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

Two individuals, both Mexican nationals who entered the United States without inspection and had resided in the country for several years with U.S. citizen children, were arrested by immigration authorities following traffic stops in Florida. After their arrests, they were placed in removal proceedings and detained without the possibility of a bond hearing under 8 U.S.C. § 1225(b)(2)(A), which the Department of Homeland Security argued required mandatory detention of unadmitted aliens found in the interior of the United States. Each petitioner filed a habeas corpus petition in the United States District Court for the Southern District of Florida, challenging their detention without bond and arguing that they were eligible for bond under § 1226(a) of the Immigration and Nationality Act.The district court concluded that § 1226, not § 1225(b)(2)(A), governed their detention, finding that the petitioners were not “seeking admission” at the time of their arrest, and therefore were entitled to bond hearings. The court did not address their other claims. Following this ruling, both individuals received bond hearings and were released from custody. The government appealed, maintaining that all unadmitted aliens present in the United States are subject to mandatory detention under § 1225(b)(2)(A).The United States Court of Appeals for the Eleventh Circuit held that § 1225(b)(2)(A) does not apply to unadmitted aliens merely present in the country’s interior unless they are actively seeking lawful entry after inspection by an immigration officer. Instead, § 1226 governs the detention of such individuals, making them generally eligible for bond. The court affirmed the district court’s grant of habeas relief, finding no basis in the text, structure, or history of the INA to support the government’s broader reading of § 1225(b)(2)(A). View "Alvarez v. Warden, Federal Detention Center Miami" on Justia Law

A renowned photographer entered into a 2014 agreement with a licensing agency, granting it the exclusive worldwide right to license, market, and promote certain of her images. However, she reserved for herself the right to collaborate with or deliver these images to specific individuals or entities for special projects or other endeavors she deemed of interest. In subsequent years, the photographer took photographs for a magazine under agreements that reserved rights to her studio. The agency discovered that some of these photographs appeared on websites operated by the defendants and sued them for copyright infringement, supplying an authorization letter from the photographer permitting it to act on her behalf in matters relating to copyright infringement.In the United States District Court for the Southern District of Florida, the defendants argued that the agency lacked statutory standing under the Copyright Act because it was not the legal or beneficial owner of an exclusive right under the copyright. The district court agreed, finding that the photographer’s retention of certain rights in the agreement meant the agency did not have an exclusive license, and therefore lacked standing. The court granted summary judgment to the defendants. It also denied the agency’s late motion to amend the complaint to add the photographer as a co-plaintiff.The United States Court of Appeals for the Eleventh Circuit reviewed the case and held that the district court’s analysis was mistaken: the reservation of certain rights by the photographer did not automatically eliminate the agency’s ability to hold other exclusive rights. The appellate court vacated the summary judgment, affirmed the denial of the motion to amend, and remanded for further proceedings, instructing the district court to reconsider the standing issue and the effect of the authorization letter in light of its opinion. View "Great Bowery Inc. v. Consequence Sound LLC" on Justia Law

Roger Tejon subscribed to a video streaming service operated by Zeus Networks, LLC, through its online platform using an Apple device. To register, Tejon chose between an annual or monthly plan by clicking one of two large, red buttons on a “Choose your plan” page. Below these buttons, in small, gray text was a hyperlinked “Terms of Service,” which included a mandatory arbitration clause, but there was no requirement that Tejon click on this link to complete his subscription. Tejon later alleged that Zeus shared his viewing history and personally identifiable information with a social media company without his consent and sued Zeus for violating the Video Privacy Protection Act.Zeus moved to compel arbitration, arguing that Tejon had consented to the arbitration clause by signing up for an account. The United States District Court for the Southern District of Florida denied this motion. The district court found that the terms of service hyperlink was not conspicuous enough to put a reasonably prudent user on inquiry notice of the arbitration provision.The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s denial de novo. The Eleventh Circuit held that the design of Zeus’s subscription page did not provide sufficient inquiry notice of the arbitration agreement to bind Tejon. The court explained that the hyperlink to the terms was small, in gray font, and located beneath prominent action buttons, making it easy to overlook. The court further noted that the page did not explicitly state that clicking the subscription button would bind the user to arbitration. The Eleventh Circuit affirmed the district court’s order denying the motion to compel arbitration. View "Tejon v. Zeus Networks, LLC" on Justia Law

