Justia U.S. 11th Circuit Court of Appeals Opinion Summaries

Investors in a major energy company alleged that the company and several executives misled them about involvement in a Florida election-interference scheme. The alleged scheme included tactics such as supporting “ghost” candidates in state and local elections, bribery, covert payments, and manipulating media outlets. These actions were reportedly orchestrated by the company’s main subsidiary and its CEO, with assistance from a political consulting firm. When reports of the scheme began to surface, the company and its executives publicly denied any involvement or wrongdoing, including direct statements to the press and investors. However, after further scrutiny and media coverage, the company’s leadership changed course, abruptly terminating the subsidiary’s CEO and filing updated risk disclosures with the Securities and Exchange Commission (SEC) that acknowledged potential legal and reputational risks associated with the allegations. On the same day as these disclosures, the company’s stock price fell sharply, resulting in significant losses for investors.Previously, the United States District Court for the Southern District of Florida dismissed the investors’ complaint, concluding that the plaintiffs failed to adequately plead loss causation—a necessary element of securities fraud. The District Court found that the investors did not identify a sufficient corrective disclosure linking the alleged fraud to the stock price decline.The United States Court of Appeals for the Eleventh Circuit reviewed the case and disagreed with the District Court. The Eleventh Circuit held that the plaintiffs plausibly alleged loss causation by identifying corrective disclosures—namely, the company’s risk disclosures, the CEO’s abrupt departure, and a unique compensation claw-back provision—that collectively revealed enough truth to the market to undermine prior denials. The court found the alleged sequence of disclosures, price drop, and market analyst reactions sufficient at the pleading stage. The Eleventh Circuit reversed the District Court’s dismissal and remanded for further proceedings. View "City of Hollywood Police Officers Retirement Syst v. NextEra Energy, Inc." on Justia Law

Donald J. Trump filed a lawsuit in the United States District Court for the Southern District of Florida against dozens of defendants, including Hillary Clinton, the Democratic National Committee, several law firms, and individuals, alleging that they conspired to spread false claims of his collusion with Russia during the 2016 presidential campaign. Trump asserted multiple claims, including two under the Racketeer Influenced and Corrupt Organizations Act (RICO) and three under Florida law, such as injurious falsehood and conspiracy to commit malicious prosecution. He alleged that these actions caused him substantial financial harm and loss of business opportunities.After extensive pleadings, the district court dismissed Trump’s amended complaint with prejudice, holding that his federal racketeering claims were untimely and legally insufficient, and that his state law claims either failed to state a claim or were also untimely. The court found the complaint to be a “shotgun pleading” and cited numerous factual inaccuracies and implausible legal theories. The court also dismissed claims against certain defendants for lack of personal jurisdiction, but did so with prejudice. Subsequently, the district court imposed sanctions on Trump and his attorneys for filing frivolous claims and pleadings, based both on its inherent authority and Rule 11, and denied Trump’s motions for reconsideration and to disqualify the judge.Upon appeal, the United States Court of Appeals for the Eleventh Circuit affirmed most of the district court’s orders. The appellate court held that Trump’s racketeering claims were untimely and meritless, and that his state law claims failed for both procedural and substantive reasons. However, the Eleventh Circuit found that the district court lacked personal jurisdiction over one defendant, Orbis, and therefore vacated the dismissal with prejudice as to Orbis, remanding with instructions to dismiss those claims without prejudice. The sanctions orders and other rulings were affirmed, and requests for appellate sanctions were denied. View "Trump v. Clinton" on Justia Law

