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

In 2006, Nivis Martin and her ex-husband participated in a scheme in which the pair lied on a series of mortgage applications relating to property they held in Florida. After a trial by jury, Martin was convicted of multiple counts of bank and wire fraud, sentenced to a prison term of 46 months, and ordered to pay close to $1 million in restitution. On appeal, Martin challenged her convictions, contending that the district court erred in denying her motion for judgment of acquittal on all counts because the evidence was insufficient. She also challenged her sentence, arguing that her offense level should have been reduced pursuant to United States Sentencing Guidelines section 3B1.2 to reflect her minimal or minor role in the offense. Finally, she contended that the trial court erred when it imposed an order of restitution. After thorough review, the Eleventh Circuit affirmed her convictions and sentence, but vacated the restitution award and remand for a new determination of the victims’ losses. View "United States v. Martin" on Justia Law

Defendant Jacques Maddox appealed his 78-month sentence, which was imposed after a jury convicted him of aiding and abetting an attempted armed robbery of a Walgreens drug store in 2013. That jury, however, also acquitted Defendant of aiding and abetting the use of a firearm in furtherance of a crime of violence. On appeal, Defendant argued that the district court erred in imposing: (1) a five-level enhancement based on his accomplice’s brandishing of a firearm during the attempted robbery; and (2) a two-level enhancement based on injuries inflicted on a victim by this accomplice. After careful review, the Eleventh Circuit found no reversible error and affirmed Defendant’s sentence. View "United States v. Maddox" on Justia Law

Plaintiff, a deputy sheriff, filed suit against CCG and its sheriff under 42 U.S.C. 1983, alleging that, upon taking office after winning his election, the sheriff transferred her to a less prestigious position with much less responsibility and authority based on her support of his opponent in the election. The court affirmed the district court's conclusion that (1) her First Amendment claim was foreclosed as a matter of law by this court’s precedent, despite the fact that CCG’s civil service system prohibits employment decisions based on political patronage, and (2) her Fourteenth Amendment claim could not proceed to trial because no genuine dispute existed over whether the sheriff’s proffered reasons for her transfer were a pretext for discrimination. View "Ezell v. Darr" on Justia Law

Plaintiff appealed the dismissal of his 42 U.S.C. 1983 suit, alleging claims related to a beating by prison staff, for which he was denied medical treatment. The district court dismissed the suit for failure to exhaust administrative remedies. The court reversed the district court's judgment because the district court failed to follow the two-step process the court has created for deciding exhaustion challenges, and because in concluding that one of plaintiff's grievances did not exhaust, the district court enforced a procedural bar that the prison may have waived. View "Whatley v. Warden" on Justia Law

Plaintiff filed suit asserting claims for, among other things, unlawful arrest in violation of 42 U.S.C. 1983 and intentional infliction of emotional distress under Florida law, claiming that he was unlawfully arrested without probable cause based only on his refusal of an officer’s request to provide biographical information for a report. The court held that, in the absence of exigent circumstances, the government may not conduct the equivalent of a Terry stop inside a person’s home. However, in this case, because the law on this point was not clearly established in this Circuit, the court affirmed the district court’s entry of summary judgment on qualified immunity grounds to the officer, who reached into plaintiff’s home to arrest and handcuff him when, in the course of what the officer described as a Terry stop, plaintiff declined to identify himself in response to the officer's questioning. The court also affirmed the district court's dismissal of plaintiff's state-law claim for failure to establish a claim. View "Moore v. Pederson" on Justia Law

Plaintiff, currently incarcerated in the Special Management Unit (SMU) at Georgia Diagnostic and Classification Prison (GDCP), filed suit alleging claims stemming from injuries he sustained during a prison riot and from the conditions of his confinement at the hospital after the riot. The court affirmed the dismissal of plaintiff's failure to protect claim arising out of the prison riot because plaintiff did not adequately allege a substantial risk of serious harm in the period leading up the prison riot. However, the court concluded that plaintiff did adequately plead an Eighth Amendment violation arising out of his three-day hospital stay. Moreover, as to the claim that plaintiff had been confined in conditions lacking in basic sanitation, Deputy Warden Powell is not entitled to qualified immunity. The Deputy was put on fair notice both by the court's caselaw and the knowledge that forcing a prisoner to soil himself over a two-day period while chained in a hospital bed creates an obvious health risk and is an affront to human dignity. The court further concluded that plaintiff cannot recover compensatory or punitive damages because he has not alleged any physical injury resulting from his hospital stay, under the Prison Litigation Reform Act, 42 U.S.C. 1997e(e). However, plaintiff can proceed with his claim for nominal damages for a violation of his Eighth Amendment rights. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Brooks v. Warden" on Justia Law

