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

A developer purchased approximately 430 acres in Georgia and later sold a 103-acre tract to an investment company. This company, Savannah Shoals, LLC, planned to donate a conservation easement over the 103-acre tract. Expert testing determined that the property contained materials suitable for use as crushed rock aggregate, and an expert report valued the potential of an aggregate quarry on the property at $23.1 million. Savannah Shoals then completed a series of transactions to acquire and transfer membership interests in the property, after which it granted the conservation easement and claimed a $23 million tax deduction for its donation.The Internal Revenue Service (IRS) disallowed the deduction, arguing that Savannah Shoals had grossly overstated the value of the easement. The IRS issued a Final Partnership Administrative Adjustment, finding the deduction unsupported and imposing a 40% penalty for gross valuation misstatement. Savannah Shoals challenged these findings in the United States Tax Court. After a four-day trial with expert testimony, the Tax Court concluded that the property’s highest and best use was not as an aggregate quarry, but rather for low-density residential and recreational purposes. Relying on comparable sales and the actual transaction value, the Tax Court determined the easement’s value to be $480,000 and upheld the 40% penalty.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the Tax Court’s decision. The Eleventh Circuit held that the Tax Court was not required to apply a specific four-factor test for highest and best use and that its focus on market demand and feasibility was appropriate under the law and regulations. The appellate court also found no abuse of discretion in the admission of expert testimony and concluded that the Tax Court’s factual findings were not clearly erroneous. The judgment of the Tax Court was affirmed. View "Savannah Shoals, LLC v. Commissioner of Internal Revenue" on Justia Law

A group of employees in the commercial aviation sector challenged their employers’ COVID-19 policies, which required vaccination unless a religious or medical exemption was obtained. Those with exemptions had to comply with periodic testing and mask-wearing. The plaintiffs objected to the requirements on religious and personal grounds, alleging that the accommodations for religious objectors were inadequate and burdensome. While the complaint did not claim anyone was terminated, it did allege some employees were assigned to less desirable flights due to these policies.The United States District Court for the Southern District of Florida dismissed all claims against Flight Services International and certain claims against Atlas Air for lack of personal jurisdiction. The court also dismissed the remaining claims against Atlas Air for failure to state a claim. The plaintiffs then appealed to the United States Court of Appeals for the Eleventh Circuit.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The appellate court held that there was no personal jurisdiction over Flight Services International because it was neither incorporated nor headquartered in Florida, and the alleged contacts with Florida were insufficient for either general or specific jurisdiction. Regarding Atlas Air, the court found that the plaintiffs failed to state a plausible claim under Title VII, as there were no facts suggesting religious discrimination or hostile intent. The court held that the plaintiffs could not bring claims under the Federal Food, Drug, and Cosmetic Act, as enforcement is limited to the federal government. Constitutional claims under § 1983 and Bivens failed because Atlas Air is a private entity. Additionally, the state law tort claims for invasion of privacy, negligent disclosure, and intentional infliction of emotional distress were found insufficiently pleaded or unsupported by the alleged facts. The judgment of dismissal was affirmed. View "Estate of Caviness v. Atlas Air, Inc." on Justia Law

