Justia Civil Rights Opinion Summaries

Plaintiffs were employees of VMSB’s restaurant. They argue that VMSB failed to meet its minimum wage and overtime pay obligations under the Fair Labor Standards Act and comparable Florida laws. Plaintiffs’ complaint alleged three counts, and both sides filed cross-motions for summary judgment. Plaintiffs moved the district court to approve the settlement and to “direct the clerk to dismiss Count III” with prejudice. The district court ultimately adopted the magistrate judge’s report and recommendation and entered judgment for VMSB on Counts I and II. Plaintiffs filed a notice of appeal regarding Counts I and II.   The Eleventh Circuit dismissed the appeal. The court explained that Federal Rule of Civil Procedure 41(a)(2) provides only for the dismissal of an entire action. Any attempt to use this rule to dismiss a single claim, or anything less than the entire action, will be invalid—just like it would be under Rule 41(a)(1). Because the parties here attempted to use Rule 41(a) to dismiss a single count and not an entire lawsuit, a final judgment was never rendered. Accordingly, the court found that it lacks jurisdiction to hear this appeal. View "Israel Rosell, et al. v. VMSB, LLC" on Justia Law

Plaintiff, a Florida prisoner, brought a complaint under 42 U.S.C. Section 1983 alleging sexual abuse by Defendant, a pastor at a church Plaintiff attended more than thirty years ago. A magistrate judge granted Plaintiff leave to proceed in forma pauperis and then recommended that the case be dismissed for failure to state a claim. In response, Plaintiff submitted a filing seeking to voluntarily dismiss the case and to receive a refund of his court fees. The district court, rather than treating Plaintiff’s filing as a self-executing notice of dismissal under Fed. R. Civ. P. 41 referred the matter to the magistrate judge, who issued a report recommending that Plaintiff’s requests be denied. The magistrate judge made that recommendation in an attempt to further the purposes of the “three-strikes provision” of the Prison Litigation Reform Act (“PLRA”). The district court adopted the magistrate judge’s recommendation, and this appeal followed.  Plaintiff, represented by counsel on appeal, contends that the district court erred by invoking the PLRA’s purposes to trump his clear right to voluntarily dismiss the action under Rule 41.   The Eleventh Circuit vacated the district court’s judgment. The court explained that it found no language in the PLRA purporting to limit or condition a plaintiff’s right to voluntarily dismiss an action “without a court order” under Rule 41(a) in the prisoner-litigation context. Plaintiff acted within the bounds of Rule 41(a) by filing a notice of dismissal before Defendant responded. That notice was effective immediately upon filing and deprived the court of jurisdiction over the case. View "Jason Elliott Smith v. Delwyn Gerald Williams" on Justia Law

Eberspaecher North America (“ENA”), is a company that manufactures car components with its headquarters in Novi, Michigan and six other locations across the country. An employee at one of these locations—ENA’s Northport, Alabama plant—complained to the Equal Employment Opportunity Commission (“EEOC”) that he was fired for taking protected absences under the Family Medical Leave Act (“FMLA”). An EEOC Commissioner charged ENA with discrimination under the Americans with Disabilities Act Amendments Act (“ADAAA”), listing only the Northport facility in the written charge. The EEOC then issued requests for information on every employee terminated for attendance-related infractions at each of ENA’s seven domestic facilities around the nation. ENA objected to the scope of those requests. The district court ordered ENA to turn over information related to the Northport, Alabama, facility but refused to enforce the subpoena as to information from other facilities. The EEOC appealed, arguing that the district court abused its discretion. In the alternative, the EEOC contends that, even if the charge were limited to the Northport facility, nationwide data is still relevant to its investigation.   The Eleventh Circuit affirmed the district court’s order enforcing only part of the EEOC’s subpoena. The court explained the EEOC’s investigatory process is a multi-step process designed to notify employers of investigations into potentially unlawful employment practices. The court held that the EEOC charged only ENA’s Northport facility— which provided notice to ENA that the EEOC was investigating potentially unlawful employment practices only at that specific facility—and thus that the nationwide data sought by the EEOC is irrelevant to that charge. View "Equal Employment Opportunity Commission v. Eberspaecher North America Inc." on Justia Law