A nurse practitioner working in Georgia became involved in a nationwide Medicare fraud scheme between 2018 and 2019. She took part-time telemedicine jobs and reviewed patient charts for durable medical equipment (DME) prescriptions, such as neck and knee braces. The scheme involved submitting thousands of DME orders to Medicare for patients who had not actually been examined or treated as required by law. Federal investigators discovered she was signing orders, attesting to patient assessments and medical necessity, despite never contacting or examining the patients. Several orders were found to be fraudulent, such as prescribing braces to deceased or bedridden patients, or to patients with amputated limbs. She received compensation per chart reviewed, and her records indicated knowledge of the fraudulent nature of the activity.The United States District Court for the Southern District of Georgia presided over her trial, where she was charged with conspiracy, health care fraud, making false statements, aggravated identity theft, and related offenses. The jury found her guilty on sixteen counts but acquitted her of conspiracy to commit health care fraud. At sentencing, the district court applied a two-level enhancement for obstruction of justice based on perjury, citing her false testimony and inconsistencies. Her motion for a new trial was denied as untimely; the court rejected her claim of excusable neglect due to her attorney’s actions.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed four main issues: sufficiency of evidence, the lack of a deliberate ignorance jury instruction, the sentencing enhancement for perjury, and the denial of her new trial motion. The appellate court found sufficient evidence for all convictions, held that the absence of the deliberate ignorance instruction did not prejudice her substantial rights, affirmed the obstruction of justice enhancement, and found no abuse of discretion in the denial of the new trial motion. The Eleventh Circuit affirmed her convictions and sentence. View "USA v. Beaufils" on Justia Law

The case involves a Florida-based title insurer that suffered significant financial setbacks, prompting a series of business restructurings and asset transfers. In 2009, the company entered a joint venture with another title insurance group, forming a new entity to handle certain business functions. Over subsequent years, the original company retained substantial assets and continued operations, but further financial decline led to a 2015 agreement in which it transferred assets and liabilities to its business partner, in exchange for the assumption of its policy liabilities. The Florida insurance regulator scrutinized and ultimately approved the transaction after requiring additional commitments from the acquiring party.The United States Bankruptcy Court for the Middle District of Florida later oversaw the company’s Chapter 11 proceedings. The appointed Creditor Trustee brought an adversary proceeding against the acquiring parties and related entities, alleging that the asset transfer constituted a fraudulent transfer under federal bankruptcy law and Florida statutes, and sought to impose successor liability and alter ego claims. The bankruptcy court held a bench trial, excluding portions of the Trustee’s expert valuation as unreliable, and found that the company had received reasonably equivalent value in the transaction. The court also rejected the successor liability and alter ego theories, finding insufficient evidence of continuity of ownership, improper purpose, or harm to creditors.The United States District Court for the Middle District of Florida affirmed the bankruptcy court’s rulings. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the record and affirmed the district court’s order. The Eleventh Circuit held that the bankruptcy court did not err in excluding the Trustee’s expert, that the asset transfer was for reasonably equivalent value and not fraudulent, and that the successor liability and alter ego claims failed for lack of evidence and legal sufficiency. View "Stermer v. Old Republic National Title Insurance Company" on Justia Law

Cheriese Johnson began experiencing a range of symptoms, including coughing and pain in her hands and feet, prior to her employment in July 2016 with The William Carter Company. She purchased a long-term disability insurance policy from Reliance Standard that became effective in October 2016. During the three months before her coverage began, Johnson sought medical care for various symptoms and received several diagnoses, but not scleroderma. In early 2017, after her policy was active, she was diagnosed with scleroderma—a rare autoimmune disease—following a lung biopsy. Johnson then filed a claim for long-term disability benefits, which Reliance Standard denied, arguing her disability was caused by a preexisting condition for which she had received treatment during the policy’s lookback period.After her claim was denied and her appeal was unsuccessful, Johnson sued Reliance Standard in the United States District Court for the Northern District of Georgia under the Employee Retirement Income Security Act (ERISA). She moved for judgment on the administrative record, while Reliance Standard sought summary judgment. The district court granted summary judgment to Reliance Standard, finding its decision to deny benefits was correct under the terms of the policy.On appeal, the United States Court of Appeals for the Eleventh Circuit reversed the district court’s judgment. Applying ERISA’s interpretive framework and reviewing the plan administrator’s decision de novo, the Eleventh Circuit held that Reliance Standard’s interpretation of the policy was both incorrect and unreasonable. The court concluded that Johnson had not received medical treatment “for” scleroderma during the lookback period because neither she nor her doctors suspected or intended to treat that specific condition at that time. The court found that Reliance Standard’s interpretation was arbitrary and capricious, and remanded for further proceedings consistent with its opinion. View "Johnson v. Reliance Standard Life Insurance Company" on Justia Law

