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

Carey Dale Grayson, an Alabama prisoner, sought a preliminary injunction to halt his scheduled execution by nitrogen hypoxia, arguing that the method violated the Eighth Amendment due to the risk of conscious suffocation and other potential harms. Grayson proposed alternative methods of execution, including nitrogen gas with sedation and a sequential injection of ketamine followed by fentanyl.The United States District Court for the Middle District of Alabama denied Grayson's motion, finding that he did not demonstrate a substantial likelihood of success on the merits of his Eighth Amendment claim. The court held an evidentiary hearing where expert testimonies were presented. The court found that Grayson's evidence was speculative and did not show that the nitrogen hypoxia protocol created an unacceptable risk of pain. The court also found that the proposed alternatives were not feasible or readily implemented.The United States Court of Appeals for the Eleventh Circuit reviewed the district court's decision for abuse of discretion. The appellate court affirmed the district court's denial of the preliminary injunction, agreeing that Grayson failed to show a substantial likelihood of success on the merits. The court noted that the district court's factual findings were not clearly erroneous and that the nitrogen hypoxia protocol had been successfully used in previous executions without evidence of conscious suffocation or other significant issues. The appellate court concluded that the district court did not abuse its discretion in denying the preliminary injunction. View "Grayson v. Commissioner, Alabama Department of Corrections" on Justia Law

Rockwater, Inc., doing business as Peerless Manufacturing Company, sold three peanut-drying trailers and was audited by the IRS, which determined that Rockwater owed excise taxes on these sales. Rockwater paid the taxes, statutory interest, and penalties, then filed a claim for a refund with the IRS. Subsequently, Rockwater filed a lawsuit against the United States for a full refund and attorney’s fees. The United States District Court for the Middle District of Georgia granted summary judgment in favor of Rockwater for the refund of excise taxes, statutory interest, and penalties but denied the request for attorney’s fees. The United States appealed the decision regarding the taxes and statutory interest but not the penalties.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court concluded that the district court erred in determining that Rockwater’s peanut-drying trailers were “off-highway transportation vehicles” exempt from the excise tax. The court found that the trailers were not specially designed for the primary function of transporting peanuts off-highway and that their capability to transport a load over public highways was not substantially limited or impaired. The trailers had standard highway equipment, could travel at road speed limits, and did not require special permits for highway use.The Eleventh Circuit reversed the district court’s grant of summary judgment to Rockwater regarding the excise taxes and statutory interest and remanded with instructions to enter final judgment for the United States for taxes and statutory interest. The court affirmed the district court’s ruling that Rockwater was not required to pay penalties, as the government did not appeal this part of the decision. View "Rockwater, Inc. v. United States" on Justia Law

The case involves a fatal shooting by Deputy Jafet Santiago-Miranda, who fired his weapon into a moving vehicle, killing two young individuals, Angelo Crooms and Sincere Pierce. The plaintiffs, representing the estates of the deceased, claimed that Santiago-Miranda used excessive force, failed to render medical aid, and committed state-law battery. They also raised claims against Deputy Carson Hendren and Sheriff Wayne Ivey. The incident occurred after the deputies pursued a vehicle they believed to be stolen, which then accelerated towards Santiago-Miranda, prompting him to fire his weapon.The United States District Court for the Middle District of Florida granted summary judgment in favor of the defendants. The court dismissed all claims against Hendren with prejudice and ruled that Santiago-Miranda's use of force was constitutionally permissible. The plaintiffs appealed the summary judgment decision regarding Santiago-Miranda and Sheriff Ivey.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's decision. The appellate court held that Santiago-Miranda's use of deadly force was reasonable under the circumstances, as he had probable cause to believe that his life was in danger when the vehicle accelerated towards him. The court also found that the plaintiffs' state law battery claims failed for the same reasons. Additionally, the court affirmed the summary judgment in favor of Sheriff Ivey on the Monell claims, as there was no underlying constitutional violation by Santiago-Miranda. View "Baxter v. Hendren" on Justia Law

MaChelle Joseph, a former head women’s basketball coach at Georgia Tech, and Thomas Crowther, a former art professor at Augusta University, filed separate complaints alleging sex discrimination and retaliation under Title IX and other laws. Joseph claimed that Georgia Tech provided fewer resources to the women’s basketball team compared to the men’s team and retaliated against her for raising these issues. Crowther alleged that he was retaliated against after being accused of sexual harassment and participating in the investigation.The United States District Court for the Northern District of Georgia dismissed Joseph’s Title IX claims, ruling that Title VII precluded them, and granted summary judgment against her remaining claims. For Crowther, the district court denied the motion to dismiss his Title IX claims, allowing them to proceed.The United States Court of Appeals for the Eleventh Circuit reviewed these consolidated appeals. The court held that Title IX does not provide an implied right of action for sex discrimination in employment, reversing the district court’s decision to allow Crowther’s Title IX claims and affirming the dismissal of Joseph’s Title IX claims. The court also ruled that Crowther’s retaliation claim under Title IX, based on his participation in the investigation, did not state a valid claim. Additionally, the court found that Joseph’s claims of sex discrimination under Title VII, based on her association with the women’s team, were not viable. Finally, the court affirmed the summary judgment against Joseph’s retaliation claims under Title VII, Title IX, and the Georgia Whistleblower Act, concluding that she failed to show that the reasons for her termination were pretextual. View "Joseph v. Board of Regents of the University System of Georgia" on Justia Law

