Justia Civil Rights Opinion Summaries

Articles Posted in US Court of Appeals for the Eleventh Circuit
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The Eleventh Circuit reversed the district court's judgment in defendant's favor in an action brought by plaintiff, alleging that defendant violated the Fourth Amendment by arresting plaintiff inside the home of plaintiff's parents. Defendant, a sheriff's deputy, went to the home to question plaintiff about an earlier incident. When plaintiff declined to talk to defendant alone, an argument ensued, and plaintiff went back inside the home, where defendant then entered and arrested plaintiff. The court held that defendant violated the Fourth Amendment's protection against unreasonable seizures when he arrested plaintiff inside of his home. The court also held that plaintiff's right to be free from a warrantless, in-home arrest was clearly established and that no exception to the warrant requirement even plausibly applies in this case. Accordingly, the court remanded for further proceedings. View "Bailey v. Swindell" on Justia Law

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On remand from the Supreme Court, the Eleventh Circuit remanded the case to the district court with instructions to issue a writ of habeas corpus vacating petitioner's sentence and entitling him to a new sentencing hearing. Applying Brecht v. Abrahamson, the court reviewed the trial judge's error under Ake v. Oklahoma, holding that the constitutional error in this case was structural. The court held that the Ake error infected the entire sentencing hearing from beginning to end, because petitioner was prevented from offering any meaningful evidence of mitigation based on his mental health, or from impeaching the State's evidence of his mental health. The court held that this Ake error defies analysis by harmless-error review and thus prejudice to petitioner was presumed. View "McWilliams v. Commissioner, Alabama Department of Corrections" on Justia Law

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Tokyo Valentino filed suit against the County, challenging certain business licensing and adult entertainment ordinances, and seeking damages under 42 U.S.C. 1983, as well as declaratory and injunctive relief. At issue in this appeal was the district court's second dismissal of Tokyo Valentino's claims. The Eleventh Circuit affirmed the district court's dismissal of Tokyo Valentino's claim for compensatory damages relating to the appeal of the ordinances, because Tokyo Valentino's second amended complaint does not contain factual allegations that establish it suffered a cognizable injury in fact for which compensatory damages might be warranted. However, the court reversed the dismissal of Tokyo Valentino's request for a declaratory judgment regarding whether its sale of sexual devices constitutes a lawful prior nonconforming use authorized under the repealed ordinances and whether the new ordinances' failure to include provisions grandfathering in prior lawful uses violates federal and state law. Finally, the court held that the district court abused its discretion by abstaining under Younger v. Harris, 401 U.S. 37, 91 S. Ct. 746 (1971), from hearing Tokyo Valentino's claims stemming from the County's new ordinances. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Tokyo Gwinnett, LLC v. Gwinnett County" on Justia Law

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The Eleventh Circuit affirmed the district court's denial of a petition for writ of habeas corpus under 28 U.S.C. 2254. The court held that, although petitioner exhausted his due process claims based on lost or destroyed evidence, the Georgia Supreme Court's denial of the claims on direct appeal was entitled to deference under section 2254(d). In this case, there was no evidence that officers knew or should have known that the lost or destroyed evidence was exculpatory and the record contained no allegation of official animus towards petitioner or of a conscious effort to suppress exculpatory evidence. The court also held that the district court did not err in denying petitioner's request for a stay. View "Davis v. Sellers" on Justia Law

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Plaintiffs filed suit challenging two policies related to the provision of basic utility services from the City on the ground that the policies have a disproportionate impact on black and Hispanic residents. The Eleventh Circuit vacated the district court's dismissal of the complaint for failure to state a claim, holding that section 3604(b) of the Fair Housing Act is unambiguous and reaches certain post-acquisition conduct, including post-acquisition conduct related to the provision of services. The panel held that a service within the meaning of section 3604(b) must be a housing-related service that is directly connected to the sale or rental of a dwelling, and the water, gas, and electricity services at issue here fall within the scope of section 3604(b). Finally, the court rejected the City's argument that it is not a housing provider subject to section 3604(b), and held that section 3604(b) does not limit its applicability in such a manner and the court's case law has never held that only housing providers are subject to liability thereunder. Accordingly, the court remanded for further proceedings. View "Georgia State Conference of the NAACP v. City of LaGrange" on Justia Law

