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

Plaintiff, an Orthodox Jew serving time as a prisoner of the State of Florida, filed a complaint against defendants alleging violations of the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. 2000cc et seq. Plaintiff claimed that defendants violated his right to practice his religion because they would not give him a strictly kosher diet. The court concluded that plaintiff's claims were not moot because Florida has not unambiguously terminated its policy which deprived plaintiff of kosher meals; while safety and cost could be compelling governmental interests, defendants have not carried their burden to show that Florida's policy in fact furthered these two interests; and defendants have not carried their burden of showing that Florida's policy of not providing kosher meals to prison inmates was the least restrictive means to further the cost and security interests they asserted. Because defendants failed to satisfy their burden at summary judgment, the court reversed the district court's grant of summary judgment to them and remanded for further proceedings. View "Rich v. Secretary, FL Dept. of Corrections, et al" on Justia Law

Plaintiff sued Coca-Cola, his employer, alleging that the psychiatric/psychological fitness-for-duty evaluation he was required to undergo violated 42 U.S.C. 12112(d)(4)(A), a provision of the Americans with Disabilities Act (ADA). The court affirmed the district court's grant of summary judgment for Coca-Cola, concluding that the evaluation was both job-related and consistent with business necessity and, therefore, permissible under the ADA. View "Owusu-Ansah v. The Coca-Cola Co." on Justia Law

Petitioner, convicted of several drug-related offenses, filed a 28 U.S.C. 2254 petition for a writ of habeas corpus alleging, inter alia, ineffective assistance of counsel. At issue on appeal was whether the district court violated the rule laid down in Clisby v. Jones, that district courts resolve all claims for relief presented in a 28 U.S.C. 2254 petition regardless of whether relief was granted or denied. The court concluded that the district court violated Clisby by failing to address the ineffective assistance of counsel claim the magistrate judge overlooked. Despite a party's failure to object to a magistrate judge's conclusions on legal issues, the court's precedent did not foreclose a party's ability to seek de novo review on appeal. Therefore, the court vacated and remanded. The court suggested that it should, in the exercise of its supervisory powers, adopt a new rule that attached consequences to the failure to object to a magistrate judge's report and recommendation. View "Dupree v. Warden, et al." on Justia Law

Plaintiffs appealed the denial of their motion to vacate the district court's order dismissing their claims against defendants on forum non conveniens grounds. This case arose out of an airplane crash in Venezuela of West Caribbean flight 708, while en route from Panama to Martinique. Plaintiffs' success in arguing to the Court of Cessation that a plaintiff's initial choice of forum under the Montreal Convention precluded other available forums from exercising jurisdiction over the same claims did not constitute "sufficient extraordinary" circumstances to warrant Rule 60(b)(6) relief. Plaintiffs could have raised the same argument initially in their opposition to forum non conveniens dismissal in the Southern District of Florida. Because they failed to do so, the court concluded that their attempt to raise the argument anew in their motion to vacate must also fail. Accordingly, the court affirmed the judgment. View "Bapte, et al. v. West Caribbean Airways, et al." on Justia Law

In this interlocutory appeal, the Secretary appealed the district court's order granting Odebrecht a preliminary injunction barring the Department's enforcement of a Florida law known as the Cuba Amendment, 2012 Fla. Laws 196, section 2. The Amendment prevented any company that did business in Cuba - or that was in any way related to a company that did business in Cuba - from bidding on state or local public contracts in the State of Florida. The court concluded that Odebrecht has demonstrated a substantial likelihood of success on its claim that the Cuba Amendment violated the Supremacy Clause of the Constitution under principles of conflict preemption; Odebrecht would have suffered irreparable harm absent the injunction; the balance of harms strongly favored the injunction; and the injunction did not disserve the public interest. Accordingly, the court affirmed the judgment. View "Odebrecht Construction, Inc. v. Secretary, FL DOT" on Justia Law