The case involves an individual who orchestrated a scheme in which he recruited travelers to take fully paid trips to Costa Rica, under the guise of participating in an insurance company’s security audit. In reality, these travelers were unknowingly used to smuggle cocaine into the United States inside canned goods labeled as fruits and vegetables. The individual coordinated travel arrangements, provided financial support for trip-related expenses, and ensured the travelers received the cans. The scheme was exposed when one traveler was caught with cocaine at customs and cooperated with authorities, leading to the organizer’s arrest. Further investigation revealed extensive communications and financial transactions related to the drug smuggling operation.After charges were initially dismissed, the same individual resumed similar activities, resulting in additional arrests and a multi-count indictment for cocaine importation, possession, and money laundering. Several co-conspirators, including the individual’s main contact, cooperated with the government. The main contact also paid for the defendant’s legal fees, raising concerns about conflicts of interest. The United States District Court for the Northern District of Georgia oversaw the trial, during which the defendant argued lack of knowledge regarding the cocaine, challenged evidentiary rulings, and objected to the government’s handling of cooperating witnesses.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed multiple claims, including alleged violations of the Sixth Amendment right to counsel, evidentiary errors, improper quashing of subpoenas, incorrect jury instructions, due process violations, and the reasonableness of the sentence imposed. The Eleventh Circuit held that none of the alleged errors warranted reversal. The court found no Sixth Amendment violations, upheld the admission of cell phone evidence, affirmed the quashing of subpoenas for lack of proper foundation, determined that the jury instructions were appropriate, and concluded that the sentence was both procedurally and substantively reasonable. The judgment of the district court was affirmed. View "USA v. Blair" on Justia Law

A political action committee (SMP) created and broadcast a television advertisement during a 2017 Alabama Senate special election. The ad referenced news reports about allegations of sexual misconduct by the Republican nominee. In particular, two key statements appeared in consecutive frames: one stated that the nominee was “banned from the Gadsden Mall . . . for soliciting sex from young girls”; the other noted that “one he approached was 14 and working as Santa’s helper.” The ad ran over 500 times. The nominee, who lost the election, contended that the juxtaposition of these statements created the false and defamatory implication that he had solicited sex from the 14-year-old referenced.In the United States District Court for the Northern District of Alabama, the nominee sued for defamation and false-light invasion of privacy, focusing on the implication created by these two statements together. The case proceeded to a jury trial. The jury found for the plaintiff on both claims and awarded $8.2 million in compensatory damages. The district court denied SMP’s renewed motion for judgment as a matter of law or for a new trial.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed whether there was clear and convincing evidence that SMP acted with “actual malice,” as required under New York Times v. Sullivan, for defamation against a public figure. The court held that, in cases of defamation by implication, the plaintiff must show both that the defendant knew of or recklessly disregarded the falsity of the implication and that the defendant intended to communicate, or recklessly disregarded, the defamatory implication. The court found the evidence insufficient to meet this standard and reversed the district court’s denial of judgment as a matter of law, remanding with instructions to enter judgment for SMP. View "Moore v. Senate Majority PAC" on Justia Law

Two former pilots for a major airline, who also served as reservists in the United States Air Force, brought suit against their employer. They claimed that the airline forced them out of their jobs because of their military service obligations, and that the company’s handling of their pension contributions and vacation accrual during military leave violated the Uniformed Services Employment and Reemployment Rights Act (USERRA). The pilots had been investigated by the airline for abusing military and sick leave policies, including instances where they claimed sick leave from the airline but performed military duties on those days, and for reporting false military obligations to avoid work.The United States District Court for the Northern District of Georgia granted summary judgment to the airline on all claims. The court found that, while the pilots established a prima facie case that their military service was a motivating factor in their resignations, the airline demonstrated legitimate, non-discriminatory reasons for its actions: the pilots’ abuse of sick-leave benefits. Regarding the pension-contribution claim, the district court determined that the pilots’ rates of compensation were not reasonably certain and that the airline’s method of calculating pension contributions during military leave exceeded statutory requirements. For the vacation-time claim, the court held there was no evidence showing that pilots on comparable non-military leave accrued vacation time, as required by USERRA.The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo and affirmed the district court’s grant of summary judgment on all counts. The appellate court held that the airline’s actions were justified by the pilots’ misuse of sick leave, the pension calculations met or exceeded legal obligations, and the vacation accrual policy did not violate USERRA because no comparable leave existed. View "McLean v. Delta Air Lines, Inc." on Justia Law

A seaman who worked aboard a Cayman Islands-flagged yacht suffered a right shoulder injury while helping recover an underwater scooter at the direction of his captain. After the incident, the seaman alleged he was denied pain medication, reassigned to night shifts to hide his injury from guests, and eventually repatriated to his home country without his belongings. He sued the yacht’s beneficial owner, the captain, the vessel’s record owner, his nominal employer, the yacht’s manager, and the insurer, asserting various claims including negligence under the Jones Act, unseaworthiness, failure to provide maintenance and cure, failure to treat, negligence, conversion, and breach of insurance contract.The defendants (except the insurer) removed the case to the United States District Court for the Southern District of Florida under the New York Convention, citing an arbitration provision in the seaman’s employment agreement requiring disputes to be arbitrated in the Cayman Islands. The district court compelled arbitration as to the Jones Act, maintenance and cure, and failure to treat claims against the yacht owner, the beneficial owner, and the employer, but remanded the remaining claims to state court. The insurer later settled.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision compelling arbitration for the Jones Act, maintenance and cure, and failure to treat claims against the nominal employer, and for the maintenance and cure and failure to treat claims against the yacht owner and beneficial owner. However, it reversed the order to the extent it compelled arbitration of the Jones Act claim against the yacht owner and beneficial owner, finding insufficient allegations of concerted misconduct to warrant estoppel. The court dismissed the cross-appeal for lack of jurisdiction as to the remanded claims. The main holding is that arbitration must be compelled for the relevant claims as to the nominal employer, and for maintenance and cure and failure to treat as to the yacht owner and beneficial owner, but not for the Jones Act claim against the latter two. View "Chemaly v. Lampert" on Justia Law

