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

Three individuals were detected by U.S. authorities aboard a “go-fast” vessel approximately 158 nautical miles southeast of Isla Beata, Dominican Republic. During the encounter, the men were seen discarding packages, later recovered as cocaine. The Coast Guard boarded the vessel, whose master claimed Colombian nationality, but Colombian authorities would not confirm or deny the vessel’s registration. As a result, U.S. authorities deemed the vessel “stateless” and seized approximately 375 kilograms of cocaine. The men were arrested and charged under the Maritime Drug Law Enforcement Act (MDLEA) with conspiracy to possess with intent to distribute cocaine while onboard a vessel subject to U.S. jurisdiction.The United States District Court for the Southern District of Florida denied the defendants’ joint motion to dismiss the indictment. The court relied on Eleventh Circuit precedent upholding the constitutionality of the MDLEA, specifically regarding Congress’s ability to assert jurisdiction over stateless vessels on the high seas under the protective principle of international law. After the motion was denied, all three defendants pleaded guilty. At sentencing, the district court imposed varying terms of imprisonment and supervised release, granting some downward variances but denying a minor-role reduction to one defendant, who raised the issue on appeal.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court’s rulings. The appellate court held that binding circuit precedent forecloses constitutional challenges to the MDLEA, including claims based on the Felonies Clause, the lack of a nexus to the United States, and the statute’s definition of “stateless vessel.” The court also held that recent amendments to the Sentencing Guidelines regarding minor-role reductions were substantive and not retroactively applicable. The district court’s denial of a minor-role reduction and all other challenged rulings were affirmed. View "USA v. Martinez" on Justia Law

The case involves a business arrangement among AE OpCo, AAR, and Short Brothers, centered on a procurement contract. AAR’s subsidiary manufactured airline parts for Short Brothers, and AAR guaranteed its subsidiary’s performance. When AE OpCo acquired AAR’s business, it assumed the obligation to perform under the contract, while AAR guaranteed AE OpCo’s performance to Short Brothers. In turn, AE OpCo agreed to indemnify AAR if AE OpCo defaulted. Later, AE OpCo filed for bankruptcy and rejected the procurement contract, prompting both Short Brothers and AAR to file claims in the bankruptcy proceeding.The United States Bankruptcy Court for the Middle District of Florida considered three claims from AAR: an indemnification claim for potential liability to Short Brothers, a defense-costs claim for legal fees incurred in ongoing litigation with Short Brothers in Northern Ireland, and a bankruptcy-costs claim for attorneys’ fees incurred in the bankruptcy proceedings. The bankruptcy court disallowed the indemnification claim as contingent and barred by 11 U.S.C. § 502(e)(1)(B), allowed the defense-costs claim as a fixed, non-contingent claim, and disallowed the bankruptcy-costs claim as a post-petition unsecured claim.On direct appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the bankruptcy court’s disallowance of the indemnification claim, holding that under Delaware law, the settlement between AE OpCo and Short Brothers did not release AE OpCo’s liability, so AAR remained co-liable and the claim was properly disallowed under § 502(e)(1)(B). The appellate court also affirmed the allowance of the defense-costs claim, finding it was not contingent since all events giving rise to liability had occurred. However, the court reversed the disallowance of the bankruptcy-costs claim, holding that neither § 502(b) nor § 506(b) barred allowance of such a claim, and remanded for further proceedings. View "AE OPCO III, LLC v. AAR CORP." on Justia Law

