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

Three children attending a government-owned daycare center at Robins Air Force Base in Georgia suffered physical and emotional abuse at the hands of two childcare workers. The children’s parents, who had entrusted them to the Center and paid for their care, alleged that the government had provided assurances of safety and had adopted formal criteria to prevent and respond to child abuse. The parents claimed that the Center’s director failed to report the abuse to authorities and that the government breached its duty to protect the children.The parents brought suit against the United States under the Federal Tort Claims Act (FTCA) in the United States District Court for the Middle District of Georgia, alleging negligence in failing to protect the children. The government moved to dismiss, arguing that the claims were barred by the FTCA’s intentional tort exception, which preserves sovereign immunity for claims arising out of certain intentional torts, including assault and battery. The district court agreed, finding that the parents’ claims were dependent on the employment status of the abusers and thus fell within the exception. The court dismissed the complaint for lack of subject matter jurisdiction and denied the parents’ motion to amend, reasoning that amendment would be futile.On appeal, the United States Court of Appeals for the Eleventh Circuit held that the FTCA’s intentional tort exception did not apply because the government’s duty to care for and protect the children was independent of the employment status of the abusers. The court vacated the district court’s dismissal and denial of leave to amend, and remanded for further proceedings, instructing the district court to consider whether the parents had stated a claim for relief. View "John Doe, 1 v. USA" on Justia Law

Kevin Lewis, who is legally blind, was arrested in Georgia on an outstanding warrant and detained for less than 48 hours in the Chatham County jail and for about 16 days in the Fulton County jail. During both periods of incarceration, Lewis alleges he was denied assistance with reading documents, navigating the facilities, accessing the grievance process, and obtaining requested medications. He also reports that, despite his requests, he was not provided accommodations for using jail telephones and kiosks.After his release and the dismissal of criminal charges against him, Lewis filed suit in the United States District Court for the Northern District of Georgia against Sheriffs John Wilcher and Patrick Labat in their official capacities, seeking damages and injunctive relief under Title II of the Americans with Disabilities Act and § 504 of the Rehabilitation Act. The district court granted summary judgment in favor of the sheriffs. The court found that Lewis had not produced sufficient evidence to show he was denied benefits or discriminated against “by reason of” his disability, and had not shown that the sheriffs engaged in intentional discrimination. Regarding his claims for injunctive relief, the court determined they were moot because Lewis was no longer incarcerated.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The appellate court held that Lewis failed to present evidence of intentional discrimination by the sheriffs, as required for damages under both statutes. It also held that his claims for injunctive relief were moot, as there was no reasonable expectation he would be subject to the challenged conditions again. The district court’s grant of summary judgment was thus affirmed. View "Lewis v. Sheriff, Fulton County Georgia" on Justia Law

Several individuals who reside in DeKalb County, Georgia, outside the city limits of Atlanta, opposed the construction of a new public safety training facility on city-owned land and wished to collect signatures for a referendum petition to repeal the city ordinance authorizing the lease for the facility. Atlanta’s municipal code required that signature gatherers for such petitions be residents of the City of Atlanta. Because they did not meet this residency requirement, the plaintiffs filed suit against the City, arguing that the restriction violated their First Amendment rights. They sought a preliminary injunction to prevent enforcement of the residency requirement, as well as other relief connected to the signature collection process.The United States District Court for the Northern District of Georgia granted the preliminary injunction, enjoining Atlanta from enforcing the residency requirement for signature gatherers. The court also ordered the City to issue new petitions without the residency restriction and restarted the 60-day signature collection period, while counting previously collected signatures. The City appealed the injunction and obtained a stay from the United States Court of Appeals for the Eleventh Circuit.On appeal, the United States Court of Appeals for the Eleventh Circuit held that the plaintiffs failed to demonstrate irreparable harm sufficient for injunctive relief. The court specified that, under Kemp v. City of Claxton, 496 S.E.2d 712 (Ga. 1998), Georgia law does not allow the use of a referendum petition to challenge or repeal a city ordinance unless it amends the city charter. Because the plaintiffs could not lawfully utilize the referendum process for their intended purpose, they lacked a right to the process and consequently could not show irreparable injury. The Eleventh Circuit vacated the preliminary injunction and remanded the case to the district court for further proceedings. View "Baker v. City of Atlanta" on Justia Law

