Justia Constitutional Law Opinion Summaries

Plaintiffs challenged various provisions of Alabama's House Bill 56, the "Beason-Hammon Alabama Taxpayer and Citizen Protection Act" (H.B. 56). Because the court found that the United States was likely to succeed on its claims that sections 10 and 27 of H.B. 56 were preempted, the court dismissed the HICA plaintiffs' appeal as to those sections as moot. The court vacated as moot the district court's injunction of section 8 and remanded for the dismissal of the challenge to that section, as the statutory amendment had removed the challenged language. In light of the court's decision on the substantive provisions of sections 10, 11, and 13, the court vacated as moot the district court's order insofar as it preliminarily enjoined the last sentence of sections 10(e), 11(e), and 13(h). The court found that at least one of the HICA plaintiffs had standing to challenge section 28 and that it violated the Equal Protection Clause. Therefore, the court reversed the district court's decision and remanded for the entry of a preliminary injunction. Finally, the court concluded, for reasons stated in the United State's companion cases, Nos. 11-14532, 11-14674, that the HICA plaintiffs could not succeed on the merits of their facial challenges to sections 12, 18, and 30 at this time.

Plaintiff appealed the district court's grant of summary judgment in a class action suit alleging that Broward County's employee wellness program violated the Americans with Disabilities Act of 1990 (ADA), 42 U.S.C. 12101 et seq. Plaintiff alleged that the wellness program's biometric screening and online Health Risk Assessment questionnaire violated the ADA's prohibition on non-voluntary medical examinations and disability-related inquiries. The court held that the district court did not err in finding as a matter of law that the wellness program was a "term" of Broward County's group health insurance plan, such that the wellness program fell within the ADA's safe harbor provision.

Petitioner William Ernest Kuenzel, a state prisoner, appealed the district court’s dismissal of his habeas corpus petition under 28 U.S.C. section 2254. Because Petitioner’s claims are procedurally barred under state law and he has made no attempt to demonstrate cause for (or prejudice from) his default, Petitioner could not obtain relief without properly supporting a claim of actual innocence. Petitioner was unable to carry this burden; so the Eleventh Circuit affirmed the dismissal of his petition.

Petitioner-Appellant Anthony Ponticelli, a death row inmate in the Florida Department of Corrections, raised two issues about the denial of his petition for the writ of habeas corpus: (1) the prosecution violated his right to due process when it allegedly suppressed evidence of and failed to correct false testimony about an agreement to provide immunity for a witness for the state and about Petitioner's use of cocaine shortly before the murders; (2) his trial counsel provided ineffective assistance of counsel by failing to present evidence of his incompetence to stand trial and by failing to present mitigating evidence of drug use and mental health problems during the penalty phase. Upon review, the Eleventh Circuit concluded both of Petitioner's arguments failed: the Florida Supreme Court reasonably determined the underlying facts as to the first issue; and on both issues, neither contravened nor unreasonably applied clearly established federal law. Accordingly, the Court affirmed the denial of Petitioner's petition for the writ.

Petitioner Odulene Dormescar, a native and citizen of Haiti, appealed a removal order issued by an immigration judge because he had been convicted of an aggravated felony. The Board of Immigration Appeals dismissed his appeal of that order. He has petitioned the Eleventh Circuit for review. His petition presented three issues: (1) whether the Eleventh Circuit had subject matter jurisdiction; if it did, then the second (2) issue was whether res judicata barred the Department of Homeland Security’s proceedings against Petitioner based on the aggravated felony conviction. If it did not, the third (3) issue was whether the Department had the authority to amend the notice to appear to charge Petitioner as "admitted to the United States, but . . . removable" when he was originally charged as an inadmissible "arriving alien." Upon review, the Eleventh Circuit concluded that it had jurisdiction over this case, res judicata did not apply, and that the Department had the authority to amend the notice to appear to charge Petitioner as admitted but removable.

Defendant-Appellant James Mathurin was convicted of a number of armed robbery and weapons charges. These convictions resulted from a five-month-long crime spree in Miami-Dade County that took place when Defendant was seventeen-years-old. On appeal, Defendant challenged his convictions on a number of grounds, one of which is that the government violated his rights under the Speedy Trial Act. The narrow question on appeal before the Eleventh Circuit was whether the time during which plea negotiations are conducted is automatically excludable from the Speedy Trial Act’s thirty-day window for filing an information or indictment. After review, the Court concluded that the time during which plea negotiations are conducted are not automatically excludable. Therefore, the Court reversed the District Court’s denial of Defendant's motion to dismiss, vacated his convictions, and remanded the case to the District Court with instructions to determine whether dismissal of the charges should be with or without prejudice.

The dispute underlying this appeal concerned the constitutionality of a large religious statue located directly outside the courthouse in Dixie County, Florida. The American Civil Liberties Union of Florida, Inc. (“ACLU”) brought suit against the County, arguing that such a monument violates the First Amendment’s Establishment Clause. The County moved for summary judgment on the ground that John Doe, the ACLU member through whom the ACLU claimed standing, could not demonstrate an actual injury that he had suffered as a result of the display. The district court denied the motion. The ACLU later moved for summary judgment, which the district court granted. Upon review, the Eleventh Circuit found that due to a material conflict in the evidence, an evidentiary hearing on the issue of standing was merited. The Court therefore remanded the case so that such a hearing could be conducted.

Petitioner Elias Jimenez-Galicia, a native and citizen of El Salvador, sought judicial review of a final order of removal issued by the Board of Immigration Appeals ("BIA"). The BIA's order affirmed an immigration judge's ("IJ") order of removal and denial of Petitioner's request for cancellation of removal. The denial was based on a determination that Petitioner lacked good moral character. Because the Fourth Circuit was not presented with a genuine question of law, the Court lacked jurisdiction to review the BIA's discretionary determination that Petitioner lacked good moral character. Therefore the Court dismissed the petition.

The Eleventh Circuit consolidated two criminal cases involving sophisticated financial structuring arrangements between related corporate subsidiaries. Appellants, William Allen Broughton and Richard William Peterson were convicted of conducting a "modern-day financial shell game" in which they falsified financial statements, exchanged paper ownership over non-extant fraudulent assets, and collected insurance premiums and monthly payments from unwitting innocents. Collectively, they stated two bases for reversal: (1) Broughton contended that the Government's purported failure to file charges within the relevant statutes of limitations "demand[ed]" reversal; and (2) both Appellants claimed that the district court erred in denying their motions for judgment of acquittal due to an insufficiency of evidence. Finding no error, the Eleventh Circuit affirmed Appellants' convictions.

When Edith Entrekin was admitted to a nursing home in Alabama, she signed a contract requiring the arbitration of "all claims or disputes" that she or the executor of her future estate might have against the nursing home. After Entrekin died, the executor of her estate brought an action against the nursing home for damages under Alabama's wrongful death statute. The district court denied the nursing home's motion to compel arbitration. The issue on appeal to the Eleventh circuit centered on whether a decedent's agreement with a nursing home to arbitrate any claims that she or her executor may have in the future against the nursing home bind her executor to arbitrate a wrongful death claim against the nursing home under Alabama law? The Court found it was "compelled" to follow the Alabama Supreme Court's holdings and compel arbitration of the wrongful death claim in this case. The Court reversed the district court's order denying the nursing home's motion to compel arbitration and remanded the case with instructions to compel arbitration.