Justia Constitutional Law Opinion Summaries

Plaintiff sued defendant under 42 U.S.C. 1983, alleging that her termination was unconstitutional under the First Amendment because it was based on her candidacy. The court held that the First Amendment, as interpreted by the Supreme Court and the Eleventh Circuit, did not require defendant to retain her political opponent after becoming superior court clerk for the county. Accordingly, the court affirmed the district court's grant of summary judgment in favor of defendant. View "Underwood v. Harkins, et al" on Justia Law

In 2010, the Commissioner issued four summonses to third-party financial institutions to determine whether the Miccosukee Tribe had complied with its federal withholding requirements during the period from 2006-2009. The Tribe petitioned to quash the summonses on the grounds of sovereign immunity, improper purpose, relevance, bad faith, and overbreadth. The district court denied those petitions. Because the court concluded that tribal sovereign immunity did not bar the issuance of these third-party summonses, the district court did not clearly err when it found that the summonses were issued for a proper purpose, and the Tribe lacked standing to challenge the summonses for overbreadth, the court affirmed the judgment. View "Miccosukee Tribe of Indians v. United States" on Justia Law

Petitioner, a death row inmate, appealed the district court's denial of his petition for writ of habeas corpus brought pursuant to 28 U.S.C. 2254. Petitioner contended that he was denied a fair trial by an impartial judge and unbiased jury because the jury gave the judge and the bailiff inappropriate gag gifts at the conclusion of the trial. Specifically, some jurors gave the judge chocolate candy in the shape of a penis and a bailiff chocolate candy shaped as female breasts. Petitioner also contended that there was racial discrimination in the selection of the jury. The court held that it was not unreasonable for the Georgia Supreme Court to find that petitioner did not prove purposeful discrimination by the state in the selection of the jury. The court also held, without condoning the regrettable behavior of either, that both the jury and the judge remained impartial and unbiased throughout the trial. Accordingly, the court affirmed the district court's denial of habeas relief.

Plaintiffs, individually and on behalf of all others similarly situated, brought these actions against defendants for injunctive relief and damages under 42 U.S.C. 1983. Plaintiffs alleged that the FDOT promulgated a policy of "detaining" motorists in violation of the Fourth and Fourteenth Amendments. The court held that the complaint allegations did not state a constitutional violation; defendants were entitled to qualified immunity; and summary judgment of the district court denying qualified immunity to defendants was reversed and the case remanded with instructions to dismiss.

Plaintiff appealed summary judgment in favor of her former employer and against her complaint of discrimination in violation of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101, and Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e. At issue was whether the employer was entitled to sovereign immunity. The court held that the employer was a state agency immune from plaintiff's complaint of disability discrimination and that the district court correctly granted summary judgment against plaintiff's complaint of racial discrimination where plaintiff unequivocally answered "no" when she was asked if her termination had anything to do with her race.

Petitioner, a Honduran national, appealed the denial of his petition for a writ of habeas corpus. This appeal involved the constitutional separation of powers and the limited judicial role in the extradition of a foreign national. On appeal, petitioner contended that the United Nations Convention Against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment barred his extradition by the Secretary of State, that the murder of the victim constituted a political offense for which he could not be extradited, and there was no valid extradition treaty in force between Honduras and the United States. The court held that petitioner's first argument was not ripe because the Secretary of State has not yet determined whether he was likely to be tortured nor decided whether to extradite him, and his other arguments lacked merit. Accordingly, the court vacated in part and affirmed in part the denial of petitioner's petition for a writ of habeas corpus, lifted the stay of the extradition proceedings, and remanded with instructions to dismiss petitioner's claim under the Convention Against Torture.

Objectors appealed the district court's approval of a class action settlement. The underlying case involved allegations that Disney violated Title III of the Americans with Disabilities Act, 42 U.S.C. 12182 et seq., by implementing a policy that banned the use of two-wheeled vehicles, including Segways, by customers within its park and hotels, without exception. The court held that the district court did not abuse its discretion in certifying the class and in approving the settlement. Accordingly, the court affirmed the settlement orders.

This case arose out of a leasing agreement between Contour and the Seminole Tribe. Contour appealed from a district court order dismissing its Amended Complaint for lack of subject matter jurisdiction on account of the Tribe's sovereign immunity. The district court rejected Contour's arguments and affirmed the judgment. Because the problems of inconsistency and unfairness that were inherent in the procedural posture of Lapides v. Bd. of Regents of the Univ. Sys. of Ga. were absent in this case, and because an Indian tribe's sovereign immunity was of a far different character than a state's Eleventh Amendment immunity, the court declined to extend Lapides. In regards to Contour's Indian Civil Rights Act, 25 U.S.C. 1301-1303, claim, it must fail because the Supreme Court had already held that Indian tribes were immune from suit under the statute. Finally, in regards to the equitable estoppel claim, that claim was unavailable because it was grounded on a waiver provision contained within a lease agreement that was wholly invalid as a matter of law.

This appeal involved challenges to ten provisions of Alabama's House Bill 56, the "Beason-Hammon Alabama Taxpayer and Citizen Protection Act" (H.B. 56). The stated purpose of the legislation was to discourage illegal immigration within the state and maximize enforcement of federal immigration laws through cooperation with federal authorities. The court found that the United States was likely to succeed on the merits of its challenges to sections 10, 11(a), 13(a), 16, 17, and 27 of H.B. 56. The court agreed with the United States that it was not likely to succeed on the merits of its challenge to section 12(a) or section 18 at this time. The court also found that the United States had not shown at this stage that it was likely to succeed on the merits of its challenge to section 30. Finally, the court dismissed the United States' appeal as to section 28 as moot, as the court's opinion in the private plaintiffs' companion case fully disposed of that issue.

Defendants appealed the district court's order granting plaintiffs' motion and preliminarily enjoined enforcement of sections 7 and 8 of House Bill 87, the Illegal Immigration Reform and Enforcement Act of 2011 (H.B. 87), on the ground that each was preempted by federal law. H.B. 87 was enacted to address the problem of illegal immigration within the state. The court held that section 7 could not be reconciled with the federal immigration scheme or the individual provisions of the Immigration and Nationality Act (INA), 8 U.S.C. 1101 et seq. Accordingly, the court affirmed in part the district court's order preliminarily enjoining enforcement of section 7. The court reversed in part the portion of that order enjoining section 8.