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

An employee at a Miami car dealership filed suit against her employer and its manager, alleging sexual harassment and discrimination. During her four months of employment, she experienced persistent verbal and physical harassment by the manager and other colleagues, which included inappropriate comments, unwanted touching, and suggestions that she use her appearance to sell cars. Unable to endure the harassment, she resigned and brought claims under both Title VII of the Civil Rights Act and the Florida Civil Rights Act.The United States District Court for the Southern District of Florida presided over the trial. The jury found in favor of the plaintiff, awarding her $81,028 in compensatory damages and $750,000 in punitive damages. The defendants moved to reduce the damages, arguing that Title VII capped damages at $50,000 for employers with fewer than 101 employees, and the Florida statute capped punitive damages at $100,000. The court ultimately awarded the plaintiff $181,028—her full compensatory damages plus $100,000 in punitive damages under the Florida statute—reasoning that she was entitled to the larger of the two statutory caps.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The appellate court held that when a jury awards damages for claims under both Title VII and a parallel state law, and the verdict does not allocate damages between the statutes, the plaintiff’s recovery may be up to the sum of the statutory maximums under each law. The court further held that the Title VII $50,000 employee-headcount cap is an affirmative defense, and, because the dealership failed to timely assert it, the defense was waived. The court reversed the district court’s judgment and remanded with instructions to enter judgment for $481,028. View "Khatabi v. Car Auto Holdings LLC" on Justia Law

Two American companies, Declan Flight, Inc. and Right Rudder Aviation, LLC (RRA), developed successful sales and distribution relationships with Pipistrel, a Slovenian aircraft manufacturer, through contracts signed in 2020 and 2021. Their contracts contained forum-selection clauses specifying Slovenia as the forum for disputes. In 2022, Textron, Inc., a large U.S. aerospace company, acquired Pipistrel through its subsidiary Textron eAviation, Inc. Shortly after the acquisition, Textron and eAviation orchestrated the termination of Declan’s and RRA’s contracts. RRA also lost a separate sales contract with Mesa Airlines after Textron and eAviation allegedly interfered with that business relationship.Declan and RRA sued Textron and eAviation in the United States District Court for the Middle District of Florida, alleging tortious interference with the Pipistrel contracts and with the Mesa Airlines contract. The district court dismissed the claims related to the Pipistrel contracts (Counts I and II) for forum non conveniens, holding that the forum-selection clauses could be enforced by Textron and eAviation—nonsignatories—under the federal doctrine of equitable estoppel, thus requiring litigation to proceed in Slovenia. The district court also found that personal jurisdiction existed for the Mesa Airlines claim (Count III), but dismissed it for failure to state a claim.On appeal, the United States Court of Appeals for the Eleventh Circuit reversed the dismissal of Counts I and II. The court held that the applicability of the forum-selection clauses is governed by Slovenian law, not federal common law, and that Slovenian law does not permit nonsignatories to invoke these clauses. Thus, the district court erred in applying the modified forum non conveniens rule from Atlantic Marine. The Eleventh Circuit also reversed the finding of personal jurisdiction over Textron and eAviation as to Count III, remanding all claims for further proceedings. View "Declan Flight, Inc. v. Textron eAviation, Inc." on Justia Law