A man was investigated after Google and Yahoo flagged several of his email accounts for sending and storing what appeared to be child pornography. Both companies identified the user through information like a shared recovery phone number, birthdate, and selfies associated with the accounts. Yahoo manually reviewed and confirmed the images as child pornography before reporting them to the National Center for Missing and Exploited Children (NCMEC). Google used both human review and a hash-value matching protocol, whereby a file’s unique digital fingerprint was compared against a database of previously identified illegal images. One of the files in the defendant’s account matched the hash of a known child pornography image. Law enforcement, after receiving tips from NCMEC, conducted warrantless searches and confirmed the illicit nature of the files, leading to search warrants for the defendant’s residence and devices, which yielded more incriminating evidence.The United States District Court for the Middle District of Florida denied the defendant’s motions to suppress the evidence (arguing a Fourth Amendment violation), to dismiss one of the charges on double jeopardy grounds, and to exclude certain evidence. The court also rejected his arguments concerning the admissibility of defense evidence, the sufficiency of the evidence, and the jury instructions. The defendant was convicted by a jury on both distribution and possession charges and given an enhanced sentence based on a finding of a pattern of activity involving abuse or exploitation. His subsequent motions for psychological evaluation and sentencing continuance were also denied.On appeal, the United States Court of Appeals for the Eleventh Circuit held that Google’s use of hash-value matching constituted a valid private search under the Fourth Amendment, so the government’s warrantless review did not violate the defendant’s rights. The court also held that possession and distribution of child pornography are separate offenses for double jeopardy purposes. The appellate court affirmed all district court decisions except for the application of a pattern-of-activity sentencing enhancement, which it found improper; it vacated the sentence and remanded for resentencing. View "USA v. Brillhart" on Justia Law

The case concerns an Alabama resident who was injured by an uninsured motorist while riding his motorcycle. At the time, he held two separate insurance policies: a standard auto insurance policy from GEICO covering his motorcycle, and a specialty policy from Essentia Insurance Company covering his antique truck. The GEICO policy provided uninsured motorist coverage as required by Alabama law, and the insured collected $25,000 under it. Essentia’s policy, which covered only the antique vehicle, excluded uninsured motorist coverage for accidents involving vehicles other than the covered antique truck. The policy also required the insured to maintain a separate insurance policy that satisfied Alabama’s minimum coverage requirements.After Essentia denied his claim for uninsured motorist coverage, the insured brought suit in the United States District Court for the Middle District of Alabama. Essentia moved for summary judgment, arguing that its specialty policy’s coverage exclusion was valid because the insured had other coverage meeting Alabama’s requirements. The district court denied Essentia’s motion in part, holding Essentia liable for uninsured motorist benefits, but limited the liability to the statutory minimum of $25,000, and entered judgment accordingly. Essentia appealed.The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s summary judgment de novo and reversed. The Eleventh Circuit held that Alabama law permits insurers to fulfill mandatory coverage requirements through multiple policies, and that Essentia’s exclusion is enforceable so long as the insured has other coverage meeting statutory requirements. The court remanded the case for further proceedings consistent with its opinion. View "Clayton v. Essentia Insurance Company" on Justia Law

An inmate at St. Clair Correctional Facility in Alabama brought suit under 42 U.S.C. § 1983 after he was assaulted by another prisoner in 2018. Previously, he had been attacked in 2016 and had requested transfer to segregation due to safety concerns but was denied by prison officials. Upon his return to St. Clair in 2017, he again sought protective housing, citing ongoing threats and hazardous conditions, including frequent violence, unauthorized inmate movement, and periods of absent supervision. Despite these requests, he remained in the general population and was ultimately assaulted, resulting in serious injuries.The United States District Court for the Northern District of Alabama first dismissed most of his claims, allowing only the Eighth Amendment deliberate-indifference claim based on a generalized risk of violence to proceed. After discovery, the district court granted summary judgment to the prison officials, finding that the plaintiff had failed to establish a genuine dispute of material fact as to whether he faced a substantial risk of serious harm. In an earlier appeal, the United States Court of Appeals for the Eleventh Circuit vacated the summary judgment due to improper denial of discovery, remanding for further proceedings. On remand, the district court again granted summary judgment, reasoning that the plaintiff had not sufficiently contextualized the violence statistics or provided adequate support for his allegations.Upon review, the United States Court of Appeals for the Eleventh Circuit held that the plaintiff had provided sufficient evidence—including statistical data on inmate assaults, contextual information about prison conditions, and sworn allegations of specific dangerous features—to create a genuine dispute of material fact regarding exposure to a substantial risk of serious harm. The court vacated the district court’s grant of summary judgment and remanded for further proceedings. View "Marbury v. Warden" on Justia Law