An individual incarcerated in a county jail in Alabama died after several months in custody, during which his mother, acting as administrator of his estate, alleges he was denied adequate medical care. The county jail had contracted with a private company, Preemptive Forensic Health Solutions, to provide all inmate medical care, even though the company employed no physicians and was allegedly incompetent. Prior to the decedent's death, multiple inmates had died under this company's care, and concerns about inadequate medical treatment became a significant issue in a local sheriff’s election. Despite these concerns and the new sheriff’s efforts to terminate the contract, the county continued and even renewed the agreement with the company, retaining exclusive control over its continuation.The United States District Court for the Northern District of Alabama granted summary judgment to the county, holding that Alabama law limited the county's role to funding inmate healthcare, not providing it, and thus precluded liability under 42 U.S.C. § 1983. The district court determined that only the sheriff was responsible for administering medical care in the jail and that the county had fulfilled its statutory duty by paying for services.The United States Court of Appeals for the Eleventh Circuit reversed this decision. The appellate court held that, under Monell v. Department of Social Services of City of New York and Ancata v. Prison Health Services, Inc., a county can be liable under § 1983 if it adopts or maintains a policy or custom that results in deliberate indifference to inmates' constitutional rights. The court found sufficient evidence for a jury to conclude that the county’s policy of contracting with an incompetent provider—and preventing the sheriff from changing it—could have caused the decedent’s Eighth Amendment violation. The court ruled that Alabama law does not bar such liability and remanded the case for further proceedings. View "Smothers v. Childers" on Justia Law

Jason Starr, following a contentious divorce from his ex-wife Sara Starr, was required to pay substantial monthly support and other financial obligations. Evidence showed Jason was deeply frustrated by these requirements and expressed anger in personal writings. After Sara moved out, she confided to a friend that she feared Jason would kill her. Prior to the murder, Jason suggested to a friend that his brother Darin could “take care of” marital problems for a fee. Darin, living in Texas, purchased a motorcycle with Jason’s financial assistance and received additional payments from Jason through a third party. Cell-site data and witness testimony placed Darin near Sara’s Alabama residence in the days leading up to her murder. Sara was shot and killed outside her home, and surveillance footage showed a motorcycle leaving the scene shortly after. Darin returned to Texas the same day. Later, while in jail for an unrelated offense, Darin made statements implying Jason owed him a significant favor.A federal grand jury in the United States District Court for the Middle District of Alabama indicted Jason and Darin Starr for using interstate commerce facilities in the commission of a murder-for-hire, in violation of 18 U.S.C. § 1958. At trial, the government presented circumstantial evidence linking both brothers to the crime. The jury convicted both Jason and Darin, and the district court imposed mandatory life sentences.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed claims that the district court erred by excluding alternate perpetrator evidence, admitting certain hearsay and investigative testimony, and that the evidence was insufficient to support conviction. The Eleventh Circuit held that the district court properly excluded speculative alternate perpetrator evidence, correctly admitted the challenged statements under evidentiary rules, and found the evidence sufficient for conviction. The court affirmed both convictions and sentences. View "USA v. Starr" on Justia Law

