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

This appeal presents the issue of whether Deputy John Allen and Sheriff Louis Roberts are entitled to qualified and state-agent immunity from Plaintiff’s complaint that he was arrested pursuant to a warrant based on a false affidavit. After Plaintiff drove a methamphetamine trafficker to an undercover drug sting, Allen obtained a warrant from a magistrate judge and arrested him. Florida charged Plaintiff with aiding and abetting drug trafficking and detained him for over six months before dismissing the charges. Plaintiff sued Allen and Roberts under federal and state law, alleging that Allen illegally arrested, detained, and prosecuted him and that Roberts was deliberately indifferent to and negligently caused Allen’s misconduct. The district court granted summary judgment for the officers.   The Eleventh Circuit affirmed, holding that Allen’s warrant affidavit—excluding any false statements—supplied probable cause for Plaintiff’s arrest. The court explained that Plaintiff’s argument that Allen conspired to violate his constitutional rights fails. The court wrote that Plaintiff cannot identify an underlying constitutional violation. “A plaintiff may state a Section 1983 claim for conspiracy to violate constitutional rights by showing a conspiracy existed that resulted in the actual denial of some underlying constitutional right.” Accordingly, in the absence of a constitutional violation, Plaintiff cannot prove a derivative-conspiracy claim. View "Tyler Land v. Sheriff of Jackson County Florida, et al." on Justia Law

Artists (collectively “plaintiffs”) appealed the district court’s entry of summary judgment in favor of the City of Miami Beach on their First Amendment claim brought against the City under 42 U.S.C. Section 1983. The City contracted with the artists to create and curate a series of artworks that the City would own. The district court entered summary judgment after finding that the City’s removal of one piece of Plaintiffs’ artwork constituted government speech and was immune from First Amendment scrutiny.   The Eleventh Circuit affirmed. The court explained that Plaintiffs argued that “artistic expression” is the type of speech at issue here and concede that it “has sometimes been used to convey government speech.” However, they suggest that the history factor requires the majority of the historical use of a type of speech to have been by the government, as opposed to by private individuals. The court wrote that even assuming, as Plaintiffs contend, that artistic expression has historically been used for private speech more often than government speech, this does not negate the government’s own long historical use of artistic expression to convey messages. The history factor does not require the government to show that it historically commissioned more artwork than private individuals and institutions. The court concluded that just as “governments are not obliged under the First and Fourteenth Amendments to permit the presence of a rebellious army’s battle flag in the pro-veterans parades that they fund and organize,” they are not obliged to display any particular artwork in the art exhibitions that they fund, organize, and promote. View "Jared McGriff, et al. v. City of Miami Beach" on Justia Law

This case stems from a car accident that claimed the lives of four young women. The women’s estates sued the driver who rear-ended their car, for negligence. And the estates sued the driver’s employer, Discount Rock & Sand, Inc., for negligently entrusting the company’s truck to the driver and for vicarious liability for Blanco’s negligent driving. The district court ordered the dismissal of the claim against the driver. The remaining claims against Discount Rock went to trial, and the jury found the company liable and awarded nearly $12 million in damages to the estates. Discount Rock appealed the judgment.   The Eleventh Circuit affirmed. The court concluded that although the stipulation did not comply with rule 41(a)(1)(A)(ii), the district court’s order dismissing the claim against the driver satisfied rule 41(a)(2)—which allows a district court to dismiss an action by court order at a plaintiff’s request. And on the merits, the court concluded that: (1) Discount Rock was not entitled to judgment as a matter of law on the negligent entrustment claim; (2) any error in instructing the jury on the rear-end-collision presumption was harmless; and (3) there was no reversible error in publishing the demonstrative aid. The court explained that there was sufficient evidence for the jury to find that Discount Rock negligently entrusted the driver with the modified truck. And even though the district court erred in instructing the jury on Florida’s rebuttable presumption that a rear-ending driver was negligent, that error wasn’t “to the prejudice of” Discount Rock because Discount Rock failed to produce evidence rebutting the presumption. View "Ricardo Sanchez, et al. v. Discount Rock & Sand, Inc." on Justia Law

