Justia Civil Rights Opinion Summaries

The Eleventh Circuit affirmed the district court's dismissal of plaintiff's complaint and denied his emergency motion for a stay of execution as moot. The court rejected plaintiff's challenge to Georgia's requirement that a prisoner show he acted with due diligence in filing his motion, and Georgia’s requirement that the favorable DNA testing results create a reasonable probability that he would have been acquitted had those results been available at trial.The court also held that the district court properly dismissed plaintiff's as-applied due process claim because, to the extent he made the challenge in his complaint, he expressly disavowed it in his reply to the State's motion to dismiss; even if the argument were not waived, it was foreclosed by circuit precedent; and the claim amounted to an assertion that the state court misapplied state law, which, without more, did not violate the federal Constitution. Finally, the court held that, because plaintiff failed to identify a cause of action that meets the actual injury requirement for a claimed denial of access to the courts, the district court properly dismissed his access to the courts claims for lack of subject matter jurisdiction. View "Cromartie v. Shealy" on Justia Law

On remand from the en banc court, the Eleventh Circuit affirmed the district court's grant of summary judgment in favor of the Authority. At issue in this appeal was whether, under the Due Process Clause of the Fourteenth Amendment, some evidence supported the decision of the Authority to terminate plaintiff's housing voucher issued under Section 8 of the Housing Act of 1937.Although the court agreed with plaintiff that the Due Process Clause mandates some evidentiary support for voucher-termination decisions, this requirement does not mandate a robust substantive evaluation of the sufficiency of the evidence supporting an administrative determination. Rather, the court explained that the relevant question was whether there was any evidence in the record that could support the conclusion reached and that this decision need only have some basis in fact. In this case, the decision to terminate plaintiff's voucher satisfied the "some evidence" standard, where the evidence supported the conclusion reached by the Authority that plaintiff had engaged in drug-related criminal activity that disqualified her from the program. View "Yarbrough v. Decatur Housing Authority" on Justia Law

Plaintiffs filed a putative class action alleging that during the 2016 Democratic presidential primaries the DNC and its chairwoman improperly tipped the scales in favor of former Secretary of State Hillary Clinton, who was challenging Senator Bernie Sanders for the Democratic presidential nomination.The Eleventh Circuit held that some named plaintiffs representing the DNC donor class have adequately alleged Article III standing, but that no named plaintiffs representing the Sanders donor class have done so. The court dismissed the fraud and negligent misrepresentation claims on the merits, holding that plaintiffs representing the DNC donor class failed to allege with particularity the manner in which they relied on defendants' statements. Therefore, the general allegation of reliance was not fatal to the Article III standing of the DNC donor class, but it fell short of Federal Rule of Civil Procedure 9(b)'s heightened pleading standard.The court also held that the District of Columbia Consumer Protection Procedures Act claim of the DNC donor class failed the plausibility standard set out in cases like Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 556–57 (2007); plaintiffs in the DNC donor class have failed to state a claim for unjust enrichment under Florida law; plaintiffs in the Democratic voter class failed to allege an injury-in-fact sufficient to confer Article III standing when they alleged a breach of fiduciary duty by the DNC and its chairwoman; and the district court did not err in dismissing the complaint without sua sponte granting plaintiffs leave to file a second amended complaint. Accordingly, the court affirmed the district court's judgment of dismissal, remanding for amendment of its order. View "Wilding v. DNC Services Corp." on Justia Law

Plaintiff, a minor, filed suit under 42 U.S.C. 1983, against the sheriff and deputy who had entered her home and arrested her after her former best friend committed suicide. Defendants charged plaintiff with the crime of aggravated stalking, a felony, which includes harassing a child under sixteen years of age. The warrantless arrest took place at plaintiff's home; the charges were eventually dismissed; but plaintiff's name and photograph had already been released to the media and she was publicly blamed for the death.On appeal, plaintiff challenged the dismissal of her claim that there was no probable cause for the arrest, and the judgment entered on the jury's verdict that the deputy had consent to enter her home to make the arrest. The court affirmed and held that, based on the deputy's investigation, a reasonable person in his position would have concluded that plaintiff willfully, maliciously, and repeatedly harassed her former friend and classmate. The court also held that the district court abused its discretion when it concluded that the jury's verdict was not against the great weight of the evidence and did not result in a miscarriage of justice. In this case, the jury was free to conclude that, by opening the door and stepping back, plaintiff's father was giving the deputies his consent to enter the home. The court also held that the district court did not abuse its discretion by denying plaintiff's motion for a new trial based on her belated curtilage argument, which was not presented to the jury. Finally, the court held that plaintiff was not entitled to a new trial based on the district court's response to the jury's question about the screened-in porch. View "Gill v. Judd" on Justia Law

