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

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 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

Plaintiffs worked as detention officers for Glynn County under Sheriff Jump’s supervision. Although it is unclear from the record whether the Officers are formally deputy sheriffs, it is undisputed that they are, at minimum, direct employees of Sheriff Jump, in his official capacity, akin to deputies. The Officers brought a Fair Labor Standards Act (FLSA) collective action alleging that the County “illegally calculated their and other detention officers’ overtime wages.” The County moved to dismiss for failure to state a claim. In response, the Officers amended their complaint to include Sheriff Jump in his individual capacity. The County and Sheriff Jump then moved to dismiss the amended complaint for lack of subject-matter jurisdiction and for failure to state a claim, arguing that neither defendant was the Officers’ employer under the FLSA.   The Eleventh Circuit affirmed both the district court’s denial of the Officers’ motion for leave to amend and its ultimate dismissal of the amended complaint. The court held that the district court correctly dismissed the Officers’ complaint against Sheriff Jump in his individual capacity because he is not an “employer” under the FLSA. Further, the court agreed with the district court that Sheriff Jump would be entitled to Eleventh Amendment immunity when making compensation decisions for his employees. Further, the court held that Georgia “retained its Eleventh Amendment immunity” from suits in federal court for breach-of-contract claims because no statute or constitutional provision “expressly consents to suits in federal court. View "Langston Austin, et al. v. Glynn County, Georgia, et al." on Justia Law

Plaintiff sued The Savannah College of Art and Design, Inc. (“SCAD”) for race discrimination and retaliation after he was fired from his job as Head Fishing Coach. As part of his employment onboarding, however, Plaintiff signed a document agreeing to arbitrate—not litigate—all legal disputes that arose between him and SCAD. Accordingly, SCAD moved to dismiss and compel arbitration. The district court, approving and adopting the magistrate judge’s Report and Recommendation (“R & R”), granted SCAD’s motion. On appeal, Plaintiff argued that the district court erred by ignoring that his agreement with SCAD was unconscionable and that SCAD waived its right to arbitrate. He also argued that the district court abused its discretion in rejecting his early discovery request.   The Eleventh Circuit affirmed the district court’s order granting SCAD’s motion to dismiss and compel arbitration. The court concluded that the Plaintiff’s arbitration agreement is neither substantively nor procedurally unconscionable. Further, the court found that SCAD did not waive its right to enforce arbitration and that the district court did not abuse its discretion in overruling Plaintiff’s request for early discovery. In short, the court concluded that Plaintiff is bound by his agreement to arbitrate his legal claims against SCAD. View "Isaac Payne v. Savannah College of Art and Design, Inc." on Justia Law

Following an investigation, Rollins determined that Plaintiff- John Doe violated its sexual misconduct policy. Doe was able to graduate and receive his undergraduate degree but was not allowed to participate in commencement/graduation ceremonies. Rollins imposed a sanction of dismissal, resulting in permanent separation of Doe without the opportunity for readmission; privilege restrictions, including a prohibition on participating in alumni reunion events on or off campus; and a contact restriction as to Roe. Doe sued Rollins in federal court, asserting two claims under Title IX, 20 U.S.C. Section 1681—one for selective enforcement and one for erroneous outcome—and a third claim under Florida law for breach of contract. Following discovery, the district court excluded the opinions proffered by Doe’s expert as to Rollins’ purported gender bias. Then, on cross-motions for summary judgment, the district court (a) entered summary judgment in favor of Rollins on the Title IX claims and (b) entered partial summary judgment in favor of Doe on the breach of contract claim.   The Eleventh Circuit affirmed. The court concluded that the district court did not abuse its discretion in precluding Doe’s expert from presenting opinions about Rollins’ purported gender bias and that it correctly granted summary judgment in favor of Rollins on Doe’s two Title IX claims. On the breach of contract claim, the court wrote that it cannot review Doe’s challenge to the district court’s partial denial of summary judgment because materiality is not a purely legal issue under Florida law and was later resolved by the jury. View "John Doe v. Rollins College" on Justia Law

Two companies filed a lawsuit in federal court against two of their former employees, who had served in executive positions. The former executives responded by suing the companies in Florida state court. They later moved for summary judgment in the federal action. While that motion was pending, the companies moved for a voluntary dismissal without prejudice of their federal action, which the executives opposed. The district court granted the companies’ motion for voluntary dismissal, and it denied the executives’ request for attorney’s fees and costs incurred in defending the federal lawsuit to that point. On remand, the district court again granted the voluntary dismissal. The executives moved to alter or amend that judgment and be awarded fees and costs immediately, which the court denied. The executives appealed.   The Eleventh Circuit affirmed. The court explained that the district court sufficiently protected the executives from the prejudice of duplicative litigation by essentially inviting them to move for payment of their costs and fees if the companies ever refiled their federal lawsuit. The court adequately explained its reasoning for granting the dismissal without prejudice on that condition. In all aspects of the decision, the court acted within its discretion. View "Emergency Recovery, Inc., et al v. Bryan Hufnagle, et al" on Justia Law