The defendant was indicted for knowingly possessing machinegun conversion devices, which are considered machineguns under federal law. He moved to dismiss the indictment, arguing that the federal prohibition on possessing machineguns violates the Second Amendment when applied to adult citizens without felony convictions. After the district court denied his motion, he pleaded guilty, admitting that he knowingly sold three machinegun conversion devices to an undercover officer. He was sentenced to 24 months in prison and three years of supervised release.The United States District Court for the Southern District of Florida denied the defendant’s motion to dismiss the indictment. The court concluded that machineguns are not in common use, are dangerous and unusual, and thus not protected by the Second Amendment. Alternatively, it found that machinegun conversion devices not attached to a firearm are merely accessories and not “Arms” under the Second Amendment. Following the denial, the defendant pleaded guilty and was sentenced.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed whether the Second Amendment protects possession of machineguns in light of Supreme Court precedent. The Eleventh Circuit applied a de novo standard of review and held that machineguns are not protected by the Second Amendment because they are not weapons typically possessed by law-abiding citizens for lawful purposes and are considered dangerous and unusual. The court also noted the historical and widespread regulation and prohibition of machineguns. The Eleventh Circuit affirmed the defendant’s conviction, holding that the federal machinegun ban is constitutional, including as applied to law-abiding, non-felon adults. The disposition by the Eleventh Circuit was to affirm the conviction. View "USA v. Alsenat" on Justia Law

State officials in Florida constructed an immigration detention facility at the Dade-Collier Training and Transition Airport, located in the Florida Everglades, using state funds and employees. The facility was built on state property and managed by state law enforcement, although federal Immigration and Customs Enforcement (ICE) officials inspected the site and occasionally coordinated the transport and detention of individuals there. The state planned to seek federal reimbursement but had not received any federal funding at the time of the events in question. Several state agencies operated under agreements with the federal government, pursuant to 8 U.S.C. § 1357(g), allowing them to assist with immigration enforcement, but Florida retained control over the facility’s management and construction.The Friends of the Everglades, the Center for Biological Diversity, and the Miccosukee Tribe of Indians of Florida filed suit in the United States District Court for the Southern District of Florida. They alleged violations of the Administrative Procedure Act (APA) and the National Environmental Policy Act (NEPA), claiming that officials failed to conduct a required environmental review before constructing and operating the facility. The district court issued a preliminary injunction halting further construction, requiring removal of certain structures, and prohibiting detention of additional individuals at the site. The court found that the plaintiffs were likely to succeed on the merits, concluding that the construction was a final agency action and a major federal action under NEPA, and that federal officials exercised substantial control over the project.On appeal, the United States Court of Appeals for the Eleventh Circuit held that the plaintiffs failed to demonstrate either a final agency action under the APA or substantial federal control necessary to trigger NEPA, given that Florida constructed and controlled the facility without federal funding or operational authority. The court also found that the district court’s injunction violated a statutory prohibition against enjoining immigration enforcement. The Eleventh Circuit vacated the preliminary injunction and remanded for further proceedings. View "Friends of the Everglades, Inc. v. Secretary of the U.S. Department of Homeland Security" on Justia Law

Two individuals purchased Florida prepaid college tuition savings plans for their daughters in 2004 and 2006. The plans promised to cover tuition at Florida public colleges or transfer an equivalent amount to non-Florida colleges if the beneficiary chose to attend elsewhere. In 2007, the Florida Legislature authorized a new “tuition differential” fee, exempting holders of existing plans from paying that fee at Florida colleges. The Florida Prepaid College Board amended the plan contracts to specify that this new fee was not covered for out-of-state schools. Over a decade later, when both daughters chose to attend out-of-state colleges, the Board declined to transfer an amount equivalent to the tuition differential fee.The purchasers filed a putative class action in the United States District Court for the Southern District of Florida against members of the Board, alleging that the Board’s refusal violated the Contracts and Takings Clauses of the U.S. Constitution. They sought declaratory and injunctive relief to prevent the Board from applying the statutory exemption and contract amendments to beneficiaries attending non-Florida schools. The Board moved to dismiss, arguing it was protected by sovereign immunity. A magistrate judge recommended denying the motion, reasoning the relief sought was prospective. However, the district court disagreed, ruling that the relief requested was essentially a demand for a refund, thus barred by the Eleventh Amendment, and dismissed the complaint with prejudice.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that the suit was barred by sovereign immunity because the relief sought would require specific performance of a contract with the state, which is not permitted under Ex parte Young and related Supreme Court precedent. However, the appellate court vacated the district court’s dismissal with prejudice and remanded with instructions to dismiss without prejudice, as the dismissal was for lack of subject-matter jurisdiction. View "Lavina v. Florida Prepaid College Board" on Justia Law