Plaintiff was let go from her position at Brandstar Studios shortly after her father fell ill. Following her termination, Plaintiff sued Brandstar under the Family and Medical Leave Act and the Americans with Disabilities Act. The district court granted Brandstar summary judgment. On appeal, Plaintiff argued that Brandstar executives interfered with her rights under the FMLA. Second, she asserted that her termination constituted associational discrimination under the ADA. And finally, she claimed that the district court improperly weighed the evidence on summary judgment rather than construing the facts in her favor.   The Eleventh Circuit affirmed. The court explained that the parties agreed that Brandstar provided Plaintiff the leave she requested in her May 2 email and that she received full pay for those days. In fact, Plaintiff accidentally clocked in on her two days of requested leave, and Brandstar HR executives circled back weeks later to ensure that she corrected her timecard to reflect her requested leave. Thus, Plaintiff can’t demonstrate that she was harmed by Brandstar’s technical failure to notify her of her FMLA rights. Further, the court found that not only did Plaintiff fail to “request leave” in the May 6 email, but there’s also no indication that Brandstar “acquired knowledge” on its own that she wanted leave for an FMLA-qualifying reason. Moreover, the court found that the only evidence Plaintiff marshaled is the “temporal proximity” between her father’s acute onset decline and her termination—which isn’t enough to show pretext. View "Jessica Graves v. Brandstar Studios, Inc." on Justia Law

After being fired by his employer, Anheuser-Busch Companies, LLC, Intervenor filed suit in federal district court, alleging that his termination reflected racial discrimination and retaliation in violation of Title VII. Anheuser-Busch filed a motion seeking to compel arbitration of Intervenor’s district court claims, asserting that at the time when he was hired, Intervenor had agreed to be bound by the company’s Dispute Resolution Policy. Intervenor disagreed that he was required to arbitrate his claims. After Anheuser-Busch asked the district court to compel arbitration, Intervenor filed an unfair labor practice charge with the NLRB, arguing that Defendant’s efforts to enforce its arbitration agreement contravened the collective bargaining agreement and constituted a unilateral change to the terms of Intervenor’s employment, in violation of the National Labor Relations Act (“NLRA”).   The Eleventh Circuit granted the petition for review of the Board’s order dismissing the complaint, vacated the decision of the Board, and remanded for consideration of whether enforcement of the Dispute Resolution Policy against Intervenor would violate the NLRA. The court held that the Board applied an erroneously narrow standard for determining whether Anheuser-Busch’s motion had an illegal objective. The court explained that on remand, the Board should instead determine whether the outcome sought by Anheuser-Busch’s motion— the compelled arbitration of Brown’s Title VII claims under the Dispute Resolution Policy—would violate the NLRA. If the Board decides that the answer to that question is “yes,” it should then order all relief that is appropriate based on Anheuser-Busch’s unlawful conduct. View "International Brotherhood of Teamsters Local 947 v. National Labor Relations Board" on Justia Law

Plaintiff alleged (1) Officer N. used excessive force when he tased Plaintiff at the scene of an automobile wreck, (2) Officer H. failed to intervene to prevent Officer N’s excessive force, and (3) the City of Madison, Alabama admitted the officers’ actions were the result of its municipal policy. Relying on body camera footage, Defendants Officer N., Officer H., and the City moved to dismiss. The district court granted their motions to dismiss. On appeal, Plaintiff argued the district court erred by (1) considering the officers’ body camera footage when ruling on Defendants’ motions to dismiss without converting them into summary judgment motions, (2) granting qualified immunity to Officer N., (3) dismissing Plaintiff’s failure-to-intervene claim against Officer H., and (4) dismissing his municipal liability claim against the City.   The Eleventh Circuit affirmed. The court concluded that the district court properly considered the body camera footage, correctly ruled that Officer N. did not violate a constitutional right and thus Officer H. had no duty to intervene and accurately determined that Plaintiff’s claim against the City failed as a matter of law. The court explained Officer N.’s use of the taser was justified because of (1) Plaintiff’s repeated failure to comply with Officer N.’s commands, (2) Plaintiff’s unsafe driving that had just caused an automobile accident, (3) Plaintiff’s repeated efforts to get back in the vehicle, (4) Plaintiff’s physical resistance to Officer N.’s attempts to remove him from the vehicle, and (5) the tense, uncertain, and rapidly evolving series of events. Thus, the court concluded that Officer N.’s single use of a taser in dart mode was objectively reasonable. View "Curtis Baker v. City of Madison, Alabama, et al." on Justia Law

