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

Alice Guan and her homeowners association (HOA), Ellingsworth Residential Community Association, Inc., were involved in a dispute after Guan failed to conform her yard to the HOA’s covenants. Ellingsworth sued Guan in state court, and Guan countersued for various state-law claims. The state court awarded Guan costs and fees, but before she could collect, Ellingsworth filed for subchapter V bankruptcy.In the Bankruptcy Court, Guan filed several motions, including objections to Ellingsworth’s subchapter V eligibility and reorganization plan, and a motion for relief from the automatic stay. The Bankruptcy Court overruled Guan’s objections, confirming Ellingsworth’s subchapter V status and reorganization plan, and denied her motion for relief from the stay. Guan appealed these decisions to the District Court.The District Court affirmed the Bankruptcy Court’s orders, finding that Ellingsworth was eligible for subchapter V as it was engaged in business activities, and that the reorganization plan was fair and equitable. The court also upheld the denial of Guan’s motion for relief from the stay, concluding that the Bankruptcy Court did not abuse its discretion and had jurisdiction over Guan’s claims.Guan also appealed the Bankruptcy Court’s denial of her motion to abstain from ruling on state law issues. The District Court dismissed this appeal for lack of jurisdiction, stating that the abstention order was not a final appealable order.The United States Court of Appeals for the Eleventh Circuit affirmed the District Court’s decisions on subchapter V eligibility, the reorganization plan, and the denial of stay relief. However, it vacated the dismissal of Guan’s abstention appeal, remanding it to the District Court for further consideration, as the denial of mandatory abstention is immediately appealable. View "Guan v. Ellingsworth Residential Community Association, Inc." on Justia Law

North American Sugar Industries, Inc. ("North American Sugar") filed a lawsuit against five defendants under Title III of the Helms-Burton Act, alleging that the defendants unlawfully trafficked its property, which was confiscated by the Cuban government. The defendants include three East Asian corporations (Xinjiang Goldwind Science & Technology Co., Ltd., Goldwind International Holdings (HK) Ltd., and BBC Chartering Singapore Pte Ltd.), and two U.S. corporations (DSV Air & Sea, Inc. and BBC Chartering USA, LLC). North American Sugar claimed that the defendants participated in a conspiracy involving trafficking from China, through Miami, Florida, and then to Puerto Carupano, Cuba.The U.S. District Court for the Southern District of Florida dismissed the case for lack of personal jurisdiction, adopting a magistrate judge's recommendation. The magistrate judge found that the alleged trafficking occurred in Cuba, not Florida, and that none of the defendants engaged in any activity in Florida related to the shipments. North American Sugar objected, but the district court upheld the recommendation, concluding that the Helms-Burton Act violations occurred only in Cuba.The United States Court of Appeals for the Eleventh Circuit reviewed the case and found that the district court erred in its narrow interpretation of the Helms-Burton Act. The Act broadly defines "traffics" to include various activities, and the court noted that trafficking can occur outside of Cuba. The appellate court also found that the district court improperly weighed conflicting evidence without holding an evidentiary hearing, as required under the prima facie standard.The Eleventh Circuit vacated the district court's order and remanded the case for further proceedings, instructing the lower court to reconsider personal jurisdiction in light of the correct interpretation of the Helms-Burton Act and to address whether any defendants committed trafficking activities in Florida. The court also directed the district court to consider the conspiracy theory of personal jurisdiction if it finds jurisdiction over any defendant. View "North American Sugar Industries, Inc. v. Xinjiang Goldwind Science & Technology Co., Ltd." on Justia Law

Troy Olhausen, a former Senior Vice President of Business Development and Marketing at Arriva Medical, LLC, filed a qui tam action under the False Claims Act against his former employers, Arriva, Alere, Inc., and Abbott Laboratories, Inc. He alleged that the defendants submitted fraudulent claims to the Center for Medicare and Medicaid Services (CMS) for reimbursement. Specifically, Olhausen claimed that Arriva submitted claims without obtaining required assignment-of-benefits signatures and failed to disclose or accredit certain call-center locations that processed claims.The United States District Court for the Southern District of Florida dismissed Olhausen’s third amended complaint, holding that he failed to plead with the particularity required under Federal Rule of Civil Procedure 9(b) that any fraudulent claims were actually submitted to the government. The district court found that Olhausen did not provide sufficient details to establish that false claims had been submitted, as he did not work in the billing department and lacked firsthand knowledge of the claim submissions.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the case. The court concluded that Olhausen adequately pled with particularity that allegedly false claims were submitted under Count II, which involved claims for heating pads that lacked assignment-of-benefits signatures. The court found that the internal audit allegations provided sufficient indicia of reliability to satisfy Rule 9(b). However, the court upheld the dismissal of Count IV, which alleged that Arriva failed to disclose or accredit certain call-center locations, as Olhausen did not adequately allege that any claims involving these locations were actually submitted. Consequently, the court vacated the dismissal of Counts II and VI (conspiracy) and remanded them for further proceedings, while affirming the dismissal of Count IV. View "Olhausen v. Arriva Medical, LLC" on Justia Law