Plaintiff’s CPA failed to file Plaintiff’s tax returns for three consecutive years: 2014 through 2016. In 2019, the IRS assessed Plaintiff with over seventy thousand dollars in penalties for violating Section 6651(a) of the Internal Revenue Code and barred him from applying his 2014 overpayment to taxes owed for 2015 and 2016. Plaintiff sued, arguing that his failure to file was due to reasonable cause. He also sought a refund of the penalties. The district court granted summary judgment for the government, concluding that United States v. Boyle foreclosed Plaintiff’s claims. Plaintiff appealed.   The Eleventh Circuit affirmed. The court explained that if Plaintiff’s CPA had failed to file paper tax returns, there would be no question that Boyle would have precluded a reasonable cause defense and a refund. However, the court explained that no circuit court has yet applied Boyle to e-filed tax returns. The court decided that Boyle’s bright line rule applies to e-filed returns. Thus, the court concluded that Plaintiff’s reliance on his CPA does not constitute “reasonable cause” under Section 6651(a)(1). View "Wayne Lee v. USA" on Justia Law

These appeals are about a pending insurance contract dispute between Positano Place at Naples I Condominium Association, Inc., and Empire Indemnity Insurance Company, which issued an insurance policy (the “Policy”) to Positano for coverage of five buildings that Positano owns in Naples, Florida. Following Hurricane Irma, Positano filed a first-party claim for property insurance benefits under the Policy, claiming that Hurricane Irma damaged its property and that the damage was covered by the Policy. Empire determined that there was coverage to only three of the five buildings covered by the Policy but disagreed as to the amount of the loss. Positano sought to invoke appraisal based on the Policy’s appraisal provision. Positano sued Empire in Florida state court, and Empire removed the case to federal court based on diversity jurisdiction. Positano moved to compel appraisal and to stay the case pending the resolution of the appraisal proceedings, which Empire opposed. The magistrate judge issued a report recommending that the district court grant Positano’s motion, and, over Empire’s objection, the district court ordered the parties to appraisal and stayed the proceedings pending appraisal. Empire timely appealed the district court’s order.   The Eleventh Circuit dismissed the appeal. The court concluded that the district court’s order compelling appraisal and staying the proceedings pending appraisal is an interlocutory order that is not immediately appealable under 28 U.S.C. Section 1292(a)(1). The court concluded that the order compelling appraisal and staying the action pending appraisal is not immediately appealable under the Federal Arbitration Act (“FAA”). View "Positano Place at Naples I Condominium Association, Inc. v. Empire Indemnity Insurance Company" on Justia Law

The Eleventh Circuit reversed the district court’s grant of qualified immunity following Plaintiff’s Section 1983 false arrest claim and a state law false arrest claim against two Huntsville, Alabama police officers and the City itself. Plaintiff brought both a Section 1983 false arrest claim and a state law false arrest claim against two Huntsville, Alabama, police officers and the City itself. After the district court concluded that the officers were entitled to qualified immunity because they had arguable probable cause to arrest Plaintiff, he appealed.   The Eleventh Circuit reversed the district court’s grant of summary judgment. The court explained that the officers violated Plaintiff’s clearly established Fourth Amendment rights when they arrested him with neither actual nor arguable probable cause. The district court dismissed Plaintiff’s state law claims against Defendants because it determined that arguable probable cause was a defense to those claims as well. The court wrote that the district court did not conduct any independent analysis of these claims and instead linked its decision directly to the finding of arguable probable cause on the federal claims. There was no actual probable cause to conclude that Plaintiff was driving a car without displaying his license at the time the officer arrived. Nor could any reasonable officer interpret the law as permitting arrest in this case, and therefore there was no arguable probable cause either. Accordingly, the court held that there was no arguable probable cause—i.e., the lack of probable cause was clearly established. View "Roland Edger v. Krista McCabe, et al." on Justia Law

Plaintiff became a firefighter for the City of Sanford, Florida, in 1999. At the age of 47, Plaintiff took disability retirement on November 1, 2018. When Plaintiff retired, she continued to receive free health insurance through the City. Under a policy in effect when Plaintiff first joined the fire department, employees retiring for qualifying disability reasons, such as Plaintiff’s Parkinson’s disease, received free health insurance until the age of 65. But, unbeknownst to Plaintiff, the City changed its benefits plan in 2003. Under the new plan, disability retirees such as Plaintiff are entitled to the health insurance subsidy for only twenty-four months after retiring. Her complaint alleged various claims, including violations of Title I of the Americans with Disabilities Act, the Rehabilitation Act, and the Florida Civil Rights Act. The district court entered judgment for the City.   The Eleventh Circuit affirmed. The court explained that because Plaintiff cannot establish that the City committed any discriminatory acts against her while she could perform the essential functions of a job that she held or desired to hold, her Title I claim fails. For the same reason, so do her claims under the Rehab Act and the Florida Civil Rights Act. Further, the court held that the City’s s benefits plan does not run afoul of the Equal Protection Clause. Disabled persons are not a suspect class, and government-paid health insurance is not a recognized fundamental right. Thus under rational basis review, the City’s benefits plan advances the legitimate governmental purpose of conserving funds. View "Karyn D. Stanley v. City of Sanford, Florida" on Justia Law

