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

In 2017, Roy Moore, a Republican candidate for a U.S. Senate seat in Alabama, faced allegations of sexual misconduct with minors. Following his election loss, Moore filed a defamation lawsuit against Guy Cecil, Priorities USA, and Bully Pulpit Interactive LLC. The claims involved tweets by Cecil, a press release by Priorities USA, and a digital ad. Moore argued that the tweets were defamatory and that the press release and digital ad falsely labeled him a "child molester" and "child predator."The United States District Court for the Northern District of Alabama dismissed the tweet-based claims for lack of personal jurisdiction, as Cecil had no significant contacts with Alabama. The court also dismissed the press release and digital ad claims for failure to state a claim, concluding that Moore did not sufficiently allege actual malice, a requirement for defamation claims involving public figures. The court allowed Moore to amend his complaint, but the amended complaint was also dismissed for the same reasons.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court affirmed the district court's dismissal of the tweet-based claims, agreeing that Cecil's tweets were not aimed at Alabama but rather at a national audience. The court also upheld the dismissal of the press release and digital ad claims, finding that Moore failed to allege facts showing that the defendants acted with actual malice. The court noted that ill-will or improper motive does not equate to actual malice, which requires knowledge of falsity or reckless disregard for the truth.The Eleventh Circuit concluded that the district court correctly dismissed the claims for lack of personal jurisdiction and failure to state a claim, affirming the lower court's decision. View "Moore v. Cecil" on Justia Law

Roland McCarthy, a white man, was hired as Finance Director by the City Commission of Cordele, Georgia, in 2017 and promoted to City Manager in January 2021. During his tenure, Joshua Deriso campaigned for chairman of the City Commission, expressing intentions to replace white employees with African Americans and to have an all-black City Commission. After winning the election, Deriso and other black commissioners voted to fire McCarthy and replace him with a black City Manager, Angela Henderson Redding. McCarthy was warned by Deriso and another commissioner, Royce Reeves, that he would be replaced due to his race and could not return to his former position because he did not "look like" them.The United States District Court for the Middle District of Georgia dismissed McCarthy's complaint, ruling that he failed to state plausible claims of racial discrimination against the City. The court found that McCarthy did not sufficiently allege that the Commission acted with a racially discriminatory motive, as only one voting commissioner was alleged to have racial animus. The court also dismissed claims against Deriso in his official capacity as duplicative of claims against the City and dismissed claims against Deriso in his individual capacity, citing qualified immunity.The United States Court of Appeals for the Eleventh Circuit reviewed the case and vacated the district court's dismissal of McCarthy's claims against the City. The appellate court found that McCarthy plausibly alleged that the Commission discriminated against him because of his race, based on Deriso's and Reeves's statements and the racial composition of the vote. However, the court affirmed the dismissal of claims against Deriso in his individual capacity, as he did not have the authority to make the official decision to fire McCarthy. The case was remanded for further proceedings. View "McCarthy v. City of Cordele Georgia" on Justia Law

The case involves a qui tam action under the False Claims Act (FCA) brought by Relators against Great American Insurance Company (GAIC) and Native American Services Corporation (NASCO). The Relators allege that GAIC and NASCO fraudulently took control of DWG & Associates, Inc. (DWG), a company that had graduated from the Small Business Administration's (SBA) 8(a) program but was still performing on 8(a) contracts. The 8(a) program is designed to help small, disadvantaged businesses compete for federal contracts. DWG, initially owned and controlled by a disadvantaged individual, Gose, lost its eligibility when GAIC and NASCO allegedly took over its ownership and control without notifying the SBA or seeking a waiver, as required by the program's regulations.The United States District Court for the Middle District of Florida dismissed the Relators' claims with prejudice. The court found that DWG, having graduated from the 8(a) program, was no longer a "participant" and thus not subject to the program's ownership and control requirements. Consequently, the court ruled that Relators failed to allege any false claims. Additionally, the court held that fraudulent inducement related to bidding on government contracts was not actionable under the FCA and that Relators failed to meet the particularity requirements of Rule 9(b) for pleading fraud.The United States Court of Appeals for the Eleventh Circuit reversed the District Court's decision. The appellate court held that a business that has graduated from the 8(a) program but is still performing on 8(a) contracts remains a "participant" and is subject to the program's ownership and control requirements. The court further held that submitting bids and claims for payment under these circumstances without notifying the SBA or obtaining a waiver could constitute an actionable claim under the FCA. The court also found that Relators' complaint met the particularity requirements of Rule 9(b) by providing sufficient details about the alleged fraudulent conduct, including the specific contracts, task orders, and the date DWG became ineligible to bid. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Berry v. Native American Services Corporation" on Justia Law

