Justia Civil Rights Opinion Summaries

Plaintiff had three possible strikes: one dismissal for failure to state a claim, another dismissal for failure to exhaust administrative remedies, and a summary judgment for failure to exhaust. The first dismissal is a strike because the dismissing court expressly said it was dismissing the action for failure to state a claim. At issue was whether: (1) “Is a dismissal for failure to exhaust administrative remedies a ‘strike’ for purposes of the Prison Litigation Reform Act?”; and (2) “If a dismissal for failure to exhaust administrative remedies can be a ‘strike’ for purposes of the [Act]’s ‘three strikes’ provision, does Wells have three strikes?”   The Eleventh Circuit reversed the dismissal of Plaintiff’s complaint based on the three-strikes rule and remanded for further proceedings. The court explained that it agreed with the district court that the second dismissal—for failure to exhaust—counted as a strike because the dismissing court gave some signal in its order that the action was dismissed as frivolous, malicious, or for failure to state a claim. But the court agreed with Plaintiff that the summary judgment for failure to exhaust was not a strike because it was not a dismissal for failure to state a claim. Thus, without three strikes, the district court erred in dismissing Plaintiff’s complaint under the three-strikes rule. View "Jeremy John Wells v. Warden, et al" on Justia Law

Deputy sheriffs arrested Plaintiff based on a warrant for another man of the same name, detained him, and released him when his identity was verified three days later. Plaintiff sued the deputies for violating his alleged due process right to be free from over-detention under 42 U.S.C. Section 1983. The district court dismissed Plaintiff’s complaint for failure to state a claim.   At issue was whether an individual detained for three days based on mistaken identity for a valid arrest warrant has stated a claim for relief under the Fourteenth Amendment for his over-detention. The Eleventh Circuit affirmed. The court reasoned that under Baker v. McCollan, no violation of due process occurs if a detainee’s arrest warrant is valid and his detention lasts an amount of time no more than three days. And both conditions are met here. The court explained that Plaintiff was arrested on a valid warrant and held for only three days. Thus, under Baker, Plaintiff’s complaint did not state a claim for a violation of his due process rights. View "David Sosa v. Martin County, Florida, et al." on Justia Law

Residents of the Royal Palm Village Mobile Home Park in Haines City, Florida, sued the Park’s owners in federal court. The residents alleged that the owners had engaged in fraud by, among other things, illegally passing on costs to the residents, embellishing lot descriptions to justify increased rents, and falsely promising to upgrade roads and other common areas. The residents filed an amended complaint alleging violations of a slightly different collection of state and federal statutes: four counts under both the federal and Florida RICO statutes—as well as one under the ADA. The owners moved to dismiss. The district court dismissed the amended complaint for essentially the same reasons that it had dismissed the initial complaint. The owners now appeal the district court’s rejection of their fee requests pertaining to the first and second amended complaints. Those complaints, the owners argue, were also “to enforce” the FMHA because the residents predicated the RICO claims in those complaints on violations of the FMHA.   The Eleventh Circuit affirmed the district court’s ruling. The court explained that here the alleged FMHA violations set out in the residents’ amended complaints were not independent legal claims, but rather components of other claims (e.g., the RICO claims). The amended complaints did not seek any relief under the FMHA. Nor did they request compliance with the FMHA. Those complaints, therefore, were not “proceeding[s] to enforce provisions” of the FMHA. The district court correctly denied fees to the owners as to those complaints under Section 723.068. View "Royal Palm Village Residents, Inc., et al v. Monica Slider, et al" on Justia Law

The Florida Legislature passed the Combatting Violence, Disorder, and Looting, and Law Enforcement Protection Act, also known as House Bill 1 (“HB 1”), 2021 Fla. Leg. Sess. Laws Serv. ch. 2021-6. HB 1 redefined the crime of “riot.” After HB 1’s passage, Dream Defenders and other organizations that lead protests for racial justice challenged the new definition as unconstitutional, alleging that it infringed their members’ First Amendment right to engage in peaceful protest. The district court agreed with the plaintiffs that the new statutory definition was vague and overbroad and, therefore likely to chill or deter their members’ exercise of their First Amendment rights. The court entered a preliminary injunction that prevented the defendants, Governor DeSantis and three sheriffs, from taking any steps to enforce the law using the new definition.   The Eleventh Circuit deferred its decision as to the preliminary injunction in this case until the Florida Supreme Court has had the opportunity to consider the following certified question:What meaning is to be given to the provision of Florida Stat. § 870.01(2) making it unlawful to “willfully participate[] in a violent public disturbance involving an assembly of three or persons, acting with a common intent to assist each other in violent and disorderly conduct, resulting in . . . [i]njury to another person; . . . [d]amage to property; . . . or [i]mminent danger of injury to another person or damage to property”? View "Dream Defenders, et al v. Governor of the State of Florida, et al" on Justia Law

