Justia Constitutional Law Opinion Summaries

TASER International, Inc., obtained an injunction against “Phazzer [Electronics] and its officers, agents, servants, employees, and attorneys; and any other persons who are in active concert or participation with Phazzer Electronics or its officers, agents, servants, employees, or attorneys” (the “2017 injunction”). The injunction prohibited Phazzer Electronics from distributing or causing to be distributed certain stun guns and accompanying cartridges that infringed on TASER’s intellectual property. At the time of the TASER-Phazzer Electronics litigation, Steven Abboud controlled Phazzer Electronics, and Phazzer Electronics employed, among others, Defendant. In 2018, after the district court found Abboud in contempt for violating the 2017 injunction, Abboud and Defendant went to work for other entities with “Phazzer” in their names. Based on that activity, the district court found Defendant (and others) in contempt of the 2017 injunction. At issue on appeal is whether the 2017 injunction extended broadly enough to bind Defendant and prohibit her conduct under the theories of liability that the government has pressed and the district court decided   The Eleventh Circuit vacated Defendant’s conviction. The court concluded that the record cannot sustain Defendant’s conviction.  The court explained that the district court did not make factual findings about whether Defendant was a key employee. Nor did it determine whether she so controlled Phazzer Electronics and the litigation that resulted in the 2017 injunction that it would be fair to say she had her day in court on that injunction. View "USA v. Diana Robinson" on Justia Law

Plaintiff brought both a Section 1983 false arrest claim and a state law false arrest claim against two Huntsville, Alabama, police officers and the City itself. The district court concluded that the officers were entitled to qualified immunity, and Plaintiff appealed.   The Eleventh Circuit reversed the district court’s grant of qualified immunity. The court explained that, in general, when government officials are performing discretionary duties, as all parties concede they were in this case, they are entitled to qualified immunity. A plaintiff may rebut this entitlement by showing that the government officials (1) committed a constitutional violation; and (2) that this violation was “clearly established” in law at the time of the alleged misconduct.   The court explained that it has been clearly established for decades that the police are free to ask questions, and the public is free to ignore them. It has been clearly established prior to Plaintiff’s arrest that any legal obligation to speak to the police and answer their questions arises as a matter of state law. And the state statute itself, in this case, is clear and requires no additional construction: police are empowered to demand from an individual three things: “name, address and an explanation of his actions.” It was thus clearly established at the time of Plaintiff’s arrest that Defendant could not demand he produce physical identification. Thus, no reasonable officer could have believed there was probable cause to arrest Plaintiff for obstructing governmental operations. And this theory cannot support the grant of qualified immunity to the officers. View "Roland Edger v. Krista McCabe, et al" on Justia Law

Plaintiffs worked as detention officers for Glynn County under Sheriff Jump’s supervision. Although it is unclear from the record whether the Officers are formally deputy sheriffs, it is undisputed that they are, at minimum, direct employees of Sheriff Jump, in his official capacity, akin to deputies. The Officers brought a Fair Labor Standards Act (FLSA) collective action alleging that the County “illegally calculated their and other detention officers’ overtime wages.” The County moved to dismiss for failure to state a claim. In response, the Officers amended their complaint to include Sheriff Jump in his individual capacity. The County and Sheriff Jump then moved to dismiss the amended complaint for lack of subject-matter jurisdiction and for failure to state a claim, arguing that neither defendant was the Officers’ employer under the FLSA.   The Eleventh Circuit affirmed both the district court’s denial of the Officers’ motion for leave to amend and its ultimate dismissal of the amended complaint. The court held that the district court correctly dismissed the Officers’ complaint against Sheriff Jump in his individual capacity because he is not an “employer” under the FLSA. Further, the court agreed with the district court that Sheriff Jump would be entitled to Eleventh Amendment immunity when making compensation decisions for his employees. Further, the court held that Georgia “retained its Eleventh Amendment immunity” from suits in federal court for breach-of-contract claims because no statute or constitutional provision “expressly consents to suits in federal court. View "Langston Austin, et al. v. Glynn County, Georgia, et al." on Justia Law

