Justia Civil Rights Opinion SummariesArticles Posted in US Court of Appeals for the Eleventh Circuit
Thomas B. Ireland v. Bill Prummell, et al.
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
Lynette Christmas v. Harris County, Georgia, et al
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. v. Walt Disney Parks and Resorts US, Inc.
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
Demetrius Rashard Luke v. Jameel H. Gulley
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
Reginald L. Gundy v. City of Jacksonville, Florida, et al
This appeal arises from a legislative invocation given by an invited, guest speaker before the opening of a Jacksonville City Council meeting. A City Council member Anna Brosche, and a then-mayoral candidate, invited Plaintiff to give the invocation at the March 12, 2019, City Council meeting. When Plaintiff transitioned to levying criticisms against the City’s executive and legislative branches, the president of the City Council at the time, A.B., interrupted Plaintiff and later cut off his microphone. Plaintiff brought suit against both the City and A.B. in his personal capacity. In his first two counts, actionable under 42 U.S.C. Section 1983, Plaintiff alleged that both the City and Mr. Bowman violated his First Amendment rights under the Free Exercise Clause (Count I) and the Free Speech Clause (Count II) of the United States Constitution. The district court granted the Defendants’ motion to dismiss in part and denied it in part. The Eleventh Circuit held that the district court erred in deeming Plaintiff’s invocation to be private speech in a nonpublic forum, the court affirmed the district court’s orders on the alternative ground that the invocation constitutes government speech, not subject to attack on free speech or free exercise grounds. The court explained that he did not bring a claim under the Establishment Clause. And since his invocation constitutes government speech, his speech is not susceptible to an attack on free speech or free-exercise grounds. View "Reginald L. Gundy v. City of Jacksonville, Florida, et al" on Justia Law
Tracey M. Chance v. Ariel Cook, et al
Plaintiff a female employee of Wakulla County (“the County”), worked for the County’s building department. Plaintiff filed a lawsuit in federal district court for, among other claims, the County’s violation of Title VII of the Civil Rights Act of 1964. In the present case, Plaintiff filed a five-count complaint against the defense attorneys for the County. The defense attorneys and their law firms filed several motions to dismiss under Federal Rule of Civil Procedure 12(b)(6). The district court dismissed the complaint, explaining that Plaintiff’s alleged facts did not demonstrate that the defense attorneys for the County had engaged in a conspiracy that met the elements of 42 U.S.C. Section 1985(2). Plaintiff’s complaint suggested that the defense attorneys filed the complaint for the “sole benefit of their client rather than for their own personal benefit.” Alternatively, Plaintiff points to the fact that the County defense attorneys had been aware of Plaintiff’s recordings for many months and only reported her recordings to law enforcement when they learned that Plaintiff “insist[ed] on her right to testify in federal court about the recordings and present them as evidence” in the sexual harassment case. The Eleventh Circuit affirmed. The court explained that per Farese, it is Plaintiff’s burden to allege facts that establish that the County defense attorneys were acting outside the scope of their representation when they told law enforcement about Plaintiff’s recordings. Here, Plaintiff but in no way suggests that the defense attorneys were acting outside the scope of their representation, thus her Section 1985(2) claims were properly dismissed. View "Tracey M. Chance v. Ariel Cook, et al" on Justia Law
Chabad Chayil, Inc. v. The School Board of Miami-Dade County Florida, et al.