Plaintiff is a U.S. citizen and a U.S. national, as that term is defined in 22 U.S.C. Section 6023(15). He claims to be the “rightful owner of an 82.5% interest in certain commercial waterfront real property in the Port of Santiago de Cuba,” identified by the Cuban government as La Marítima and Terminal Naviera. According to the complaints, the knowing and intentional conduct of Carnival and Royal Caribbean constitutes trafficking under Section 6023(13)(A). As a result, Plaintiff—who provided the cruise lines with written notice by certified mail of his intent to commence an action under Title III—claims that he is entitled to damages under Section 6082.   The Eleventh Circuit granted the petition for panel rehearing and vacated our prior opinion. The court held that Plaintiff has standing to assert his Title III claims, but that those claims fail on the merits. The court explained that the Cuban government confiscated La Marítima prior to March 12, 1996, and because Plaintiff acquired his interest in the property through inheritance after that date, his claims failed. The court, therefore, affirmed the district court’s grant of judgment on the pleadings in favor of Carnival and Royal Caribbean. View "Javier Garcia-Bengochea v. Carnival Corporation" on Justia Law

Defendant, the School Board of St. Johns County (the “School Board”), is responsible for providing “proper attention to health, safety, and other matters relating to the welfare of students” within the St. Johns County School District (the “School District”). Plaintiff, is a transgender boy. The case involves the practice of separating school bathrooms based on biological sex. This appeal required the court to determine whether separating the use of male and female bathrooms in public schools based on a student’s biological sex violates (1) the Equal Protection Clause of the Fourteenth Amendment, U.S. Const. amend. XIV, Sections 1, and (2) Title IX of the Education Amendments Act of 1972. The district court enjoined the School Board from prohibiting Plaintiff’s use of the male bathrooms and granted Plaintiff $1,000 in compensatory damages.   The Eleventh Circuit reversed and remanded the district court’s order. The court explained that commensurate with the plain and ordinary meaning of “sex” in 1972, Title IX allows schools to provide separate bathrooms on the basis of biological sex. That is exactly what the School Board has done in this case; it has provided separate bathrooms for each of the biological sexes. And to accommodate transgender students, the School Board has provided single-stall, sex-neutral bathrooms, which Title IX neither requires nor prohibits. Nothing about this bathroom policy violates Title IX. Further, the court wrote that whether Title IX should be amended to equate “gender identity” and “transgender status” with “sex” should be left to Congress—not the courts. View "Drew Adams v. School Board of St. Johns County, Florida" on Justia Law

Plaintiffs L.E., B.B., A.Z., and C.S., are students who have respiratory disabilities (“Students”). They appealed the denial of their motion for a temporary restraining order and preliminary injunction. The Students sued Defendants, the Superintendent of the Cobb County School District, individual members of the Cobb County School Board, and the Cobb County School District (collectively, “CCSD”), in the wake of the COVID-19 pandemic. The Students claim that CCSD’s refusal to provide reasonable accommodations for access to in-person schooling constitutes a violation of Title II of the Americans with Disabilities Act (“ADA”) and Section 504 of the Rehabilitation Act (“Section 504”).   The Eleventh Circuit reversed and remanded for analysis under the correct scope: access to the benefits provided by in-person schooling. The court held this claim presents a live controversy that survives mootness and the district court erred in its review of the Students’ discrimination claims. The Students argue that CCSD ignored those recommendations and continues to disregard CDC guidance in this respect. Therefore, this remains a live controversy. A judgment in their favor would grant the Students meaningful relief by requiring CCSD to follow the guidance on accommodating students with disabilities under the ADA and Section 504 as it is updated—a practice the Students claim CCSD refuses to do. Thus, this claim remains a live controversy. Further, the court wrote that the district court erred in holding the Students must show a substantial likelihood of success on the merits on a disparate treatment claim. View "L.E., et al v. Superintendent of Cobb County School District, et al" on Justia Law

