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

After eight years of litigation involving ten different parties, Continental Holdings, Inc. (Continental) appealed the district court’s denial of its November 2015 motion to voluntarily dismiss Houston Pipe Line Company, L.P. and HPL GP, LLC (collectively, Houston) from the case pursuant to Federal Rule of Civil Procedure 41(a)(2). Continental argues that we should reverse the district court’s Rule 41(a)(2) decision and vacate all of the subsequent orders governing its dispute with Houston.   The Eleventh Circuit dismissed the appeal. The court explained that over the course of this litigation, many parties filed motions pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(ii) in an attempt to voluntarily dismiss their claims against another party. For each motion, fewer than all parties involved in the litigation provided a signature. Yet, Rule 41(a)(1)(A)(ii) only permits a plaintiff to dismiss an action without a court order by filing “a stipulation of dismissal signed by all parties who have appeared. The court explained that because multiple motions made under this Rule were not signed by all parties who appeared in the lawsuit, they were ineffective, and the claims they purported to dismiss remain pending before the district court. Consequently, there has not been a final judgment below, and the court explained that it lacks jurisdiction to consider the merits of this appeal. View "City of Jacksonville v. Jacksonville Hospitality Holdings, L.P., et al" on Justia Law

Plaintiff was the Chief Meteorologist at CBS46, an Atlanta news station. But during his tenure, female colleagues raised repeated complaints that he engaged in inappropriate conduct and sexual harassment—including “compliments” about appearance, sexually charged language, requests for nude photos, and more. Plaintiff, who is white, alleges that he was terminated because of his race in violation of 42 U.S.C. Section 1981. The sexual harassment justification, he says, was just a pretext. The district court granted summary judgment to Defendants.   The Eleventh Circuit affirmed. The court wrote that the ultimate question in any discrimination case is whether the defendant intentionally discriminated against the plaintiff based on race. Here, Plaintiff failed to show that a reasonable jury could conclude that Defendant terminated his employment because he was white.   The court explained that Plaintiff notes that the station’s new meteorologist is a Hispanic woman. However, Plaintiff mostly argued that the existence of race data on the corporate form meant that he was fired because he was white. The court explained Plaintiff lacked direct evidence of discrimination, he lacked evidence that Defendant treated his race as a factor favoring his termination, and he lacked evidence that Defendant treated similarly situated non-white employees more favorably. On the other hand, Defendant has produced extensive evidence of Plaintiff’s sexual harassment, which is a valid, nondiscriminatory reason for his termination. The court explained that on this record, no reasonable jury could infer that Defendant’s justification was pretext for race discrimination. View "Paul Ossmann v. Meredith Corporation" on Justia Law

Employer provides security for NASA and employs approximately 40 security officers. Employee was hired as a security officer in 2018. After learning that his pay did not increase as promised after completing his training, Employee and a co-worker who was in a similar position sought reimbursement of unpaid wages. Employee wired both employees their missing wages, but Employee was not paid for other reimbursements he believed he was entitled to.After Employee and several co-workers were caught using their personal cell phones, Employee was suspended pending an investigation. The other co-workers received less severe disciplinary sanctions, if any.After review, the NLRB found that Employee engaged in protected concerted activity on several occasions and that Employer violated Section 8(a)(1)5 of the NLRA. Employer filed a petition for review with the Eleventh Circuit.The Eleventh Circuit denied Employer's petition for review of an NLRB decision finding that Employer unlawfully terminated Employee for engaging in activity protected under the National Labor Relations Act. View "Security Walls, LLC v. National Labor Relations Board" on Justia Law

A nine-year-old girl took her own life after a classmate repeatedly delivered racist insults to her. The girl's mother and grandmother sought to hold the school system and several school officials accountable for her death. The family filed a lawsuit asserting claims arising under federal and state law against the school system and the school officials. The district court granted summary judgment to the school system and its officials, concluding that the family failed to satisfy various elements of their federal statutory claims and that qualified immunity barred at least one of the claims. The court concluded that the state law claims failed on immunity grounds. The family appealed.The Eleventh Circuit affirmed. Although the response of the school system and its officials was "truly discouraging," the standard for relief in cases of student-on-student harassment was not met. The court explained that a reasonable jury could not find that DCS acted with deliberate indifference, that it intentionally discriminated against the girl, or that Defendants' actions were arbitrary or conscience-shocking. Thus, the district court did not err in granting summary judgment to the defendants on the family's Title IX, Title VI, equal protection, and substantive due process claims. View "Jasmine Adams, et al v. Demopolis City Schools, et al" on Justia Law

Plaintiff alleged that Defendant falsely arrested him, used excessive force in doing that, and then was deliberately indifferent to Plaintiff’s alleged medical needs. The district court granted Officer Miller’s motion for summary judgment and dismissed Plaintiff’s case for failure to state a claim.   The Eleventh Circuit affirmed the district court’s entry of summary judgment in part and reversed in part. The court explained that the dash-cam recording from Plaintiff’s interaction with Defendant proves definitively that Defendant did not falsely arrest Plaintiff. And though the dash-cam recording does not resolve Plaintiff’s deliberate indifference claim, Plaintiff hasn’t shown that any violation Defendant may have committed was clearly established. So Defendant is entitled to qualified immunity on that claim as well. As for Plaintiff’s excessive-force claim, the recording did not capture Defendant’s physical arrest of Plaintiff. Accordingly, the court wrote that it must rely on the default summary-judgment rule and assume the truth of Plaintiff’s attestations that Defendant used excessive force in arresting him. Thus the court concluded that the excessive-force claim survives summary judgment. View "Eric K. Brooks v. D Miller" on Justia Law