In January 2021, many customers of the online financial services company Robinhood were aggressively buying specific stocks known as “meme stocks” in a frenzy that generated widespread attention. Robinhood suddenly restricted its customers’ ability to buy these meme stocks (but not their ability to sell them). Some Robinhood customers who could not buy the restricted stocks brought this putative class action, seeking to represent both Robinhood customers and all other holders of the restricted meme stocks nationwide who sold the stocks during a certain period. As Robinhood customers, they allege that they lost money because Robinhood stopped them from acquiring an asset that would have continued to increase in value.   The Eleventh Circuit affirmed the district court’s dismissal of the claims. The court explained that Plaintiffs failed to state a claim. The court explained that its contract with Robinhood gives the company the specific right to restrict its customers’ ability to trade securities and to refuse to accept any of their transactions. Thus, the court wrote that because Robinhood had the right to do exactly what it did, Plaintiffs’ claims in agency and contract cannot stand. And under basic principles of tort law, Robinhood had no tort duty to avoid causing purely economic loss. View "Andrea Juncadella, et al v. Robinhood Financial LLC, et al" on Justia Law

Plaintiff filed suit against The University of Miami (Miami), alleging the school should refund a portion of the payments that she made for the Spring 2020 semester since she did not receive the expected benefit of in-person learning. Plaintiff marshaled a number of claims, including breach of express contract, breach of implied contract, and unjust enrichment. Miami filed a motion for summary judgment on each of Plaintiff’s claims, which the district court granted in full.   The Eleventh Circuit affirmed. The court explained that it is entirely valid for Plaintiff to take the position that Miami should have based its prorated refunds on a different day than it did. The problem, however, is that Plaintiff fails to present “more than a scintilla” of evidence to support her contention that Miami should have refunded 48% of the fees for the Spring 2020 semester. The court reasoned that an announcement extending spring break by itself does not support the contention that all fee-based facilities and services were suddenly unavailable to students such that Miami’s refund was inadequate. And while Plaintiff offers a report from an unsworn economist’s input as evidence, Plaintiff cannot rely on that report to show there is a genuine issue of material fact about this point. Unsworn reports may not be taken into account by a district court when it rules on a motion for summary judgment. View "Adelaide Dixon v. University of Miami" on Justia Law

Continental Casualty Company and Valley Forge Insurance Company (collectively, “the insurers”) and Winder Laboratories, LLC and Steven Pressman (collectively, “the insureds”) appeal and cross-appeal from the district court’s judgment in this insurance coverage dispute. In short, the parties’ insurance agreements required the insurers to defend the insureds against certain third party lawsuits. After being sued by non-party Concordia Pharmaceuticals Inc., S.A.R.L. (“Concordia”), the insureds sought coverage under the policies. The insurers agreed to defend the insureds against Concordia, subject to a reservation of rights, including the right to seek reimbursement of defense costs incurred for claims not covered by the policies. The insurance agreements themselves, however, did not provide for reimbursement.   The Eleventh Circuit affirmed. First, the court agreed that the insurers did not have a duty to defend the insureds in the underlying action. To supplement this analysis, the court held that the duty to defend was extinguished when the district court’s ruling was issued. Second, the court agreed that the insurers do not have a right to reimbursement because the reservation of rights letters did not create a new contract, the insurers’ unjust enrichment argument is untenable, and the court wrote that it does not believe the Supreme Court of Georgia would upend the State’s insurance law framework by establishing a right to reimbursement for an insurer who has no contractual right to recoupment. View "Continental Casualty Company, et al v. Winder Laboratories, LLC, et al" on Justia Law

This appeal arose out of an insurance dispute between Plaintiff and Safeco Insurance Company of Illinois. After an accident in which her vehicle suffered substantial damage, Plaintiff made a claim under her Safeco-issued insurance policy for the damage. Safeco declared her vehicle a total loss and paid her what it deemed to be the actual cash value of her vehicle. The district court granted summary judgment to Safeco.   The Eleventh Circuit affirmed. The court explained that as proof that a policyholder is reasonably likely to need to incur dealer fees, Plaintiff pointed to the facts that (1) she incurred dealer fees in purchasing both the Lexus that was totaled and her Subaru replacement vehicle, (2) approximately 50-70% of Safeco policyholders are likely to purchase a vehicle from a dealer, and (3) approximately 85-95% of dealerships charge dealer fees. These facts, viewed in the light most favorable to Plaintiff, do not give rise to a genuine dispute of material fact. Plaintiff’s three data points show a reasonable likelihood that a policyholder will incur dealer fees if she chooses to purchase her replacement vehicle from a dealer. And they show that a policyholder is reasonably likely to purchase a replacement vehicle from a dealer. But they do not show that a policyholder is reasonably likely to need to purchase a replacement vehicle from a dealer. Plaintiff has failed as a matter of law to satisfy the Mills standard; therefore, the district court correctly awarded Safeco summary judgment on this issue. View "Gina Signor v. Safeco Insurance Company of Illinois" on Justia Law