A sign operator installed two advertising signs near Interstate 85 in Atlanta in 1993, after obtaining permits under the city’s 1982 sign code. These permits were renewed several times. In 2015, after the Supreme Court’s decision in Reed v. Town of Gilbert, the city amended its sign code, removing several content-based provisions but allowing lawful, nonconforming signs to remain. When the sign operator later sought to upgrade the signs, the city approved the changes, but private parties challenged the decision. The Superior Court of Fulton County found that the original permits were unlawful under the 1982 code, making the signs illegal. The city then ordered removal of the signs and issued citations when the order was not followed.The sign operator, joined by the property owner and its president, sued the City of Atlanta in the United States District Court for the Northern District of Georgia, seeking a declaration that the 1982 sign code was unconstitutional under the First Amendment and seeking to enjoin its enforcement. The district court initially dismissed some claims for lack of jurisdiction, then reconsidered and ruled in favor of the plaintiffs, concluding that the code was content-based and subject to strict scrutiny, which the city had not attempted to satisfy.On appeal, the United States Court of Appeals for the Eleventh Circuit held that the plaintiffs only had standing to challenge the provision of the 1982 code that applied to their signs—section 16-28.019(7)—rather than the entire code. The court further held that this provision, which distinguished between on-premises and off-premises signs, was content-neutral under the Supreme Court’s decision in City of Austin v. Reagan National Advertising of Austin, LLC. The Eleventh Circuit vacated the district court’s judgment and injunction and remanded for further proceedings to determine whether the provision meets the applicable intermediate scrutiny standard. View "Anderson v. City of Atlanta, Georgia" on Justia Law

A group of three major construction firms formed a joint venture to undertake Florida’s largest infrastructure project: the reconstruction and expansion of a major interstate. The venture’s contractual and financial structure was complicated, involving a public-private partnership in which a concessionaire entity financed the project, hired the joint venture to perform the actual construction, and would gain long-term maintenance rights. One member of the joint venture, aware of mounting losses, proposed a strategy for the venture to attempt to exit the project or use the threat of termination as leverage in negotiations. This strategy relied on a contested interpretation of the contract and was opposed by the other members, who considered it dangerously speculative and likely to cause greater harm.As losses increased, the dissenting member stopped contributing required capital to the joint venture, accusing the managing partner of breaching its fiduciary duties by refusing to pursue the proposed termination strategy, and alleging a conflict of interest due to overlapping ownership between the managing partner and the concessionaire. The other members responded by contributing additional funds to keep the project solvent and countersued for breach of contract and indemnity.The United States District Court for the Middle District of Florida held a bench trial and found that the managing partner had not breached any fiduciary duty or acted with gross negligence. The court also found that the dissenting member had materially breached the joint venture agreement by refusing to pay its share of capital calls, and ordered it to reimburse the other members, including prejudgment interest and attorneys’ fees.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed. The court held that the managing partner had acted in the best interest of the joint venture by not pursuing the proposed termination, and that there was no actionable conflict of interest under Florida partnership law. The court also concluded that the dissenting member’s failure to fund was a material breach, entitling the other members to indemnification and statutory prejudgment interest. View "The Lane Construction Corporation v. Skanska USA Civil Southeast, Inc." on Justia Law

A prisoner at Phillips State Prison in Georgia stabbed a high-ranking member of the Bloods gang and, for his protection, was placed in protective custody and then transferred to Baldwin State Prison. The transfer request referenced the risk from the gang member he had assaulted. Upon arrival at Baldwin, the prisoner was placed in the general population rather than protective custody. There, after a brief period, he was stabbed to death by another inmate associated with the Bloods gang. The prisoner’s parents and estate brought claims against five Georgia Department of Corrections officials, alleging violations of the Eighth Amendment based on deliberate indifference to the risk the prisoner faced.The United States District Court for the Middle District of Georgia dismissed some claims as time-barred and, on summary judgment, found that all defendants were entitled to qualified immunity. The district court concluded that none of the officials had violated clearly established law or demonstrated the subjective awareness required for Eighth Amendment liability under claims of deliberate indifference.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed whether the district court correctly applied the standard for deliberate indifference, as clarified in Wade v. McDade and Farmer v. Brennan. The Eleventh Circuit held that, while the risk to the prisoner was objectively serious, none of the defendants possessed the necessary subjective knowledge that their own conduct placed the prisoner at substantial risk of serious harm. The court emphasized that deliberate indifference requires actual, specific knowledge of the risk and a disregard of that risk. As a result, the Eleventh Circuit affirmed the district court’s grant of qualified immunity to all defendants and upheld the dismissal of the claims. View "McClinton v. Warden" on Justia Law

