisions. The court held that Officer Alexander acted reasonably under the Fourth Amendment given the circumstances, which included a crowded mall, the sound of gunshots, and Mr. Bradford running with a gun towards two men. The court also found that a verbal warning was not feasible due to the immediate threat perceived by Officer Alexander. Additionally, the court upheld the dismissal of the state law claims, concluding that the Mall defendants did not owe a duty to protect Mr. Bradford from the criminal acts of a third party and that the complaint did not plausibly allege foreseeability or incompetency in hiring, training, and supervising Officer Alexander. View "Pipkins v. City of Hoover, Alabama" on Justia Law

A class of incarcerated juvenile offenders in Florida, all sentenced to life in prison with the possibility of parole under a now-defunct sentencing scheme, sued the Commissioners of the Florida Commission on Offender Review. They claimed that the parole system violated the Eighth Amendment's prohibition against cruel and unusual punishment and the Fourteenth Amendment's due process rights. The plaintiffs argued that the parole system did not provide a meaningful opportunity for release based on demonstrated maturity and rehabilitation.The United States District Court for the Middle District of Florida granted summary judgment to the Commissioners, dismissing the plaintiffs' claims. The court found that Florida's parole system did not violate the Eighth Amendment or the Fourteenth Amendment's Due Process Clause. The plaintiffs appealed the decision.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that Florida's parole system does not violate the Eighth Amendment for either homicide or non-homicide juvenile offenders. For homicide offenders, the system is not a sham and provides a genuine possibility of parole, satisfying the requirements set forth in Miller v. Alabama. For non-homicide offenders, the system offers a meaningful opportunity for release based on demonstrated maturity and rehabilitation, as required by Graham v. Florida.Regarding the due process claim, the court concluded that the plaintiffs did not have a constitutionally protected liberty interest in parole under either state law or the Eighth Amendment. Therefore, their procedural due process claim failed. The Eleventh Circuit affirmed the district court's grant of summary judgment to the Commissioners. View "Howard v. Coonrod" on Justia Law

Several college volleyball players accused their coach of physical, verbal, psychological, and sexual abuse. The players alleged that the coach engaged in a pattern of sexual harassment and abuse, including inappropriate touching and forcing players to engage in uncomfortable physical interactions. They also claimed that the coach's misconduct was reported to various university administrators and assistant coaches, who either witnessed or were informed of the abuse.The United States District Court for the Southern District of Alabama dismissed the players' Title IX and § 1983 claims with prejudice for failure to state a claim. The court found that the players had abandoned their breach-of-contract claims and dismissed those with prejudice. The court also declined to exercise supplemental jurisdiction over the remaining state-law claims, dismissing them without prejudice.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's dismissal. The court held that the players failed to state a Title IX claim because only certain university administrators were "appropriate persons" to receive notice of the misconduct, and the players did not provide sufficient actual notice of sexual harassment to those individuals. The court also found that the university did not act with deliberate indifference upon receiving the notice.Regarding the § 1983 claims, the court held that the players did not show that the university employees' conduct violated clearly established substantive-due-process principles. The court concluded that the employees were entitled to qualified immunity because the players did not provide case law with indistinguishable facts, a broad statement of principle, or conduct so egregious that it clearly violated constitutional rights.The Eleventh Circuit affirmed the district court's order dismissing the players' Title IX and § 1983 claims. View "DeMarcus v. University of South Alabama" on Justia Law

