Justia Constitutional Law Opinion Summaries

A woman who had a long history of calling her local sheriff’s office—often to complain about gunfire she believed was coming from private property near her home—called both the non-emergency number and 911 on Thanksgiving Day 2018 to report gunshots. Dispatchers informed her that deputies had previously investigated and determined the gunfire was lawful and that no further response would be made. Despite these explanations, she persisted, escalating her complaint to a 911 call. She declined offers to speak with deputies and refused contact when a deputy came to her home. Based on her repeated calls and refusal to accept the dispatchers’ explanations, two sheriff’s office employees initiated an investigation and swore out an affidavit for her arrest under a Georgia statute prohibiting disruptive or harassing conduct during 911 calls. The local district attorney later dismissed the charge.The woman then filed a civil suit in the United States District Court for the Southern District of Georgia, alleging violations of her First and Fourth Amendment rights, including claims of retaliatory arrest and malicious prosecution. The district court denied qualified immunity to the two officers on the First Amendment retaliation and malicious prosecution claims, finding genuine disputes of material fact regarding probable cause and the officers’ conduct in seeking the arrest warrant.On appeal, the United States Court of Appeals for the Eleventh Circuit considered whether the officers were entitled to qualified immunity. The court held that the officers were entitled to rely on the collective knowledge of the sheriff’s office dispatchers, who were aware of the plaintiff’s history of similar calls and the lawful nature of the gunfire. The court concluded that, given this collective knowledge, the officers had at least arguable probable cause to seek the plaintiff’s arrest under the relevant Georgia statute. As a result, the Eleventh Circuit reversed the district court’s denial of qualified immunity. View "Prospero v. Sullivan" on Justia Law

A physician licensed in Florida worked at a weight management clinic, where he was responsible for maintaining a federal registration to dispense controlled substances. After a report of missing controlled substances at the clinic, local police and the Drug Enforcement Administration (DEA) began investigating. The investigation revealed that the physician had issued numerous prescriptions for controlled substances without proper documentation of a doctor-patient relationship, failed to maintain required records, did not properly report or store controlled substances, and dispensed medication in violation of labeling requirements. The physician claimed that another clinic employee had forged his signature on some prescriptions and denied personal wrongdoing.The DEA issued an Order to Show Cause, notifying the physician of its intent to revoke his registration and deny pending applications, citing violations of federal and state law. The physician submitted a Corrective Action Plan but did not request a hearing. The DEA Administrator reviewed the evidence, including expert testimony and the physician’s admissions, and found that the physician’s continued registration would be inconsistent with the public interest. The Administrator revoked the registration and denied all pending applications, emphasizing the physician’s failure to accept responsibility and the inadequacy of his proposed corrective measures.The United States Court of Appeals for the Eleventh Circuit reviewed the DEA’s final order under an abuse of discretion standard, deferring to the agency’s factual findings if supported by substantial evidence. The court held that the physician received adequate procedural due process, as he was given notice and an opportunity for a hearing, which he declined. The court also rejected the argument that the DEA was required to find knowing or intentional misconduct under Ruan v. United States, holding that such a mens rea requirement does not apply to administrative revocation proceedings under 21 U.S.C. § 824. The petition for review was denied. View "Ashraf v. Drug Enforcement Administration" on Justia Law

Two Florida residents who use medical marijuana in compliance with state law sought to purchase firearms but were denied after disclosing their marijuana use on a federal form. A third individual, a lawful gun owner, wished to participate in Florida’s medical marijuana program but refrained due to concerns about federal prosecution. All three, along with the Florida Commissioner of Agriculture, challenged the constitutionality of federal statutes and regulations that prohibit “unlawful users” of controlled substances—including marijuana—from possessing or purchasing firearms. The complaint did not allege that the plaintiffs had been convicted of any crimes or that their marijuana use rendered them dangerous.The United States District Court for the Northern District of Florida assumed the plaintiffs were protected by the Second Amendment but dismissed the complaint. The court applied the historical analysis required by District of Columbia v. Heller and New York State Rifle & Pistol Association v. Bruen, concluding that the federal prohibitions were consistent with the nation’s tradition of disarming individuals engaged in criminal conduct or deemed dangerous, such as felons, the mentally ill, or habitual drug users.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the case de novo. The court held that, at the motion to dismiss stage, the government failed to show that the plaintiffs—state-law-compliant medical marijuana users—were relevantly similar to either felons or dangerous individuals, the two historical analogues offered to justify the federal restrictions. The court emphasized that the complaint did not allege facts showing the plaintiffs were dangerous or had committed felonies. Accordingly, the Eleventh Circuit vacated the district court’s dismissal and remanded the case for further proceedings, holding that the plaintiffs had plausibly alleged a violation of their Second Amendment rights as applied to them. View "Florida Commissioner of Agriculture v. Attorney General of the United States" on Justia Law