Florida enacted a law prohibiting public university professors from endorsing or promoting certain ideas related to race, color, sex, and national origin in classroom instruction. The law, known as the Individual Freedom Act, identifies eight specific concepts that professors are barred from espousing, such as claims of moral superiority based on race or sex, inherent racism or oppression, and the idea that virtues like merit or colorblindness are themselves racist or sexist. The law allows professors to discuss these concepts in a neutral way, but not to advocate for them, and imposes severe penalties on both individual professors and universities for violations, including the loss of significant funding and potential termination of employment.Groups of professors and students from several Florida public universities filed lawsuits in the United States District Court for the Northern District of Florida, arguing that the Act violated their First Amendment rights by restricting viewpoint-based expression and was unconstitutionally vague. The district court granted preliminary injunctions in both cases, enjoining enforcement of the Act’s classroom restrictions against the plaintiffs, finding that at least one plaintiff had standing to challenge each prohibited concept. The court concluded the Act was likely unconstitutional as applied to public university professors.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s grant of a preliminary injunction. The Eleventh Circuit affirmed, holding that the Act’s restrictions amount to unconstitutional viewpoint discrimination in violation of the First Amendment. The court distinguished between permissible curricular control by universities and the broad, legislative ban imposed by the state’s political branches. It concluded that neither public-employee speech doctrine nor government speech doctrine justified the law’s suppression of disfavored ideas in the university classroom, and that the Act impermissibly infringed on academic freedom and open inquiry. The preliminary injunction was affirmed. View "Pernell v. Commissioner of the FL State Board of Education" on Justia Law

The dispute centers on whether the U.S. Department of Education may constitutionally rely on private educational accreditors in disbursing federal education funds. Under the Higher Education Act, colleges and universities must be accredited by a recognized accreditor for their students to be eligible for federal financial aid. Accreditors are private, voluntary organizations funded by the schools they accredit. Florida challenged this arrangement, alleging that it unconstitutionally delegates government power to private accreditors and violates both the Appointments Clause and the Spending Clause, claiming the accreditation requirement is an unascertainable condition for federal funds.The United States District Court for the Southern District of Florida reviewed the suit after Florida brought four claims: a private nondelegation doctrine challenge, an Appointments Clause challenge, a Spending Clause challenge, and a now-abandoned Administrative Procedure Act challenge. The federal government moved to dismiss, and the district court granted the motion. The district court found no unlawful delegation of government power, noted that Title IV funds are directed to students and not institutions, determined the accreditation requirement is unambiguous, and dismissed the Appointments Clause claim because accreditors do not determine eligibility for federal funds.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s dismissal de novo. The Court held that private accreditors do not exercise government authority that could violate the Vesting Clauses or the Appointments Clause. The Court also determined that the accreditation requirement is an ascertainable condition for federal funds, as it is a well-understood, longstanding practice and does not amount to an ambiguous or novel restriction. The Eleventh Circuit affirmed the district court’s dismissal of Florida’s suit. View "State of Florida v. Secretary, US Department of Education" on Justia Law

A man who was convicted of possessing child pornography in 2013 served his sentence and later married and had a son. Despite completing sex offender treatment and complying with supervised release conditions, he remained subject to Alabama’s Sex Offender Registration and Community Notification Act (“the Act”). This law prohibits him, for life, from residing with or conducting overnight visits with any minor—including his own child—because his conviction involved a child-related offense. The Act contains no mechanism for relief or individualized assessment, even for parents who have shown rehabilitation.After the birth of his son, the man sued the Sheriff and District Attorney of Tuscaloosa County and the Alabama Attorney General under 42 U.S.C. § 1983, seeking to enjoin enforcement of the Act’s prohibition against living with his child. The United States District Court for the Middle District of Alabama granted summary judgment in his favor, declaring the Act’s prohibition facially unconstitutional and issuing a universal injunction. On appeal, a panel of the United States Court of Appeals for the Eleventh Circuit affirmed in part, reversed in part, and vacated and remanded in part, finding the Act unconstitutional as applied to the plaintiff but vacating the universal injunction. The panel’s opinion was then vacated, and the case was reheard en banc.The United States Court of Appeals for the Eleventh Circuit held that all parents—including those with past convictions or “misconduct”—enjoy a fundamental right to live with their children under the Fourteenth Amendment. The court rejected Alabama’s argument that certain classes of parents lack this right due to prior offenses. The court remanded the case to the panel for further proceedings under strict scrutiny, requiring Alabama to show its law is narrowly tailored to serve a compelling state interest. The court affirmed in part and remanded in part. View "Henry v. Sheriff of Tuscaloosa County, Alabama" on Justia Law

