Justia Constitutional Law Opinion Summaries

The Eleventh Circuit reversed the district court's grant of summary judgment to defendants in an action alleging that plaintiff was unlawfully discharged from the police department based on disability and/or racial or gender discrimination. The court held that plaintiff's evidence was insufficient to meet her prima facie burden that she was actually disabled, but was sufficient on whether she was regarded as disabled. The court also held that the district court erred in holding that plaintiff failed to produce sufficient evidence that she was a qualified individual. The court reasoned that, in this case, there was significant evidence that cuts against Union City's contention that exposure to OC spray and Taser shocks were essential functions of the job of police detective. The court also held that plaintiff met her prima facie burden of demonstrating that the City discriminated against her because of her perceived disability. Plaintiff had produced sufficient evidence that she was not a direct threat, the differing treatment of plaintiff's white colleagues, in combination with the rest of the evidence, was part of a mosaic of circumstantial evidence sufficient to create a triable issue of material fact on whether the police department's actions were discriminatory on the basis of race and/or gender. Finally, the court rejected plaintiff's claim of municipal liability. View "Lewis v. Union City, Georgia" on Justia Law

The Eleventh Circuit affirmed the district court's dismissal of plaintiff's claims alleging that her constitutional rights were violated when she was denied access to hearings at the Atlanta Immigration Court. The court affirmed the district court's determination that the immigration court judge was entitled to absolute immunity. The court held that the judge was acting within his judicial capacity when he closed immigration hearings, in which plaintiff was not a party to, nor counsel for, any of the parties. The court held that absolute immunity protected the judge both from plaintiff's Bivens claim and her claim for injunctive relief. Finally, plaintiff has failed to satisfy the difficult burden of showing that the district court abused its unique and substantial discretion in deciding whether to exercise jurisdiction over plaintiff's claim for declaratory judgment. View "Stevens v. U.S. Attorney General" on Justia Law

The Eleventh Circuit reversed the district court's dismissal of a habeas petition as time-barred and remanded for further proceedings. Under Florida law, petitioner's corrected Federal Rule of Criminal Procedure 3.850 motion related back to September 27, 2010. In keeping with Florida's rule, the court concluded that the Antiterrorism and Effective Death Penalty Act (AEDPA) limitation period was tolled from that date until the conclusion of the Rule 3.850 proceedings on March 1, 2013. The court held that because petitioner's 28 U.S.C. 2254 petition was filed less than one year later, his section 2254 petition was timely. View "Green v. Secretary, Department of Corrections" on Justia Law

The Eleventh Circuit vacated the district court's denial of an 18 U.S.C. 3583(e)(1) motion for early termination of supervised release. The court held that because a defendant may appeal a court's decision to deny him early termination of supervised release, and because appellate review must be meaningful, a district court’s order, in light of the record, must demonstrate that the pertinent factors were taken into account. In this case, nothing in the record or in the district court's order showed that it considered the required 18 U.S.C. 3553(a) factors. Therefore, the court remanded the case for further consideration and explanation. View "United States v. Johnson" on Justia Law

The Eleventh Circuit affirmed the district court's denial of a 28 U.S.C. 2254 petition for habeas relief. The court held that it was error for the trial court to give an instruction that had the effect of removing the defense of self-defense from the case, but the error was not fundamental. The court interpreted the Second District Court of Appeal decision rejecting petitioner's ineffective assistance of appellate counsel claim as having been based on the theory that while the forcible felony exception instruction was error, it was not fundamental error and, as a result, the direct appeal court would not have decided that claim on the merits if appellate counsel had raised the claim. In the alternative, the court did not believe that the instruction was fundamental error under Florida law. View "Pinkney v. Secretary, DOC" on Justia Law

The Eleventh Circuit held that the district court engaged in a thorough and comprehensive analysis of the record and acted within its discretion in finding that petitioner was competent to proceed as he saw fit and rationally chose to abandon his federal habeas appeal. Although petitioner's counsel filed a second notice of appeal, petitioner chose to dismiss all appeals, discharge counsel, and proceed with execution. The court could discern no clear error in the district court's determination and affirmed the district court's judgment and dismissal of the appeal. View "Eggers v. Alabama" on Justia Law

The Eleventh Circuit granted in part and denied in part defendants' motion for panel rehearing, granted defendants' motion for publication of the opinion, vacated its prior opinion, and substituted the following opinion.Plaintiff filed suit under 42 U.S.C. 1983 and 1988 and Florida law, alleging claims of excessive force, false arrest, false imprisonment, battery/unnecessary force, and malicious prosecution, arising from Lieutenant Smith's arrest of plaintiff. A jury returned a verdict for defendants and the district court denied plaintiff's motion for new trial. The court held that the district court abused its discretion in not asking the jury plaintiff's proposed voir dire question, which was: "Do you harbor any biases or prejudices against persons who are gay or homosexual?" Given the pretrial documentation concerning plaintiff's homosexual relationships, and the characterization of the altercation that led to his arrest as a domestic dispute, the risk that latent, undiscovered prejudices may have influenced the jury's verdict was substantial. Furthermore, the error was not harmless. Accordingly, the court vacated and remanded. View "Berthiaume v. Smith" on Justia Law

The Eleventh Circuit affirmed the district court's grant of summary judgment to defendants in an action alleging excessive force against Daniel Hammett. Hammett was shot and killed by an officer in a confrontation during the course of executing a warrant. The court held that plaintiff failed to produce evidence that suggested the "split-second judgments" of officers violated the Fourth Amendment as they responded to the "tense, uncertain, and rapidly evolving" events of the day. In this case, the actions of Defendant Horsley and Whitener were objectively reasonable and Defendant Mayfield was entitled to summary judgment because his bullet did not strike Hammett. View "Hammett v. Paulding County, Georgia" on Justia Law

The Eleventh Circuit withdrew its prior opinion and issued this opinion in its place. The court affirmed the district court's denial of petitioner's 28 U.S.C. 2254 habeas petition and held that the state court's denial of his Brady claim was entitled to deference under the Antiterrorism and Effective Death Penalty Act of 1996 and that the state court's denial was neither an unreasonable determination of the facts nor an unreasonable application of clearly established federal law. View "Rimmer v. Secretary, FL DOC" on Justia Law

The Eleventh Circuit affirmed the denial of a petition for habeas relief based on the ineffective assistance of counsel at the guilt phase of petitioner's trial. Petitioner alleged that she was denied effective assistance because a revolving door of trial attorneys, collectively, left her unable to muster an adequate defense. The state court deemed her challenge procedurally defaulted. Although the court did not rule out that an ineffective assistance of counsel claim could be based on the lack of continuity of counsel, and the court agreed that petitioner could show cause why she failed to raise her claim at the appropriate time in state court, the court concluded that petitioner could not demonstrate that the lack of continuity of counsel prejudiced her case. Therefore, petitioner could not overcome the procedural default and could not demonstrate a meritorious claim of ineffective assistance of counsel. View "Harris v. Commissioner, Alabama Department of Corrections" on Justia Law