On February 11, 2021, Twitter suspended Project Veritas, an investigative journalistic organization, for allegedly violating its policy against publishing private information. Four days later, CNN's Ana Cabrera and Brian Stelter discussed the suspension on-air, with Cabrera suggesting that Twitter banned Veritas for "promoting misinformation." Veritas disputed this characterization, asserting that the suspension was due to a violation of Twitter's "doxxing" policy. When CNN refused to issue a retraction, Veritas sued for defamation.The United States District Court for the Northern District of Georgia granted CNN's motion to dismiss for failure to state a claim, concluding that Cabrera's statements were substantially true under New York defamation law and thus not actionable. The court found that the statements about misinformation were not significantly different in their impact on Veritas's reputation compared to the actual reason for the suspension.The United States Court of Appeals for the Eleventh Circuit reviewed the case and reversed the district court's decision. The appellate court held that Veritas plausibly alleged a defamation claim under New York law, as the statements made by Cabrera were not substantially true and could have a different effect on the audience's perception compared to the actual reason for the suspension. The court also determined that Veritas plausibly alleged that the statements were made with actual malice, as Cabrera had previously tweeted the correct reason for the suspension, indicating knowledge of the true facts.The Eleventh Circuit concluded that the district court erred in dismissing the case and remanded it for further proceedings. The main holding was that Veritas's defamation claim was plausible because the statements were not substantially true and were made with actual malice. View "Project Veritas v. Cable News Network, Inc." on Justia Law

Rodolfo Maisonet was arrested for conspiring to distribute cocaine, a crime subject to a mandatory minimum sentence. He initially cooperated with the government, providing some information about the drug distribution scheme. However, he continued his criminal activities and was caught again. Before sentencing, Maisonet submitted an affidavit with additional information about the conspiracy, but the district court found that he had not fully disclosed all relevant information and imposed the mandatory minimum sentence.The United States District Court for the Northern District of Florida held that Maisonet's lies and ongoing criminal activity made him ineligible for the safety valve provision, which allows for sentencing without regard to mandatory minimums if certain conditions are met. The court also indicated that his affidavit did not provide all necessary information about the drug distribution scheme.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court disagreed with the district court's legal conclusion that Maisonet's continued criminal activity and lies automatically disqualified him from safety valve relief. The statute requires that a defendant provide all information by the time of sentencing, regardless of whether the government already knows the information or if the defendant's cooperation was prompted by a government investigation. However, the appellate court affirmed the district court's factual finding that Maisonet's affidavit did not fully disclose all relevant information about the drug distribution scheme. This factual determination was not clearly erroneous, and thus, the district court's imposition of the mandatory minimum sentence was upheld. View "USA v. Maisonet" on Justia Law

Thomas Swinford was shot and killed by Athens-Clarke County police officers after he refused to drop a gun and instead raised and pointed it at the officers. His widow, Jayne Swinford, filed a lawsuit in Georgia state court alleging claims under 42 U.S.C. § 1983 and Georgia’s wrongful death statute against seven officers, the police chief, and the county government. The case was removed to federal court.The defendants moved to dismiss the complaint on qualified and official immunity grounds, relying on body camera footage showing the events leading up to the shooting. The district court considered the footage and granted the motion to dismiss, finding that the officers acted reasonably and did not violate Thomas’s constitutional rights. The court also denied Mrs. Swinford’s motion to amend her complaint and her motion for reconsideration.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court determined that the district court properly considered the body camera footage under the incorporation-by-reference doctrine. The footage showed that the officers had probable cause to believe Thomas posed a serious threat when he raised his gun at them, justifying their use of deadly force. The court found that the officers did not use excessive force and were entitled to qualified immunity. Consequently, the supervisory liability claim against the police chief and the Monell claim against the county also failed.The Eleventh Circuit affirmed the district court’s orders, including the denial of Mrs. Swinford’s motion to amend her complaint and her motion for reconsideration. View "Swinford v. Santos" on Justia Law

