Justia Civil Rights Opinion Summaries

Plaintiffs filed suit challenging a city ordinance and resolution subjecting alarm companies to a series of fines when a false alarm is sounded at one of the properties which they service. The district court dismissed the substantive and procedural due process claims.The court held that the ordinance and resolution at issue easily survive rational basis scrutiny where imposing a fine on the alarm companies is rationally related to the City's strong interests in reducing the number of false alarms that heavily burden its police and fire departments and waste public resources. The court also held that plaintiffs lack standing to pursue their procedural due process claim as nonjusticiable where there is no cognizable injury for standing purposes when a party fails to attempt an appeal and instead merely points to some procedural elements within a regulation, without alleging how those features injured them or even might potentially cause them some concrete harm. View "The Georgia Electronic Life Safety & System Assoc. v. The City of Sandy Springs" on Justia Law

The Eleventh Circuit reversed the district court's dismissal of a petition for writ of habeas corpus under 28 U.S.C. 2254 as untimely. The court held that its decisions in Hall v. Secy, Dep't of Corr., 921 F.3d 983, 988–90 (11th Cir. 2019); Green v. Sec'y, Dep't of Corr., 877 F.3d 1244, 1247–49 (11th Cir. 2017), issued after the district court dismissed the petition, foreclosed the government's arguments.Hall and Green held that the one-year limitations period tolled the day a petitioner filed a procedurally noncompliant Rule 3.850 motion if he was permitted to and did later file a compliant motion. Therefore, a compliant Rule 3.850 motion relates back to the date of filing of a noncompliant motion, such that the compliant motion was "properly filed" and "pending" as of that date for purposes of tolling the limitations period in section 2244 of Title 28. In this case, because the limitations period tolled on the date of petitioner's initial motion, the court held that he timely filed his petition in federal court. Accordingly, the court remanded for further proceedings. View "Bates v. Secretary, Department of Corrections" on Justia Law

The Eleventh Circuit affirmed the district court's judgment and denial of habeas relief to petitioner. Petitioner was convicted of capital murder for leaving an elderly woman in the hot trunk of a car, where she eventually suffered a heart attack and died, after robbing her.The court held that the state court's determination that petitioner's counsel was not encumbered by an actual conflict that adversely affected his performance was neither contrary to nor an unreasonable application of clearly established law or an unreasonable determination of the facts. The court also held that the petition failed to establish ineffective assistance of counsel during the penalty phase of his capital trial where his lawyers failed to adequately investigate and present mitigating evidence, because petitioner failed to establish prejudice. View "Dallas v. Warden" on Justia Law

Plaintiff filed suit against two officers, alleging claims of malicious prosecution under both the Fourth Amendment and Alabama law. After plaintiff was shot by one of the officers and spent two months in a hospital recovering, he spent more than 16 months in pretrial detention on charges of attempted murder. The charges were eventually dropped when a news organization eventually published a video recorded on a dashboard camera that supported plaintiff's account that he had dropped his gun and complied with the officers' commands.The Eleventh Circuit affirmed the district court's denial of summary judgment based on qualified immunity to the officers. The court held that the record presents a genuine dispute of fact about whether plaintiff's pretrial detention was unlawful where, regardless of its applicability to warrantless arrests, the any-crime rule does not apply to claims of malicious prosecution under the Fourth Amendment; malicious prosecution requires plaintiff to prove that the judicial determination of probable cause underlying his seizure was invalid; and plaintiff has established a genuine issue of fact over whether he suffered an unconstitutional seizure pursuant to legal process. Furthermore, the officers caused plaintiff's injury and plaintiff had a clearly established right to not be seized based on intentional and material misrepresentations in a warrant application. The court also held that the officers are not entitled to state-agent immunity because a genuine dispute of fact exists about whether the officers acted maliciously. View "Williams v. Aguirre" on Justia Law

After Costco terminated plaintiff, who has been deaf since birth, she filed suit in Florida state court for violations of the Florida Civil Rights Act of 1992 (FCRA). After Costco removed the case to federal court, the case went to trial, and the jury returned a verdict in favor of Costco on one count of wrongful termination, but against the company on plaintiff's failure-to-accommodate claim. The district court subsequently granted summary judgment to Costco for judgment as a matter of law on the failure-to-accommodate claim.The Eleventh Circuit affirmed, holding that there was insufficient evidence to support plaintiff's failure-to-accommodate claim. In this case, plaintiff failed to point to a specific instance in which she needed an accommodation and was denied one. The court stated that it cannot hold that an employer fails to reasonably accommodate a deaf employee when it provide her with on-demand access to live sign-language interpreters at two, convenient locations within her place of work; when it goes further to provide on-site person interpreters for larger, group meetings; when it arranges a thorough training session on deaf culture, pursuant to the plaintiff's request; and when the plaintiff's general manager—the supervisor who was the sole subject of her sole complaint—resolves to improve his relationship with the plaintiff by attending multiple, one-on-one training sessions. View "D'Onofrio v. Costco Wholesale Corp." on Justia Law