In 2002, the grand jury indicted Petitioner for (1) armed bank robbery, (2) knowingly carrying, using, possessing, and discharging a firearm during and in relation to a crime of violence, and (3) possessing a firearm as a felon. The government then filed a notice that Petitioner qualified for the enhanced sentence under section 3559. Petitioner appealed his convictions and sentences, and the Eleventh Circuit affirmed. Petitioner then filed in the district court a second section 2255 motion. The issue here is whether the Supreme Court has announced a “new rule of constitutional law” that applies to the residual clause in 18 U.S.C. section 3559.   The Eleventh Circuit vacated the district court’s order and remanded for Petitioner’s motion to be dismissed for lack of jurisdiction. The court noted that its decision is narrow, and it has not decided whether the three-strikes law’s residual clause is unconstitutionally vague. The court wrote that it has not decided whether the three-strikes law’s residual clause is unconstitutionally vague. Further, the court explained that it has not decided whether Petitioner met his burden under Beeman. Instead, the court’s review was limited to the threshold question of whether Petitioner has met the jurisdictional requirements of section 2255(h)(2).   The court reasoned that the district court had jurisdiction to consider Petitioner's second section 2255 motion only if he could establish that a new constitutional rule supported his claim. But no decision from the Supreme Court has announced the new rule that Petitioner needs. The district court therefore lacked jurisdiction to decide whether Petitioner’s motion had any merit. View "Charles Edward Jones v. USA" on Justia Law

Zen Group, Inc., is “a Florida Medicaid provider of services to developmentally-disabled minors.” Zen Group alleges that beginning in 2018, the Florida Agency for Health Care Administration wrongfully attempted to recoup payments rendered under the Agency’s “Behavior Analysis Services Program.” Zen Group asserts that the officials made baseless referrals for investigation of fraud and suspended payments to Zen Group in retaliation for the previous exercise of its constitutional rights in an administrative proceeding. Zen Group complained that the officials’ retaliation violated its due-process rights under the Fourteenth Amendment and its speech and petition rights under the First Amendment. The district court dismissed the complaint.   The Eleventh Circuit affirmed. The court held that Zen Group’s due process and First Amendment claims for damages are both barred by qualified immunity. And Zen Group lacks standing to seek injunctive relief. The court explained that Zen Group alleged that it had “completely ceased operations” in June 2020. It did not allege that it had resumed providing services to Medicaid recipients. The court explained that in that context, the most it can fairly infer from the assertion that Zen Group “remains a Florida Medicaid provider” is that Zen Group remains an active corporation authorized by the state to provide Medicaid services, even though it is not currently doing so. The allegations in the amended complaint do not support the inference that Zen Group faces anything more than a speculative risk of future injury if it resumes providing services or the officials decide to engage in retaliatory fraud referrals against an inactive provider with respect to services rendered in the past. View "Zen Group, Inc., et al v. State of Florida Agency for Health Care Administra, et al" on Justia Law

A jury found Defendant guilty of various drug crimes. Now on appeal, Defendant attacked his indictment, claiming that the grand jury’s probable cause determination was rendered defective by the district court’s special procedures related to the Covid-19 pandemic. Under these procedures, grand jurors met in three separate federal courthouses but were joined together by videoconferencing. Defendant also argued that the wiretaps used to gather evidence against him did not meet the statutory necessity requirement.   The Eleventh Circuit affirmed. The court held that the COVID-19 accommodations that Defendant criticized introduced no fundamental error into his prosecution. The court wrote that Defendant does not claim that they affected the grand jury’s decision in any way. As for the statutory necessity claim, the district court did not clearly err in deciding that the wiretaps were necessary. The court further explained that a review of the wiretap affidavits themselves shows that they provided more than enough explanation to comply with the law. After describing the investigation’s history and goals, the affidavits comprehensively outlined the “Need for Interception” and discussed “Alternative Investigative Techniques.” They exhaustively detailed why previous sources of information and reasonable alternative methods—including physical surveillance, cameras, interviews, undercover agents, subpoenas, search warrants, trash searches, and more—would not suffice. The court found that such thorough and specific affidavits easily satisfy the legal requirements. View "USA v. James Lamount Graham" on Justia Law