Plaintiff is a Florida death-row prisoner who is scheduled to be executed on May 3, 2023, at 6:00 p.m. Barwick brought an action under 42 U.S.C. Section 1983, arguing that the Governor of Florida and several other state officials violated his constitutional right to due process because they did not adequately consider his candidacy for executive clemency. He also moved for an emergency stay of execution. The district court denied Plaintiff’s motion for a stay. Plaintiff then moved in this Court for a stay of execution pending appeal.   The Eleventh Circuit denied Plaintiff’s motion for a stay. The court explained that here Plaintiff argued that the State violated his due-process rights because it did not provide any standards that would govern the clemency decision. But under the Eleventh Circuit’s binding precedent, the court wrote it cannot agree that the Due Process Clause requires the State to provide any such standards. An initial problem with Plaintiff’s argument about the State’s lack of standards is that it runs counter to Supreme Court authority. Further, the court held that it cannot agree with Plaintiff’s argument that his clemency proceeding was arbitrary because the Commission allegedly “provided false guidance” when it said it was not concerned with his guilt but then “myopically focused on [his] crime.” Accordingly, the court held that Plaintiff’s due-process claim does not have a substantial likelihood of success on the merits. View "Darryl Barwick v. Governor of Florida, et al" on Justia Law

Greater Birmingham Ministries (“GBM”), an Alabamian non-profit organization dedicated to aiding low-income individuals, and several Alabamian felons (collectively “Appellants”) appealed the district court’s summary judgment denying their Equal Protection Clause challenge to Amendment 579 of the Alabama state constitution, their Ex Post Facto Clause, challenge to Amendment 579’s disenfranchisement provisions, and their National Voting Registration Act of 1993 (“NVRA”), challenge to the format of Alabama’s mail voting registration form.The Eleventh Circuit affirmed. The court held that (1) Amendment 579 successfully dissipated any taint from the racially discriminatory motives behind the 1901 Alabama constitution; (2) Amendment 579 does not impose punishment for purposes of the Ex Post Facto Clause; and (3) Alabama’s mail voting registration form complies with the NVRA. The court wrote that it rejects Appellants’ invitation to review the extent the Alabama legislature debated the “moral turpitude” language of Amendment 579. Further, the court explained that Section 20508(b)(2)(A) is a notice statute enacted for the convenience of voting registrants. Alabama’s mail-in voting form has provided sufficient notice by informing registrants that persons convicted of disqualifying felonies are not eligible to vote and providing an easily accessible link whereby voters convicted of felonies can determine their voter eligibility. Accordingly, Alabama has complied with the requirements of Section 20508(b)(2)(A). View "Treva Thompson, et al. v. Secretary of State for the State of Alabama, et al." on Justia Law

Plaintiff, one day before the expiration of the statutory limitations period, initiated suit pro se against federal prison officials on behalf of his deceased mother’s estate. Plaintiff, who had unsuccessfully attempted to retain counsel before filing suit, did not know that he could not represent his mother’s estate pro se and needed, instead, to secure legal representation. Several months later, but before responsive pleadings were filed by Defendants, he retained counsel who entered an appearance and filed an amended complaint on behalf of the estate reasserting the original cause of action, asserting additional causes of action, and adding the United States as a defendant. Plaintiff assumed that retaining counsel and filing an amended complaint corrected his original mistake. The district court disagreed and dismissed the suit.
The Eleventh Circuit reversed. The court explained that while Plaintiff was not legally authorized under 28 U.S.C. Section 1654 to represent the Estate pro se, the district court erred in dismissing the case without first providing Plaintiff an opportunity to rectify his mistake by obtaining counsel. Once properly represented, the Estate was entitled to file the amended complaint as a matter of course pursuant to Rule 15(a)(1). Further, the FTCA claims asserted therein were timely, and the Bivens claims relate back to the date of filing of the original complaint. Therefore, the Estate’s claims can proceed. View "Grant Sunny Iriele v. Richard Carroll Griffin, et al" on Justia Law

This appeal concerns whether several organizations may sue the governor and attorney general of Florida in federal court to challenge a state law that requires local law enforcement to cooperate with federal immigration officials. The state law provides that local officials shall support the enforcement of federal immigration law and cooperate with federal immigration initiatives and officials and that local officials may transport aliens subject to an immigration detainer to federal custody. Several plaintiff organizations sued the Florida governor and the Florida attorney general to enjoin enforcement of the law. The organizations alleged that the provisions about support and cooperation were adopted with the intent to discriminate based on race and national origin in violation of the Fourteenth Amendment. And they maintained that the transport provision is preempted by federal law. After a bench trial, the district court permanently enjoined the governor and attorney general from enforcing compliance with these provisions.The Eleventh Circuit vacated and remand with instructions to dismiss for lack of jurisdiction. The court held that this controversy is not justiciable because the organizations lack standing. The organizations have not established a cognizable injury and cannot spend their way into standing without an impending threat that the provisions will cause actual harm. Moreover, the organizations’ alleged injury is neither traceable to the governor or attorney general nor redressable by a judgment against them because they do not enforce the challenged provisions. Instead, local officials, based on state law, must comply with federal immigration law. View "City of South Miami, et al v. Governor of the State of Florida, et al" on Justia Law