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

A dispute arose after a rare vehicle, originally owned by a Wisconsin man, was stolen and shipped to Europe. Richard Mueller inherited the vehicle and sold part of his interest to Joseph Ford. Years later, TL90108 LLC (“TL”) purchased the vehicle overseas and, upon attempting to register it in the United States, was notified that Ford and Mueller were the owners of record. Ford and Mueller sued TL in Wisconsin state court for a declaratory judgment and replevin. The trial court dismissed the case on statute-of-repose grounds, but the Wisconsin Court of Appeals reversed, and the Wisconsin Supreme Court granted review. While the appeal was pending, Ford filed for Chapter 11 bankruptcy but did not list TL as a creditor or provide it with formal notice of the bankruptcy proceedings or relevant deadlines.The United States Bankruptcy Court for the Southern District of Florida set a deadline under Federal Rule of Bankruptcy Procedure 4007(c) for creditors to file complaints objecting to the discharge of debts. TL did not file a complaint before this deadline, as it was unaware of the relevant facts supporting a fraud claim until later discovery in the Wisconsin litigation. After learning of Ford’s alleged fraud, TL moved to extend the deadline and file a complaint under 11 U.S.C. § 523(c), arguing for equitable tolling and asserting a due process violation due to inadequate notice. The bankruptcy court denied the motion, relying on the Eleventh Circuit’s precedent in In re Alton, which held that equitable tolling does not apply to Rule 4007(c) deadlines.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the bankruptcy court’s decision. The court held that its prior decision in In re Alton remains binding and precludes equitable tolling of Rule 4007(c)’s deadline, even in light of subsequent Supreme Court decisions. The court also held that TL’s actual notice of the bankruptcy proceeding satisfied due process, and thus, the deadline could not be extended on that basis. View "TL90108 LLC v. Ford" on Justia Law

Caterpillar Financial Services Corporation and Venequip Machinery Sales Corporation Miami entered into an inventory loan agreement governed by Tennessee law, under which Venequip Miami could borrow funds by executing promissory notes. Venequip Miami executed six such notes, totaling approximately $4.77 million. The agreement specified that default would occur if Venequip Miami failed to repay principal or interest when due, or if there was a material adverse change in its financial condition. After a related affiliate defaulted on a separate loan in Curaçao, Caterpillar Financial declared an event of default under the inventory loan agreement, accelerated the debt, and demanded repayment. Venequip Miami did not repay, and Caterpillar Financial alleged that the outstanding amount exceeded $10 million.Caterpillar Financial filed a breach of contract suit in the United States District Court for the Southern District of Florida. Venequip Miami moved to dismiss the complaint under Federal Rule of Civil Procedure 12(b)(6), arguing that Caterpillar Financial failed to specify which provision of the inventory loan agreement was breached. The district court agreed, finding the complaint insufficient because it did not identify the specific provision breached among several possible events of default, and dismissed the case with prejudice. Caterpillar Financial’s subsequent motion to amend the judgment and file an amended complaint was denied.The United States Court of Appeals for the Eleventh Circuit reviewed the dismissal de novo. The court held that under federal pleading standards, a breach of contract plaintiff is not required to identify the specific contractual provision breached, but must plausibly allege nonperformance. The court found that Caterpillar Financial’s complaint sufficiently alleged the existence of a contract, nonperformance by Venequip Miami, and resulting damages. The Eleventh Circuit reversed the district court’s judgment and remanded the case for further proceedings. View "Caterpillar Financial Services Corp. v. Venequip Machinery Sales Corp." on Justia Law

A federal prisoner diagnosed with a painful uterine fibroid sought medical treatment, including surgery, while incarcerated. Despite recommendations from two outside physicians for surgical intervention, prison medical staff repeatedly denied her requests for surgery. The prisoner followed the Bureau of Prisons’ four-step administrative grievance process: she attempted informal resolution, filed a formal written request, appealed to the regional director, and then submitted a final appeal (BP-11 form) to the Bureau’s General Counsel. Although she properly completed and mailed the BP-11 form, prison officials claimed they never received or logged it, and the tracking system showed no record of its receipt.The United States District Court for the Northern District of Alabama initially dismissed her Federal Tort Claims Act claims but allowed her to amend her complaint to pursue Eighth Amendment claims against individual medical staff. After further proceedings, the district court dismissed her amended complaint, concluding that she failed to exhaust administrative remedies because her BP-11 form was never logged as received and because she filed her lawsuit before the General Counsel’s response period had expired.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that the prisoner satisfied her obligation to exhaust administrative remedies by properly completing and mailing the BP-11 form, even though prison officials failed to log or process it. The court further held that the administrative remedy process was unavailable to her due to the lack of guidance on how to proceed when officials fail to file a properly submitted grievance, making the process “prohibitively opaque.” The Eleventh Circuit vacated the district court’s dismissal and remanded the case for further proceedings. View "McGuire-Mollica v. Griffin" on Justia Law