Plaintiff filed suit against the members of the Florida Board of Hearing Aid Specialists and the Secretary of the Florida Department of Health, each in their official capacities, alleging that three Florida statutes administered by defendants are preempted by federal law and/or violate plaintiff's due process rights. The district court dismissed plaintiff's claims.The Eleventh Circuit affirmed the district court's dismissals for failure to state a claim pertaining to the Licensing Statute and Mail Order Ban. Because any infirmity in the Pre-Sale Testing Statute is not inextricably linked to the Licensing Statute, and because state licensing schemes are not preempted by 21 U.S.C. 360k(a)'s express preemption provision, the court held that plaintiff failed to state a claim that the Licensing Statute is preempted by federal law. Because the Mail Order Ban does not embed the Pre-Sale Testing Statute within it, and because the Mail Order Ban does not relate to the safety or effectiveness of the device, the court held that plaintiff failed to state a claim that the Mail Order Ban is preempted by federal law. The court reversed the district court's dismissal for lack of standing and held that plaintiff has standing to challenge the Pre-Sale Testing Statute. Accordingly, the court remanded for further proceedings. View "Taylor v. Polhill" on Justia Law

The Eleventh Circuit sua sponte vacated its previous opinion and substituted the following option.The court affirmed the denial of habeas relief to petitioner, rejecting petitioner's claims of ineffective assistance of counsel and that he is intellectually disabled and therefore ineligible for the death penalty. The court held that the state court did not unreasonably determine that petitioner failed to establish objectively incompetent performance by his counsel during the penalty phase of his trial for failing to present mitigation evidence. Even if petitioner had demonstrated that counsel's performance was deficient, he failed to demonstrate prejudice. The court also held that the state court did not unreasonably determine the facts or unreasonably apply Atkins v. Virginia, 536 U.S. 304 (2002), with respect to the intellectual component of intellectual disability; the record supports the state court's conclusion that petitioner does not have substantial deficits in adaptive behaviors; and the ample record of petitioner's childhood does not point to intellectual disability before age 18. View "Jenkins v. Commissioner, Alabama Department of Corrections" on Justia Law

This appeal arose from an action brought by plaintiffs who object to the City of Lakeland's decision to relocate a Confederate monument from one city park to another, contending that the relocation violates their rights under the First Amendment's Free Speech Clause and the Fourteenth Amendment's Due Process Clause.The Eleventh Circuit held that plaintiffs lack standing to pursue either their First Amendment claim or their due process claim. Plaintiffs have not shown that they have suffered a particularized Article III injury of the sort that distinguishes them from other interested observers and thus qualifies them, specifically, to invoke federal-court jurisdiction. Rather, plaintiffs' allegations implicate only the generalized desires to promote Southern history and to honor Confederate soldiers. Therefore, the court vacated and remanded the with-prejudice dismissal of plaintiffs' First Amendment claim, with instructions that the district court should dismiss without prejudice for lack of jurisdiction. The court affirmed the district court's without-prejudice dismissal of the due process claim. View "Gardner v. Mutz" on Justia Law

After a pretrial detainee, Kenneth Grochowski, was killed by his cellmate, William Alexander Brooks, while both men were detained at the Clayton County Jail, Grochowski's surviving adult children filed a civil rights action against the County and four supervisors at the jail. Plaintiffs alleged that the conditions at the jail violated Grochowski's due process rights under the Fourteenth Amendment and that those conditions caused his death.The Eleventh Circuit affirmed the district court's grant of the jail supervisors' motion for summary judgment based on qualified immunity. The court held that plaintiffs have failed to show that the jail supervisors violated a constitutionally protected right because they failed to show that the Constitution requires in-person security screenings or consideration of violent misdemeanors and that the Constitution requires jail officials to conduct rounds more frequently than once per hour. The court also affirmed the district court's grant of summary judgment in favor of the County, holding that plaintiffs failed to show that either the jail design or its funding and staffing levels violated Grochowski's Fourteenth Amendment rights. Finally, the court granted the district court's order granting the County's motion for a protective order regarding the decision-making process with respect to the design and funding of the jail. View "Grochowski v. Clayton County, Georgia" on Justia Law

The Eleventh Circuit held that the district court erred in issuing an injunction against the County and the Director of the Miami-Dade Corrections and Rehabilitations Department (MDCR), requiring defendants to employ numerous safety measures to prevent the spread of COVID-19 and imposing extensive reporting requirements. Metro West inmates had filed a class action challenging the conditions of their confinement under 42 U.S.C. 1983 and seeking habeas relief under 28 U.S.C. 2241 for the named plaintiffs with a "medically vulnerable" subclass of inmates.The court held that plaintiffs failed to show a substantial likelihood of success on the merits of their constitutional claim for deliberate indifference. The court explained that the district court erred in relying on the increased rate of infection, and in concluding that defendants' inability to ensure adequate social distancing constituted deliberate indifference. In this case, the court simply could not conclude that, when faced with a perfect storm of a contagious virus and the space constraints inherent in a correctional facility, defendants acted unreasonably by "doing their best." The court also agreed with defendants that the district court erred in its likelihood-of-success-on-the-merits analysis because it failed to consider "two threshold issues": (1) the heightened standard for municipal liability under Monell v. Department of Social Services, 436 U.S. 658 (1978), and (2) exhaustion under the Prison Litigation Reform Act. Finally, the court held that the district court erred in holding, without any meaningful analysis, that plaintiffs would suffer irreparable injury absent an injunction. Furthermore, the district court erred in its determination of the balance-of-the-harms and public-interest factors. View "Swain v. Junior" on Justia Law