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

Allianz appealed the district court's grant of judgment in favor of plaintiff on his claim that Allianz miscalculated the monthly benefit to which he was entitled under a long-term disability insurance policy. Allianz contended that the district court improperly interpreted the offset provision of the policy. The court concluded that the policy's offset provision was not afflicted with ambiguity and the district court should not have resorted to canons of construction to determine the unwritten intent of the provision. Accordingly, the court reversed and remanded for entry of judgment in favor of Allianz. View "Duckworth v. Allianz Life Ins. Co., et al" on Justia Law

Buyers sued Bahamas Sales, and others associated with Bahamas Sales, alleging that they engaged in appraisal fraud. Buyers purchased undeveloped lots in a planned resort in the Bahamas where the purchase contracts contained a provision that required all disputes to be litigated in the Bahamas. The district court dismissed for improper venue. The court held that the district court erred when it determined that Buyers' claims fell within the scope of the lot purchase contracts' forum-selection clauses; the district court erred in applying equitable estoppel to allow the Mortgage Entities and the Credit Suisse Entities (nonsignatories to the lot purchase contracts) to invoke the lot purchase contracts' forum-selection clauses; and reversed the district court's judgment granting the motions to dismiss for improper venue and remanded for further proceedings. View "Bailey, et al v. ERG Enterprises, LP, et al" on Justia Law

SJH sued HMA for breach of contract and, in the alternative, under the doctrine of promissory estoppel, after HMA reneged on its "promise" to purchase the assets of SJH. By filing the Premerger Notifications, the parties represented the following as true: (1) the Asset Sale Agreement would not become a binding, enforceable contract until signed by the parties; (2) the Letter of Intent superseded any agreements - whether written or oral - that could have existed between the parties regarding HMA's acquisition of the hospital assets; and (3) the parties had a good faith intention to complete the transaction and were not using the notification process to vet a purely hypothetical transaction with the agencies. To this end, the parties were obligated to attend the hearing the Georgia Attorney General had scheduled and to cooperate with each other in presenting the case of HMA's acquisition. In light of these findings, the court found no error in the district court's decision to grant HMA summary judgment on the breach of contract claim (Count 1). The court also held that SJH's promissory estoppel claim (Count 4) failed because the Letter of Intent "clearly reflected the parties' intentions not to be bound until a definitive and binding [Asset Sale Agreement] was finalized and executed." View "St. Joseph Hospital, Augusta, et al v. Health Mgmt. Assoc., Inc." on Justia Law

This dispute stemmed from WaMu's lease agreement with Interface, the lessor. WaMu subsequently closed as a "failed bank" and entered into receivership under the direction of the FDIC. The FDIC then entered into a Purchase and Assumption Agreement (P&A Agreement) with JPMorgan, which set forth the terms and conditions of the transfer of WaMu's assets and liabilities to JPMorgan. Interface filed a breach of lease claim against JPMorgan. On appeal, Interface challenged two district court orders that granted JPMorgan's motion for summary judgment, denied Interface's motion for summary judgment, and granted the FDIC's, the intervenor, request for declaratory relief. The court concluded that Interface was not an intended third-party beneficiary of the P&A Agreement executed between FDIC and JPMorgan, and, as a result, Interface lacked standing to enforce its interpretation of that agreement. The court also concluded that the district court lacked jurisdiction to award declaratory relief to the FDIC. Consequently, the court vacated and remanded the judgment. View "Interface Kanner, LLC v. JPMorgan Chase Bank, N.A., et al" on Justia Law

This case stemmed from a dispute related to the purchase of a lot in the Bahamas. The court held that the district court erred when it determined that the appraisal fraud claims were within the scope of the lot purchase contract's forum-selection clause. The court also held that the district court erred in applying equitable estoppel to allow the nonsignatories to the lot purchase contract to invoke the lot purchase contract's Bahamian forum-selection clause. Accordingly, the court reversed the district court's judgment granting the motion to dismiss for improper venue and remanded for further proceedings. View "Bahamas Sales Assoc., LLC v. Byers" on Justia Law