A plaintiff, Alin Pop, filed a putative class action against LuliFama.com LLC and other defendants, including several social media influencers, alleging a violation of the Florida Deceptive and Unfair Trade Practices Act (FDUTPA). Pop claimed he purchased Luli Fama swimwear after seeing influencers endorse the products on Instagram without disclosing they were paid for their endorsements. Pop argued that this non-disclosure was deceptive and violated FDUTPA.The case was initially filed in Florida state court but was removed to the United States District Court for the Middle District of Florida. The defendants moved to dismiss the complaint, and the district court granted the motion, dismissing the complaint with prejudice. The court held that because Pop's FDUTPA claim sounded in fraud, it was subject to the heightened pleading standards of Federal Rule of Civil Procedure 9(b). The court found that Pop's complaint failed to meet this standard as it did not specify which posts led to his purchase, which defendants made those posts, when the posts were made, or which products he bought. The court also found that the complaint failed to state a claim under the ordinary pleading standards.Pop appealed to the United States Court of Appeals for the Eleventh Circuit. The Eleventh Circuit affirmed the district court's dismissal, agreeing that Rule 9(b)'s particularity requirement applies to FDUTPA claims that sound in fraud. The court found that Pop's allegations closely tracked the elements of common law fraud and thus required particularity in pleading. The court also held that Pop failed to properly request leave to amend his complaint, and therefore, the district court did not err in dismissing the complaint with prejudice. View "Pop v. LuliFama.com LLC" on Justia Law

Jeanne Weinstein, a former server at The Ridge Great Steaks & Seafood, filed a collective action complaint alleging that the restaurant and its operator, Stephen Campbell, violated the Fair Labor Standards Act (FLSA) by not meeting the federal minimum wage requirement. The Ridge paid servers and bartenders $2.15 per hour, supplementing their income with tips to meet the $7.25 minimum wage. The Ridge also required servers and bartenders to contribute 3% of their gross food sales to a tip pool, which was used to pay support staff. Any excess tips were supposed to be distributed to bartenders, but there were inconsistencies in the record-keeping and distribution process.The United States District Court for the Northern District of Georgia granted unopposed motions to voluntarily dismiss five opt-in plaintiffs. The court also ruled partially in favor of the defendants on summary judgment, finding that the tip pool funds were not distributed to non-tipped employees. The remaining issue for trial was whether the defendants retained any portion of the tip pool funds.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court affirmed the district court's judgment, holding that Rule 41(a) permits the dismissal of a single plaintiff in a multiple-plaintiff case if all claims brought by that plaintiff are dismissed. The court also found no error in the district court's conclusion that the defendants did not retain any of the extra tips and operated a lawful tip pool within the parameters of the FLSA. Consequently, the defendants successfully asserted the tip credit defense, and the plaintiffs could not prevail on their minimum wage claim. View "Weinstein v. 440 Corp." on Justia Law

A qui tam relator, Sedona Partners LLC, alleged that several transportation service providers (TSPs) engaged in a fraudulent scheme to defraud a U.S. government shipping program. The TSPs were accused of submitting low-ball bids to win contracts and then falsely certifying the need for foreign flag vessel waivers, despite knowing that U.S. flag vessels were available. This allowed them to use cheaper foreign vessels, thereby increasing their profits while undercutting competitors who submitted legitimate bids.The United States District Court for the Southern District of Florida initially dismissed Sedona's first amended complaint without prejudice, citing a lack of specificity in the allegations. Sedona then filed a second amended complaint, which included new allegations based on information obtained during discovery. The defendants moved to dismiss this complaint and to strike the new allegations, arguing that they were derived from discovery and thus circumvented the heightened pleading requirements of Federal Rule of Civil Procedure 9(b). The district court agreed, struck the discovery-based allegations, and dismissed the second amended complaint with prejudice, concluding that without these allegations, Sedona failed to meet Rule 9(b)'s particularity requirement.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 Rule 9(b) does not prohibit courts from considering allegations based on information obtained in discovery when deciding a motion to dismiss. The court emphasized that Rule 9(b)'s text does not restrict the source of information used to satisfy its requirements and that supplementing the rule with such a restriction would contravene the Supreme Court's guidance against adding pleading requirements on a case-by-case basis. The appellate court vacated the district court's order dismissing the complaint and remanded the case for further proceedings. View "Sedona Partners LLC v. Able Moving & Storage Inc." on Justia Law