Two former employees of a large utility holding company, participants in the company’s defined-benefit pension plan, challenged the way their monthly retirement benefits were calculated. Both men, after vesting in the plan, selected joint-and-survivor annuities that would provide payments to their spouses if they died first. The plaintiffs argued that the plan used outdated and unreasonable actuarial assumptions—some based on mortality tables from 1951 or earlier—to determine both the conversion of their accrued single-life annuity benefit to a joint-and-survivor annuity and to calculate charges for mandatory preretirement survivor annuity coverage. They alleged these practices resulted in significantly lower monthly benefits than they would have received if reasonable, current actuarial assumptions had been used.The plaintiffs filed suit in the United States District Court for the Northern District of Georgia, asserting violations of the Employee Retirement Income Security Act of 1974 (ERISA). They claimed the plan failed to provide “actuarial equivalence” between single-life and joint-and-survivor annuities as required by ERISA, and that excessive reductions for preretirement survivor benefits amounted to unlawful forfeiture of accrued benefits. The district court dismissed the complaint for failure to state a claim.On appeal, the United States Court of Appeals for the Eleventh Circuit held that ERISA’s “actuarial equivalence” provision requires plans to use actuarial assumptions that a reasonable actuary would use at the time of benefit determination—not arbitrary or outdated assumptions. The court further held that employers cannot impose preretirement survivor benefit charges that exceed the actual, reasonably calculated cost of providing those benefits. Because the plaintiffs plausibly alleged violations of these standards, the Eleventh Circuit reversed the district court’s dismissal and remanded the case for further proceedings. View "Drummond v. Southern Company Services, Inc." on Justia Law

A police officer in Fort Myers, Florida, observed Jddarrian Irons carrying a distinctive fanny pack and later found a handgun in it after stopping the car he was riding in. Irons, who had a prior felony conviction for attempted carjacking, was indicted for being a felon in possession of a firearm under federal law. He pleaded guilty to the charge.A probation officer prepared a presentence report recommending a base offense level of 20 under §2K2.1(a)(4)(A) of the Sentencing Guidelines, based on Irons’s prior conviction for a crime of violence, and a three-level reduction for acceptance of responsibility. The government, agreeing with most of the report, argued for a four-level enhancement under §2K2.1(b)(6)(B), contending Irons possessed the firearm in connection with the felony offense of carrying a concealed firearm under Florida law. The United States District Court for the Middle District of Florida adopted these recommendations, calculating a total offense level of 21 and imposing a sentence of 46 months in prison and three years of supervised release. The court also imposed special conditions of supervised release, including requirements to obtain a GED and submit to computer searches.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The appellate court affirmed the district court’s calculation of the base offense level, holding that attempted carjacking qualifies as a crime of violence under the relevant Sentencing Guidelines, and that a four-level enhancement was appropriate because the firearm facilitated Irons’s concealed-carry offense. However, the appellate court vacated the conditions of supervised release requiring Irons to obtain his GED and to submit his computer to searches, ruling that these conditions were not properly pronounced at sentencing. The case was remanded for resentencing on those conditions. View "USA v. Irons" on Justia Law

A hotel owner in Georgia faced a lawsuit brought by J.G., who alleged that she suffered injuries from being sex trafficked by third parties at the hotel between 2018 and 2019. The owner was insured under a commercial policy with an insurer, which included both general liability and personal and advertising injury coverage. The policy also contained two relevant endorsements: one excluded coverage for injuries arising from “abuse or molestation,” and the other limited or excluded coverage for injuries resulting from assault or battery offenses.After J.G. filed her lawsuit, the insurer provided the hotel with a defense, subject to a reservation of rights. Subsequently, the insurer initiated a declaratory judgment action in the United States District Court for the Northern District of Georgia, seeking a ruling that it did not owe coverage for J.G.'s claims under the policy. The hotel moved to dismiss the insurer’s complaint, arguing that the duty to indemnify was not ripe because liability had not yet been determined in the underlying action, and that the duty to defend existed because the allegations potentially fell within the policy’s coverage.The District Court evaluated the complaint and concluded that the insurer had a duty to defend the hotel in the underlying action, as the allegations in J.G.’s complaint potentially triggered coverage and the endorsements did not unambiguously bar or limit coverage. However, the court found the request for a declaration regarding the duty to indemnify was not ripe and retained jurisdiction over that issue. The insurer appealed, arguing the district court’s order was immediately appealable as an injunction. The United States Court of Appeals for the Eleventh Circuit held that the order was not final nor did it have the practical effect of an injunction, and therefore dismissed the appeal for lack of jurisdiction. View "Northfield Insurance Co. v. North Brook Industries, Inc." on Justia Law

