Justia Civil Rights Opinion Summaries

After the City denied zoning permits to construct a Buddhist meditation and retreat center in a residential area of Mobile, the Association and its incorporators filed suit alleging violations of the Free Exercise and Equal Protection Clauses of the United States Constitution, several provisions of the federal Religious Land Use and Institutionalized Persons Act (RLUIPA), the Alabama Constitution, and state common-law principles.The Eleventh Circuit held that the district court applied the wrong standard in evaluating plaintiffs' claims under RLUIPA's substantial-burden provision and the Free Exercise Clause, and that the district court should reconsider those claims on remand under the proper standard, but that the district court properly rejected plaintiffs' claims under RLUIPA's equal-terms and nondiscrimination provisions and the Equal Protection Clause. The court also held that the district court misread the Alabama Religious Freedom Amendment (ARFA) and should reconsider plaintiffs' ARFA claim under the court's interpretation, but that the district court correctly rejected plaintiffs' negligent-misrepresentation claim. Therefore, the court vacated in part and remanded for further proceedings. The court affirmed the district court's rejection of plaintiffs' remaining claims. View "Thai Meditation Association of Alabama, Inc. v. City of Mobile" on Justia Law

The Eleventh Circuit affirmed the district court's denial of the 28 U.S.C. 2254 habeas corpus petition. The court held that the district court did not err in concluding that petitioner was not denied his right to counsel when the state court accepted his motion to withdraw his guilty plea without first appointing him new counsel or providing him an opportunity to confer with counsel; the district court did not err in concluding that petitioner's appellate counsel was not ineffective for failing to argue he had been denied his right to counsel before withdrawing his guilty plea; and the district court did not err in concluding that petitioner's appellate counsel was not ineffective for failing to raise a claim that petitioner did not knowingly and voluntarily waive his right to counsel, in violation of Faretta v. California, 422 U.S. 806 (1975). View "Tuomi v. Secretary, Florida Department of Corrections" on Justia Law

Petitioner appealed the district court's denial of his 28 U.S.C. 2255 petition for writ of habeas corpus. The Eleventh Circuit granted a certificate of appealability and held that the district court violated Clisby v. Jones, 960 F.2d 925 (11th Cir. 1992) (en banc), by failing to address petitioner's claim that he no longer qualified as an armed career criminal in light of Johnson v. United States, 576 U.S. 591 (2015), because his prior 1988 Alabama conviction for attempted first-degree robbery has no state law elements. The court explained that Clisby requires a federal district court to resolve all claims for relief raised in a petition for writ of habeas corpus pursuant to section 2254, regardless of whether habeas relief is granted or denied. In this case, the district court never in the first instance resolved petitioner's claim that his attempted robbery conviction could not be a violent felony because, as an offense unrecognized by Alabama law, it has no elements at all. Accordingly, the court vacated the denial of the section 2255 petition without prejudice and remanded. View "Senter v. United States" on Justia Law

The Eleventh Circuit vacated its previous opinion and issued the following opinion.Plaintiff and the Association filed suit under Title II of the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act against several Florida entities and officials, challenging defendants' failure to provide captioning for live and archived videos of Florida legislative proceedings.The court affirmed the district court's denial of defendant's motion to dismiss, holding that it has jurisdiction to hear defendants' interlocutory appeal. The court affirmed the district court's alternative holding that Congress validly abrogated defendants' Eleventh Amendment immunity for these claims under Title II regardless of whether a fundamental right is implicated. Because the court affirmed on this basis, it did not reach the question of whether the ability to participate in the democratic process is a fundamental right. The court stated that Congress validly abrogated sovereign immunity for this claim under the standard for important rights that nonetheless receive only rational basis review.The court also affirmed the district court's holding that plaintiffs were entitled to pursue injunctive relief under the doctrine of Ex parte Young for allegedly ongoing violations of Title II. Finally, given the substantial overlap between plaintiffs' ADA and Rehabilitation Act claims, the court held that the district court did not encroach on the Legislative Defendants' immunity. View "National Association of the Deaf v. Florida" on Justia Law

Plaintiff, who is civilly committed and housed in the Florida Civil Commitment Center (FCCC), filed a pro se 42 U.S.C. 1983 action alleging that, during a trip to a court hearing located about 600 miles from the FCCC, defendants restrained, transported, and temporarily housed him in a manner that was inconsistent with professional judgment and therefore violated his Fourteenth Amendment rights. The district court dismissed the case for failure to state a claim.The Eleventh Circuit reversed the district court's dismissal of plaintiff's Fourteenth Amendment Due Process claims arising from his bathroom-related allegations and his jail-housing claim, as well as the order dismissing defendants for lack of service. However, plaintiff's allegations about the shackles, transport by van instead of airplane, the stale sandwich he was given, and the driving speeds fail to state a Fourteenth Amendment claim. Therefore, the court affirmed the district court's dismissal order in all other respects, remanding for further proceedings. View "Bilal v. GEO Care, LLC" on Justia Law

