Justia Constitutional Law Opinion Summaries

Plaintiff a female employee of Wakulla County (“the County”), worked for the County’s building department. Plaintiff filed a lawsuit in federal district court for, among other claims, the County’s violation of Title VII of the Civil Rights Act of 1964. In the present case, Plaintiff filed a five-count complaint against the defense attorneys for the County. The defense attorneys and their law firms filed several motions to dismiss under Federal Rule of Civil Procedure 12(b)(6). The district court dismissed the complaint, explaining that Plaintiff’s alleged facts did not demonstrate that the defense attorneys for the County had engaged in a conspiracy that met the elements of 42 U.S.C. Section 1985(2).   Plaintiff’s complaint suggested that the defense attorneys filed the complaint for the “sole benefit of their client rather than for their own personal benefit.” Alternatively, Plaintiff points to the fact that the County defense attorneys had been aware of Plaintiff’s recordings for many months and only reported her recordings to law enforcement when they learned that Plaintiff “insist[ed] on her right to testify in federal court about the recordings and present them as evidence” in the sexual harassment case.   The Eleventh Circuit affirmed. The court explained that per Farese, it is Plaintiff’s burden to allege facts that establish that the County defense attorneys were acting outside the scope of their representation when they told law enforcement about Plaintiff’s recordings. Here, Plaintiff but in no way suggests that the defense attorneys were acting outside the scope of their representation, thus her Section 1985(2) claims were properly dismissed. View "Tracey M. Chance v. Ariel Cook, et al" on Justia Law

Petitioner was sentenced to death by a Florida court for the murder of a five-month-old baby. After an unsuccessful direct appeal and two rounds of state collateral proceedings, he sought habeas corpus relief in federal court. In this appeal from the denial of his federal petition, the Eleventh Circuit considered Petitioner’s claims that the state trial court violated his right against self-incrimination under the Fifth Amendment when it admitted his confessions and other statements he made to the police into evidence at his trial, and that his trial attorney provided ineffective assistance at the penalty phase in violation of the Sixth Amendment.   The Eleventh Circuit affirmed the district court’s denial. The court explained that the state court’s admission of his statements at trial did not violate Petitioner’s constitutional rights because he made those statements either spontaneously or after reinitiating discussions with police and knowingly and voluntarily waiving his Miranda rights. Further, a strategic decision not to call a witness whose testimony is not entirely problem-free and to focus instead on other available mitigating evidence does not amount to a deprivation of the Sixth Amendment right to counsel, and the state court’s decision to that effect was not objectively unreasonable. View "Andrew Richard Lukehart v. Secretary, Florida Department of Corrections, et al" on Justia Law

Defendants appealed their convictions and the ensuing sentences on multiple counts arising out of their conspiracy to commit access device fraud. On appeal they argued that: (1) law enforcement agents violated their Fourth Amendment rights by illegally entering their house after arresting them; (2) the district court impermissibly lowered the government’s burden of proof during voir dire; (3) the district court erred in applying two-level enhancements to their base offense levels for possessing device-making equipment; (4) the district court erred in applying two-level aggravating-role enhancements; (5) their total sentences were procedurally unreasonable; and, finally, (6) their sentences, overall, were substantively unreasonable.   The Eleventh Circuit affirmed. The court the record demonstrates Defendants’ deep involvement in the planning and organization of the fraudulent scheme and their vital role in the commission of the offenses, as well as their involvement in decision-making and recruitment, all of which was far more extensive than the role played by the co-conspirator. To the extent Defendants argue that they could not both receive aggravating-role enhancements since they were equally involved, a defendant eligible for an aggravating-role enhancement “does not have to be the sole leader of the conspiracy for the enhancement to apply.” The district court did not clearly err in applying the aggravating-role enhancements to the brothers’ offense levels. Further, the court wrote that the district court imposed an otherwise substantively reasonable total sentence for each defendant. View "USA v. Igor Grushko, et al." on Justia Law