The City filed three separate fair housing lawsuits against Wells Fargo, Bank of America, and Citigroup, alleging that each bank had engaged in a decade-long pattern of discriminatory lending by targeting minorities for predatory loans. Each complaint contained the same two causes of action: one claim arising under the Fair Housing Act (FHA), 42 U.S.C. 3601 et seq., as well as an unjust enrichment claim under Florida law. The district court dismissed the City's FHA claim. The court found that the City has constitutional standing to pursue its FHA claims; under controlling Supreme Court precedent, the “zone of interests” for the FHA extends as broadly as permitted under Article III of the Constitution, and therefore encompasses the City’s claim; while the court agreed with the district court that the FHA contains a proximate cause requirement, the court found that this analysis is based on principles drawn from the law of tort, and that the City has adequately alleged proximate cause; and the court concluded that the “continuing violation doctrine” can apply to the City’s claims, if they are adequately pled. The court concluded that the district court erred in dismissing the City’s federal claims with prejudice and in denying the City’s motion for leave to amend on the grounds of futility because the district court imposed too stringent a zone of interests test and wrongly applied the proximate cause analysis. The court affirmed the dismissal of the state law claim because the benefits the City allegedly conferred on the defendants were not sufficiently direct to plead an unjust enrichment claim under Florida law. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "City of Miami v. CitiGroup Inc." on Justia Law

The City filed three separate fair housing lawsuits against Wells Fargo, Bank of America, and Citigroup, alleging that each bank had engaged in a decade-long pattern of discriminatory lending by targeting minorities for predatory loans. Each complaint contained the same two causes of action: one claim arising under the Fair Housing Act (FHA), 42 U.S.C. 3601 et seq., as well as an unjust enrichment claim under Florida law. The district court dismissed the City's FHA claim. The court found that the City has constitutional standing to pursue its FHA claims; under controlling Supreme Court precedent, the “zone of interests” for the FHA extends as broadly as permitted under Article III of the Constitution, and therefore encompasses the City’s claim; while the court agreed with the district court that the FHA contains a proximate cause requirement, the court found that this analysis is based on principles drawn from the law of tort, and that the City has adequately alleged proximate cause; and the court concluded that the “continuing violation doctrine” can apply to the City’s claims, if they are adequately pled. The court concluded that the district court erred in dismissing the City’s federal claims with prejudice and in denying the City’s motion for leave to amend on the grounds of futility because the district court imposed too stringent a zone of interests test and wrongly applied the proximate cause analysis. The court affirmed the dismissal of the state law claim because the benefits the City allegedly conferred on the defendants were not sufficiently direct to plead an unjust enrichment claim under Florida law. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "City of Miami v. Wells Fargo & Co." on Justia Law

The City filed suit against the Bank, alleging that the Bank engaged in a decade-long pattern of discriminatory lending in the residential housing market that caused the City economic harm. The City asserts a claim arising under the Fair Housing Act (FHA), 42 U.S.C. 3601 et seq., as well as an unjust enrichment claim under Florida law. The district court dismissed the City's FHA claim with prejudice. The court found that the City has constitutional standing to pursue its FHA claims; under controlling Supreme Court precedent, the “zone of interests” for the FHA extends as broadly as permitted under Article III of the Constitution, and therefore encompasses the City’s claim; while the court agreed with the district court that the FHA contains a proximate cause requirement, the court found that this analysis is based on principles drawn from the law of tort, and that the City has adequately alleged proximate cause; and the court concluded that the “continuing violation doctrine” can apply to the City’s claims, if they are adequately pled. The court concluded that the district court erred in dismissing the City’s federal claims with prejudice and in denying the City’s motion for leave to amend on the grounds of futility because the district court imposed too stringent a zone of interests test and wrongly applied the proximate cause analysis. The court affirmed the dismissal of the state law claim because the benefits the City allegedly conferred on the defendants were not sufficiently direct to plead an unjust enrichment claim under Florida law. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "City of Miami v. Bank of America Corp." on Justia Law

In this appeal, the court considered whether Florida’s Rental Tax and Florida’s Utility Tax, as applied to matters occurring on Seminole Tribe lands, violate the tenets of federal Indian law. The court held that Florida’s Rental Tax is expressly precluded by 25 U.S.C. 465, and, in the alternative, is preempted by the comprehensive federal regulation of Indian land leasing. Therefore, the court affirmed the district court's order as to this issue. The court concluded, however, that the district court erred in placing the legal incidence of the Utility Tax on the Tribe and find that, on this record, the Tribe has not demonstrated that the Utility Tax is generally preempted by federal law. Therefore, the court reversed as to this issue and remanded for further proceedings. View "Seminole Tribe v. Stranburg" on Justia Law