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

Articles Posted in Civil Procedure
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After injuring her foot on a rug while onboard a Carnival ship, plaintiff filed suit against Carnival in both state and federal court, seeking damages for the injuries she allegedly suffered onboard the ship. In this case, plaintiff entered into a contract with Carnival that contained a forum-selection clause. Under the forum-selection clause's plain language, when jurisdiction for a claim could lie in federal district court, federal court is the only option for a plaintiff. The court held that plaintiff's claim for negligence at sea falls well within the walls of the federal court's admiralty jurisdiction. Even without explicitly invoking admiralty jurisdiction, the court held that plaintiff's complaint is subject to Federal Rule of Civil Procedure 9(h)'s provision rendering her claim an admiralty or maritime claim. View "DeRoy v. Carnival Corp." on Justia Law

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After the district court upheld third-party counterclaim defendants' removal of this case from Alabama state court, the Supreme Court issued Home Depot U.S.A., Inc. v. Jackson, 139 S. Ct. 1743 (2019), which held that third-party counterclaim defendants cannot remove a "civil action" under 28 U.S.C. 1441(c). The Eleventh Circuit held that Home Depot makes the holding in Carl Heck Engineers, Inc. v. Lafourche Parish Police Jury, 622 F.2d 133 (5th Cir. 1980), no longer good law. Therefore, the court reversed the district court's denial of third-party counterclaim plaintiffs Philip and Jennie Bowling's motion to remand, which was based in substantial part on Carl Heck. The court explained that the analysis in Home Depot leaves no doubt that, even if Carl Heck involves section 1441(c), it is no longer good law because it is impossible to read the statute as a whole and conclude that the same term in sections 1441(a) and 1441(c) has different meanings. Furthermore, section 1441(c) does not provide for removal jurisdiction of the Bowlings' claims against the third-party counterclaim defendants here because section 1441(a) is the operative clause that authorizes removal, and section 1441(c) merely adds a condition for certain types of civil cases. Because the district court erred in denying the Bowlings' motion to remand, the court held that the district court's order granting third-party counterclaim defendants' motion for summary judgment must be vacated, and the entire case must be remanded to state court. View "Bowling v. U.S. Bank National Ass'n" on Justia Law

Posted in: Civil Procedure
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The Eleventh Circuit joined its sister circuits in holding that a district court may address a sanctions motion based on its inherent powers or 28 U.S.C. 1927 even if it lacks jurisdiction over the underlying case. The court explained that these sanctions, like Rule 11 sanctions, do not require a court to rule on the merits of the underlying case. Furthermore, the purpose of the sanctions outlasts the end of the case. In this case, the court held that the district court did not abuse its discretion by denying defendant's motion for sanctions, because defendant failed to make a showing of bad faith. Defendant's only exhibit submitted to show bad faith could be interpreted in more than one way, and the district court also considered defendant's nearly three-year delay in bringing his sanctions motion. View "Hyde v. Irish" on Justia Law

Posted in: Civil Procedure
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The Eleventh Circuit affirmed the district court's dismissal of a Freedom of Information Act (FOIA) suit against the Florida Federal Judicial Nominating Commission and its former statewide chair. The district court dismissed the action for want of subject matter jurisdiction because neither the Commission nor the chair is an "agency" within the meaning of FOIA. The court agreed with the district court that the Commission is not an agency. However, because this fact creates a defect in the merits of the complaint rather than in the district court's jurisdiction, the court held that the complaint failed to state a claim upon which relief can be granted. View "Statton v. Florida Federal Judicial Nominating Commission" on Justia Law

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Plaintiff filed suit against Bay Point in state court and added DCT as a plaintiff in an amended complaint, alleging that Bay Point's foreclosure of two properties caused him to lose the collateral's value exceeding the debt balance, and to suffer mental anguish. After Bay Point removed to bankruptcy court, the district court affirmed the bankruptcy court's order in favor of Bay Point. Plaintiff and DCT appealed, but then the district court granted DCT's motion to dismiss. The Eleventh Circuit held that plaintiff lacked Article III standing, because he failed to allege a particularized, actual injury. Furthermore, plaintiff was not a person aggrieved. Therefore, plaintiff may not appeal the district court's decision affirming the bankruptcy court's order. View "Thakkar v. Bay Point Capital Partners, LP" on Justia Law