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

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

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

In 2010, four individuals sued the Revolutionary Armed Forces of Colombia (FARC) under the Anti-Terrorism Act, resulting in a default judgment of $318 million against FARC. Unable to collect from FARC, the plaintiffs sought to garnish assets of Samark José López Bello and his companies, alleging they were agents or instrumentalities of FARC. The district court initially ruled in favor of the plaintiffs, but the Eleventh Circuit reversed, mandating a jury trial to determine the agency status of López and his companies.On remand, the district court scheduled a jury trial and allowed discovery. The plaintiffs sought to depose López and requested documents. López and his companies filed motions for protective orders to avoid discovery, which the district court denied, warning of sanctions for non-compliance. López failed to appear for his deposition and did not comply with document requests. Consequently, the district court entered default judgments against López and his companies, citing willful disobedience and the inability to compel compliance due to López's fugitive status.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court affirmed the district court's entry of default judgments, finding no abuse of discretion. The Eleventh Circuit held that the district court correctly interpreted its scheduling order to allow discovery and found that López's failure to comply with discovery orders was willful. The court also determined that less severe sanctions would not ensure compliance, given López's fugitive status. The Eleventh Circuit dismissed the argument that the district court lacked jurisdiction due to an appeal of the protective order denials, as those orders were not final or immediately appealable. View "Stansell v. Lopez Bello" on Justia Law

Two plaintiffs, Lester Jenkins and Dwight Siples Jr., participated in the cleanup of the Deepwater Horizon oil spill and later developed chronic sinusitis, which they attributed to exposure to crude oil and dispersants during the cleanup. They filed suits against BP Exploration & Production, Inc. and BP America Production Company, claiming that their medical conditions were caused by this exposure. The plaintiffs relied on expert testimony to establish general causation, which is necessary in toxic-tort cases where the medical community does not recognize the alleged toxins as harmful.The United States District Court for the Northern District of Florida reviewed the expert testimonies of Dr. Michael Freeman and Dr. Gina Solomon, who opined that a causal relationship existed between the cleanup work and chronic sinusitis. However, the district court excluded their testimonies, finding that neither expert identified a minimal level of exposure at which crude oil, its dispersants, or associated chemicals are hazardous to humans. The court also noted that the experts failed to identify a statistically significant association between the chronic conditions and exposure to crude oil, assess the limitations of various studies, or meaningfully consider causal factors. Consequently, the district court granted summary judgment in favor of BP.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 the district court did not abuse its discretion in excluding the expert testimonies. It emphasized that in toxic-tort cases, plaintiffs must demonstrate the levels of exposure that are hazardous to humans generally. The court found that the experts failed to establish a harmful level of exposure for crude oil or its dispersants and did not adequately support their causation opinions with reliable scientific evidence. Therefore, the summary judgment in favor of BP was affirmed. View "In Re Deepwater Horizon Belo Cases" on Justia Law

Fane Lozman owns a parcel of submerged and upland land in the City of Riviera Beach, Florida. After the city enacted a comprehensive plan and ordinance restricting development, Lozman sued, claiming the city deprived his property of all beneficial economic use without just compensation. Lozman has not applied for any permits, variances, or rezoning to understand the extent of permitted development on his land. He also faced federal and state enforcement actions for unauthorized modifications to his property.The United States District Court for the Southern District of Florida granted summary judgment for Riviera Beach. The court found that Lozman did not have any right to fill his submerged land under federal and state law, was not denied all economically productive or beneficial uses of his land, and did not plead a ripe Penn Central regulatory taking claim.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that Lozman's claim was not ripe for judicial review because he had not received a final decision from Riviera Beach regarding the application of the comprehensive plan and ordinance to his property. Lozman had not applied for any permits, variances, or rezoning, which are necessary to determine the nature and extent of permitted development. The court vacated the district court's judgment and remanded with instructions to dismiss Lozman’s complaint without prejudice for lack of subject-matter jurisdiction. View "Lozman v. City of Riviera Beach" on Justia Law