Following a government investigation into an afterschool program run by Plaintiff Chabad Chayil, Inc., Defendant Miami-Dade County Public Schools (“MDCPS”) barred Chabad from continuing to use its facilities. Chabad sued both MDCPS and the investigating authority—Miami-Dade County’s Office of Inspector General (“OIG”)—for alleged violations of its federal constitutional rights. The district court dismissed those claims with prejudice and without leave to amend, and Chabad appealed. The Eleventh Circuit affirmed concluding that the district court properly dismissed all of Chabad’s Section 1983 claims against the MDCPS and OIG, and the court affirmed the dismissal of those claims without leave to amend. The court explained that the unspecified acts of unidentified OIG investigators in this single case do not plausibly allege an official policy of the OIG, or even a custom that rises to the force of law. Thus, the district court properly dismissed the Free Exercise claim against the OIG. Further, Chabad did not demonstrate that its comparators were similarly situated in all relevant respects. Accordingly, the district court correctly dismissed the Equal Protection claim against the OIG. Moreover, the court explained that to impose liability under Section 1983, the government entity’s actions must be the “moving force” behind the deprivation of a constitutional right. The OIG does not have the authority to refuse any group permission to use school board property–that power lies with MDCPS. Thus, even if the OIG did act in accordance with some official policy or custom, that policy or custom did not cause Chabad’s harm. View "Chabad Chayil, Inc. v. The School Board of Miami-Dade County Florida, et al." on Justia Law
Monteria Najuda Robinson v. William Sauls, et al
This case arises out of the shooting death of Plaintiff’s son. It required the Eleventh Circuit to decide whether video evidence creates a genuine dispute of material fact concerning whether law enforcement officers used excessive force while trying to arrest Plaintiff’s son.Plaintiff filed claims under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 (1971), against Officers Heinze, Hutchens, and Doyle, alleging that they violated her son’s Fourth Amendment rights by using excessive force in attempting to arrest him. The three Task Force officers sought summary judgment on the Bivens claims. They argued that they were entitled to qualified immunity because they used a reasonable level of force under the circumstances The Eleventh Circuit held that the district court correctly granted summary judgment to Officer Hutchens because he was entitled to qualified immunity. The district court also correctly determined that Officers Doyle and Heinze were entitled to qualified immunity for their actions before the flashbang detonated. Accordingly, the court affirmed those portions of the district court’s order. The district court erred, however, by granting qualified immunity to Officers Doyle and Heinze for their actions after the flashbang exploded. The court therefore reversed the district court’s order insofar as it granted them summary judgment on Plaintiff’s claim that they employed excessive force after the flashbang detonated. The court remanded for further proceedings consistent. View "Monteria Najuda Robinson v. William Sauls, et al" on Justia Law
William E. Henry v. Attorney General, State of Alabama
The former Speaker of the House of the Alabama Legislature was the target of a grand jury investigation in Lee County, Alabama. He was accused of misusing his office for personal gain, including by funneling money into his printing business. Plaintiff was a state representative at the time of the investigation into Speaker Hubbard. Plaintiff believed that he had evidence undermining the accusations against the speaker and contacted the defense team to help them. Plaintiff sued the Attorney General of Alabama in federal court. His complaint brought First Amendment claims under 42 U.S.C. section 1983. The relevant issues on appeal are: Does Alabama’s grand jury secrecy law prohibit a grand jury witness from divulging information he learned before he testified to the grand jury, and if so, does the secrecy law violate the First Amendment? And does the Alabama grand jury secrecy law’s prohibition on a witness disclosing grand jury information he learned “only by virtue of being made a witness” violate his First Amendment free speech rights? The Eleventh Circuit affirmed in part, reversed, in part, and remanded. The court concluded that Alabama’s grand jury secrecy law, unlike the Florida law in Butterworth, cannot reasonably be read to prohibit a grand jury witness from divulging information he learned before he testified to the grand jury. The court also concluded that the grand jury secrecy law’s prohibition on a witness’s disclosure of grand jury information that he learned only by virtue of being made a witness does not violate the Free Speech Clause. View "William E. Henry v. Attorney General, State of Alabama" on Justia Law
Herederos De Roberto Gomez Cabrera, LLC v. Teck Resources Limited
Plaintiff, a Florida LLC, sued a Canadian company, Teck Resources Limited, alleging that it had illegally trafficked in property to which Plaintiff says it has a claim. The district court granted Teck’s motion, holding that Florida’s long-arm statute didn’t provide jurisdiction over Teck and, additionally, that Teck lacked the necessary connection to the United States to establish personal jurisdiction under Federal Rule of Civil Procedure 4(k)(2).The Eleventh Circuit affirmed holding that courts should analyze personal jurisdiction under the Fifth Amendment using the same basic standards and tests that apply under the Fourteenth Amendment. The court wrote that applying the minimum-contacts test here is relatively straightforward. The court held that Teck doesn’t have contacts with the United States sufficient to establish either specific or general personal jurisdiction over it. Plaintiff’s suit doesn’t arise out of or relate to any of Teck’s ties with the United States. And because a relationship between the defendant’s conduct within the forum and the cause of action is necessary to exercise specific jurisdiction, the lack of any such relationship here dooms Plaintiff’s effort to establish specific personal jurisdiction over Teck. View "Herederos De Roberto Gomez Cabrera, LLC v. Teck Resources Limited" on Justia Law