Justia Civil Rights Opinion Summaries

The case involves a fatal shooting by Deputy Jafet Santiago-Miranda, who fired his weapon into a moving vehicle, killing two young individuals, Angelo Crooms and Sincere Pierce. The plaintiffs, representing the estates of the deceased, claimed that Santiago-Miranda used excessive force, failed to render medical aid, and committed state-law battery. They also raised claims against Deputy Carson Hendren and Sheriff Wayne Ivey. The incident occurred after the deputies pursued a vehicle they believed to be stolen, which then accelerated towards Santiago-Miranda, prompting him to fire his weapon.The United States District Court for the Middle District of Florida granted summary judgment in favor of the defendants. The court dismissed all claims against Hendren with prejudice and ruled that Santiago-Miranda's use of force was constitutionally permissible. The plaintiffs appealed the summary judgment decision regarding Santiago-Miranda and Sheriff Ivey.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 Santiago-Miranda's use of deadly force was reasonable under the circumstances, as he had probable cause to believe that his life was in danger when the vehicle accelerated towards him. The court also found that the plaintiffs' state law battery claims failed for the same reasons. Additionally, the court affirmed the summary judgment in favor of Sheriff Ivey on the Monell claims, as there was no underlying constitutional violation by Santiago-Miranda. View "Baxter v. Hendren" on Justia Law

MaChelle Joseph, a former head women’s basketball coach at Georgia Tech, and Thomas Crowther, a former art professor at Augusta University, filed separate complaints alleging sex discrimination and retaliation under Title IX and other laws. Joseph claimed that Georgia Tech provided fewer resources to the women’s basketball team compared to the men’s team and retaliated against her for raising these issues. Crowther alleged that he was retaliated against after being accused of sexual harassment and participating in the investigation.The United States District Court for the Northern District of Georgia dismissed Joseph’s Title IX claims, ruling that Title VII precluded them, and granted summary judgment against her remaining claims. For Crowther, the district court denied the motion to dismiss his Title IX claims, allowing them to proceed.The United States Court of Appeals for the Eleventh Circuit reviewed these consolidated appeals. The court held that Title IX does not provide an implied right of action for sex discrimination in employment, reversing the district court’s decision to allow Crowther’s Title IX claims and affirming the dismissal of Joseph’s Title IX claims. The court also ruled that Crowther’s retaliation claim under Title IX, based on his participation in the investigation, did not state a valid claim. Additionally, the court found that Joseph’s claims of sex discrimination under Title VII, based on her association with the women’s team, were not viable. Finally, the court affirmed the summary judgment against Joseph’s retaliation claims under Title VII, Title IX, and the Georgia Whistleblower Act, concluding that she failed to show that the reasons for her termination were pretextual. View "Joseph v. Board of Regents of the University System of Georgia" on Justia Law

Thomas Swinford was shot and killed by Athens-Clarke County police officers after he refused to drop a gun and instead raised and pointed it at the officers. His widow, Jayne Swinford, filed a lawsuit in Georgia state court alleging claims under 42 U.S.C. § 1983 and Georgia’s wrongful death statute against seven officers, the police chief, and the county government. The case was removed to federal court.The defendants moved to dismiss the complaint on qualified and official immunity grounds, relying on body camera footage showing the events leading up to the shooting. The district court considered the footage and granted the motion to dismiss, finding that the officers acted reasonably and did not violate Thomas’s constitutional rights. The court also denied Mrs. Swinford’s motion to amend her complaint and her motion for reconsideration.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court determined that the district court properly considered the body camera footage under the incorporation-by-reference doctrine. The footage showed that the officers had probable cause to believe Thomas posed a serious threat when he raised his gun at them, justifying their use of deadly force. The court found that the officers did not use excessive force and were entitled to qualified immunity. Consequently, the supervisory liability claim against the police chief and the Monell claim against the county also failed.The Eleventh Circuit affirmed the district court’s orders, including the denial of Mrs. Swinford’s motion to amend her complaint and her motion for reconsideration. View "Swinford v. Santos" on Justia Law