A woman became unconscious after riding home with her mother, who suspected a drug overdose and called 911. When police officers and emergency medical personnel arrived, the woman regained consciousness but refused medical assistance, adamantly stating she wished to go inside to use the restroom. As she attempted to pass one of the officers, a physical altercation ensued involving four officers. During the struggle, she sustained a fractured arm, resulting in lasting injury. She later sued the officers, alleging unlawful detention and excessive force in violation of her Fourth Amendment rights.The United States District Court for the Northern District of Georgia granted summary judgment for the officers, finding they were entitled to qualified immunity. The court determined that the officers had probable cause to execute a mental-health seizure and that their use of force was objectively reasonable under the circumstances. It also concluded that there was no duty for the other officers to intervene because no excessive force had occurred.The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo. It held that the officers did not violate the woman’s clearly established Fourth Amendment rights. The court found two independent grounds for affirming qualified immunity: first, the officers had an objectively reasonable basis to seize her under the emergency-aid doctrine, as clarified by Case v. Montana, which requires only objective reasonableness and not probable cause in emergency situations; second, they had probable cause to believe she had committed a crime due to suspected GHB possession. The court also held that the force used was not excessive, as it was proportionate and fell within established standards for physical restraint, even though injury resulted. Finally, since no excessive force occurred, the other officers had no obligation to intervene. The Eleventh Circuit affirmed the summary judgment in favor of the officers. View "Marbut v. Phillips" on Justia Law

A man was sitting in the backseat of his vehicle in a shopping center parking lot when sheriff’s deputies approached and asked for identification, suspecting loitering. The man repeatedly questioned the request, moved to the driver’s seat without complying, and started the vehicle. He drove away after deputies drew their weapons and commanded him to stop, nearly striking one deputy. The deputies pursued him, during which he drove through stop signs and on the wrong side of the road. A pursuit intervention technique caused his vehicle to spin and become pinned between police cars. Despite being boxed in, the man continued to press the accelerator, causing his tires to squeal and the car to push against a deputy’s vehicle. At this point, a deputy fired one shot, hitting the man in the eye. The man was then removed from the vehicle, handcuffed on the ground, and a deputy briefly placed a knee on his back.The United States District Court for the Northern District of Georgia granted summary judgment to the sheriff and deputies. It found that the shooting was a reasonable use of force in response to the perceived threat and that no clearly established law made the force unconstitutional. It held that the force used to arrest the man after the shooting was de minimis and not excessive. The court also determined the sheriff was entitled to sovereign immunity and the deputies to official immunity on state law claims because there was no showing of malice.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s judgment. It held that the deputies did not violate the man’s constitutional rights or act with malice, and that the sheriff was immune from suit. The court found the shooting objectively reasonable under the circumstances, the force used during the arrest minimal, and no duty for a deputy to intervene. It also affirmed immunity for state law claims. View "Bolton v. Sheriff of Coweta County" on Justia Law

T-Mobile South, a wireless service provider, applied for a permit to construct a 108-foot cell phone tower on vacant residential property in Roswell, Georgia. The City of Roswell denied the application based on its zoning ordinance, which required permits for new wireless facilities and allowed decision-makers to consider several factors. T-Mobile then sued, claiming the denial both prevented it from filling a service coverage gap and discriminated among service providers. The company sought an injunction compelling Roswell to issue the permit.Proceedings in the United States District Court for the Northern District of Georgia resulted in an initial grant of summary judgment for T-Mobile, which was reversed by the United States Court of Appeals for the Eleventh Circuit. The Supreme Court also reviewed the case and remanded it. On remand, the district court ultimately ruled in favor of T-Mobile after a bench trial, applying the “significant gap” test: it found T-Mobile had a significant gap in service that only the proposed tower would remedy and ordered Roswell to approve the necessary permits.The United States Court of Appeals for the Eleventh Circuit reviewed whether the “effective prohibition” provision of the Telecommunications Act of 1996 applies to a single permit denial. The court held that the statutory prohibition on local “regulation” that “prohibits or has the effect of prohibiting” wireless service applies to general rules or regulations, not to individual zoning decisions or permit denials. The Eleventh Circuit vacated the district court’s judgment and remanded the case for further proceedings under the correct legal standard, concluding that T-Mobile must challenge the city’s rules themselves, not individual permit denials, to invoke the effective prohibition clause. View "T-Mobile South, LLC v. City of Roswell, Georgia" on Justia Law