Spirit Airlines sold tickets to customers and collected a government-mandated security fee at the time of purchase. When customers canceled their tickets, Spirit deducted a cancellation fee and, if any value remained, issued a travel credit that expired after 60 days. If a customer did not use the credit before it expired, Spirit retained the full value—including the security fee—as revenue. Spirit either did not remit the security fee from these unused credits to the Transportation Security Administration (TSA), or, if the fee had already been remitted, offset it against future payments.The U.S. Customs and Border Protection audited Spirit and determined that it had “under-remitted” security fees by retaining those attributable to expired credits. TSA adopted these findings, concluding that Spirit owed nearly $2.8 million. Spirit sought administrative review, arguing that it was not required to remit fees for customers who did not travel, as such individuals were not “passengers” under the statute. Alternatively, Spirit asserted it had effectively refunded the fees through credits and offsets. TSA rejected these arguments, finding that the statutory scheme required remittance of all fees collected unless they were actually refunded to the customer, and that expired credits did not constitute refunds.The United States Court of Appeals for the Eleventh Circuit reviewed TSA’s decision, applying de novo review to questions of law and upholding factual findings if supported by substantial evidence. The court held that the statute required airlines to remit all security fees collected, regardless of whether the customer traveled, unless the fee was actually refunded. The court also found that TSA’s guidance gave Spirit fair notice of its obligations. The Eleventh Circuit denied Spirit’s petition for review, affirming TSA’s decision. View "Spirit Airlines, LLC v. Transportation Security Administration" on Justia Law

DISH Network L.L.C. held exclusive rights to broadcast certain Arabic-language television channels in the United States, secured through written agreements with foreign content producers. The defendants operated businesses that provided U.S. customers with unauthorized access to these channels through internet streaming devices and services, bypassing DISH’s authorization and payments. The defendants’ services relied on content delivery networks and encoders to capture, transcode, and transmit live broadcasts of the protected channels to their customers in the U.S.The United States District Court for the Middle District of Florida first considered cross-motions for summary judgment. It granted summary judgment for DISH regarding its ownership of valid copyrights but found factual disputes about infringement, leading to a bench trial. After trial, the district court ruled in favor of DISH, finding that the defendants' use of both content delivery networks and encoders constituted direct copyright infringement. The court awarded DISH a permanent injunction, $600,000 in statutory damages, attorney fees, and costs.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s legal conclusions de novo and factual findings for clear error. The appellate court rejected all arguments by the defendants, including challenges to DISH’s ownership, the validity and transfer of the copyrights, and several evidentiary rulings. The court specifically found that the audiovisual works at issue were “Collective Works” under UAE law, supporting MBC’s initial ownership, and that the transfer of rights to DISH was uncontested by the original owner. The Eleventh Circuit held that sufficient evidence showed the defendants directly infringed DISH’s exclusive rights by operating encoders, and affirmed the district court’s judgment in all respects. View "Dish Network L.L.C. v. Fraifer" on Justia Law

