Justia Civil Rights Opinion Summaries

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

Plaintiffs (the Estate) appealed the district court’s grant of summary judgment for the named Defendants. This appeal stems from the circumstances surrounding Plaintiff’s son's detention and death at the Charlotte County Jail.  The Estate brought a seven-count complaint against the named Defendants. The district court granted each of the summary judgment motions in full, finding that the Estate failed to present evidence sufficient to raise a genuine issue of material fact on any of the claims, and entered final judgment for the Defendants.   The Eleventh Circuit affirmed the grant of summary judgment for the Sherriff of Charlotte County, the jail’s health care provider, and the jail’s medical personnel. The court also affirmed the grant of summary judgment for the jail’s corrections officers. The court agreed with the district court’s conclusion that the Estate failed to carry its burden of establishing a reasonable dispute of material fact regarding whether either the prison or the Sheriff advanced an unconstitutional policy or custom. Specifically, the district court found that Ireland’s Estate presented “no evidence” of an unconstitutional policy or custom and, at most, that the  Estate pointed to isolated incidents by the prison and the Sherriff.   Further, because there is no evidence in the record from which the court can infer that the officers were aware of the man’s need for medical aid at any time during the encounter before he ultimately lost consciousness, the deliberate indifference to medical treatment claims against the officers fail and summary judgment in their favor was proper. View "Thomas B. Ireland v. Bill Prummell, et al." on Justia Law

Appellant was sexually assaulted by a deputy sheriff in Harris County, Georgia, who’s now serving an eight-year prison term. In the part of this civil-rights lawsuit, Appellant sued Harris County and the Sheriff of Harris County (Sheriff), alleging that the Sheriff failed in various ways to prevent the deputy from assaulting her. The district court found that the Sheriff was entitled to qualified immunity, and granted summary judgment.   The Eleventh Circuit affirmed. The court explained that Appellant fails the first prong of the court’s analysis because she cannot show that, in the course of supervising the deputy, the Sheriff violated her constitutional rights. The court reasoned that “It is well established in this Circuit that supervisory officials are not liable under Section 1983 for the unconstitutional acts of their subordinates on the basis of respondeat superior”. Accordingly, the court concluded that because the Sheriff had no notice of the deputy’s tendency to sexually assault civilians in his custody—he cannot be held responsible for the unpredictable acts of his subordinate View "Lynette Christmas v. Harris County, Georgia, et al" on Justia Law

A.L. is an adult male diagnosed with autism. A.L. is in his late twenties, but his developmental age is “five-to-seven years old.” A.L.’s case is one of over forty actions filed by plaintiffs with disabilities against Disney in Florida and California federal courts, asserting that Disney failed to accommodate their requested modifications to its disability-accommodation program in violation of 42 U.S.C. Section 12182(b)(2)(A)(ii). The district court entered final judgment in favor of Disney after determining that A.L.’s requested modification to receive either ten “Re-admission Passes” for each person in his party or unlimited access to Disney’s expedited “FastPass” lines for its theme park attractions was neither necessary to accommodate A.L.’s disability nor reasonable under the Americans with Disabilities Act of 1990 (the “ADA”).   The Eleventh Circuit affirmed. The court wrote it discerned no clear error in the district court’s factual findings, no legal error in its fundamental-alteration analysis, and no abuse of discretion in its evidentiary rulings. Moreover, the district court here applied the correct legal test. It considered whether the requested modification would affect merely peripheral aspects of Disney’s parks or aspects essential to Disney’s services. The court further found that the other reasons A.L. offers for the presentation of the excluded evidence are neither relevant nor probative of the individualized injunctive relief he sought. View "A. L. v. Walt Disney Parks and Resorts US, Inc." on Justia Law

In Plaintiff’s malicious prosecution claim against Defendant, a detective with the Albany Police Department, the Eleventh Circuit previously vacated an order dismissing Plaintiff’s complaint for failure to allege a favorable termination on a charge of felony murder. Plaintiff appealed the summary judgment in favor of Defendant based on qualified immunity. The district court ruled that, even though Defendant’s affidavit was insufficient to provide probable cause to support the warrant to arrest Plaintiff, the detective had at least arguable probable cause to arrest Plaintiff.   The Eleventh Circuit again vacated the order granting summary judgment in the detective’s favor and remanded. The court concluded that because Plaintiff established that the legal process underlying his seizure was constitutionally infirm and it would not have been otherwise justified, the detective does not enjoy immunity from suit. The court explained that under longstanding Supreme Court precedent, an officer must provide particular information to support an arrest warrant. Here, no “reasonably competent officer” could have concluded that a warrant should issue based on the glaring deficiencies in the affidavit. As a result, the unlawfulness of the detective’s conduct was clearly established when he acted and he was not entitled to qualified immunity. View "Demetrius Rashard Luke v. Jameel H. Gulley" on Justia Law