In March 2020, seven crewmembers of the M/V Greg Mortimer cruise ship filed a lawsuit against several companies, including CMI Leisure Management, Inc., Cruise Management International, Inc., and Vikand Medical Solutions, LLC. The crewmembers alleged that the decision to sail during the COVID-19 pandemic exposed them to foreseeable harms, resulting in six of them contracting the virus. The crewmembers had signed employment agreements with other companies that contained forum-selection and choice-of-law clauses requiring disputes to be brought in the Bahamas under Bahamian law.The United States District Court for the Southern District of Florida dismissed the action based on the forum-selection clause. The court ruled that the defendants, who were not parties to the employment agreements, could invoke the forum-selection clause under the doctrine of equitable estoppel.Upon review, the United States Court of Appeals for the Eleventh Circuit vacated and remanded the decision. The appellate court held that the defendants could not invoke the forum-selection clause in the employment agreements under the doctrine of equitable estoppel. The court reasoned that the crewmembers' claims did not rely on the terms of their employment agreements, and thus, equitable estoppel did not apply. The court remanded the case for further proceedings consistent with its opinion. View "Usme v. CMI Leisure Management, Inc." on Justia Law

The case revolves around William Spears, a front desk clerk at hotels operated by Rick Patel Sr. and his son, Rick “Sunny” Patel Jr. Spears was compensated with monthly paychecks and onsite lodging. He sued the Patels and the hotel entities under the Fair Labor Standards Act for wages owed and unpaid overtime. The district court ruled that Sunny was an employer individually liable for the violations. In calculating Spears’s damages, the court considered the stipulated value of Spears’s lodging for unpaid overtime but declined to include it in the minimum-wage calculation.The case went to a bench trial before a magistrate judge. The judge found that Spears was not paid the legally required minimum wage or overtime. The judge ruled that Rick and Sunny were employers under the Act individually liable for those violations. The judge also found that Spears was entitled to damages for unpaid overtime and minimum wages. The judge included the stipulated $630 lodging value to determine Spears’s overtime pay rate but did not give the Patels credit for the value of Spears’s lodging when calculating Spears’s unpaid minimum wages.The United States Court of Appeals for the Eleventh Circuit affirmed the ruling that Sunny was an employer under the Act due to his involvement in the day-to-day operation of the hotels and some financial control. However, the court vacated and remanded for recalculation of damages. The court held that the magistrate judge erred in excluding the stipulated value of Spears’s lodging from the calculation of his unpaid minimum wages but including it for the calculation of Spears’s overtime damages. The court reasoned that the stipulation to the value of Spears’s lodging relieved the Patels of the burden to prove at trial the reasonable cost of lodging. View "Spears v. Patel" on Justia Law

The case revolves around a products liability lawsuit filed by Virginia Redding against Coloplast Corporation. Redding alleged that vaginal mesh devices inserted inside her body were defectively designed. Coloplast argued that Redding's suit was time-barred under Florida's four-year statute of limitations for products liability lawsuits, as her claim accrued more than four years before she filed suit. The district court sided with Redding, and Coloplast appealed.The case was previously reviewed by the United States District Court for the Middle District of Florida. The district court denied Coloplast's motion for summary judgment, arguing that Redding's suit was time-barred. The court found that the facts in a similar case, Eghnayem v. Boston Scientific Corporation, were "strikingly similar" to Redding's case and compelled the conclusion that Redding's injuries were not sufficiently different from the symptoms that could have occurred as a result of the surgeries to put her on notice.The United States Court of Appeals for the Eleventh Circuit affirmed the district court's decision. The court concluded that the evidence, viewed in the light most favorable to Redding, did not overwhelmingly establish that she knew or should have known about a compensable injury arising out of Coloplast's mesh before September 18, 2010, such that a reasonable jury could not conclude otherwise. As a result, Redding's claims were not time-barred under Florida's four-year statute of limitations. View "Redding v. Coloplast Corp." on Justia Law

The case involves Martha Isabel Rosales-Mendez, a Honduran native who illegally entered the United States. After being apprehended by border patrol agents, she was served with a notice to appear for a removal hearing. The agents recorded an address provided by her boyfriend over the phone, which turned out to be incorrect. Consequently, Rosales-Mendez did not receive the second notice setting the date and time of her removal hearing, leading to her being ordered removed in absentia when she failed to appear.Rosales-Mendez's case was initially reviewed by an immigration judge who ordered her removal in absentia after she failed to attend the hearing. She later discovered the removal order and moved to reopen the removal proceeding, arguing lack of notice. However, the immigration judge denied the motion. The Board of Immigration Appeals affirmed the decision, stating that since Rosales-Mendez failed to provide a correct address, the officials were excused from providing her notice of her removal hearing.The United States Court of Appeals for the Eleventh Circuit denied Rosales-Mendez's petition for review. The court held that immigration officials were not required to give notice of a removal hearing to an alien who provided them an inaccurate home address. The court reasoned that Rosales-Mendez, through her boyfriend, provided an incorrect address and failed to correct it, thereby forfeiting her right to actual notice of her removal hearing. The court concluded that Rosales-Mendez was properly ordered removed in absentia. View "Rosales-Mendez v. U.S. Attorney General" on Justia Law