Following a government investigation into an afterschool program run by Plaintiff Chabad Chayil, Inc., Defendant Miami-Dade County Public Schools (“MDCPS”) barred Chabad from continuing to use its facilities. Chabad sued both MDCPS and the investigating authority—Miami-Dade County’s Office of Inspector General (“OIG”)—for alleged violations of its federal constitutional rights. The district court dismissed those claims with prejudice and without leave to amend, and Chabad appealed.   The Eleventh Circuit affirmed concluding that the district court properly dismissed all of Chabad’s Section 1983 claims against the MDCPS and OIG, and the court affirmed the dismissal of those claims without leave to amend.   The court explained that the unspecified acts of unidentified OIG investigators in this single case do not plausibly allege an official policy of the OIG, or even a custom that rises to the force of law. Thus, the district court properly dismissed the Free Exercise claim against the OIG. Further, Chabad did not demonstrate that its comparators were similarly situated in all relevant respects. Accordingly, the district court correctly dismissed the Equal Protection claim against the OIG. Moreover, the court explained that to impose liability under Section 1983, the government entity’s actions must be the “moving force” behind the deprivation of a constitutional right. The OIG does not have the authority to refuse any group permission to use school board property–that power lies with MDCPS. Thus, even if the OIG did act in accordance with some official policy or custom, that policy or custom did not cause Chabad’s harm. View "Chabad Chayil, Inc. v. The School Board of Miami-Dade County Florida, et al." on Justia Law

Petitioners, a group comprised of municipalities, individuals, and a nonprofit organization all based in South Florida, filed this petition for review, claiming that the FAA violated the National Environmental Protection Act (“NEPA”), the Clean Air Act, the Department of Transportation Act, and the U.S. Constitution’s Due Process Clause. Among other things, Petitioners say the FAA’s Purpose and Need Statement was seriously deficient in violation of NEPA; its Cumulative Impact Assessment was improper and violated NEPA.   The Eleventh Circuit denied the petitions for review concluding that none of the Petitioners’ claims have merit. The court held that the FAA scrupulously adhered to the requirements of the relevant statutes and afforded the public numerous opportunities to comment on the proposed changes. The court explained that the FAA engaged in an exhaustive study of the South-Central Florida Metroplex Project’s impact on the environment and noise levels in the affected area, and it found no significant impact. It also provided ample opportunity for the various stakeholders to learn about and comment on the project and complied with all procedural requirements. View "City of North Miami v. FAA, et al." on Justia Law

This case arises out of the shooting death of Plaintiff’s son. It required the Eleventh Circuit to decide whether video evidence creates a genuine dispute of material fact concerning whether law enforcement officers used excessive force while trying to arrest Plaintiff’s son.Plaintiff filed claims under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 (1971), against Officers Heinze, Hutchens, and Doyle, alleging that they violated her son’s Fourth Amendment rights by using excessive force in attempting to arrest him. The three Task Force officers sought summary judgment on the Bivens claims. They argued that they were entitled to qualified immunity because they used a reasonable level of force under the circumstances   The Eleventh Circuit held that the district court correctly granted summary judgment to Officer Hutchens because he was entitled to qualified immunity. The district court also correctly determined that Officers Doyle and Heinze were entitled to qualified immunity for their actions before the flashbang detonated. Accordingly, the court affirmed those portions of the district court’s order. The district court erred, however, by granting qualified immunity to Officers Doyle and Heinze for their actions after the flashbang exploded. The court therefore reversed the district court’s order insofar as it granted them summary judgment on Plaintiff’s claim that they employed excessive force after the flashbang detonated.  The court remanded for further proceedings consistent. View "Monteria Najuda Robinson v. William Sauls, et al" on Justia Law

