Justia Civil Rights Opinion Summaries

A jury awarded to the EEOC and an employee back pay, compensatory damages, and punitive damages after finding that the employer, Exel, discriminated against her because of her sex. The district court denied Exel's motion for a renewed motion for judgment as a matter of law as to liability, but granted the motion as to the jury's punitive damages award. The Eleventh Circuit affirmed, holding that the employee's evidence was sufficient for a reasonable jury to find that she suffered discrimination because of her sex. The court also held that, under prior precedent, the district court properly vacated the jury's punitive damages award. View "EEOC v. Exel, Inc." on Justia Law

Petitioner, convicted in 1986 of three counts of malice murder and set for execution on March 15, 2018, sought permission to file a second habeas petition and a stay of execution, seeking to present claims that his execution would violate the Eighth and Fourteenth Amendments because the state destroyed evidence in connection with a post-conviction DNA test of vaginal washings from one body and because he is actually innocent. The Muscogee County Superior Court denied Petitioner’s motion; the Georgia Supreme Court denied review. The Eleventh Circuit denied relief. The court declined to draw the adverse inference against the state that the DNA evidence exculpates the Petitioner. The Petitioner has not demonstrated that the state contaminated the sample in bad faith. The testimony at the evidentiary hearing demonstrated that the sample was contaminated with a specially used quality control sample, which was handled by another scientist who used shared the same lab area. Petitioner’s contamination claim is not based on an event that occurred during Petitioner’s prosecution for the murders. Petitioner’s claim that he is actually innocent of the murder, has been barred by the Supreme Court: Claims of actual innocence based on newly discovered evidence have never been held to state a ground for federal habeas relief absent an independent constitutional violation occurring in the underlying state criminal proceeding. View "In re: Carlton" on Justia Law

Petitioner, convicted in 1986 of three counts of malice murder and set for execution on March 15, 2018, sought permission to file a second habeas petition and a stay of execution, seeking to present claims that his execution would violate the Eighth and Fourteenth Amendments because the state destroyed evidence in connection with a post-conviction DNA test of vaginal washings from one body and because he is actually innocent. The Muscogee County Superior Court denied Petitioner’s motion; the Georgia Supreme Court denied review. The Eleventh Circuit denied relief. The court declined to draw the adverse inference against the state that the DNA evidence exculpates the Petitioner. The Petitioner has not demonstrated that the state contaminated the sample in bad faith. The testimony at the evidentiary hearing demonstrated that the sample was contaminated with a specially used quality control sample, which was handled by another scientist who used shared the same lab area. Petitioner’s contamination claim is not based on an event that occurred during Petitioner’s prosecution for the murders. Petitioner’s claim that he is actually innocent of the murder, has been barred by the Supreme Court: Claims of actual innocence based on newly discovered evidence have never been held to state a ground for federal habeas relief absent an independent constitutional violation occurring in the underlying state criminal proceeding. View "In re: Carlton" on Justia Law

The Eleventh Circuit reversed the district court's denial of defendants' motion to dismiss plaintiff's 42 U.S.C. 1983 and state law claims on the basis of qualified immunity and official immunity. In this case, plaintiff filed suit against three officers after he was arrested for violating Georgia's mask statute during a protest in downtown Atlanta. The court held that defendants were entitled to qualified immunity on the section 1983 claims where plaintiff failed to show that his arrest violated a constitutional right and that the right was clearly established at the time of the arrest. The court also held that defendants were entitled to official immunity on the state law claims where there was no evidence that defendants acted with actual malice or an actual intent to injure plaintiff. Accordingly, the court remanded for further proceedings. View "Gates v. Khokar" on Justia Law