Plaintiff as pulled over by a deputy of the Jackson County Sheriff’s Office for erratic driving. During the stop, the deputy noticed an open container of beer and decided to issue a warning citation. The deputy wrote—but never delivered—the ticket. Instead, a few minutes into the stop, he ordered Plaintiff out of the truck so he could walk his drug-sniffing dog around the vehicle. Plaintiff resisted the deputy’s commands verbally and then physically. The deputy arrested him for obstruction and Plaintiff suffered minor injuries. His truck was searched, but no drugs were found. The obstruction charge was later dismissed. A couple years after this encounter, Plaintiff filed claims against the deputy and the Jackson County Sheriff under 42 U.S.C. Section 1983 and Florida common law.   The Eleventh Circuit vacated he district court’s summary judgment on the Section 1983 claim against the deputy, but only with respect to the issue of whether the deputy unlawfully prolonged the traffic stop in violation of Plaintiff’s Fourth Amendment rights. The court also vacated the district court’s summary judgment on the false imprisonment claim against both the deputy and the Jackson County Sheriff, but only with respect to the issues of whether the deputy tortiously detained Plaintiff by (1) unlawfully prolonging the traffic stop and (2) arresting Plaintiff without probable cause. The court affirmed the district court’s summary judgment in all other respects. View "Michael Baxter v. Louis Roberts, III, et al." on Justia Law

Plaintiff a veteran currently imprisoned by the state of Florida, sued prison and state officials under 42 U.S.C. Section 1983, alleging that they violated his rights under Section 5301 by taking his VA benefits from his inmate account to satisfy liens and holds stemming from medical, legal, and copying expenses he had incurred in prison. Plaintiff also sought to enjoin a Florida administrative rule requiring that inmates have their VA benefits sent directly to their inmate accounts for prison officials to honor the funds’ protected status, which Plaintiff contended violates Section 5301, thereby running afoul of the Supremacy Clause of the United States Constitution. After dismissing some of Defendants, the district court granted qualified immunity to those remaining. It also found that Plaintiff lacked standing to challenge Florida’s administrative rule.   The Eleventh Circuit affirmed. The court held that Plaintiff lacks standing because he has failed to show a “real” and “immediate” threat of future injury from complying with the Florida Direct Deposit Rule, pointing only to injuries in the distant past. Although it appears that Plaintiff initially suffered concrete harm when he transitioned to keeping two addresses on file with the VA (i.e., receiving VA checks several months late in the spring of 2013), that harm occurred only in the immediate aftermath of the address change—over nine years ago. Thus the court held that because Plaintiff has not shown a “real or immediate threat” of future injury from keeping two addresses to comply with Florida’s administrative rule, he lacks standing to challenge it. View "John David Wilson, Jr. v. Secretary, Department of Corrections, et al" on Justia Law

Plaintiff, an Alabama prisoner, brought this 42 U.S.C. Sec. 1983 action alleging long delays in his receipt of treatment for hernias and for post-surgery complications. In his pro se third amended complaint, Plaintiff asserted claims of deliberate indifference to his serious medical needs against: (1) Wexford Health Sources, Inc. (“Wexford”), a private contractor that provides health care services for Alabama inmates; (2) Kay Ivey, the Governor of Alabama; and (3) Jefferson Dunn, the Commissioner of the Alabama Department of Corrections.The district court (1) granted summary judgment in favor of Wexford and (2) dismissed Roy’s complaint against Governor Ivey and Commissioner Dunn for failure to state a claim.The Eleventh Circuit affirmed, finding that only one of several statements from other inmates that Plaintiff presented satisfied the requirements of 28 U.S.C. Sec. 1746 because the other statements were only presented as "affidavits" and did not mention the statement was “true and correct” and was made “under penalty of perjury." Considering Plaintiff's remaining evidence, the Eleventh Circuit held that the district court did not err in entering judgment in favor of Defendants. View "Larry Roy v. Kay Ivy, et al." on Justia Law