Plaintiff, a sheriff’s department employee, had an affair with the wife of a county administrator. The mistress allegedly conducted a smear campaign against Plaintiff’s wife and, when the affair ended, against Plaintiff as well. The sheriff’s department fired Plaintiff and a local prosecutor declined to prosecute the mistress for harassment. Suspecting the county administrator had a hand in both actions, Plaintiffs sued the mistress, the county administrator, and a host of other county officials for violating state and federal law. The district court entered a summary judgment in favor of the officials and certified that judgment as final even though claims against the mistress remained pending.   The Eleventh Circuit dismissed the appeal, finding that the district court abused its discretion when it determined that the summary judgment warranted certification under Rule 54(b). The determination in this case that there was no just reason for delay rested on a single factual finding—that “[t]his litigation could potentially remain pending for quite a lengthy time due to the COVID-19 pandemic.” The court wrote that there is no indication that the delays here would cause anything other than inconvenience. Indeed, if pandemic-related delays alone justified an immediate appeal, Rule 54(b) certifications” would cease to “be reserved for the unusual case. View "Chase Peden, et al v. Glenn Stephens, et al" on Justia Law

Several states challenged the portion of the vaccine mandate as it pertains to employees who work on or in connection with a covered contract, or share a workplace with another employee who does. The district court determined that Plaintiffs were entitled to a preliminary injunction.On appeal, the Eleventh Circuit agreed with the district court that Plainitffs were likely to prevail on the merits. However, the court also found that the injunction’s nationwide scope was too broad. Thus, the Eleventh Circuit affirmed the district court’s order to the extent that it enjoins federal agencies from enforcing the mandate against the plaintiffs and to the extent that it bars the federal government from considering a bidder’s compliance with the mandate when deciding whether to grant a contract to a plaintiff or to a nonparty bidder. However, the Eleventh Circuit vacated the remaining portion of the preliminary injunction. View "State of Georgia, et al v. President of the United States, et al" on Justia Law

Petitioner appealed the district court’s order denying his petition for writ of habeas corpus. The Eleventh Circuit issued a certificate of appealability (“COA”) with respect to: “Whether trial counsel provided ineffective assistance of counsel in violation of the Sixth Amendment to the United States Constitution when at the penalty phase of trial, it failed to conduct a reasonable mitigation investigation and failed to uncover and present mitigation evidence.”   The Eleventh Circuit affirmed the district court’s order. The court concluded that Petitioner’s claim of ineffective assistance of trial counsel was exhausted in state court. The court explained that Petitioner’s claim in state court did not contain any factual allegations in support of his claim that his trial counsel was ineffective in failing to investigate and present “substantial evidence” of mitigation. His allegations remained largely unchanged in his briefing to the Alabama Court of Appeals and the Supreme Court of Alabama.   Further, the court held that Petitioner failed to make any argument that the Alabama Court of Criminal Appeals’ denial of Petitioner’s claim of ineffective assistance of counsel was contrary to or involved an unreasonable application of Strickland, or that it was based on an unreasonable determination of the facts in light of the evidence presented in state court.   Moreover, the court agreed with the district court’s determination under the Antiterrorism and Effective Death Penalty Act (AEDPA) that Petitioner has not demonstrated the Alabama courts’ denial of his Strickland claims were “contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court.” View "David Freeman v. Commissioner, Alabama Department of Corrections." on Justia Law

Petitioners petitioned for review concerning whether it was arbitrary and capricious for the Food and Drug Administration (FDA or Administration) to issue marketing denial orders to six tobacco companies for their electronic nicotine-delivery systems without considering the companies’ marketing and sales-access-restriction plans designed to minimize youth exposure and access. The Administration refused to consider the marketing and sales-access-restriction plans.   The Eleventh Circuit granted the petitions for review, set aside the orders of the Administration, and remanded to the Administration. The court concluded that it was arbitrary and capricious for the Administration to ignore the relevant marketing and sales-access restriction plans do not mandate a different result on remand. The court acknowledged the evidence in the record cataloged by the dissent of the serious risk to youth, and it may be that the Administration will conclude on remand that the marketing and sales-access restriction plans submitted in the tobacco companies’ applications do not outweigh those risks. The court wrote that it decides only that the Administration must at least consider the relevant evidence before it, which includes the companies’ marketing and sales-access-restriction plans. View "Bidi Vapor LLC v. U.S. Food and Drug Administration, et al" on Justia Law