The case centers on Kenny Faulk, a Black man, who was conditionally offered a sales position by Dimerco Express USA, a transportation company. The offer was rescinded after the company’s president learned of Faulk’s race, despite Faulk successfully passing a background check that revealed only a prior misdemeanor conviction. Internal communications and testimony showed that Dimerco’s leadership, particularly its president, maintained a policy of hiring only white individuals for sales positions and had rejected non-white applicants for this reason. Faulk later learned that a white applicant with a more significant criminal history was hired for a similar position, and after discovering the discriminatory policy, he filed suit against Dimerco for racial discrimination under 42 U.S.C. § 1981.The United States District Court for the Northern District of Georgia presided over the trial. At trial, Dimerco sought to introduce evidence of Faulk’s unrelated 2019 arrest to undermine his emotional distress claim, but the district court ultimately excluded this evidence, finding it minimally relevant and highly prejudicial. The jury returned a verdict for Faulk, awarding him $90,000 in lost wages, $300,000 in emotional distress damages, and $3 million in punitive damages. Dimerco moved for a new trial, arguing that misconduct by Faulk’s counsel and evidentiary errors required one, or alternatively, for remittitur of the damages as excessive. The district court denied these motions.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s rulings. The court held that any misconduct by Faulk’s counsel was effectively cured by the district court’s instructions and did not deprive Dimerco of a fair trial. The evidentiary rulings were not erroneous or, if so, were harmless. The compensatory and punitive damages were supported by the evidence and not unconstitutionally excessive. The judgment in Faulk’s favor was affirmed in all respects. View "Faulk v. Dimerco Express USA Corp." on Justia Law

In 2016, law enforcement officers were tasked with apprehending an individual, Jamarion Robinson, who had several outstanding felony warrants. The officers, including two federal task force members, located Robinson at an apartment and conducted a raid that resulted in his death. Five years after the incident, a state grand jury in Georgia indicted these officers on charges including felony murder, aggravated assault, burglary, making a false statement, and violation of oath by a public officer. The officers removed the case to the United States District Court for the Northern District of Georgia, arguing they were entitled to a federal forum under 28 U.S.C. § 1442 as federal officers.After removal, the State of Georgia sought to have the case remanded to state court, but the district court denied the motion. Later, the State requested a “limited remand” to return to state court solely to seek a superseding indictment that would modify the charges. The district court denied this request, concluding it lacked statutory authority for such a remand and noting the State had alternative means for pursuing additional charges. The court also found the State’s request untimely and speculative regarding necessity.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed whether it had jurisdiction to consider the district court’s denial of the “limited remand.” The Eleventh Circuit held that it lacked appellate jurisdiction because the order was not final and did not qualify under the collateral order doctrine or as an appealable injunction under 28 U.S.C. § 1292(a)(1). The court reasoned that federal law did not prohibit the State from seeking a superseding indictment in state court, and the district court’s order did not prevent the State from doing so. The appeal was dismissed for lack of jurisdiction. View "Georgia v. Heinze" on Justia Law

An employee worked for Cowin & Company for nearly three decades, performing construction in coal mines and regularly being exposed to coal dust. Years after his employment ended, he filed a claim for benefits under the Black Lung Benefits Act, alleging total disability due to pneumoconiosis (“black lung disease”) caused by his coal mine work. The claimant relied on a regulatory presumption that applies to miners who have a disabling breathing impairment and at least fifteen years of qualifying coal mine employment. A key dispute in the case involved how to calculate a “year” of coal mine employment under Department of Labor regulations.An administrative law judge initially granted benefits, finding the claimant had at least fifteen years of qualifying employment, thus triggering the presumption. Cowin & Company appealed to the Benefits Review Board, which vacated the benefits award in part and instructed the judge to recalculate the length of coal mine employment, questioning the method used to credit years of employment. On remand, the judge again found more than fifteen years, but the Board disagreed with the method, holding that a claimant must prove both a 365/366-day period of employment and at least 125 working days during that period. Ultimately, after further proceedings, the administrative law judge found only 13.76 years of qualifying employment, and the Board affirmed the denial of benefits.The United States Court of Appeals for the Eleventh Circuit reviewed the Board’s decision. The court held that, under the plain text of the relevant regulation, a claimant establishes a “year” of coal mine employment by showing at least 125 working days in or around coal mines during a calendar year or partial periods totaling one year. The court granted the petition for review, vacated the Board’s decision, and remanded for further proceedings. View "Hayes v. Director, OWCP" on Justia Law