The Eleventh Circuit affirmed the district court's grant of summary judgment for defendants in an action brought by the estate of Ananias Shaw, who was shot and killed by a police officer. Shaw was coming towards the officer with a hatchet when the officer shot him. The court held that a reasonable officer could have concluded, as the officer here did, that the law did not require him to wait until the hatchet was being swung toward him before firing in self-defense. Therefore, the district court did not err in granting summary judgment as to the excessive force claim. Furthermore, the district court did not err in granting summary judgment as to the false arrest claim and the officer was entitled to state agent immunity on all of the state law claims. View "Shaw v. City of Selma" on Justia Law

The Eleventh Circuit affirmed the district court's grant of summary judgment for defendants in an action brought by the estate of Ananias Shaw, who was shot and killed by a police officer. Shaw was coming towards the officer with a hatchet when the officer shot him. The court held that a reasonable officer could have concluded, as the officer here did, that the law did not require him to wait until the hatchet was being swung toward him before firing in self-defense. Therefore, the district court did not err in granting summary judgment as to the excessive force claim. Furthermore, the district court did not err in granting summary judgment as to the false arrest claim and the officer was entitled to state agent immunity on all of the state law claims. View "Shaw v. City of Selma" on Justia Law

The Eleventh Circuit granted a petition for panel rehearing, withdrew the previous published opinion, and substituted this opinion. The court denied the petition for review of the BIA's order affirming petitioner's removal from the United States. The court held that 8 U.S.C. 1432(a) did not discriminate based on gender where, had the situation been reversed, if petitioner's mother had become a lawful permanent resident, was naturalized, and raised him in the United States while his father remained in Jamaica, he still would not have derived citizenship because his parents never legally separated. The court also held that section 1432(a) did not unconstitutionally discriminate based on legitimacy and, in the alternative, assuming without deciding that section 1432(a)(3)'s distinction based on marital choice was a legitimacy based classification, the statute passed constitutional muster. The court agreed with its sister circuits that section 1432(a) was substantially related to protecting parental rights. Finally, section 1432(a) did not unconstitutionally burden petitioner's fundamental right to maintain a family unit. View "Levy v. U.S. Attorney General" on Justia Law

The Eleventh Circuit reversed and remanded the district court's summary judgment dismissal of plaintiff's discrimination claims against Manheim, her employer. Plaintiff alleged that the employer discriminated against her by paying her less than her male predecessor. The court held that, taking the evidence in the light most favorable to plaintiff, she was entitled to proceed to trial on her Equal Pay Act and Title VII claims. In this case, a jury could conclude that plaintiff was entitled to relief under the Equal Pay Act because the evidence supported a finding that she has made a prima facie case and that Manheim failed to establish an affirmative defense in response, and that plaintiff was entitled to relief under Title VII because the evidence supported a finding that her sex "was a motivating factor for" the pay disparity between her and her male predecessor. View "Bowen v. Manheim Remarketing, Inc." on Justia Law

In this school desegregation case, black schoolchildren opposed a motion filed by the Gardendale City Board of Education to permit it to operate a municipal school system. The district court devised and permitted a partial secession that neither party requested. The Eleventh Circuit held that the district court did not clearly err when it found that the Board moved to secede for a racially discriminatory purpose; the district court did not not clearly err when it found, in the alternative, that the secession would impede the desegregation efforts of the Jefferson County Board; but the district court abused its discretion when it sua sponte permitted the partial secession of the Board. Accordingly, the court affirmed in part, reversed in part, and remanded with instructions to deny the motion to secede. View "Stout v. Gardendale City Board of Education" on Justia Law

The Eleventh Circuit reversed the district court's decision issuing a writ of habeas corpus setting aside petitioner's failure-to-register conviction on the ground that his prior sodomy conviction was invalid under Lawrence v. Texas, 539 U.S. 558, 123 S. Ct. 2472 (2003). The court held that petitioner's claim that Lawrence voided his sodomy conviction was unexhausted and thus the district court erred by entertaining it. The court also held that the Court of Appeals, in light of Georgia state law, correctly found that petitioner suffered no prejudice under Strickland v. Washington, 466 U.S. 668, 104 S. Ct. 2052 (1984). View "Green v. Georgia" on Justia Law