Sara Watts, an African American woman, sued her former homeowners’ association, Joggers Run Property Owners Association (HOA), alleging racial discrimination under the Fair Housing Act (FHA) and the Civil Rights Act. Watts claimed the HOA interfered with her property enjoyment through unwarranted citations, restricted access to amenities, and discriminatory treatment as a former HOA board member. She cited provisions from the FHA (42 U.S.C. §§ 3604(b), 3617) and the Civil Rights Act (42 U.S.C. §§ 1981, 1982).The United States District Court for the Southern District of Florida dismissed Watts' claims, ruling that the FHA did not cover discriminatory conduct occurring after the purchase of her home and that Watts failed to specify the contractual terms the HOA allegedly violated. The court found her allegations insufficient to support claims under the FHA and the Civil Rights Act.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that Watts presented plausible claims under the FHA and the Civil Rights Act. It found that the FHA's language is broad and inclusive, prohibiting a wide range of discriminatory conduct related to housing. The court concluded that the HOA's actions, including restricted access to amenities and selective enforcement of rules, fell within the scope of the FHA. The court also determined that Watts sufficiently alleged intentional racial discrimination causing contractual injury under Section 1981 and that the HOA's actions violated her right to use property on an equal basis with White citizens under Section 1982.The Eleventh Circuit reversed the district court's dismissal and remanded the case for further proceedings. View "Watts v. Joggers Run Property Owners Association, Inc." on Justia Law

Brian Albert, a bank compliance officer, sought certification as a money-laundering examiner by taking an exam administered by the Association of Certified Anti-Money Laundering Specialists. Due to his anxiety and learning disorders, Albert requested to take the closed-book exam in an open-book format. The Association denied this request but offered other accommodations, such as extended time and a separate testing area. Albert sued the Association under § 309 of the Americans with Disabilities Act (ADA), claiming the denial violated his rights.The United States District Court for the Northern District of Georgia granted summary judgment in favor of the Association, concluding that § 309 did not require the Association to provide an open-book format as it would fundamentally alter the nature of the exam. Albert appealed, and the Eleventh Circuit Court of Appeals vacated and remanded the case, instructing the district court to evaluate the claim under § 309 of the ADA, not § 302.On remand, the district court again granted summary judgment for the Association, holding that Albert's request for an open-book exam was not reasonable as it would fundamentally alter the exam's nature. The court relied on the Association's evidence that the exam was designed to test a candidate's knowledge without reliance on external materials, and allowing an open-book format would lower the standard for certification.The United States Court of Appeals for the Eleventh Circuit affirmed the district court's decision. The court held that § 309 of the ADA does not require a test provider to offer accommodations that would fundamentally alter the nature of its exam. Since Albert's request for an open-book format would change what the exam measures, it was not a reasonable accommodation under § 309. View "Albert v. Association of Certified Anti-Money Laundering Specialists, LLC" on Justia Law

Edward Burrell, an inmate at Clarke County Jail, suffered a heart attack while serving a sentence. Chief Deputy Sheriff and Jail Administrator Tyler Norris drove Burrell to the hospital instead of calling an ambulance and released him from jail to avoid medical costs. Burrell died shortly after arriving at the hospital. Barbara Donald, administratrix of Burrell's estate, claimed that Norris's actions delayed medical care and caused Burrell's death, bringing a federal constitutional claim and an Alabama wrongful-death claim.The United States District Court for the Southern District of Alabama denied Norris's motion for summary judgment on both claims. The court held that Norris was not entitled to qualified immunity because he acted outside his discretionary authority by releasing Burrell early. The court also found that a reasonable jury could determine Norris's actions violated Burrell's constitutional rights. The court did not address whether Norris's actions violated clearly established law. For the wrongful-death claim, the court denied summary judgment under Alabama’s jailer immunity statute, concluding Norris was not acting within the scope of his duties.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that Norris acted within his discretionary authority when he decided to drive Burrell to the hospital. The court emphasized that the discretionary-authority inquiry focuses on the general nature of the action, not whether the officer made the correct decision. The court found that Norris's actions did not violate any clearly established constitutional right and concluded that Norris was entitled to qualified immunity for the federal claim, reversing the district court's denial of summary judgment.Regarding the state wrongful-death claim, the court noted that the district court conflated state immunity with statutory jailer immunity. The court vacated the district court's denial of summary judgment on the state claim and remanded for the district court to determine whether to exercise supplemental jurisdiction and, if so, to decide the issue of state immunity. View "Donald v. Norris" on Justia Law