Plaintiff, on behalf of herself and the Estate, challenged the district court's grant of summary judgment to Zenith on the Estate's breach of the insurance contract claim. After review and oral argument, the court certified questions to the Florida Supreme Court: (1) Does the estate have standing to bring its breach of contract claim against Zenith under the employer liability policy? (2) If so, does the provision in the employer liability policy which excludes from coverage "any obligation imposed by workers' compensation . . . law" operate to exclude coverage of the estate's claim against Zenith for the tort judgment? (3) If the estate's claim was not barred by the workers' compensation exclusion, does the release in the workers' compensation settlement agreement otherwise prohibit the estate's collection of the tort judgment? View "Morales v. Zenith Ins. Co." on Justia Law

When Dustin Myers and Kelley Bowman ended their engagement, Dustin attempted to retrieve the diamond ring and other personal property. That attempt prompted allegations that Dustin had stolen Kelley's dog, followed by a police chase on rural roadways, and a brief arrest of Dustin and his father, Rodney Myers. The Myers subsequently field a complaint against Murry Bowman, Kelly's father and the magistrate judge of Jefferson County; Wiley Clark Evans, a deputy sheriff who arrested the Myers; and Charles Hutchins, Evans's supervisor. The complaint alleged that defendants conspired to violate and violated the Myers' rights under the Fourth and Fourteenth Amendments, 42 U.S.C. 1983. After reviewing the videotape of the police chase and other evidence, the court agreed with the district court that the Myers' effort to make a federal case out of these events failed: Murry and Evans did not subject the Myers to excessive force; Evans had probable cause to arrest the Myers; Murry did not act under color of law; and the Myers failed to present any evidence that Murry, Evans, and Hutchins conspired to commit a false arrest. Accordingly, the court affirmed the grant of summary judgment against the Myers' complaint. View "Myers, et al v. Bowman, et al" on Justia Law

This case stemmed from requests to the Nursing Facilities from spouses and attorneys-in-fact for medical records of deceased nursing home residents. At issue was whether section 400.145 of the Florida Statutes was preempted by the Federal Health Insurance Portability and Accountability Act of 1996 (HIPAA), 42 U.S.C. 1320d to d-9, and its implementing regulations. The court held that section 400.145 and HIPAA could not be reconciled and the court agreed with the district court that the Florida statute stood as an obstacle to the accomplishment and execution of the full purposes and objectives of HIPAA in keeping an individual's protected health information strictly confidential. Accordingly, the court affirmed the district court's judgment that the Florida statute was preempted and its grant of summary judgment in favor of the Nursing Facilities, explaining that the Florida statue afforded nursing home residents less protection than was required by the federal law. View "OPIS Mgmt. Res. LLC, et al v. Sec., FL Agency for Health Care Admin." on Justia Law

Plaintiff filed a complaint that her former employer discriminated against her after she became pregnant. At issue was whether direct estoppel barred a claim of pregnancy discrimination under state law when a jury found at trial that plaintiff suffered no adverse employment action regarding her claim of retaliation for exercising her right to maternity leave under federal law. The court concluded that the jury verdict against plaintiff's claim of retaliation estopped plaintiff from relitigating the common issue of whether she suffered an adverse employment action. Accordingly, the court affirmed the grant of summary judgment against plaintiff's claim of pregnancy discrimination. View "DuChateau v. Camp, Dresser & McKee, Inc." on Justia Law

Plaintiff appealed from the district court's dismissal of his amended complaint asserting, inter alia, violations of his Constitutional rights, based on the Rooker-Feldman doctrine and res judicata principles. At issue was the preclusive effect of a prior state court eviction action initiated by the City against plaintiff. The court concluded that the state court proceedings as to the First Amendment issues raised in the second amended counterclaim did not end prior to the commencement of the federal action and therefore, Rooker-Feldman did not divest the court of jurisdiction, regardless of whether the claims raised in state court were identical to those raised in federal courts. Consequently, the court need not address the City's arguments as to whether any of the claims asserted in the federal amended complaint were inextricably intertwined with a state court judgment. The court further concluded that none of the federal causes of action were barred by res judicata under Florida's transaction test; defendants have not specified what issues they believe were identical in the federal amended complaint and in the eviction action, but instead, defendants merely restated their res judicata argument as a collateral estoppel argument; and the Admiralty Action had no preclusive effect of any of the issues raised here. Accordingly, the court reversed the district court's dismissal of plaintiff's amended complaint and remanded for further proceedings. View "Lozman v. City of Riviera Beach, FL, et al" on Justia Law