The case concerns a defendant who pleaded guilty to possessing a firearm as a convicted felon, in violation of federal law. The defendant had four prior convictions under Georgia law for drug offenses involving cocaine, all committed on separate occasions. These prior convictions were used to classify him as an “armed career criminal,” triggering a mandatory minimum sentence of 15 years under the Armed Career Criminal Act (ACCA). The defendant did not dispute the existence of these convictions or that they occurred on different occasions. However, he argued that Georgia’s definition of cocaine is broader than the federal definition, contending that this difference should prevent his prior convictions from qualifying as ACCA predicate offenses.The United States District Court for the Middle District of Georgia overruled the defendant’s objection to the ACCA enhancement. The court concluded that the Georgia convictions counted as “serious drug offenses” under the ACCA and sentenced him to 210 months in prison. During sentencing, the court rejected arguments based on an expert’s declaration claiming a definitional mismatch between state and federal cocaine laws.Upon review, the United States Court of Appeals for the Eleventh Circuit considered whether Georgia law, by defining cocaine more broadly than federal law, rendered the prior convictions ineligible for ACCA enhancement. The appellate court held that for a substance to be a controlled substance under Georgia law, it must be listed on both Georgia and federal drug schedules. Thus, even if Georgia’s statutory language is broader, a conviction could not be based on conduct outside the federal definition. The court also rejected an argument based on changes to the federal schedules concerning “ioflupane.” The Eleventh Circuit affirmed the district court’s application of the ACCA enhancement. View "USA v. Carter" on Justia Law

A 65-year-old homeless man was encountered by two Atlanta police officers near a highway on-ramp after he was observed receiving money from a driver. When approached, he fled on foot, and one officer pursued him across traffic. The man, unarmed and non-threatening, crossed a guardrail and began descending a steep embankment toward a highway. Without giving a verbal warning, the officer fired his taser in dart mode, striking the man in the back, causing him to fall down the embankment and suffer catastrophic injuries, including traumatic brain injury and quadriplegia.The man’s guardian filed suit in the United States District Court for the Northern District of Georgia against the officer and the City under 42 U.S.C. § 1983, alleging excessive force, as well as related state-law claims. The district court granted partial summary judgment on certain state claims and dismissed others by stipulation. At trial, the jury found in favor of the plaintiff, awarding $60 million against the City and $40 million against the officer (split between compensatory and punitive damages). The district court later set aside the verdict against the City, holding there was insufficient evidence of municipal liability, and reduced the punitive damages against the officer to $1 million.The United States Court of Appeals for the Eleventh Circuit reviewed these outcomes. It held that the officer was not entitled to qualified immunity, because tasing an unarmed, non-dangerous suspect fleeing on foot in a highly dangerous location, without warning, constituted excessive force under clearly established law. The appellate court affirmed setting aside the verdict against the City, finding insufficient evidence that any City policy or failure to enforce the body camera policy was the moving force behind the violation. The reduction of punitive damages to $1 million was upheld as constitutional. The court also affirmed the district court’s rulings on medical expenses and attorney’s fees. View "Edwards v. Grubbs" on Justia Law