Justia Constitutional Law Opinion Summaries

The Eleventh Circuit vacated its previous opinion and issued the following opinion.Plaintiff and the Association filed suit under Title II of the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act against several Florida entities and officials, challenging defendants' failure to provide captioning for live and archived videos of Florida legislative proceedings.The court affirmed the district court's denial of defendant's motion to dismiss, holding that it has jurisdiction to hear defendants' interlocutory appeal. The court affirmed the district court's alternative holding that Congress validly abrogated defendants' Eleventh Amendment immunity for these claims under Title II regardless of whether a fundamental right is implicated. Because the court affirmed on this basis, it did not reach the question of whether the ability to participate in the democratic process is a fundamental right. The court stated that Congress validly abrogated sovereign immunity for this claim under the standard for important rights that nonetheless receive only rational basis review.The court also affirmed the district court's holding that plaintiffs were entitled to pursue injunctive relief under the doctrine of Ex parte Young for allegedly ongoing violations of Title II. Finally, given the substantial overlap between plaintiffs' ADA and Rehabilitation Act claims, the court held that the district court did not encroach on the Legislative Defendants' immunity. View "National Association of the Deaf v. Florida" on Justia Law

Plaintiff, who is civilly committed and housed in the Florida Civil Commitment Center (FCCC), filed a pro se 42 U.S.C. 1983 action alleging that, during a trip to a court hearing located about 600 miles from the FCCC, defendants restrained, transported, and temporarily housed him in a manner that was inconsistent with professional judgment and therefore violated his Fourteenth Amendment rights. The district court dismissed the case for failure to state a claim.The Eleventh Circuit reversed the district court's dismissal of plaintiff's Fourteenth Amendment Due Process claims arising from his bathroom-related allegations and his jail-housing claim, as well as the order dismissing defendants for lack of service. However, plaintiff's allegations about the shackles, transport by van instead of airplane, the stale sandwich he was given, and the driving speeds fail to state a Fourteenth Amendment claim. Therefore, the court affirmed the district court's dismissal order in all other respects, remanding for further proceedings. View "Bilal v. GEO Care, LLC" on Justia Law

The Eleventh Circuit reversed the district court's grant of habeas relief to petitioner. Petitioner argues that his appellate counsel was ineffective for failing to raise a certain juror's presence on the trial jury. Because the Warden concedes that counsel performed deficiently, the only issue is prejudice.The court held that the state habeas court's ruling that petitioner did not prove that the juror was actually biased against him was not based on an unreasonable determination of fact under 28 U.S.C. 2254(d)(2). In this case, the court cannot say for certain what the juror meant when he raised his hand in response to a question during voir dire regarding a murder prosecution involving a shooting, and, for that reason, the court cannot say the state court's finding was unreasonable. The court also held that the state court did not unreasonably apply Strickland v. Washington when it held that petitioner failed to establish a reasonable probability that his appeal would have been decided differently had appellate counsel raised the presence of the juror. Finally, the court held that Georgia's juror non-impeachment statute is not an alternative basis for relief. View "Teasley v. Warden, Macon State Prison" on Justia Law

Plaintiff filed suit alleging that Godiva chocolate stores had printed too many credit card digits on hundreds of thousands of receipts over the course of several years, and pointed out that those extra numbers were prohibited under a federal law aimed at preventing identity theft. After the parties agreed on a class settlement, the Supreme Court issued Spokeo, Inc. v. Robins, which held that a party does not have standing to sue when it pleads only the bare violation of a statute.The Eleventh Circuit held that plaintiff has no standing because he alleged only a statutory violation and not a concrete injury. In this case, plaintiff alleged that a cashier handed him a receipt containing some of his own credit card information printed on it. Although the receipt violated the law because it contained too many digits, the court explained that plaintiff has alleged no concrete harm or material risk of harm stemming from the violation. Therefore, this amounts to nothing more than a "bare procedural violation, divorced from concrete harm." Consequently, the court cannot evaluate the fairness of the parties' settlement and vacated the district court's order approving it. View "Muransky v. Godiva Chocolatier, Inc." on Justia Law

Plaintiff filed suit against the State, arguing that O.C.G.A. 45-5-3.2 violates the Georgia Constitution and the Due Process Clause of the Fourteenth Amendment to the extent it allows the State to cancel the November 2020 election for the office of district attorney for the Western Judicial Circuit. Plaintiff sought a preliminary injunction that would require the State to hold the election, which the district court granted.Because the Eleventh Circuit is bound by the Supreme Court of Georgia's decision that O.C.G.A. 45-5-3.2, as challenged here, violates the Georgia Constitution, the court held that the district court did not abuse its discretion by finding that plaintiff established a substantial likelihood of success in her argument that O.C.G.A. 45-5-3.2 violates the Georgia Constitution and the Due Process Clause of the Fourteenth Amendment. The court also held that the district court did not abuse its discretion by concluding that plaintiff would suffer an irreparable injury unless an injunction was granted, because the State's enforcement of O.C.G.A. 45-5-3.2 would deprive plaintiff of her right to vote in the November 2020 district attorney election. Finally, the district court did not abuse its discretion by finding that the balance of harms and public interest weigh in favor of granting the injunction. Accordingly, the court affirmed the district court's order granting the preliminary injunction. View "Gonzalez v. Governor of the State of Georgia" on Justia Law