On November 14, 2020, Officer David Collier and his partner arrived at a residence in Escambia County, Florida, to serve arrest warrants on Jacob Settle and his wife. Settle was in his truck parked closely alongside the house in a dark, debris-filled backyard. When the officers approached and identified themselves, Settle refused to exit the vehicle. After Collier threatened to break the truck’s windows, Settle started the engine and shifted the transmission into gear. Collier, believing he and his partner were in imminent danger due to his proximity to the truck, fired his gun into the vehicle, fatally wounding Settle. Settle’s estate sued Collier for excessive force under the Fourth Amendment and for battery under Florida law.The United States District Court for the Northern District of Florida considered Collier's motion for summary judgment, in which he asserted qualified immunity and state law immunity. The district court denied the motion, finding that a reasonable jury could conclude Collier violated Settle’s constitutional rights by using deadly force on a non-moving vehicle that did not pose a risk to the officers. The district court also denied state immunity for the battery claim, reasoning that a jury could find Collier acted with wanton disregard for Settle’s safety.The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s decision de novo. The appellate court held that Collier was entitled to qualified immunity, concluding that his use of deadly force was objectively reasonable because Settle’s actions—starting the engine and shifting the truck into gear while resisting arrest—could reasonably be perceived as an immediate threat. The court further held that Collier was entitled to state statutory immunity from the battery claim, as his conduct met the standards for justified use of force under Florida law. The Eleventh Circuit reversed the district court’s decision and remanded with instructions to enter judgment for Collier. View "Settle v. Collier" on Justia Law

An individual developed a disabling respiratory condition after working for over fifteen years in coal transportation for two companies. His employment included time as a railroad engineer, during which he transported coal to and from an underground mine and, after that mine's closure, worked at an aboveground preparation plant connected to another underground mine by a long conveyor belt. For much of this period, he was regularly exposed to coal dust. Later, he suffered significant respiratory impairment, leading him to apply for benefits under the Black Lung Benefits Act. After his death, his widow continued the claim for survivor’s benefits.An administrative law judge (ALJ) initially denied the claim, finding that the individual had not worked for the required fifteen years “in an underground coal mine” due to absences and because his work at the preparation plant was not “in an underground mine.” The ALJ concluded that the plant, being over five miles from the underground mine and separated by undeveloped land, was not “appurtenant” to the mine and that conditions at the plant were not substantially similar to an underground mine. The Benefits Review Board reversed, holding that the preparation plant was “appurtenant” to the mine due to functional connection, ownership, and the conveyor system, thus qualifying the employment for the statutory presumption. The Board then awarded benefits based on this presumption.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that aboveground work at an underground coal mine can qualify for the presumption under the Act, but the statutory definition of “coal mine” imposes geographical limits. The court found the Board erred by disregarding the distance between the plant and the mine and by not deferring to the ALJ’s factual determination. The Eleventh Circuit vacated the Board’s decision and remanded for further proceedings. View "Fairfield Southern Company v. Director, Office of Workers' Compensation Programs" on Justia Law

Florida challenged a federal agency document known as the “Informational Bulletin” that interpreted Medicaid’s hold-harmless rule and threatened to claw back billions in Medicaid funds if certain state practices continued. Florida’s Medicaid funding system relies on a Directed Payment Program, under which local governments assess special fees on private hospitals, pool these fees, and transfer the funds to the state agency, which then uses them to secure additional federal matching funds. The state feared the new federal interpretation could jeopardize its program and moved to preliminarily enjoin the Bulletin’s implementation.The United States District Court for the Southern District of Florida, following a magistrate judge’s recommendation, denied Florida’s motion for a preliminary injunction and dismissed the case for lack of subject matter jurisdiction. The district court held that the Bulletin was not a “final agency action” under the Administrative Procedure Act (APA), and therefore not subject to judicial review.The United States Court of Appeals for the Eleventh Circuit reviewed the case and found that, contrary to the district court’s conclusion, the Bulletin was indeed a final agency action subject to judicial review under the APA. However, the Eleventh Circuit held that Florida was unlikely to succeed on the merits of its challenge, concluding that the Bulletin’s interpretation of the Medicaid hold-harmless rule was consistent with the statutory text, was not arbitrary or capricious, and did not require notice-and-comment rulemaking. The court thus reversed the dismissal of the complaint, affirmed the denial of the preliminary injunction, and remanded the case for further proceedings. View "Florida Agency for Health Care Administration v. Administrator for the Centers for Medicare & Medicaid Services" on Justia Law

An individual incarcerated in a county jail in Alabama died after several months in custody, during which his mother, acting as administrator of his estate, alleges he was denied adequate medical care. The county jail had contracted with a private company, Preemptive Forensic Health Solutions, to provide all inmate medical care, even though the company employed no physicians and was allegedly incompetent. Prior to the decedent's death, multiple inmates had died under this company's care, and concerns about inadequate medical treatment became a significant issue in a local sheriff’s election. Despite these concerns and the new sheriff’s efforts to terminate the contract, the county continued and even renewed the agreement with the company, retaining exclusive control over its continuation.The United States District Court for the Northern District of Alabama granted summary judgment to the county, holding that Alabama law limited the county's role to funding inmate healthcare, not providing it, and thus precluded liability under 42 U.S.C. § 1983. The district court determined that only the sheriff was responsible for administering medical care in the jail and that the county had fulfilled its statutory duty by paying for services.The United States Court of Appeals for the Eleventh Circuit reversed this decision. The appellate court held that, under Monell v. Department of Social Services of City of New York and Ancata v. Prison Health Services, Inc., a county can be liable under § 1983 if it adopts or maintains a policy or custom that results in deliberate indifference to inmates' constitutional rights. The court found sufficient evidence for a jury to conclude that the county’s policy of contracting with an incompetent provider—and preventing the sheriff from changing it—could have caused the decedent’s Eighth Amendment violation. The court ruled that Alabama law does not bar such liability and remanded the case for further proceedings. View "Smothers v. Childers" on Justia Law

