Justia Civil Rights Opinion Summaries

John Labriola, a media aide for the Miami-Dade Board of County Commissioners, wrote an inflammatory opinion piece criticizing the Equality Act, using derogatory language towards the LGBT community. Following public backlash and internal complaints, the County suspended him without pay, mandated anti-discrimination training, and eventually terminated him for not completing the training.Labriola sued Miami-Dade County in the United States District Court for the Southern District of Florida, alleging retaliation for exercising his First Amendment rights, compelled speech, and that the County's anti-discrimination policy was unconstitutionally overbroad. The district court granted summary judgment in favor of the County on all counts, applying the Pickering-Connick test to Labriola's free speech and free exercise claims, and ruling that his free-press claim was invalid because he was not a journalist.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court affirmed the district court's decision, holding that Labriola's free speech and free exercise claims failed the Pickering-Connick balancing test, as his speech impeded the County's ability to perform its duties efficiently and disrupted workplace harmony. The court also rejected Labriola's free-press claim, noting that even though the district court erred in stating he couldn't bring the claim as a non-journalist, his claim failed on the merits. Additionally, the court found no evidence to support Labriola's compelled speech claim, as the required training did not compel him to express views he disagreed with. Lastly, the court dismissed Labriola's overbreadth challenge to the County's anti-discrimination policy, as he failed to demonstrate that the policy was substantially overbroad.The Eleventh Circuit affirmed the district court's grant of summary judgment to Miami-Dade County on all counts. View "Labriola v. Miami-Dade County" on Justia Law

In March 1988, Isaiah Harris, a sheriff in Montgomery County, Alabama, was killed. His wife, Louise, was having an affair and conspired with her lover, Lorenzo McCarter, to have Harris killed for insurance money. McCarter recruited Michael Sockwell and Alex Hood to carry out the murder. Sockwell was later convicted of capital murder for pecuniary gain and sentenced to death.Sockwell appealed his conviction, arguing that the prosecution used peremptory strikes to exclude Black jurors in a discriminatory manner, violating Batson v. Kentucky. The Alabama Court of Criminal Appeals (ACCA) affirmed his conviction, finding no clear error in the trial court’s denial of the Batson challenge. The Alabama Supreme Court also affirmed, stating that the prosecutor’s identification of a juror’s race was merely descriptive and not a race-based reason for the strike.Sockwell then filed a habeas corpus petition in the United States District Court for the Middle District of Alabama, which was denied. The district court found the strike of a Black juror, Eric Davis, problematic but concluded that the Alabama Supreme Court did not unreasonably apply Batson. The district court granted a certificate of appealability on the Batson issue, and Sockwell appealed to the United States Court of Appeals for the Eleventh Circuit.The Eleventh Circuit held that the Alabama Supreme Court unreasonably applied federal law by not properly considering all relevant circumstances under Batson’s third step. The court found that the prosecutor’s history of Batson violations, statistical evidence of disproportionate strikes against Black jurors, and the comparison of Davis to similarly situated white jurors indicated purposeful discrimination. The Eleventh Circuit reversed the district court’s ruling and directed it to issue a writ of habeas corpus, allowing Alabama the right to retry Sockwell. View "Sockwell v. Commissioner, Alabama Department of Corrections" on Justia Law

In the early hours of August 22, 1972, military officers at the Almirante Zar Naval Base in Trelew, Argentina, removed nineteen unarmed political prisoners from their cells and shot them, resulting in what became known as the Trelew Massacre. The plaintiffs in this case are the surviving family members of four of those prisoners. They filed a lawsuit against Roberto Guillermo Bravo, one of the officers involved in the massacre, seeking compensatory and punitive damages under the Torture Victim Protection Act (TVPA) for the extrajudicial killing and torture of their relatives.The United States District Court for the Southern District of Florida heard the case. A jury found Mr. Bravo liable for the deaths and awarded the plaintiffs over $24 million. Mr. Bravo appealed, arguing that the district court erred by equitably tolling the TVPA statute of limitations on the plaintiffs’ claims until October 15, 2012. The district court had concluded that extraordinary circumstances, including the plaintiffs’ fear of reprisal, inability to locate Mr. Bravo, and inability to discover crucial evidence, justified tolling the statute of limitations.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court vacated the district court’s judgment, finding that the district court failed to make sufficient findings of fact to support its ruling on equitable tolling. The appellate court remanded the case for additional findings on whether the plaintiffs were entitled to equitable tolling beyond March 2008. The court also instructed the district court to reconsider whether the plaintiffs acted with due diligence in filing their claims, particularly in the case of Eduardo Cappello, who was found not to have acted diligently by the district court. The appellate court upheld the district court’s exclusion of evidence regarding the victims' alleged ties to communism and Cuba, finding no abuse of discretion. View "Camps v. Bravo" on Justia Law

In July 2020, Jamie Cunningham burglarized a car dealership in Cobb County, Georgia, and fled the scene. Cobb County police officers pursued him, and during the arrest, they used physical force to handcuff him. Cunningham later filed a lawsuit under 42 U.S.C. § 1983 against certain police officers and Cobb County, alleging excessive force in violation of the Fourth Amendment and Georgia law. He also claimed that Cobb County was liable under the Monell doctrine for the officers' actions.The United States District Court for the Northern District of Georgia granted summary judgment in favor of the defendants. The court held that the officers were entitled to qualified immunity on the Fourth Amendment claim because their use of force was objectively reasonable and did not violate clearly established law. The court also found that the officers were entitled to official immunity on the state-law claim because Cunningham failed to show that the officers acted with actual malice. Additionally, the court granted summary judgment for Cobb County on the Monell claim, concluding that there was no underlying constitutional violation by the officers and no evidence of a defective custom or policy by Cobb County.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the officers' actions were objectively reasonable under the circumstances, as Cunningham had resisted arrest and the officers had a reasonable belief that he might be armed. The court also agreed that the officers did not act with actual malice, and thus were entitled to official immunity. Finally, the court affirmed the summary judgment for Cobb County, as there was no underlying constitutional violation to support the Monell claim. View "Cunningham v. Cobb County, Georgia" on Justia Law

Law enforcement used a specialized software tool, Torrential Downpour, to download files containing child pornography from a specific IP address associated with the defendant. Torrential Downpour is designed to force a single-source download from a user on the BitTorrent peer-to-peer network, allowing officers to link specific files to a particular IP address. After obtaining these files, police secured a warrant and seized the defendant’s computer and other devices, which contained additional child pornography. The defendant argued that he did not knowingly share files and that he had a reasonable expectation of privacy in the files downloaded by law enforcement.The United States District Court for the Northern District of Florida held an evidentiary hearing on the defendant’s motion to suppress the evidence, considering expert testimony about BitTorrent’s functionality. The court found the government’s expert more credible and determined that the defendant had made the files available to the public. The court concluded that the use of Torrential Downpour did not access any information not already publicly shared and denied the motion to suppress. The court also denied a motion in limine to prevent the government from showing child pornography images to the jury, finding that the probative value was not substantially outweighed by the danger of unfair prejudice, especially since the defendant did not object to specific images.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed. The court held that the use of Torrential Downpour to download files from a peer-to-peer network did not constitute a search under the Fourth Amendment because the defendant had no reasonable expectation of privacy in files he made publicly available. The court also held that the district court did not abuse its discretion in allowing the government to show a representative sample of images to the jury without first reviewing specific images, given the lack of specific objections. View "USA v. Ewing" on Justia Law

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