A tenured English professor at a public university objected to the administration’s decision to resume in-person instruction during the Covid-19 pandemic. The professor, who had health concerns and was partially vaccinated, communicated his opposition by emailing students about his forced return to the classroom, attaching correspondence with his department chair, and using an unconventional email signature. The university responded by reassigning his courses, placing him on paid leave, and proposing a five-day suspension without pay, along with requirements for improved email professionalism. The professor then filed a lawsuit alleging violations of his First Amendment and procedural due process rights.The United States District Court for the Northern District of Florida dismissed the complaint. The court found that the professor’s email did not constitute protected speech under the First Amendment, as it was gratuitous information in a logistical message sent in his professional capacity. The court also rejected the procedural due process claim for failure to exhaust state-law remedies. The court’s dismissal order allowed the professor until July 3 to amend his complaint, instructing the clerk to enter judgment if no amendment was filed. The professor did not amend, and the clerk did not immediately enter judgment. On July 14, the court issued another order directing entry of judgment, which the clerk entered that day. The professor filed his notice of appeal on August 10.The United States Court of Appeals for the Eleventh Circuit reviewed whether the appeal was timely. Applying its precedent from Schuurman v. Motor Vessel Betty K V, the court held that the thirty-day appeal period began on the last day set for amending the complaint, not the later date when judgment was entered. Because the notice of appeal was filed more than thirty days after the amendment deadline, the court dismissed the appeal for lack of jurisdiction. View "Burt v. President of University of Florida" on Justia Law

An Army veteran serving a lengthy prison sentence in Florida applied for and received disability benefits for service-related post-traumatic stress disorder. Initially, the Veterans Benefits Administration approved his claim at a 70 percent rate, later increasing it to 80 percent. However, after his felony conviction and incarceration, the Administration reduced his monthly benefits to a 10 percent rate pursuant to 38 U.S.C. § 5313, which limits disability payments for veterans incarcerated for more than 60 days due to a felony.The veteran filed a pro se complaint in the United States District Court for the Middle District of Florida, naming the United States Congress as defendant. He alleged that the statute reducing his benefits violated the Bill of Attainder Clause and the Equal Protection component of the Fifth Amendment, seeking both prospective and retroactive relief. A magistrate judge recommended dismissal, assuming without deciding that the court had jurisdiction over facial constitutional challenges, but finding the claims frivolous. The district court adopted this recommendation, dismissing the complaint and declining to address the plaintiff’s general objections.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that sovereign immunity barred the suit against Congress, as Congress has not waived immunity for constitutional claims arising from its enactment of legislation. The court further held that any amendment to name a different defendant would be futile because the Veterans’ Judicial Review Act provides an exclusive review scheme for challenges to veterans’ benefits decisions, channeling all such claims—including constitutional challenges—through the administrative process and ultimately to the Court of Appeals for Veterans Claims and the Federal Circuit. The Eleventh Circuit vacated the district court’s judgment and remanded with instructions to dismiss the case without prejudice for lack of jurisdiction. View "Johnson v. United States Congress" on Justia Law

Two Black celebrities brought suit after being stopped by Clayton County, Georgia police officers on the jet bridge while boarding flights at Hartsfield-Jackson Atlanta International Airport. The officers, as part of a drug interdiction program, stopped passengers after they had cleared security and boarding checks, requested and retained their identification and boarding passes, questioned them about drugs, and asked to search their luggage. Both plaintiffs alleged they felt coerced, were not free to leave, and believed they had no choice but to comply. They further alleged that the program disproportionately targeted Black passengers and that the stops were neither random nor consensual.The United States District Court for the Northern District of Georgia dismissed all claims. It found the encounters were voluntary and not seizures under the Fourth Amendment, that any searches were consensual, and that the plaintiffs failed to plausibly allege racial discrimination or a policy supporting municipal liability. The court also granted qualified immunity to the individual officers.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that the plaintiffs plausibly alleged they were subjected to unreasonable seizures and, in one case, an unreasonable search, in violation of the Fourth Amendment. The court found that the circumstances—officers blocking the plaintiffs’ paths, retaining their documents, and questioning them in a confined space—amounted to seizures, and that the search was not voluntary. However, the court affirmed qualified immunity for the individual officers, as the law was not clearly established. The court also found that the plaintiffs plausibly alleged a policy or custom by Clayton County that could support municipal liability under Monell. The court affirmed dismissal of the equal protection claims, finding insufficient allegations of discriminatory intent. The court reversed in part, allowing the Fourth Amendment claims against Clayton County to proceed. View "Andre v. Clayton County" on Justia Law