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The Eleventh Circuit affirmed the district court's denial of petitioner's 28 U.S.C. 2254 federal habeas corpus petition challenging his convictions for first-degree murder and possession of a firearm during the commission of a felony. Applying de novo review, the court held that petitioner's trial counsel did not provide ineffective assistance by failing to investigate and present available evidence that his relationship with the victim was loving and respectful and that he did not "live off" her, because the evidence at issue was repetitious; even assuming that counsel provided ineffective assistance, petitioner failed to show prejudice; and although petitioner's claim was procedurally defaulted, the court held that the Florida Supreme Court's decision denying his Brady claim was not based on an unreasonable determination of the facts and was not contrary to, or an unreasonable application of, clearly established federal law. View "Riechmann v. Florida Department of Corrections" on Justia Law

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Defendant, a probation officer, appealed the district court's conclusion that she was not entitled to quasi-judicial immunity, qualified immunity, and Georgia official immunity from plaintiff's 42 U.S.C. 1983 and state law claims. The Eleventh Circuit held that the conduct at issue here—a Georgia probation officer applying for an arrest warrant—is not the kind of conduct entitled to absolute, quasi-judicial immunity. The court also held that defendant was not entitled to Georgia statutory immunity because defendant was an employee of the county. However, the court held that defendant's actions did not violate plaintiff's clearly established rights and a reasonable officer in defendant's position could have believed that her actions were lawful. In this case, the complaint did not allege that defendant intentionally disregarded pertinent exculpatory information about plaintiff. Because defendant never received a phone call indicating that plaintiff had paid his fine, she already possessed evidence that he had not paid. Therefore, defendant was entitled to qualified immunity. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Washington v. Rivera" on Justia Law

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Plaintiff filed suit against Habitat for Humanity under the Fair Housing Amendments Act, which prohibits an entity from discriminating against a disabled individual by failing to make reasonable accommodations in policies and practices that are necessary to afford the individual an equal opportunity to use and enjoy a dwelling. Plaintiff also alleged that Habitat's minimum-income requirement has a disparate impact on disabled individuals receiving social-security-disability income. The Eleventh Circuit held that a court must first consider whether a plaintiff has shown that a requested accommodation is facially reasonable and then whether a defendant has demonstrated that the accommodation would result in an undue burden or fundamental alteration to its program or policy; a plaintiff's financial state in any particular case could be unrelated, correlated, or causally related to his disability and that, in some cases, an accommodation with a financial aspect—even one that appears to provide a preference—could be necessary to afford an equal opportunity to use or enjoy a dwelling within the meaning of the Act; and plaintiff failed to create a genuine issue of material fact as to whether Habitat's minimum-income requirement disproportionately excludes SSDI recipients. Accordingly, the court affirmed the disparate-impact claim, but vacated the failure-to-accommodate claim and remanded for further proceedings. View "Schaw v. Habitat for Humanity of Citrus County, Inc." on Justia Law

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The Department of Justice filed suit against the State of Florida, seeking declaratory and injunctive relief under Title II of the Americans with Disabilities Act (ADA) and 28 C.F.R. 35.130(d). The Department alleged that Florida was failing to meet its obligations under Title II by unnecessarily institutionalizing hundreds of children with disabilities in nursing facilities. The Department also alleged that Florida's Medicaid policies and practices placed other children who have "medically complex" conditions, or who are "medically fragile," at risk of unnecessary institutionalization. The Eleventh Circuit held that the Attorney General has a cause of action to enforce Title II of the ADA. The court held that when Congress chose to designate the "remedies, procedures, and rights" in section 505 of the Rehabilitation Act, which in turn adopted Title VI, as the enforcement provision for Title II of the ADA, Congress created a system of federal enforcement. The court also held that the express statutory language in Title II adopts federal statutes that use a remedial structure based on investigation of complaints, compliance reviews, negotiation to achieve voluntary compliance, and ultimately enforcement through "any other means authorized by law" in the event of noncompliance. Therefore, courts have routinely concluded that Congress's decision to utilize the same enforcement mechanism for Title II as the Rehabilitation Act, and therefore Title VI, demonstrates that the Attorney General has the authority to act "by any other means authorized by law" to enforce Title II, including initiating a civil action. Accordingly, the court reversed the district court's judgment and remanded. View "United States v. State of Florida" on Justia Law

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This consolidated appeal arose after Massage Envy’s stated reason for the termination of intervenor was its fear that she might contract and later develop Ebola due to her trip to Ghana. EEOC and intervenor appealed the entry of judgment for Massage Envy on their employment discrimination claims under the Americans with Disabilities Act of 1990 (ADA), as amended by the ADA Amendments of 2009. The Eleventh Circuit held that, even construing the statute broadly, the terms of the ADA protect persons who experience discrimination because of a current, past, or perceived disability—not because of a potential future disability that a healthy person may experience later. Therefore, the court affirmed the district court's final judgment in favor of Massage Envy. View "Lowe v. STME, LLC" on Justia Law