Chandler v. Secretary of the Florida Department of Transportation
695 F.3d 1194
11th Cir.2012Background
- Chandlers sued the Florida FDOT, Turnpike Enterprise, and Faneuil under 42 U.S.C. § 1983 for injunctive relief and damages, alleging a policy of detaining motorists until they provided personal information in exchange for release.
- FDOT authorized toll collection; tolls are collected by Faneuil employees at toll stations along the Turnpike.
- Chandlers alleged that delay in release stemmed from completing the Bill Detection Report for large-denomination bills, allegedly forcing motorists to disclose information.
- The district court denied qualified immunity; court held delay implicated Fourth Amendment seizure, despite no explicit criminal conduct by motorists.
- The district court’s reasoning was reversed: the court concluded the factual allegations did not state a plausible Fourth Amendment seizure and defendants had qualified immunity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Chandlers state a Fourth Amendment seizure claim | Chandlers assert detention during Bill Detection Report constitutes seizure | FDOT actions fall within permissible toll-collection regulation | No plausible Fourth Amendment seizure pleaded by Chandlers |
| Whether defendants are entitled to qualified immunity | Defendants violated clearly established rights by detaining motorists | Actions did not violate clearly established law; policy lawful | Defendants entitled to qualified immunity; dismissal appropriate |
| Whether the district court properly denied qualified immunity on Counts II–III | District court correctly found Fourth Amendment violation | No violation; immunity applies | Reversed; district court erred in denying immunity |
Key Cases Cited
- Von Stein v. Brescher, 904 F.2d 572 (11th Cir.1990) (Fourth Amendment seizure/stop context and qualified immunity relevance)
- Long v. Slaton, 508 F.3d 576 (11th Cir.2007) (de novo review of qualified-immunity decisions)
- Twombly, 550 U.S. 544 (U.S. 2007) (pleading standard: plausibility required)
- Iqbal, 556 U.S. 662 (U.S. 2009) (legal conclusions unmasked; plausibility required in pleadings)
- Brendlin v. California, 551 U.S. 249 (U.S. 2007) (definition of seizure; show of authority analysis)