The Eleventh Circuit affirmed the district court's grant of habeas relief to petitioner, who was convicted of felony murder and sentenced to death.The court held that the Georgia state habeas court's fact-finding was not entitled to deference in the pre-Antiterrorism and Effective Death Penalty Act of 1996 regime. In this case, the state habeas court adopted verbatim the state's proposed order; offered no guidance to the Assistant Attorney General drafting the proposed order; did not review the order, other than signing it, dating it, and changing the concluding sentence, notwithstanding the glaring errors it contained; and did so ex parte without so much as affording petitioner a chance to challenge any of it or propose an alternative order.The court also held that the district court correctly determined that petitioner's trial lawyers' conduct fell beneath an objective standard of reasonableness when they failed to adequately investigate whether petitioner suffered from organic brain damage at the time of the killing. In light of the substantial evidence petitioner demonstrated showing that he suffered from organic brain damage, the court held that the district court did not err in finding that petitioner had been prejudiced by his lawyers' deficient performance. View "Jefferson v. GDCP Warden" on Justia Law

The Eleventh Circuit reversed the district court's judgment in defendant's favor in an action brought by plaintiff, alleging that defendant violated the Fourth Amendment by arresting plaintiff inside the home of plaintiff's parents. Defendant, a sheriff's deputy, went to the home to question plaintiff about an earlier incident. When plaintiff declined to talk to defendant alone, an argument ensued, and plaintiff went back inside the home, where defendant then entered and arrested plaintiff.The court held that defendant violated the Fourth Amendment's protection against unreasonable seizures when he arrested plaintiff inside of his home. The court also held that plaintiff's right to be free from a warrantless, in-home arrest was clearly established and that no exception to the warrant requirement even plausibly applies in this case. Accordingly, the court remanded for further proceedings. View "Bailey v. Swindell" on Justia Law

On remand from the Supreme Court, the Eleventh Circuit remanded the case to the district court with instructions to issue a writ of habeas corpus vacating petitioner's sentence and entitling him to a new sentencing hearing.Applying Brecht v. Abrahamson, the court reviewed the trial judge's error under Ake v. Oklahoma, holding that the constitutional error in this case was structural. The court held that the Ake error infected the entire sentencing hearing from beginning to end, because petitioner was prevented from offering any meaningful evidence of mitigation based on his mental health, or from impeaching the State's evidence of his mental health. The court held that this Ake error defies analysis by harmless-error review and thus prejudice to petitioner was presumed. View "McWilliams v. Commissioner, Alabama Department of Corrections" on Justia Law

Tokyo Valentino filed suit against the County, challenging certain business licensing and adult entertainment ordinances, and seeking damages under 42 U.S.C. 1983, as well as declaratory and injunctive relief. At issue in this appeal was the district court's second dismissal of Tokyo Valentino's claims.The Eleventh Circuit affirmed the district court's dismissal of Tokyo Valentino's claim for compensatory damages relating to the appeal of the ordinances, because Tokyo Valentino's second amended complaint does not contain factual allegations that establish it suffered a cognizable injury in fact for which compensatory damages might be warranted. However, the court reversed the dismissal of Tokyo Valentino's request for a declaratory judgment regarding whether its sale of sexual devices constitutes a lawful prior nonconforming use authorized under the repealed ordinances and whether the new ordinances' failure to include provisions grandfathering in prior lawful uses violates federal and state law. Finally, the court held that the district court abused its discretion by abstaining under Younger v. Harris, 401 U.S. 37, 91 S. Ct. 746 (1971), from hearing Tokyo Valentino's claims stemming from the County's new ordinances. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Tokyo Gwinnett, LLC v. Gwinnett County" on Justia Law

The Eleventh Circuit affirmed the district court's denial of a petition for writ of habeas corpus under 28 U.S.C. 2254. The court held that, although petitioner exhausted his due process claims based on lost or destroyed evidence, the Georgia Supreme Court's denial of the claims on direct appeal was entitled to deference under section 2254(d). In this case, there was no evidence that officers knew or should have known that the lost or destroyed evidence was exculpatory and the record contained no allegation of official animus towards petitioner or of a conscious effort to suppress exculpatory evidence. The court also held that the district court did not err in denying petitioner's request for a stay. View "Davis v. Sellers" on Justia Law

Plaintiffs filed suit challenging two policies related to the provision of basic utility services from the City on the ground that the policies have a disproportionate impact on black and Hispanic residents.The Eleventh Circuit vacated the district court's dismissal of the complaint for failure to state a claim, holding that section 3604(b) of the Fair Housing Act is unambiguous and reaches certain post-acquisition conduct, including post-acquisition conduct related to the provision of services. The panel held that a service within the meaning of section 3604(b) must be a housing-related service that is directly connected to the sale or rental of a dwelling, and the water, gas, and electricity services at issue here fall within the scope of section 3604(b). Finally, the court rejected the City's argument that it is not a housing provider subject to section 3604(b), and held that section 3604(b) does not limit its applicability in such a manner and the court's case law has never held that only housing providers are subject to liability thereunder. Accordingly, the court remanded for further proceedings. View "Georgia State Conference of the NAACP v. City of LaGrange" on Justia Law