Beneva and Iberiabank became parties to the sublease at issue through a series of assignments. At issue was whether the sublease transferred by the FDIC to Iberiabank after it took over the assets of a failed bank was enforceable despite a clause purporting to terminate the sublease on sale or transfer of the failed bank. Because the court found that the FDIC acted within its power to enforce contracts under 12 U.S.C. 1821(e)(13)(A) and that the termination clause was unenforceable against Iberiabank as the FDIC's transferee, the court affirmed the district court's grant of summary judgment to Iberiabank. View "Iberiabank v. Beneva 41-I, LLC, et al" on Justia Law

This case stemmed from the FCC's issuance of an order requiring telecommunications carriers to make payments into a Universal Service Fund for subsidizing services for certain categories of consumers. At issue was what should happen to the intrastate portion of the fees that the customers paid to reimburse the carriers for the payments they made to the fund. The court held that the district court correctly decided that it lacked jurisdiction to decide the claims. Because the district court lacked jurisdiction to review the FCC's orders at all, it lacked jurisdiction to decide whether the orders were invalid because they were outside the jurisdictional authority of the agency. View "Self v. BellSouth Mobility, Inc., et al" on Justia Law

Plaintiff, the estate of Tore Myhra, brought suit against Royal Caribbean, seeking damages for Mr. Myhra's injuries and death. It alleged that a bacterial infection that he had acquired while on board Royal Caribbean's vessel had caused the tragic events. On appeal, the estate contended that the forum-selection clause should be invalidated both because it was against the statutorily expressed public policy of the United States and because its terms were not reasonably communicated to the Myhras. The court concluded that 46 U.S.C. 30509(a) did not prevent Royal Caribbean from including the forum-selection clause in the Myhras' contract. Nor did the court perceive any procedural or substantive error in the district court's conclusion that the clause was reasonably communicated to the Myhras. Accordingly, the decision of the district court to dismiss the case was correct and the court affirmed the judgment. View "The Estate Of Tore Myhra v. Royal Caribbean Cruises, Ltd." on Justia Law

Plaintiffs, victims of identity theft, appealed the district court's dismissal of their Second Amended Complaint for failure to state a claim upon which relief could be granted. The district court held that among its other deficiencies, the complaint failed to state a cognizable injury. The court found, however, that the complaint stated a cognizable injury for the purposes of standing and as a necessary element of injury in plaintiffs' Florida law claims. The court also concluded that the complaint sufficiently alleged the causation element of negligence, negligence per se, breach of contract, breach of implied contract, breach of the implied covenant of good faith and fair dealing, and breach of fiduciary duty. The complaint similarly alleged facts sufficient to withstand a motion to dismiss on the restitution/unjust enrichment claim. However, the complaint failed to allege entitlement to relief under Florida law for the claims of negligence per se and breach of the implied covenant of good faith and fair dealing. Therefore, the court reversed in part, affirmed in part, and remanded for further proceedings. View "Curry, et al. v. AvMed, Inc." on Justia Law

This case arose out of a leasing agreement between Contour and the Seminole Tribe. Contour appealed from a district court order dismissing its Amended Complaint for lack of subject matter jurisdiction on account of the Tribe's sovereign immunity. The district court rejected Contour's arguments and affirmed the judgment. Because the problems of inconsistency and unfairness that were inherent in the procedural posture of Lapides v. Bd. of Regents of the Univ. Sys. of Ga. were absent in this case, and because an Indian tribe's sovereign immunity was of a far different character than a state's Eleventh Amendment immunity, the court declined to extend Lapides. In regards to Contour's Indian Civil Rights Act, 25 U.S.C. 1301-1303, claim, it must fail because the Supreme Court had already held that Indian tribes were immune from suit under the statute. Finally, in regards to the equitable estoppel claim, that claim was unavailable because it was grounded on a waiver provision contained within a lease agreement that was wholly invalid as a matter of law. View "Countour Spa at the Hard Rock, v. Seminole Tribe of Florida, et al." on Justia Law