In this case, Jimmy Davis, Jr., an Alabama prisoner sentenced to death for the 1993 murder of Johnny Hazle during a gas station robbery, appealed the district court’s denial of his 28 U.S.C. § 2254 federal habeas petition. Davis argued that his trial counsel was ineffective during the penalty phase of his trial for failing to investigate and present mitigating evidence of childhood abuse and the circumstances of his prior conviction for third-degree robbery.The Alabama Court of Criminal Appeals affirmed Davis’s conviction and sentence on direct appeal. Davis then filed a state postconviction petition, which was denied after an evidentiary hearing. The state court found that Davis’s trial counsel did not perform deficiently and that Davis was not prejudiced by the alleged deficiencies. The Alabama Court of Criminal Appeals affirmed the denial of the postconviction petition, concluding that the investigation conducted by Davis’s attorneys was reasonable and that Davis failed to show prejudice.The United States District Court for the Northern District of Alabama denied Davis’s § 2254 petition, concluding that the state court’s decision was not an unreasonable application of Supreme Court precedent or based on an unreasonable determination of the facts. The Eleventh Circuit Court of Appeals reviewed the case and affirmed the district court’s denial of the habeas petition.The Eleventh Circuit held that the state court’s conclusion that Davis was not prejudiced by his counsel’s alleged deficiencies was not contrary to or an unreasonable application of clearly established federal law. The court noted that the additional mitigating evidence presented during the postconviction proceedings, including evidence of childhood abuse and the non-violent nature of the prior robbery, did not create a reasonable probability of a different outcome. The court emphasized that the state court’s decision was not so obviously wrong that it lay beyond any possibility for fairminded disagreement. View "Davis v. Commissioner, Alabama Department of Corrections" on Justia Law

Louis Mercado was charged with three counts of capital sexual battery in Florida. During his trial, the court granted judgments of acquittal on two counts and declared a mistrial on the third count due to prosecutorial error. The trial court then barred a retrial, citing the Double Jeopardy Clause. The State appealed this decision, but Mercado's attorney, mistakenly believing he had withdrawn from the case, failed to file a response brief. The appellate court reversed the trial court's decision, leading to Mercado's retrial, conviction, and life sentence.The Fifth District Court of Appeal summarily denied Mercado's state habeas petition, in which he argued ineffective assistance of counsel due to his attorney's failure to file a response brief. Mercado contended that this failure should be presumed prejudicial under United States v. Cronic, rather than requiring proof of prejudice under Strickland v. Washington. The appellate court's decision was based on the reasoning that the failure to file a brief did not constitute a complete denial of counsel.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's denial of Mercado's federal habeas petition. The court held that the state court's decision was not an unreasonable application of clearly established federal law. The Eleventh Circuit noted that the Supreme Court has never applied the Cronic presumption of prejudice to a situation where counsel failed to file an appellee's brief. Therefore, the state court's requirement for Mercado to prove actual prejudice under Strickland was deemed reasonable. View "Mercado v. Secretary, Florida Department of Corrections" on Justia Law

Transgender residents of Alabama sought to change the sex designation on their driver’s licenses without undergoing sex-change surgery, as required by Alabama’s Policy Order 63. This policy mandates that individuals wishing to change the sex on their driver’s license must submit either an amended birth certificate or a letter from the physician who performed the reassignment surgery. Plaintiffs argued that this policy violated the Equal Protection and Due Process Clauses of the Fourteenth Amendment, as well as the Free Speech Clause of the First Amendment.The United States District Court for the Middle District of Alabama ruled in favor of the plaintiffs, declaring Policy Order 63 unconstitutional under the Equal Protection Clause. The district court found that the policy classified individuals by sex and applied intermediate scrutiny, concluding that Alabama had not provided an adequate justification for the policy.The United States Court of Appeals for the Eleventh Circuit reviewed the case and reversed the district court’s decision. The appellate court held that Policy Order 63 does not impose a sex-based classification and therefore does not trigger heightened scrutiny. Instead, the policy was subject to rational basis review, which it survived. The court found that the policy rationally advances Alabama’s legitimate interest in maintaining consistent requirements for amending sex designations on state documents.The appellate court also rejected the plaintiffs’ due process and First Amendment claims. It held that the policy does not violate the right to informational privacy or the right to refuse medical treatment, as it does not force individuals to undergo surgery to obtain a driver’s license. Additionally, the court determined that the policy does not compel speech, as the information on driver’s licenses constitutes government speech, not private speech. Thus, the Eleventh Circuit reversed the district court’s judgment and upheld the constitutionality of Policy Order 63. View "Corbitt v. Secretary of the Alabama Law Enforcement Agency" on Justia Law

Robert Turner, a property owner in Suwannee County, Florida, claimed that his homestead property was sold at an impermissibly low amount under Florida law, which deprived him of any surplus after back taxes and costs were deducted. Turner had a homestead exemption on his property, which was automatically renewed until 2015. After failing to pay property taxes, a tax certificate was issued, and a tax deed sale was conducted in 2015. Turner alleged that the sale was unlawful because it did not account for the homestead exemption, and he did not receive proper notice of the sale.Turner initially sought relief in state court, challenging the removal of his homestead exemption, but his complaint was dismissed as untimely. He then filed a federal lawsuit under 42 U.S.C. § 1983, claiming violations of his constitutional rights, including First Amendment retaliation, Fourth Amendment illegal seizure, and due process violations. The federal district court dismissed his complaint, finding that abstention was warranted under the comity doctrine, which prevents federal courts from interfering with state tax administration when state remedies are adequate.The United States Court of Appeals for the Eleventh Circuit reviewed the district court's decision. The court affirmed the dismissal, holding that the relief Turner sought would disrupt Florida's administration of its ad valorem property tax scheme. The court found that Florida provided plain, adequate, and complete state remedies, including the ability to challenge tax deed sales and homestead exemption removals in state court. The court concluded that the district court did not abuse its discretion in abstaining from exercising jurisdiction under the comity doctrine. View "Turner v. Jordan" on Justia Law

