James Michael Hand v. Ron Desantis
946 F.3d 1272
| 11th Cir. | 2020Background
- Plaintiffs: James Hand and eight other convicted felons challenged Florida’s former vote-restoration system, claiming it violated the First and Fourteenth Amendments.
- District court: On cross-motions for summary judgment, it granted plaintiffs relief on Counts One–Three (challenging unfettered discretion and delays) and entered permanent injunctions restraining the Executive Clemency Board and ordering new restoration procedures; Count Four (waiting periods) was denied to plaintiffs.
- State changes: Florida voters amended the state constitution in November 2018 to restore voting rights upon completion of sentence; the legislature revised statutes in July 2019 to implement the new system.
- Effect of changes: After oral argument both parties conceded each plaintiff is now eligible to seek restoration under the new scheme, so no plaintiff needs relief from the former system.
- Eleventh Circuit action: Because the court could no longer provide meaningful relief, it held the case moot, vacated the district-court judgment as to Counts One–Three and the March 27 judgment, declined to vacate its prior stay-panel opinion, and remanded with instructions to dismiss for mootness.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a live controversy exists after state constitutional/statutory changes | Hand argued the prior system violated rights and sought relief (initially contested merits) | Board maintained the appeal, but after changes both parties conceded plaintiffs are eligible under new law | Case is moot because court cannot grant meaningful relief given the new enfranchisement system |
| Whether district-court judgment should be vacated under Munsingwear when case becomes moot on appeal | Hand requested vacatur of the prior stay-panel opinion and sought vacatur consistent with Munsingwear | Board did not prevail on keeping the district judgment intact; court evaluated vacatur remedies | Court vacated the district court’s judgment/orders as to Counts One–Three and the March 27 judgment and remanded to dismiss for mootness |
| Whether the court must vacate its own prior stay-panel order when the case becomes moot | Hand argued the stay-panel order should be vacated like a district judgment under Munsingwear | Board implicitly argued the stay should remain; Eleventh Circuit considered circuit split | Court declined to vacate its prior stay-panel opinion, adopting Fourth Circuit reasoning that stay orders are not final merits adjudications and Munsingwear is inapplicable |
| Standard for mootness / live controversy at appellate stages | Plaintiffs relied on precedent that an actual controversy must exist at all stages | Board relied on changed law; both parties later conceded eligibility under new system | Court applied Supreme Court and Eleventh Circuit mootness doctrine and dismissed for lack of jurisdiction due to mootness |
Key Cases Cited
- Steffel v. Thompson, 415 U.S. 452 (1974) (an actual controversy must exist at all stages of review)
- United States v. Munsingwear, Inc., 340 U.S. 36 (1950) (vacatur of lower-court judgments when cases become moot pending appeal)
- World Wide Supply OU v. Quail Cruises Ship Mgmt., 802 F.3d 1255 (11th Cir. 2015) (if subsequent events preclude meaningful relief, case is moot)
- Ethredge v. Hail, 996 F.2d 1173 (11th Cir. 1993) (vacating district-court judgments on mootness grounds)
- F.T.C. v. Food Town Stores, Inc., 547 F.2d 247 (4th Cir. 1977) (stay orders are not final merits adjudications; declining to apply Munsingwear to stay-panel orders)
- U.S. Bancorp Mortg. Co. v. Bonner Mall P’ship, 513 U.S. 18 (1994) (discussing vacatur of judgments after settlement/mootness)