The Eleventh Circuit reversed the district court's grant of habeas relief to petitioner. Petitioner argues that his appellate counsel was ineffective for failing to raise a certain juror's presence on the trial jury. Because the Warden concedes that counsel performed deficiently, the only issue is prejudice.The court held that the state habeas court's ruling that petitioner did not prove that the juror was actually biased against him was not based on an unreasonable determination of fact under 28 U.S.C. 2254(d)(2). In this case, the court cannot say for certain what the juror meant when he raised his hand in response to a question during voir dire regarding a murder prosecution involving a shooting, and, for that reason, the court cannot say the state court's finding was unreasonable. The court also held that the state court did not unreasonably apply Strickland v. Washington when it held that petitioner failed to establish a reasonable probability that his appeal would have been decided differently had appellate counsel raised the presence of the juror. Finally, the court held that Georgia's juror non-impeachment statute is not an alternative basis for relief. View "Teasley v. Warden, Macon State Prison" on Justia Law

Plaintiff filed suit against the State, arguing that O.C.G.A. 45-5-3.2 violates the Georgia Constitution and the Due Process Clause of the Fourteenth Amendment to the extent it allows the State to cancel the November 2020 election for the office of district attorney for the Western Judicial Circuit. Plaintiff sought a preliminary injunction that would require the State to hold the election, which the district court granted.Because the Eleventh Circuit is bound by the Supreme Court of Georgia's decision that O.C.G.A. 45-5-3.2, as challenged here, violates the Georgia Constitution, the court held that the district court did not abuse its discretion by finding that plaintiff established a substantial likelihood of success in her argument that O.C.G.A. 45-5-3.2 violates the Georgia Constitution and the Due Process Clause of the Fourteenth Amendment. The court also held that the district court did not abuse its discretion by concluding that plaintiff would suffer an irreparable injury unless an injunction was granted, because the State's enforcement of O.C.G.A. 45-5-3.2 would deprive plaintiff of her right to vote in the November 2020 district attorney election. Finally, the district court did not abuse its discretion by finding that the balance of harms and public interest weigh in favor of granting the injunction. Accordingly, the court affirmed the district court's order granting the preliminary injunction. View "Gonzalez v. Governor of the State of Georgia" on Justia Law

The Eleventh Circuit held that the district court did not clearly err in finding that House Bill 836's district map violated section 2 of the Voting Rights Act of 1965. HB 836 reduced the size of the board from nine members to seven. Where all nine members previously had come from single-member districts, now only five would, and two would be drawn from at large seats. Plaintiff alleged that the new map would violate section 2 by diluting the strength of Black voters in Sumter County. The district court agreed and entered a remedial order removing the at-large seats and drawing a new map with seven single-member districts instead.The court reviewed the entire record and held that plaintiff adduced ample evidence supporting a finding of vote dilution. The court held that the district court did not clearly err in concluding that plaintiff satisfied all three Gingles factors: first, the undisputed evidence showed that Sumter County's Black residents could form a majority in at least one additional single-member district (and probably in two); second, the Black voters in Sumter County were highly cohesive in ten of the twelve elections studied; and third, White residents vote sufficiently as a bloc to enable them usually to defeat the minority's preferred candidate. The court also held that plaintiff established that the totality of the circumstances results in an unequal opportunity for minority voters to participate in the political process and to elect representatives of their choosing. In this case, the district court did not clearly err by finding that the first, second, fifth, and seventh Senate factors weighed heavily in plaintiff's favor. The district court noted Georgia's, and Sumter County's, painful history of discrimination against its Black residents, emphasizing the high levels of racially polarized voting and observed the lack of success enjoyed by Black candidates in Sumter County. Furthermore, the special master report expressly found an easily achievable remedy available. View "Wright v. Sumter County Board of Elections and Registration" on Justia Law

The Eleventh Circuit affirmed the district court's dismissal of plaintiff's 42 U.S.C. 1983 action alleging that defendant, in his official capacity as the Commissioner of the Florida Department of Law Enforcement (FDLE), violated his constitutional rights by continuing to publish his personally identifiable information on FDLE's sex offender registry website even after plaintiff had completed probation and was no longer subject to Florida registration laws. The court held that, although plaintiff has not waived his continuing violation argument, his claims are time-barred because there was no continuing violation. Furthermore, Nichols v. United States, 136 S. Ct. 1113 (2016), does not affect the accrual of plaintiff's claims under Florida's statute of limitations. View "McGroarty v. Swearingen" on Justia Law

The Eleventh Circuit reversed the district court's grant of summary judgment based on qualified immunity to defendants in an 42 U.S.C. 1983 action brought by plaintiff, alleging that police officers used excessive force, among other things, when they tased, beat, and broke plaintiff's jaw after a routine accident investigation. The court held that the district court did not view the evidence in the light most favorable to plaintiff before ruling against him. The court stated that, at the summary judgment stage, the Graham factors favor an excessive force finding for both the tasing and the later force applied when plaintiff was taken out of the truck. Furthermore, striking a compliant suspect who has surrendered his hands and stopped all resistance amounts to a clearly established constitutional violation. View "Stryker v. City of Homewood" on Justia Law