A nonprofit corporation purchased a 192-unit apartment complex from a government agency in 1994 at a significant discount. In exchange, the purchaser agreed by contract to rent all units at below-market rates to low-income families for 40 years and to comply with annual reporting and administrative fee requirements. Around 2016, the purchaser stopped fulfilling these obligations, including the reporting and fee provisions. The government’s successor agency, through its monitoring agent, notified the purchaser of the breach and initiated legal action seeking remedies under the contract.The purchaser counterclaimed in state court, seeking a declaration that the agreement was no longer enforceable and an injunction against further enforcement. The Federal Deposit Insurance Corporation (FDIC), as successor to the original government agency, intervened, removed the case to the United States District Court for the Middle District of Florida, and moved to dismiss the counterclaim. The purchaser argued that the contract’s obligations ended when Congress repealed the statute that created the original agency and authorized such agreements. The district court rejected this argument, holding that the contract remained enforceable, dismissed the counterclaim with prejudice, and remanded the case to state court.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that the contract’s plain language required the purchaser to comply with its obligations for the full 40-year term, regardless of the repeal of the underlying statute. The court found that the FDIC, as successor, retained both contractual and statutory authority to enforce the agreement. The Eleventh Circuit affirmed the district court’s dismissal of the counterclaim, concluding that the agreement remains enforceable and the purchaser is still bound by its terms. View "Affordable Housing Group, Inc. v. Florida Housing Affordability, Inc." on Justia Law

Several landowners in Walton County, Florida, owned beachfront properties that were affected by a county ordinance enacted during the early stages of the COVID-19 pandemic. In March and April 2020, the county first closed public beaches, then issued a new ordinance that closed all beaches—public and private—making it a criminal offense for anyone, including private owners, to access or use their own beachfront property. The ordinance was enforced by law enforcement officers who entered private property, excluded owners, and threatened arrest for violations. The ordinance remained in effect for about a month, after which it expired and was not renewed.The landowners filed suit in the United States District Court for the Northern District of Florida, raising several claims, including a Takings Clause claim under the Fifth Amendment, and seeking both damages and prospective relief. The district court dismissed the claims for prospective relief as moot, finding the ordinance had expired and was unlikely to recur. On the merits, the district court granted summary judgment to the county on all damages claims, holding that the ordinance was not a per se physical taking but rather a use restriction, and that the government’s actions during a public health emergency were entitled to deference.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It affirmed the dismissal of the claims for prospective relief, agreeing that the ordinance’s expiration rendered those claims moot. However, the court reversed the district court’s judgment on the Takings Clause claim, holding that the ordinance constituted a per se physical taking because it barred owners from their property and allowed government officials to physically occupy and control access. The court remanded for a determination of just compensation, holding that no public emergency, including COVID-19, creates an exception to the Takings Clause. View "Alford v. Walton County" on Justia Law

Elisabeth Koletas, who was four months pregnant, requested a pat-down instead of passing through a body scanner at Southwest Florida International Airport due to concerns about radiation. During the pat-down, Transportation Security Officer (TSO) Sarno conducted a prolonged probe of Koletas’s vaginal area, focusing on material in her underwear. Koletas explained it was toilet paper used to stem pregnancy-related bleeding. Sarno, skeptical, moved Koletas to a private room and brought in Supervising TSO Shane, who further probed Koletas’s underwear and vaginal area. Shane directed Koletas to lift her dress and ultimately removed the toilet paper, finding no prohibited items. Koletas experienced psychological and physical distress from the encounter.After exhausting administrative remedies, Koletas filed suit against the United States in the United States District Court for the Middle District of Florida under the Federal Tort Claims Act (FTCA), alleging battery, false imprisonment, intentional infliction of emotional distress, and negligence. The United States moved to dismiss, arguing that the FTCA’s intentional tort exception preserved sovereign immunity for the alleged battery and false imprisonment. The district court agreed, relying solely on an unpublished Eleventh Circuit decision, and dismissed the case for lack of subject-matter jurisdiction.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the dismissal de novo. The court held that TSOs are “officers of the United States” empowered by law to execute searches under the FTCA’s law enforcement proviso, which waives sovereign immunity for certain intentional torts committed by such officers. The court found the statutory language unambiguous and joined five other circuits in this interpretation. The Eleventh Circuit reversed the district court’s dismissal and remanded the case for further proceedings on the merits. View "Koletas v. USA" on Justia Law