The case involves PB Legacy, Inc., a Texas-based shrimp breeding company, and American Mariculture, Inc., a Florida-based company that operated a shrimp breeding facility. PB Legacy had a contract with American Mariculture to breed shrimp. However, PB Legacy failed to fulfill its contractual obligations, including removing its shrimp from the facility on time. When American Mariculture threatened to harvest the abandoned shrimp, PB Legacy sued in state court. After a failed attempt to resolve the dispute, American Mariculture used the shrimp to launch a competing company, American Penaeid, Inc. PB Legacy then sued American Mariculture, Penaeid, and their CEO, Robin Pearl, in federal court, alleging conversion, defamation, trade secret misappropriation, breach of contract, unfair competition, and unjust enrichment.The case proceeded to a jury trial in the United States District Court for the Middle District of Florida. During the trial, the district judge had to leave before the jury returned its verdict. The parties agreed to have a magistrate judge receive the verdict. However, the magistrate judge also responded to several jury questions and rejected a request for clarification about the verdict. The jury awarded $4.95 million in damages to PB Legacy on each of their federal and state trade secret claims. Post-trial motions were filed and denied.The case was appealed to the United States Court of Appeals for the Eleventh Circuit. The defendants argued that the magistrate judge lacked authority to preside over the last three days of trial because the parties did not consent to the magistrate judge’s exercise of Article III authority. The court agreed, stating that while the parties had consented to the magistrate judge receiving the verdict, they had not consented to the magistrate judge performing non-ministerial duties such as responding to jury questions and rejecting a request for clarification about the verdict. The court vacated the judgment, remanded for a new trial, and dismissed the cross-appeal as moot. View "TB Foods USA, LLC v. American Mariculture, Inc." on Justia Law

Sylvan Plowright filed a lawsuit against Miami-Dade County, its police chief, and two of its police officers after one of the officers, Sergio Cordova, fatally shot Plowright’s dog, Niles, during an investigation. The district court dismissed Plowright’s complaint, concluding that Cordova was entitled to qualified immunity because he did not violate any clearly established right when he shot Niles.The United States Court of Appeals for the Eleventh Circuit disagreed with the lower court's decision. The court held that the use of deadly force against a domestic animal constitutes a seizure of its owner’s property subject to the Fourth Amendment’s reasonableness requirement. The court found that under the facts alleged in the complaint, no reasonable officer in Cordova’s position could have believed that Niles posed an imminent danger, and therefore, his decision to shoot Niles falls short of that requirement. The court reversed the dismissal of Plowright’s § 1983 claim against Cordova and remanded for further proceedings. The court also reversed the dismissal of Plowright’s claim for intentional infliction of emotional distress against Cordova. However, the court affirmed the dismissal of Plowright’s intentional-infliction-of-emotional-distress claim against a second officer, as well as his claims against the county and its police chief. View "Plowright v. Miami Dade County" on Justia Law

The case involves Cynthia Allen and Kristine Webb, who filed a class action lawsuit against their employer, AT&T Mobility Services, LLC, alleging pregnancy discrimination under Title VII. The district court denied their motion for class certification, and the plaintiffs settled with AT&T and voluntarily dismissed their case. The following day, Amanda Curlee, who claimed she would have been a member of the proposed class, sought to intervene in the case to appeal the denial of class certification. The district court allowed her to intervene, and she immediately appealed.The district court had denied the original plaintiffs' motion for class certification, and the plaintiffs subsequently settled with AT&T and voluntarily dismissed their case. The court had not addressed the merits of any plaintiff's discrimination claims. Amanda Curlee, who claimed she would have been a member of the proposed class, sought to intervene in the case to appeal the denial of class certification. The district court allowed her to intervene.The United States Court of Appeals for the Eleventh Circuit dismissed Curlee's appeal for lack of jurisdiction. The court found that there was no final decision as required by 28 U.S.C. § 1291 because the district court had not resolved the merits of any plaintiff's discrimination claims. The court held that Curlee, as an intervenor, must litigate her claims on the merits before she can appeal the denial of class certification. The court concluded that it lacked jurisdiction to hear Curlee's appeal because there was no final judgment in the case. View "Curlee v. AT&T Mobility Services, LLC" on Justia Law