CSX Transportation, Inc. is a freight railroad company. General Mills, Inc. operates a cereal processing plant in Georgia near one of CSX’s rail lines. A small connecting railroad connects CSX’s main rail line to General Mills’s plant. A contract between CSX and General Mills governs the use of the sidetrack.A General Mills employee suffered severe injuries while working on the sidetrack and then sued CSX for negligence. A jury found CSX liable, and CSX sought indemnification from General Mills, citing a contractual provision providing General Mills was required to indemnify CSX—regardless of whether CSX alone was responsible. The district court dismissed one of CSX’s breach-of-contract claims and granted General Mills summary judgment on the other.The Eleventh Circuit found that, under the parties’ agreement, General Mills was not required to indemnify CSX if CSX was solely negligent. However, the court disagreed with the district court that Georgia's vouchment doctrine barred CSX from litigating the issue of General Mills’s negligence. Thus, the Eleventh Circuit remanded for the district court to determine if General Mills was at least partially at fault for the injury. If so, then General Mills must indemnify CSX for at least a portion of the settlement and related expenses. View "CSX Transportation, Inc. v. General Mills, Inc." on Justia Law

Plaintiff worked as a hospital nurse for St. Vincent’s Health System. After St. Vincent’s fired her, Plaintiff sued, alleging race discrimination and retaliation under Title VII and 42 U.S.C. 1981. The district court granted summary judgment for St. Vincent’s, and Plaintiff appealed.On appeal, Plaintiff claimed she presented sufficient evidence to survive summary judgment as to all her claims. She also claimed that the district court erred in applying the McDonnell Douglas framework to a “mixed-motive” retaliation claim.The Eleventh Circuit held that Plaintiff's hostile work environment claim failed because there was no evidence of severe or pervasive harassment; Bostock v. Clayton County, 140 S. Ct. 1731 (2020) did nothing to undermine the application of McDonnell Douglas to retaliation claims because but for causation still applies; Plainitff's retaliation claim cannot survive; and disparate-treatment claim fails because there is no evidence that race played a role in her termination. View "Cynthia Diane Yelling v. St. Vincent's Health System" on Justia Law

Plaintiff was hired as the Superintendent of Dothan City Schools in Dothan, Alabama. The employment contract stated Plaintiff could only be terminated for cause. Furthermore, the contract stated that the termination would not be effective until the Board provided Plaintiff with a statement of the cause for termination and allowed her an opportunity for a hearing. Lastly, the employment contract provided that Plainitff could resign with or without cause as long as she gave at least 120 days notice in writing of her resignation to the Board. Six days after Plaintiff’s intent to resign was sent, Plaintiff alleges that the Board voted to terminate Plaintiff’s contract. She brought claims for deprivation of due process and the Fifth and Fourteenth Amendments, conspiracy to violate civil rights in violation of 42 U.S.C. Section 1985, and breach of contract. The district court dismissed Plaintiff’s claims with prejudice.   The Eleventh Circuit reversed the district court’s denial of Plaintiff’s due process claims and affirmed the district court’s denial of Plaintiff’s conspiracy and breach of contract claims. The court explained that instead of construing all ambiguities in Plaintiff’s favor, the district court used the minutes to recharacterize the allegations within Plaintiff’s complaint. When taking the factual allegations in Plaintiff’s complaint as true, there is a plausible claim for relief. In paragraph 18 of the complaint, Plaintiff’s classifies her communication as an “intent” to resign, not an actual resignation. The court wrote that the district court erred by ignoring that Plaintiff had a plausible claim to relief and not drawing reasonable inferences in her favor. View "Phyllis Edwards v. Dothan City Schools, et al" on Justia Law