Justia Civil Rights Opinion Summaries

Plaintiff filed suit against defendant, a deputy in the sheriff's office, under 42 U.S.C. 1983, alleging that plaintiff's Fourth Amendment rights were violated when the deputy seized his iPhone after plaintiff took photos and videos of a car accident crash scene from an interstate grass median. The Eleventh Circuit affirmed the district court's determination that the seizure constituted a Fourth Amendment violation. Furthermore, plaintiff's rights were clearly established at the time of the seizure such that defendant was not entitled to qualified immunity. View "Crocker v. Deputy Sheriff Steven Eric Beatty" on Justia Law

The Driver's Privacy Protection Act (DPPA) excepts authorized acts of lobbying from its purview. The Eleventh Circuit denied plaintiffs' appeal of an adverse summary judgment granted for defendants, holding that defendants were entitled to qualified immunity. Plaintiffs alleged that defendants violated the DPPA by obtaining and disclosing each plaintiff's driver's license photo for an impermissible purpose. The court held that the distribution of the photos related directly to Defendant Fewless' lobbying efforts, and when he distributed the photos, he was acting on behalf of a Federal, State, or local agency in carrying out its functions. Therefore, the district court correctly determined that defendants were entitled to summary judgment. In the alternative, defendants were entitled to qualified immunity where there was no case law clearly establishing that Fewless' use of the photos was impermissible. Furthermore, plaintiffs were required to show that no reasonable officer in the officers' position could have believed that he was accessing or distributing the photos for a permissible use under the DPPA. View "Baas v. Fewless" on Justia Law

The Driver's Privacy Protection Act (DPPA) excepts authorized acts of lobbying from its purview. The Eleventh Circuit denied plaintiffs' appeal of an adverse summary judgment granted for defendants, holding that defendants were entitled to qualified immunity. Plaintiffs alleged that defendants violated the DPPA by obtaining and disclosing each plaintiff's driver's license photo for an impermissible purpose. The court held that the distribution of the photos related directly to Defendant Fewless' lobbying efforts, and when he distributed the photos, he was acting on behalf of a Federal, State, or local agency in carrying out its functions. Therefore, the district court correctly determined that defendants were entitled to summary judgment. In the alternative, defendants were entitled to qualified immunity where there was no case law clearly establishing that Fewless' use of the photos was impermissible. Furthermore, plaintiffs were required to show that no reasonable officer in the officers' position could have believed that he was accessing or distributing the photos for a permissible use under the DPPA. View "Baas v. Fewless" on Justia Law

The Eleventh Circuit affirmed the district court's denial of a petition for habeas relief under 28 U.S.C. 2254. The court held that the Supreme Court of Georgia reasonably concluded that petitioner's attorneys were not deficient for failing to uncover mitigating evidence from petitioner's childhood. The court also held that the state court reasonably concluded that the attorneys' failure to hire an independent crime-scene expert to corroborate petitioner's account of the murders did not prejudice him. View "Morrow v. Warden, Georgia Diagnostic Prison" on Justia Law

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