The Eleventh Circuit held that the district court did not clearly err in finding that House Bill 836's district map violated section 2 of the Voting Rights Act of 1965. HB 836 reduced the size of the board from nine members to seven. Where all nine members previously had come from single-member districts, now only five would, and two would be drawn from at large seats. Plaintiff alleged that the new map would violate section 2 by diluting the strength of Black voters in Sumter County. The district court agreed and entered a remedial order removing the at-large seats and drawing a new map with seven single-member districts instead.The court reviewed the entire record and held that plaintiff adduced ample evidence supporting a finding of vote dilution. The court held that the district court did not clearly err in concluding that plaintiff satisfied all three Gingles factors: first, the undisputed evidence showed that Sumter County's Black residents could form a majority in at least one additional single-member district (and probably in two); second, the Black voters in Sumter County were highly cohesive in ten of the twelve elections studied; and third, White residents vote sufficiently as a bloc to enable them usually to defeat the minority's preferred candidate. The court also held that plaintiff established that the totality of the circumstances results in an unequal opportunity for minority voters to participate in the political process and to elect representatives of their choosing. In this case, the district court did not clearly err by finding that the first, second, fifth, and seventh Senate factors weighed heavily in plaintiff's favor. The district court noted Georgia's, and Sumter County's, painful history of discrimination against its Black residents, emphasizing the high levels of racially polarized voting and observed the lack of success enjoyed by Black candidates in Sumter County. Furthermore, the special master report expressly found an easily achievable remedy available. View "Wright v. Sumter County Board of Elections and Registration" on Justia Law

The Eleventh Circuit affirmed the district court's dismissal of plaintiff's 42 U.S.C. 1983 action alleging that defendant, in his official capacity as the Commissioner of the Florida Department of Law Enforcement (FDLE), violated his constitutional rights by continuing to publish his personally identifiable information on FDLE's sex offender registry website even after plaintiff had completed probation and was no longer subject to Florida registration laws. The court held that, although plaintiff has not waived his continuing violation argument, his claims are time-barred because there was no continuing violation. Furthermore, Nichols v. United States, 136 S. Ct. 1113 (2016), does not affect the accrual of plaintiff's claims under Florida's statute of limitations. View "McGroarty v. Swearingen" on Justia Law

The Eleventh Circuit reversed the district court's grant of summary judgment based on qualified immunity to defendants in an 42 U.S.C. 1983 action brought by plaintiff, alleging that police officers used excessive force, among other things, when they tased, beat, and broke plaintiff's jaw after a routine accident investigation. The court held that the district court did not view the evidence in the light most favorable to plaintiff before ruling against him. The court stated that, at the summary judgment stage, the Graham factors favor an excessive force finding for both the tasing and the later force applied when plaintiff was taken out of the truck. Furthermore, striking a compliant suspect who has surrendered his hands and stopped all resistance amounts to a clearly established constitutional violation. View "Stryker v. City of Homewood" on Justia Law

Plaintiff filed suit against a Miami-Dade police officer under 42 U.S.C. 1983, alleging that the officer shot him without provocation while his truck was stopped at a red light. Plaintiff is presently incarcerated, after a Florida state jury convicted him of aggravated assault and fleeing to elude among other crimes.The Eleventh Circuit held that plaintiff has not waived this appeal by failing to object to the report and recommendation, because it did not inform plaintiff of all of the consequences on appeal for failing to object. On the merits, the court held that Heck v. Humphrey, 512 U.S. 477 (1994), does not bar plaintiff's lawsuit and the district court erred in granting summary judgment in favor of the officer. In this case, the officer focuses on just two of plaintiff's state court convictions -- for aggravated assault and fleeing to elude, conceding as he must that plaintiff's remaining convictions could not be negated if his section 1983 action were to succeed. Therefore, the entry of a judgment in plaintiff's favor on his section 1983 excessive force suit would not necessarily imply the invalidity of his state court convictions. The court remanded for further proceedings. View "Harrigan v. Rodriguez" on Justia Law

The Eleventh Circuit held that the district court misapplied the Anderson-Burdick framework when it enjoined the State defendants' enforcement of a long-standing Georgia absentee ballot deadline, which requires ballots to be received by 7:00 p.m. on Election Day to be counted. The district court, instead, manufactured its own ballot deadline so that the State is now required to count any ballot that was both postmarked by and received within three days of Election Day. Because the State defendants have met all four prongs of the Nken test, the court granted their motion to stay the injunction.The court concluded that the State defendants have shown that they will likely succeed on the merits of their claim because the district court did not properly apply the appropriate framework. The court explained that Georgia's decades-old absentee ballot deadline is both reasonable and nondiscriminatory, while its interests in maintaining that deadline (especially now that absentee voting has already begun) are at least "important"—as the district court itself recognized—and likely compelling. In this case, the district court erred by finding that Georgia's Election Day deadline severely burdened the right to vote, and by improperly weighing the State's interests against this burden. The court also concluded that Georgia will suffer irreparable harm absent a stay and a stay is in the public interest. Therefore, because Georgia's decades-old Election Day deadline for absentee ballots does not threaten voting rights, and is justified by a host of interests, the court stayed the district court's injunction of that deadline. View "The New Georgia Project v. Raffensperger" on Justia Law