Eleventh Circuit revives claims arising from the Miami police's destruction of an "ugly" sailboat

Hoefling v. City of Miami, No. 14-12482 (11th Cir. Jan. 25, 2016). 

James Hoefling lived in his sailboat in the waters around Miami—or he did until the City of Miami police seized and destroyed his sailboat and everything in it. The police claimed the boat was derelict, but according to Hoefling, the Miami police have taken to seizing and destroying boats just because they’re “ugly.” (Hoefling thus has the candor to admit that his boat was ugly.) Since the destruction of his boat, Hoefling says, he has been reduced to a transient lifestyle. 

Hoefling has sued the City of Miami, asserting a number of constitutional claims. The district court dismissed Hoefling’s complaint under what it admitted was a “heightened pleading standard,” ruling that the complaint didn’t state any valid claims. It also credited a police report stating that Hoefling’s boat was derelict, and flatly rejected Hoefling’s assertions that his boat was not, in fact, derelict. 

The district court, says the Eleventh Circuit, erred not only by applying a heightened pleading standard but also by disbelieving Hoefling’s allegations that his boat was not derelict. At this stage, Hoefling’s factual allegations must be taken as true. The case is remanded for the district court to apply the law correctly.