Appellant informed the court that its case was moot and that it had been moot at the time of our decision. Appellee has since confirmed that had dissolved its limited liability company seven weeks before we decided the case, thereby eliminating any possibility of redress. The Eleventh Circuit, thus, granted Appellant’s motion to dismiss the appeal. The panel vacated its March 31, 2023 order staying the issuance of the mandate. View "Deborah Laufer v. Arpan LLC" on Justia Law

In January 2021, many customers of the online financial services company Robinhood were aggressively buying specific stocks known as “meme stocks” in a frenzy that generated widespread attention. Robinhood suddenly restricted its customers’ ability to buy these meme stocks (but not their ability to sell them). Some Robinhood customers who could not buy the restricted stocks brought this putative class action, seeking to represent both Robinhood customers and all other holders of the restricted meme stocks nationwide who sold the stocks during a certain period. As Robinhood customers, they allege that they lost money because Robinhood stopped them from acquiring an asset that would have continued to increase in value.   The Eleventh Circuit affirmed the district court’s dismissal of the claims. The court explained that Plaintiffs failed to state a claim. The court explained that its contract with Robinhood gives the company the specific right to restrict its customers’ ability to trade securities and to refuse to accept any of their transactions. Thus, the court wrote that because Robinhood had the right to do exactly what it did, Plaintiffs’ claims in agency and contract cannot stand. And under basic principles of tort law, Robinhood had no tort duty to avoid causing purely economic loss. View "Andrea Juncadella, et al v. Robinhood Financial LLC, et al" on Justia Law

Plaintiff sued the United States under the Federal Tort Claims Act, seeking to recover damages he allegedly suffered in an accident with a U.S. Postal Service truck. To meet his burden to show that the crash caused his injuries, Plaintiff planned to rely on expert testimony from several doctors who treated him after the crash. the district court granted the government’s motion for summary judgment. Both the “Court’s orders and Florida law are clear,” it said, that “to prove causation, prognosis, and/or future implications of the injury, the Plaintiff must satisfy Rule 26(a)(2)(B)’s requirements.” The district court held that none of Plaintiff’s filings satisfied those requirements and conducted no analysis on whether they satisfied Rule 26(a)(2)(C).   The Eleventh Circuit vacated the district court’s grant of summary judgment for the government. The court remanded this case to the district court for further proceedings. On remand, the court wrote that the district court should address whether Plaintiff’s disclosures complied with Rule 26(a)(2)(C), or it should issue a new scheduling order invoking its discretionary authority to adjust the default requirements of Rule 26(a)(2). The court affirmed the denial of Plaintiff’s motion for summary judgment. The court explained that no rule requires any non-retained expert witness to file a written report under Rule 26(a)(2)(B). And whether a doctor is retained (or not) depends on whether she was hired to testify or to treat. But district courts retain the discretionary power to tailor disclosure requirements. The court wrote that here, the district court misunderstood that its power to require detailed submissions from Plaintiff’s witnesses was discretionary. View "Cajule Cedant v. USA" on Justia Law

Barges around Pensacola Bay were slammed around during Hurricane Sally, leading to significant damage—including to the Pensacola Bay Bridge, which was closed for months. Skanska, the construction company that owned the barges (and was working on replacing the Bay Bridge) faced hundreds of potential lawsuits. Some were directly related to property damage, but most were economic loss claims from nearby businesses that lost customers during the months-long closure of the bridge. Skanska filed what are called petitions for limitation of liability, one for each of its 28 barges. These petitions invoked the Limitation Act. the district court decided that Skanska could not limit its liability because its own corporate officials were responsible for the negligent acts that led to the barges getting loose in the storm. It dismissed the Limitation Act petitions—freeing the claimants to pursue litigation in state court. Skanska says the district court acted too fast and also disputed several of the district court’s other decisions.   The Eleventh Circuit affirmed. The court explained that Limitation Act allows a federal court to take over all negligence claims to preserve the vessel owner’s right to limit its liability and then proportionally distribute the available assets to the successful claimants. But only to the extent necessary to protect the right to limitation; it does not create an independent right to have the full merits of each individual claim decided in federal court when no limitation is available. Further, the court concluded that it saw no reversible error in the district court’s evidentiary rulings, its findings of fact, or its spoliation sanctions. View "Skanska USA Civil Southeast, Inc. and Skanska USA v. Bagelheads, Inc., et al." on Justia Law

Plaintiff filed suit against The University of Miami (Miami), alleging the school should refund a portion of the payments that she made for the Spring 2020 semester since she did not receive the expected benefit of in-person learning. Plaintiff marshaled a number of claims, including breach of express contract, breach of implied contract, and unjust enrichment. Miami filed a motion for summary judgment on each of Plaintiff’s claims, which the district court granted in full.   The Eleventh Circuit affirmed. The court explained that it is entirely valid for Plaintiff to take the position that Miami should have based its prorated refunds on a different day than it did. The problem, however, is that Plaintiff fails to present “more than a scintilla” of evidence to support her contention that Miami should have refunded 48% of the fees for the Spring 2020 semester. The court reasoned that an announcement extending spring break by itself does not support the contention that all fee-based facilities and services were suddenly unavailable to students such that Miami’s refund was inadequate. And while Plaintiff offers a report from an unsworn economist’s input as evidence, Plaintiff cannot rely on that report to show there is a genuine issue of material fact about this point. Unsworn reports may not be taken into account by a district court when it rules on a motion for summary judgment. View "Adelaide Dixon v. University of Miami" on Justia Law