Bernard Perez, an ophthalmologist, entered into a disability insurance contract with MONY Life Insurance Company in 1988. After being diagnosed with throat cancer in 2011, Perez began receiving monthly disability benefits. MONY later suspected Perez of dishonesty in his disability claims and financial information, leading to the discontinuation of payments in February 2018. MONY sued Perez for unjust enrichment, and Perez counterclaimed for breach of contract.The Middle District of Florida held a nine-day trial where evidence showed Perez's deceitful conduct, including misrepresenting his ownership in his medical practice and overstating his physical ailments. The jury found in favor of MONY on the unjust enrichment claim, awarding $388,000, and rejected Perez's breach of contract counterclaim.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that under Florida law, an unjust enrichment claim cannot proceed when an express contract covers the same subject matter. Therefore, the district court erred in allowing the unjust enrichment claim to go to the jury. The Eleventh Circuit set aside the jury's verdict on this claim and directed the district court to vacate the judgment awarding MONY $448,930.06.Regarding Perez's breach of contract counterclaim, the Eleventh Circuit found that the district court erred in failing to interpret the ambiguous term "acceptable proof of loss" in the insurance contract. However, this error was deemed harmless because the evidence overwhelmingly showed Perez's dishonesty in his proofs of loss. Thus, the jury's verdict against Perez on his breach of contract counterclaim was affirmed. The court also affirmed the district court's evidentiary rulings and denial of sanctions. View "MONY Life Insurance Co. v. Perez" on Justia Law

A property insurance dispute arose between a church in Albany, Georgia, and its insurer following storm damage in 2014. The church's property, which included asbestos tile roofs, was insured under an all-risks policy. After the storm, the insurer's adjuster estimated repair costs at $2,300, but the church's contractor estimated over $1.3 million for full roof replacement. The church sued for breach of contract and bad faith. In 2018, Hurricane Michael caused further damage, and the church filed a claim with a different insurer, obtaining a lower repair estimate. The original insurer argued that the church's failure to disclose this second claim constituted a material misrepresentation.The United States District Court for the Middle District of Georgia excluded evidence of the alleged misrepresentation, finding it irrelevant. The jury awarded the church $1.75 million in damages, and the insurer's motion for a new trial was denied. The insurer appealed, arguing that the exclusion of misrepresentation evidence was erroneous and that the damages award was speculative and contrary to the policy terms.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It found that the insurer had waived its misrepresentation defense by not objecting during trial and by explicitly withdrawing the defense. The court also held that the jury's award, which included increased construction costs due to delays, was supported by sufficient evidence and did not constitute double recovery when combined with prejudgment interest. The court affirmed the district court's rulings and the jury's verdict. View "Central Baptist Church of Albany Georgia Inc v. Church Mutual Insurance Co." on Justia Law

Dr. Joseph Jimenez, a former medical officer for the Federal Bureau of Prisons (BOP), alleged race and national origin discrimination, retaliation under Title VII of the Civil Rights Act of 1964, and disability discrimination under the Rehabilitation Act. Dr. Jimenez, who identifies as Hispanic, claimed that his employer required him to work as a correctional officer while non-Hispanic doctors were exempt. He also alleged that the BOP denied him a reasonable accommodation for his mental health conditions.The district court dismissed Dr. Jimenez’s Title VII claims related to certain adverse employment actions for failure to exhaust administrative remedies. The court granted summary judgment to the BOP on the remaining Title VII claims, finding no evidence of discriminatory or retaliatory motives. The court later dismissed Dr. Jimenez’s Rehabilitation Act claim for lack of subject-matter jurisdiction, rejecting his attempt to correct a citation error in his complaint.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decisions. The appellate court held that Dr. Jimenez failed to exhaust administrative remedies for his claims related to the denial of bonuses and failure to promote. The court also found that Dr. Jimenez did not present sufficient evidence to show that his race, national origin, or protected activity influenced the BOP’s actions. Additionally, the court upheld the dismissal of the Rehabilitation Act claim, agreeing that the citation error was not a mere scrivener’s error and that Dr. Jimenez did not demonstrate good cause to amend his complaint after the scheduling order deadline. View "Jimenez v. Acting United States Attorney General" on Justia Law

AST & Science LLC, a company in the satellite technology and communications business, hired Delclaux Partners SA to introduce it to registered broker-dealers for investment purposes. Delclaux introduced AST to LionTree Advisors LLC, which handled AST's Series A financing. Two contracts were involved: a Finder’s Fee Agreement between AST and Delclaux, and a separate agreement between AST and LionTree. After the Series B financing, Delclaux claimed it was owed fees from four transactions, which AST refused to pay, leading to AST suing Delclaux for breach of contract, alleging Delclaux acted as an unregistered broker-dealer.The United States District Court for the Southern District of Florida denied summary judgment on AST’s complaint and granted summary judgment to AST on Delclaux’s counterclaim. Delclaux appealed, but the appeal was voluntarily dismissed due to jurisdictional questions. The district court later held that it lacked diversity jurisdiction but claimed federal-question jurisdiction, asserting that the case involved a federal issue regarding the Securities Exchange Act.The United States Court of Appeals for the Eleventh Circuit reviewed the case and disagreed with the district court’s assertion of federal-question jurisdiction. The appellate court held that the breach-of-contract claim was governed by state law and did not meet the criteria for federal-question jurisdiction under the Grable & Sons Metal Products, Inc. v. Darue Engineering & Manufacturing test. The court found that the federal issue was not substantial enough to warrant federal jurisdiction. Consequently, the Eleventh Circuit vacated the district court’s judgment and remanded the case with instructions to dismiss it for lack of subject-matter jurisdiction. View "AST & Science LLC v. Delclaux Partners SA" on Justia Law