After a boat owned by Bryan and Bethea Crabtree was severely damaged by fire while in storage in Florida, the Crabtrees sought coverage under their insurance policy with Great Lakes Insurance. Great Lakes denied their claim, alleging noncompliance with policy conditions, and subsequently filed a declaratory judgment action against the Crabtrees in the United States District Court for the District of Montana, based on the policy’s forum-selection clause and the Crabtrees’ Montana address.The parties agreed that Great Lakes would voluntarily dismiss the Montana case and refile in the United States District Court for the Southern District of Florida (SDFL), with the understanding that the Crabtrees would not contest jurisdiction or venue. Great Lakes dismissed the Montana action and refiled in SDFL. In response, the Crabtrees initiated a state court action and moved to stay or dismiss the SDFL federal suit. Instead of opposing the motion, Great Lakes voluntarily dismissed the SDFL suit as well. That same day, Great Lakes refiled a third action in Montana, which was later transferred back to SDFL at the Crabtrees’ request and with Great Lakes’s consent.Upon return to SDFL, the United States District Court for the Southern District of Florida considered whether, under Federal Rule of Civil Procedure 41(a)(1)(B), Great Lakes’s second voluntary dismissal barred further litigation of the same claim. The court granted summary judgment for the Crabtrees, holding that Rule 41(a)(1)(B) means what it says: a second voluntary dismissal acts as an adjudication on the merits, i.e., a dismissal with prejudice, even if the first dismissal was by agreement. The United States Court of Appeals for the Eleventh Circuit affirmed, concluding that Great Lakes was precluded from relitigating its claim in SDFL. View "Great Lakes Insurance SE v. Crabtree" on Justia Law

A three-year-old child, L.W., who has a rare metabolic condition that can cause life-threatening hypoglycemia, moved from Virginia to Georgia. In Virginia, he had received 96 hours per week of care through Medicaid, including private nursing and support provided by his mother. After his family relocated to Georgia, L.W.'s mother applied for comparable nursing services under the Georgia Pediatric Program (GAPP), but the state approved only 21 hours per week. Requests for increased hours were denied by the state’s contractor, Alliant Health Solutions, which relied on a policy requiring evidence of a change in medical condition to justify increasing hours. L.W.’s family and physician argued that the approved hours were insufficient and unsustainable, risking L.W.’s health and placing heavy burdens on his parents.The United States District Court for the Northern District of Georgia reviewed the case after L.W.’s mother filed suit under 42 U.S.C. § 1983, alleging that Georgia’s Medicaid program was failing to provide services required by federal law. The court found that 21 hours of nursing care per week was insufficient to meet L.W.'s medical needs, based on evidence from his mother and physician. It granted a preliminary injunction requiring Georgia to provide at least 100 hours of private nursing care per week and to evaluate future requests under the correct legal standard, without requiring a bond from the plaintiffs.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s order. It held that, regardless of the reasonableness of the state’s general policy, Georgia Medicaid must provide care sufficient to correct or ameliorate an individual patient’s medical condition as required by federal law. The Eleventh Circuit concluded that the district court did not clearly err in its factual findings, and that the injunction was proper under the applicable legal standards. View "L.W. v. Commissioner of the Georgia Department of Community Health" on Justia Law