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

Plaintiffs challenged Florida's "Patient Self-Referral Act of 1992" (the Florida Act), Fla. Stat. 456.053, which prohibited Florida physicians from referring their patients for services to business entities in which the referring physicians have a financial interest. The court concluded that the conflict preemption doctrine did not apply, and the exemptions in federal law allowing physicians serving end-stage renal disease patients to engage in self-referral did not preempt Florida's more restrict law prohibiting such conduct. The court also concluded that the Florida Act did not discriminate against interstate commerce, nor did it impose a burden on interstate commerce that was clearly excessive when compared with the law's putative local benefits. Therefore, the Florida Act did not violate the dormant Commerce Clause. Further, plaintiffs' substantive due process claim failed to survive rational basis scrutiny, and an equal protection claim would fail as well. Accordingly, the court affirmed the judgment. View "Fresenius Medical Care Holding, et al v.Tucker, et al" on Justia Law

This appeal involved a county ordinance for permitting stevedores at the Port of Miami in Miami-Dade County. FTS filed suit against the County, which owns and operates the Port. FTS alleged that the County's Port Director did not follow the ordinance's requirements at all but instead protected incumbent stevedores and kept out new entrants and competition, like FTS, by rubber-stamping and automatically renewing permits for all existing stevedore permit holders at the Port and automatically denying permits to all new applicants in violation of the dormant Commerce Clause. The court held that the ordinance as applied violated the dormant Commerce Clause and the market-participant exception was not applicable. The court also held that the evidence provided a sufficient legal basis for the jury's damages award. Accordingly, the court affirmed the judgment. View "Florida Transportation Service v. Miami-Dade County" on Justia Law

Plaintiff brought suit against her former employer under the Age Discrimination in Employment Act, 29 U.S.C. 621 et seq., after she was terminated. The district court granted summary judgment in favor of the employer because plaintiff did not present sufficient evidence from which a jury could conclude that the employer's proffered nondiscriminatory reason for the termination - that plaintiff violated (or appeared to violate) the company's conduct policies - was pretextual. In this case, the corporate executive who terminated plaintiff later said that she was an exceptional employee who had done nothing wrong, had done everything right, and should not have been fired. The court held that such evidence, when combined with a prima facie case, created a jury question as to discrimination. Accordingly, the court reversed and remanded. View "Kragor v. Takeda Pharmaceuticals America" on Justia Law

The Board challenged the district court's determination affirming the validity of a Department of Education regulation that required state and local agencies to reimburse parents and guardians for an independent educational evaluation (IEE) of their children with disabilities. The court held that the Secretary of Education did not exceed its authority in promulgating 34 C.F.R. 300.502, providing parents the right to a publicly financed IEE and therefore, the district court did not err in requiring the Board to reimburse plaintiffs for the IEE that they obtained for their child. View "Phillip C., et al v. Jefferson County Board of Education" on Justia Law

Plaintiff sued defendant under 42 U.S.C. 1983, alleging that her termination was unconstitutional under the First Amendment because it was based on her candidacy. The court held that the First Amendment, as interpreted by the Supreme Court and the Eleventh Circuit, did not require defendant to retain her political opponent after becoming superior court clerk for the county. Accordingly, the court affirmed the district court's grant of summary judgment in favor of defendant. View "Underwood v. Harkins, et al" on Justia Law

In 2010, the Commissioner issued four summonses to third-party financial institutions to determine whether the Miccosukee Tribe had complied with its federal withholding requirements during the period from 2006-2009. The Tribe petitioned to quash the summonses on the grounds of sovereign immunity, improper purpose, relevance, bad faith, and overbreadth. The district court denied those petitions. Because the court concluded that tribal sovereign immunity did not bar the issuance of these third-party summonses, the district court did not clearly err when it found that the summonses were issued for a proper purpose, and the Tribe lacked standing to challenge the summonses for overbreadth, the court affirmed the judgment. View "Miccosukee Tribe of Indians v. United States" on Justia Law

Petitioner, a death row inmate, appealed the district court's denial of his petition for writ of habeas corpus brought pursuant to 28 U.S.C. 2254. Petitioner contended that he was denied a fair trial by an impartial judge and unbiased jury because the jury gave the judge and the bailiff inappropriate gag gifts at the conclusion of the trial. Specifically, some jurors gave the judge chocolate candy in the shape of a penis and a bailiff chocolate candy shaped as female breasts. Petitioner also contended that there was racial discrimination in the selection of the jury. The court held that it was not unreasonable for the Georgia Supreme Court to find that petitioner did not prove purposeful discrimination by the state in the selection of the jury. The court also held, without condoning the regrettable behavior of either, that both the jury and the judge remained impartial and unbiased throughout the trial. Accordingly, the court affirmed the district court's denial of habeas relief. View "Wellons v. Warden, Georgia Diagnostic and Classification Prison" on Justia Law

Plaintiffs, individually and on behalf of all others similarly situated, brought these actions against defendants for injunctive relief and damages under 42 U.S.C. 1983. Plaintiffs alleged that the FDOT promulgated a policy of "detaining" motorists in violation of the Fourth and Fourteenth Amendments. The court held that the complaint allegations did not state a constitutional violation; defendants were entitled to qualified immunity; and summary judgment of the district court denying qualified immunity to defendants was reversed and the case remanded with instructions to dismiss. View "Chandler v. Secretary, FL DOT, et al" on Justia Law

Plaintiff appealed summary judgment in favor of her former employer and against her complaint of discrimination in violation of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101, and Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e. At issue was whether the employer was entitled to sovereign immunity. The court held that the employer was a state agency immune from plaintiff's complaint of disability discrimination and that the district court correctly granted summary judgment against plaintiff's complaint of racial discrimination where plaintiff unequivocally answered "no" when she was asked if her termination had anything to do with her race. View "Ross v. Jefferson Co Dept of Health" on Justia Law

Petitioner, a Honduran national, appealed the denial of his petition for a writ of habeas corpus. This appeal involved the constitutional separation of powers and the limited judicial role in the extradition of a foreign national. On appeal, petitioner contended that the United Nations Convention Against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment barred his extradition by the Secretary of State, that the murder of the victim constituted a political offense for which he could not be extradited, and there was no valid extradition treaty in force between Honduras and the United States. The court held that petitioner's first argument was not ripe because the Secretary of State has not yet determined whether he was likely to be tortured nor decided whether to extradite him, and his other arguments lacked merit. Accordingly, the court vacated in part and affirmed in part the denial of petitioner's petition for a writ of habeas corpus, lifted the stay of the extradition proceedings, and remanded with instructions to dismiss petitioner's claim under the Convention Against Torture. View "Meza v. U.S. Attorney General, et al." on Justia Law