Alfreida Hogan, an African-American woman, was employed by the Department of Veterans Affairs (VA) as a nurse practitioner from July 2012 until March 2019, when she was demoted to staff nurse and subsequently resigned. She alleged that her immediate supervisor harassed her and gave her false, negative performance reviews due to her race, leading to her demotion. In April 2019, Hogan contacted her agency counselor, claiming racial discrimination. On July 3, 2019, the counselor informed her that informal resolution efforts had ended and that she could file a formal administrative complaint. Hogan's counsel claimed to have emailed the complaint on July 19, 2019, but the VA never received it. Hogan's counsel did not follow up until April 2020, when he learned the VA had not received the complaint. The VA dismissed the complaint due to the missed 15-day filing deadline.The district court dismissed Hogan's Title VII claims for race discrimination and retaliation, citing the Eleventh Circuit's decision in Crawford v. Babbitt, which held that failure to exhaust administrative remedies was a jurisdictional bar. The district court concluded it lacked subject-matter jurisdiction due to Hogan's untimely filing of her administrative complaint.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court determined that the 15-day deadline to file a formal administrative complaint, set by EEOC regulation 29 C.F.R. § 1614.106(b), is a claims-processing rule subject to equitable tolling, not a jurisdictional requirement. The court noted that Crawford did not control this case because it involved a different issue. The court also referenced the Supreme Court's decision in Fort Bend County v. Davis, which held that Title VII's charge-filing requirement is not jurisdictional. Despite this, the court affirmed the district court's dismissal, concluding that Hogan did not demonstrate due diligence to warrant equitable tolling of the 15-day deadline. View "Hogan v. Secretary, U.S. Department of Veterans Affairs" on Justia Law

The plaintiffs, co-personal representatives of the estate of Sara Schleider, filed a lawsuit in Florida state court against GVDB Operations, LLC, and JSMGV Management Company, LLC. They alleged that the defendants failed to prevent the spread of COVID-19 at their assisted living facility, resulting in Sara Schleider contracting the virus and subsequently dying. The plaintiffs asserted state-law claims for survival and wrongful death under Florida Statute § 429.28, alleging negligence and, alternatively, willful misconduct or gross negligence.The defendants removed the case to the United States District Court for the Southern District of Florida, claiming federal subject matter jurisdiction on three grounds: acting under a federal officer, complete preemption by the Public Readiness and Emergency Preparedness (PREP) Act, and an embedded federal question concerning the PREP Act. The district court concluded it lacked subject matter jurisdiction and remanded the case to state court, finding that the defendants' arguments did not establish federal jurisdiction.The United States Court of Appeals for the Eleventh Circuit reviewed the district court's decision. The appellate court affirmed the remand, holding that the defendants did not act under a federal officer, as their compliance with federal guidelines did not equate to acting under federal authority. The court also determined that the PREP Act did not completely preempt the plaintiffs' state-law claims, as the Act's willful misconduct provision did not wholly displace state-law causes of action for negligence. Lastly, the court found that the plaintiffs' claims did not raise a substantial federal question under the Grable doctrine, as the federal issues were not necessarily raised by the plaintiffs' well-pleaded complaint. Thus, the district court's remand to state court was affirmed. View "Howard Schleider v. GVDB Operations, LLC" on Justia Law

Jimmy Ray Lightsey was convicted by a jury of possessing a firearm as a felon, possessing with intent to distribute cocaine, cocaine base, and marijuana, and possessing a firearm in furtherance of a drug-trafficking crime. At sentencing, the district court determined that Lightsey was an armed career criminal under the Armed Career Criminal Act (ACCA) and enhanced his sentence accordingly. Lightsey appealed his 240-month sentence, arguing that the district court erred in finding that his prior convictions qualified as predicate offenses under ACCA.The United States District Court for the Middle District of Florida initially reviewed the case. Lightsey was found guilty on all counts by a jury. At sentencing, the district court applied the ACCA enhancement based on Lightsey's prior convictions, including a 1997 conviction for attempted armed robbery and two drug-related convictions from 2000 and 2009. Lightsey objected to the ACCA enhancement, arguing that his prior convictions should not qualify as predicate offenses. The district court overruled his objections, noting that existing case law foreclosed his arguments, and sentenced him to 240 months in prison.The United States Court of Appeals for the Eleventh Circuit reviewed the case. Lightsey contended that his prior drug convictions did not qualify as "serious drug offenses" under ACCA because the definition of cocaine under Florida law was broader than the federal definition at the time of his federal offense. He also argued that his 1997 conviction for attempted armed robbery did not qualify as a "violent felony" under ACCA. The Eleventh Circuit held that Lightsey's drug convictions were properly considered "serious drug offenses" under ACCA, as both state and federal laws criminalized the conduct at the time of his convictions. The court also held that his attempted armed robbery conviction qualified as a "violent felony" under ACCA, following its precedent in United States v. Joyner. Consequently, the Eleventh Circuit affirmed Lightsey's sentence. View "USA v. Lightsey" on Justia Law