Over a ten-day period in April 2020, a series of armed robberies targeted MetroPCS stores in the Miami area. The perpetrator, later identified as Francisco Louis, used a consistent method and attire, including a black Mercedes with a distinctive dent. After a police chase, Louis was apprehended, and evidence linking him to the robberies was recovered from his car, satchel, and residence. He was charged with six counts of Hobbs Act robbery.After his arrest, Louis spent several months in state custody before being transferred to federal custody in January 2021. The United States District Court for the Southern District of Florida granted four government-requested continuances for his arraignment and indictment, citing COVID-19 pandemic restrictions. Louis was indicted in April 2021, and his trial was initially set for August 2021. However, Louis, through counsel, requested three additional continuances to prepare for trial, resulting in the trial beginning in March 2022. He was convicted on all counts and sentenced to 218 months in prison.On appeal to the United States Court of Appeals for the Eleventh Circuit, Louis argued violations of both the Speedy Trial Act and the Sixth Amendment’s speedy trial guarantee, as well as challenges to the sufficiency of the evidence, jury instructions, and certain evidentiary rulings. The Eleventh Circuit held that Louis had waived his statutory Speedy Trial Act claim by failing to file a valid motion to dismiss before trial. Regarding the Sixth Amendment claim, the court found that although the delay was presumptively prejudicial, the reasons for delay were attributable to the pandemic and Louis’s own requests, and he failed to show actual prejudice. The court also rejected his other challenges and affirmed the conviction and sentence. View "USA v. Louis" on Justia Law

A federal prisoner diagnosed with a painful uterine fibroid sought medical treatment, including surgery, while incarcerated. Despite recommendations from two outside physicians for surgical intervention, prison medical staff repeatedly denied her requests for surgery. The prisoner followed the Bureau of Prisons’ four-step administrative grievance process: she attempted informal resolution, filed a formal written request, appealed to the regional director, and then submitted a final appeal (BP-11 form) to the Bureau’s General Counsel. Although she properly completed and mailed the BP-11 form, prison officials claimed they never received or logged it, and the tracking system showed no record of its receipt.The United States District Court for the Northern District of Alabama initially dismissed her Federal Tort Claims Act claims but allowed her to amend her complaint to pursue Eighth Amendment claims against individual medical staff. After further proceedings, the district court dismissed her amended complaint, concluding that she failed to exhaust administrative remedies because her BP-11 form was never logged as received and because she filed her lawsuit before the General Counsel’s response period had expired.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that the prisoner satisfied her obligation to exhaust administrative remedies by properly completing and mailing the BP-11 form, even though prison officials failed to log or process it. The court further held that the administrative remedy process was unavailable to her due to the lack of guidance on how to proceed when officials fail to file a properly submitted grievance, making the process “prohibitively opaque.” The Eleventh Circuit vacated the district court’s dismissal and remanded the case for further proceedings. View "McGuire-Mollica v. Griffin" on Justia Law

Federal agents discovered that an individual was sharing files containing child pornography over a peer-to-peer network. After obtaining a search warrant, law enforcement searched his residence and seized several digital devices. Forensic analysis revealed that he had downloaded and shared over 300 images and 150 videos depicting minors engaged in sexually explicit conduct. He was indicted in the United States District Court for the Middle District of Florida on one count of possessing and accessing with intent to view child pornography involving a minor under twelve years of age. The defendant waived his right to a jury trial and proceeded to a bench trial based on stipulated facts, after which the district court found him guilty.Prior to sentencing, the United States Probation Office prepared a Presentence Investigation Report, which calculated his total offense level as 30, including a five-level enhancement for offenses involving 600 or more images. The calculation treated each video as equivalent to 75 images, based on Sentencing Commission commentary. The defendant objected, arguing that the guideline’s text did not support this interpretation, but the district court overruled the objection and imposed a sentence of 97 months’ imprisonment and 15 years of supervised release. The court also ordered restitution of $3,000 to each of thirteen victims, totaling $39,000, and denied the defendant’s request for a jury to determine restitution. The written judgment included standard conditions of supervised release, which were not individually enumerated at sentencing.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s judgment. The court held that the sentencing guideline unambiguously requires each video frame containing child pornography to be counted as one image, but since the defendant conceded that his conduct exceeded the threshold for the highest enhancement, the sentence was affirmed. The court also held that neither the Fifth nor Sixth Amendments require a jury to determine restitution amounts, and that the district court was not required to disaggregate losses caused by the initial abuse. Finally, the court found no error in the district court’s pronouncement of supervised release conditions. View "USA v. Kluge" on Justia Law

Brandon Fulton alleged that Fulton County took his horses without justification and without paying for them, violating the Fifth Amendment's Takings Clause. He initially sought relief under 42 U.S.C. § 1983 but could not establish that the County acted under an official policy or custom, as required by Monell v. Department of Social Services of New York City.The United States District Court for the Northern District of Georgia dismissed Fulton’s § 1983 claim and denied his motion to amend his complaint to sue directly under the Takings Clause. The district court reasoned that plaintiffs must sue under § 1983 for constitutional takings claims against municipalities and that Fulton failed to allege an official policy or custom causing the violation.The United States Court of Appeals for the Eleventh Circuit reviewed the case and concluded that the Takings Clause of the Fifth Amendment directly authorizes a suit for "just compensation" in federal court. The court held that the Takings Clause is self-executing and guarantees a monetary remedy when the government takes private property. The court emphasized that the Takings Clause provides a direct cause of action independent of § 1983, especially when no other adequate remedy exists. The court vacated the district court's order and remanded the case for further proceedings, allowing Fulton to amend his complaint to sue directly under the Takings Clause. View "Brandon Fulton v. Fulton County Board of Commissioners" on Justia Law