A provider of air ambulance services transported a patient insured by a health maintenance organization, but the provider was not part of the insurer’s network. After the transport, the provider and insurer could not agree on the payment amount. The dispute was submitted to the Independent Dispute Resolution (IDR) process established by the federal No Surprises Act, which requires each party to submit a payment offer and supporting rationale to an arbitrator. The arbitrator, a certified IDR entity, selected the insurer’s lower payment offer. The provider alleged that the insurer had misrepresented its “Qualifying Payment Amount” (QPA) by submitting a lower QPA to the arbitrator than it had previously provided to the provider, and claimed this constituted fraud.The United States District Court for the Middle District of Florida dismissed the provider’s complaint, finding that judicial review of IDR awards is limited to the grounds set forth in the Federal Arbitration Act (FAA), and that the provider’s allegations did not meet the heightened pleading requirements for fraud. The court also dismissed the arbitrator from the case with prejudice, holding that the No Surprises Act does not create a cause of action against IDR entities.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s dismissal. The Eleventh Circuit held that the No Surprises Act incorporates the FAA’s limited grounds for vacating arbitration awards and that the provider failed to adequately plead fraud or undue means under those standards. The court also found that the arbitrator did not exceed its authority and that it was not necessary to name the arbitrator as a defendant to challenge the award. The judgment of the district court was affirmed in full. View "REACH Air Medical Services LLC v. Kaiser Foundation Health Plan Inc." on Justia Law

Two inmates at Smith State Prison in Georgia, Miguel Jackson and Kelvin Stevenson, were involved in a prison riot on December 31, 2010, after officers discovered contraband in Jackson’s cell. The officers alleged that Jackson and Stevenson assaulted them, leading to both inmates being handcuffed and escorted away. Jackson and Stevenson claimed that, after being restrained, they were severely beaten by correctional officers. They filed suit in the United States District Court for the Southern District of Georgia against thirty-nine officers, asserting claims of excessive force and failure to intervene under the Eighth Amendment.Over the course of more than a decade, the plaintiffs voluntarily dismissed many defendants, and the district court granted partial summary judgment, leaving nine officers as defendants by the time of trial. Just before jury selection, plaintiffs moved to dismiss seven more defendants under Federal Rule of Civil Procedure 41(a)(2), which the district court granted, entering judgment in favor of those defendants and reserving the issue of costs and sanctions. The case proceeded to trial against Officers Catanzariti and Harrison. The jury found for Catanzariti on Jackson’s excessive force claim but found he failed to intervene when other officers used excessive force, awarding Jackson $1.00 in damages. Stevenson’s claims against both officers were rejected.On appeal to the United States Court of Appeals for the Eleventh Circuit, the plaintiffs challenged the district court’s grant of their Rule 41 motion and several evidentiary rulings. The Eleventh Circuit held that the district court did not abuse its discretion in granting the partial dismissal and entering judgment for the seven defendants, nor in admitting the challenged evidence. The court affirmed the district court’s final judgments. View "Jackson v. Catanzariti" on Justia Law

Two Saudi Arabian companies, Al Rushaid Petroleum Investment Company and Al Rushaid Trading Company, specialized in helping foreign manufacturers access the Saudi oil and gas market. Over several decades, they entered into various agreements with Dresser-Rand Group (DRG), including exclusive sales representation and joint venture contracts related to the sale and servicing of DRG products in Saudi Arabia. In 2014, Siemens Energy announced its acquisition of DRG, which was completed in 2015. After the acquisition, Al Rushaid alleged that Siemens excluded them from contracts and joint venture benefits, misused proprietary information, and diverted business opportunities.The United States District Court for the Middle District of Florida first dismissed Al Rushaid’s original complaint as an impermissible shotgun pleading but allowed amendment. Al Rushaid then filed an amended complaint asserting claims for tortious interference, unfair competition, and unjust enrichment. The district court dismissed all claims without prejudice, finding that Siemens was not a stranger to the relevant business relationships due to its ownership of DRG, that the unfair competition claim was improperly pleaded and lacked necessary elements, and that the unjust enrichment claim failed to meet pleading standards.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s dismissal de novo. The Eleventh Circuit affirmed the district court’s judgment in all respects. The court held that Siemens, as owner of DRG, was not a stranger to the contracts or business relationships under Florida law, defeating the tortious interference claims. The unfair competition claim was dismissed as a shotgun pleading and for failure to allege required elements. The unjust enrichment claim was dismissed for lack of clarity and because express contracts governed the subject matter. The district court’s dismissal of all claims without prejudice was affirmed. View "Al Rushaid Petroleum Investment Company v. Siemens Energy Incorporated" on Justia Law