Plaintiff was the Chief Meteorologist at CBS46, an Atlanta news station. But during his tenure, female colleagues raised repeated complaints that he engaged in inappropriate conduct and sexual harassment—including “compliments” about appearance, sexually charged language, requests for nude photos, and more. Plaintiff, who is white, alleges that he was terminated because of his race in violation of 42 U.S.C. Section 1981. The sexual harassment justification, he says, was just a pretext. The district court granted summary judgment to Defendants.   The Eleventh Circuit affirmed. The court wrote that the ultimate question in any discrimination case is whether the defendant intentionally discriminated against the plaintiff based on race. Here, Plaintiff failed to show that a reasonable jury could conclude that Defendant terminated his employment because he was white.   The court explained that Plaintiff notes that the station’s new meteorologist is a Hispanic woman. However, Plaintiff mostly argued that the existence of race data on the corporate form meant that he was fired because he was white. The court explained Plaintiff lacked direct evidence of discrimination, he lacked evidence that Defendant treated his race as a factor favoring his termination, and he lacked evidence that Defendant treated similarly situated non-white employees more favorably. On the other hand, Defendant has produced extensive evidence of Plaintiff’s sexual harassment, which is a valid, nondiscriminatory reason for his termination. The court explained that on this record, no reasonable jury could infer that Defendant’s justification was pretext for race discrimination. View "Paul Ossmann v. Meredith Corporation" on Justia Law

Defendant pleaded guilty in district court to one count of possessing a firearm as a convicted felon. The district court sentenced Defendant in 2016 to 100 months imprisonment, followed by three years of supervised release. Defendant completed his custodial sentence and began serving his three-year term of supervised release on May 10, 2018. Less than four months before his supervision was set to expire, his probation office filed a petition alleging that Defendant violated two conditions of his supervised release and asked the district court to issue a warrant for his arrest. The court revoked Defendant’s supervised release and sentenced him to serve an additional 18 months’ imprisonment “to be concurrent with any sentence already served or to be served” that a state court imposed. Defendant appealed.   The Eleventh Circuit vacated. The court explained that it rejected the government’s position that a term of supervised release is tolled while an offender absconds from supervision. Accordingly, Defendant’s supervised release term expired as scheduled in May 2021. Because his 2022 battery and resulting conviction did not occur until after that date, the district court lacked the authority to revoke Defendant’s supervised release on that basis. But because the district court nonetheless maintained jurisdiction to revoke his supervision based on his earlier violation, the court remanded for the court to decide whether to revoke Defendant’s supervision based on that violation alone and to decide what sentence to impose for that violation. View "USA v. James Reginald Talley" on Justia Law

After Petitioner’s conviction and sentence were upheld on direct appeal, Petitioner sought state post-conviction relief. As relevant here, he asserted that his attorneys rendered ineffective assistance by failing to properly advise him about the risks of not following through with his plea agreement and by not doing enough to persuade him to testify against his co-defendant. The Alabama courts rejected this ineffectiveness claim, ruling in part that Petitioner could not show prejudice resulting from his attorneys’ conduct. The district court denied Petitioner’s federal habeas corpus petition, concluding that the decision of the Alabama courts was not an unreasonable application of applicable Supreme Court precedent and was not based on an unreasonable determination of the facts.   The Eleventh Circuit affirmed. The court explained that the Alabama courts’ factual finding that Petitioner would have refused to testify against a co-Defendant, no matter what more his attorneys did, stands. Based on that finding, their ultimate conclusion that Petitioner was not prejudiced by his attorneys’ allegedly deficient performance—which constitutes a ruling on a mixed question of law and fact—is not unreasonable under Section 2254(d)(2). Accordingly, the court concluded that the Alabama courts’ factual finding that Petitioner would not have changed his mind no matter what more his attorneys might have done is entitled to a presumption of correctness. And that presumption has not been overcome by clear and convincing evidence. View "Robert Shawn Ingram v. Warden, Holman Correctional Facility" on Justia Law

In 2006, Petitioner pleaded guilty to murdering his grandmother and stepgrandfather. He was sentenced to death. After exhausting his direct appeals, Petitioner filed a petition for postconviction relief under Alabama Rule of Criminal Procedure 32, citing ineffective assistance of counsel. The circuit court agreed with Alabama and summarily dismissed Petitioner's petition. The Alabama Court of Criminal Appeals affirmed the dismissal.Petitioner then filed a petition for habeas corpus under 28 U.S.C 2254, which was dismissed on abandonment grounds. As an alternate holding, the district court found that Petitioner's claims were too conclusory to get around AEDPA.The Eleventh Circuit granted a COA on three issues, ultimately rejecting each on the basis that his claim were insufficient to overcome AEPDA deference to state court decisions. View "Ellis Louis Mashburn, Jr. v. Commissioner, Alabama Department of Corrections" on Justia Law