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Federal Rule of Civil Procedure 41(d) does not apply when a plaintiff, after dismissing the first federal action, files a subsequent action in state court. In this case, after voluntarily dismissing his federal action, plaintiff filed a second action in state court against defendant based on or including the same claim. The Eleventh Circuit held that the district court correctly determined that defendant was not entitled to costs under Rule 41(d) because plaintiff filed the second action against him in state court. View "Sargeant v. Hall" on Justia Law

Posted in: Civil Procedure
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On petition for rehearing, the Eleventh Circuit vacated and reconsidered its original opinion, substituting the following opinion. The court affirmed the district court's grant of GDC's motion to quash plaintiffs' subpoena directing GDC to testify at a Rule 30(b)(6) deposition and to produce documents concerning Georgia's lethal injection protocol. Plaintiffs argued that the information was necessary to support their 42 U.S.C. 1983 claims pending in the Southern District of Mississippi challenging the legality of Mississippi's lethal injection protocol. The court held that the district court applied the correct standard of review, the clearly erroneous or contrary-to-law standard, to the magistrate judge's ruling on the motion to quash. The court also held that the district court did not abuse its discretion by affirming the magistrate judge's ruling to grant GDC's motion to quash where the relevance of the information sought in the GDC subpoena to the pending section 1983 litigation was highly questionable; the subpoena subjected GDC to an undue burden which mandated the quashing of the subpoena under Rule 45(d)(3)(A)(iv); and compliance with plaintiffs' subpoena would impose an undue burden on the State of Georgia. View "Jordan v. Georgia Department of Corrections" on Justia Law

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This case involved the enforcement of a judgment CFTC obtained against defendant which, among other things, ordered defendant to pay $1,543,892 within 10 days in restitution to the investors who fell victim to his commodity-fraud scheme. The Eleventh Circuit vacated the district court's contempt adjudication and its modification of the restitution provisions of its judgment, holding that those provisions constitute a money judgment enforceable under the Federal Debt Collection Procedures Act, but not by the district court's civil contempt power. Therefore, the court need not consider defendant's arguments that the district court erred in considering exempt assets or defendant's wife's income in its determination of defendant's ability to pay. View "U.S. Commodity Futures Trading Commissioner v. Escobio" on Justia Law

Posted in: Civil Procedure
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The Eleventh Circuit reversed and vacated the district court's order remanding the case to state court after the case was removed to federal district court under the Class Action Fairness Act (CAFA). Because plaintiff sought equitable relief to reinstate a lapsed or surrendered life insurance policy, the court held that the face value of the policy could be used to satisfy the amount-in-controversy requirement, and that the aggregate face value of the life insurance policies here was over $75 million. Therefore, the court held that Wilco has met its burden of proving by a preponderance of the evidence that the amount in controversy exceeds the $5 million CAFA threshold. View "Anderson v. Wilco Life Insurance Co." on Justia Law

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The Eleventh Circuit vacated the district court's dismissal of plaintiffs' claims against defendants based on lack of standing. The court held that plaintiffs plausibly alleged that they suffered an economic loss when they purchased supplements that were worthless because the Federal Food, Drug, and Cosmetic Act (FDCA) prohibited sale of the supplements. The court explained that Congress, through the FDCA and the Dietary Supplement Health and Education Act (DSHEA), banned adulterated supplements to protect consumers from ingesting products that Congress judged to be insufficiently safe. In this case, the complaint's allegations establish that plaintiffs purchased adulterated dietary supplements that they would not have purchased had they known that sale of the supplements was banned. The court also held that plaintiffs sufficiently alleged sufficient facts to show that their injuries were fairly traceable to defendants. Accordingly, plaintiffs had Article III standing to pursue their claims. View "Debernardis v. IQ Formulations, LLC" on Justia Law