Amir Meshal, a professional truck driver, was stopped by Georgia State Police officers for a minor traffic infraction. During the stop, the officers discovered Meshal was on the FBI’s No Fly List. Despite instructions not to detain him based solely on this status, the officers handcuffed Meshal, placed him in a patrol car, and searched his truck. They questioned him about his religion and international travel while waiting for guidance from the FBI. After 91 minutes, the FBI cleared Meshal, and he was released with a warning citation for the traffic infraction.Meshal sued the officers in the United States District Court for the Southern District of Georgia, alleging violations of his Fourth Amendment rights due to the extended detention and the search of his truck. The officers moved to dismiss the complaint on qualified immunity grounds, arguing that Meshal failed to allege a violation of clearly established law. The district court denied the motion, finding that the complaint sufficiently alleged that the officers detained Meshal without arguable reasonable suspicion and searched his truck without arguable probable cause.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court agreed with the district court, holding that the officers were not entitled to qualified immunity at this stage. The court found that the officers lacked even arguable reasonable suspicion to justify prolonging the traffic stop beyond the time necessary to complete tasks related to the traffic infraction. Additionally, the court held that the search of Meshal’s truck was not supported by arguable probable cause. Therefore, the Eleventh Circuit affirmed the district court’s denial of qualified immunity. View "Meshal v. Commissioner, Georgia Department of Public Safety" on Justia Law

Four registered voters and several non-profit organizations sued the Cobb County Board of Elections and Registration, alleging that the 2022 redistricting map for the Cobb County School Board was an unconstitutional racial gerrymander. They claimed the map packed Black and Latino voters into certain districts to dilute their political power and maintain a majority white School Board. The plaintiffs sought declaratory and injunctive relief to prevent the use of the 2022 map in future elections.The Cobb County School District intervened as a defendant and moved for judgment on the pleadings, arguing it was not liable for any constitutional violation because the Georgia General Assembly, not the School Board, enacted the map. The district court granted the School District’s motion based on Monell v. Department of Social Services of New York, but did not immediately enter judgment. The School District continued to participate in the case, prompting the court to formally terminate it as a party. The plaintiffs and the Election Defendants then entered a settlement, leading to a preliminary injunction against the 2022 map.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court dismissed the School District’s appeal for lack of jurisdiction, holding that the School District, as a nonparty, lacked standing to appeal the preliminary injunction. The court emphasized that only parties or those who properly become parties may appeal, and the School District had not sought to reintervene for purposes of appeal. The court also noted that the School District’s participation as an amicus did not grant it the right to appeal. View "Cobb County School District" on Justia Law

A federal prisoner, LaQuan Johnson, filed a complaint under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, seeking money damages from federal prison officials, doctors, a nurse, and a kitchen supervisor. Johnson alleged violations of his constitutional rights through excessive force, failure to protect him from other inmates, and deliberate indifference to his serious medical needs. The incidents occurred while Johnson was housed at the United States Penitentiary in Atlanta, Georgia, from September 2015 to April 2019. He claimed that prison officials failed to separate pretrial detainees from convicted inmates, leading to multiple attacks on him, and that medical staff provided inadequate treatment for his injuries.The United States District Court for the Northern District of Georgia initially denied the defendants' motion to dismiss for failure to exhaust administrative remedies, finding that Johnson was denied access to the Bureau of Prisons' (BOP) administrative remedy program. However, after further discovery, the district court granted the defendants' motions for summary judgment, concluding that Johnson's claims did not entitle him to a Bivens remedy because they would require recognizing new Bivens causes of action, which the court is generally forbidden to create.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's decision. The Eleventh Circuit held that Johnson's failure to protect and deliberate indifference claims presented new Bivens contexts, as they were meaningfully different from the three contexts previously recognized by the Supreme Court in Bivens, Davis v. Passman, and Carlson v. Green. The court also found that special factors, including the existence of the BOP's administrative remedy program, counseled against extending Bivens to these new contexts. The court emphasized that the existence of an alternative remedial structure alone is sufficient to preclude the creation of a new Bivens remedy. View "Johnson v. Terry" on Justia Law