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

FEB filed suit against the government seeking to quiet title to a spoil island off Key West, known as Wisteria Island. Wisteria Island was formed as a result of the Navy's dredging operations. In this case, it is undisputed that the state of Florida, F.E.B.’s predecessor in interest, had actual knowledge of the United States’ claim to the island in 1951. F.E.B.'s Quiet Title Act (QTA), 28 U.S.C. 2409a(g), claim expired in 1963, well before initiation of this suit. The court concluded that the Submerged Lands Act (SLA), 43 U.S.C. 1301-1315, does not rise to the level of the “clear and unequivocal” abandonment of the government’s interest in Wisteria Island necessary to reset the QTA statute of limitations. The court found F.E.B.'s arguments to the contrary unpersuasive. Therefore, the court found that the QTA's statute of limitations has run and affirmed the district court's dismissal based on lack of subject matter jurisdiction. View "F.E.B. Corp. v. United States" on Justia Law

Plaintiff, a federal inmate, filed suit under the Federal Tort Claims Act (FTCA), 28 U.S.C. 2680, alleging that a Bureau of Prisons (BOP) official withheld wages he was owed for his work while incarcerated. Plaintiff also filed related claims of discrimination, retaliation, and intentional infliction of emotional distress. The court concluded that the record shows that BOP regulations allowed no discretion to refuse to pay the wages at that stage and that the refusal was not grounded in policy. Therefore, the district court erred in dismissing the claim on the basis of the pleading allegations. Accordingly, the court reversed the district court's judgment in regards to the pay claim. The court affirmed as to the other claims. View "Douglas v. United States" on Justia Law

In these consolidated appeals, plaintiff challenged the regulations implementing the contraceptive mandate of the Affordable Care Act, 42 U.S.C. 300gg-13(a), arguing that the regulations’ accommodation for nonprofit organizations with a religious objection to providing contraceptive coverage violates the Religious Freedom Restoration Act (RFRA), 42 U.S.C. 2000bb, et seq. The court concluded that the regulations do not substantially burden plaintiffs' religious exercise and, alternatively, because (1) the government has compelling interests to justify the accommodation, and (2) the accommodation is the least restrictive means of furthering those interests. The court rejected EWTN’s challenges under the Establishment and Free Exercise Clauses because the accommodation is a neutral, generally applicable law that does not discriminate based on religious denomination. The court also rejected EWTN’s challenge under the Free Speech Clause because any speech restrictions that may flow from the accommodation are justified by a compelling governmental interest and are thus constitutional. View "Eternal Word Television Network v. Secretary" on Justia Law

The County petitioned for review of the Board's ruling reversing the ALJ's findings and conclusions in a proceeding under the Federal Water Pollution Control Act, 33 U.S.C. 1367. The parties agreed that the Board incorrectly applied a de novo rather than substantial-evidence standard to the ALJ's findings. The court denied the petition for review, concluding that reviewing for substantial evidence would not have changed the result because the Board reversed the ALJ on matters of law, not fact. View "DeKalb Cnty. v. U.S. Dept. of Labor" on Justia Law

Two separate groups brought pre-enforcement challenges to the MSHA's final rule, entitled Lowering Miners’ Exposure to Respirable Coal Mine Dust, Including Continuous Personal Dust Monitors (New Dust Rule). On the first challenge, the court concluded that, consistent with the plain language of the Federal Mine Safety and Health Act of 1977 (Mine Act), 30 U.S.C. 801 et seq., and with the earlier precedent of this court, the statute as amended clearly evinces a congressional intent that, although it must consider the advice of the National Institute for Occupational Safety and Health (NIOSH), MSHA has the sole responsibility to issue regulations covering the subjects addressed by this rule. On the second challenge, the court concluded that MSHA’s decades-long effort, culminating in the publication of this rule, adequately took into account the scientific evidence of record and arrived at conclusions which, given MSHA’s expertise, are worthy of deference. Accordingly, the court denied the petitions for review. View "National Mining Ass'n v. Secretary, U.S. Dep't of Labor" on Justia Law

Petitioners filed petitions with the EPA seeking to withdraw Alabama's authorization to administer the National Pollutant Discharge Elimination System (NPDES), as part of the Clean Water Act, 33 U.S.C. 1251 et seq. On appeal, petitioners challenged the EPA's findings on some of the 22 alleged deficiencies that did not warrant the initiation of program withdrawal proceedings. The court dismissed the appeal without prejudice, concluding that it does not have jurisdiction to review the interim report with which petitioners disagreed because EPA has not made a "determination" within the meaning of section 1396(b)(1)(D). View "Cahaba Riverkeeper v. EPA" on Justia Law

This case concerns Lolita, a killer whale held in captivity since 1970, who performs each day at the Seaquarium. ALDF filed suit against the USDA for declaratory and injunctive relief, alleging that Seaquarium houses Lolita in conditions that violate the Animal Welfare Act's (AWA), 7 U.S.C. 2131-59, standards for granting a license under 7 U.S.C. 2133-34. The district court granted summary judgment to USDA. The court held that USDA’s renewal of Seaquarium’s April 2012 license is a final agency action subject to judicial review under 5 U.S.C. 706(2). On the merits, the court concluded that USDA’s licensing regulations constitute a reasonable policy choice balancing the conflicting congressional aims of due process and animal welfare, and the AWA licensing scheme is entitled to deference by the court. USDA has the discretionary enforcement authority to revoke a license due to noncompliance. Only Congress possesses the power to limit the agency’s discretion and demand annual, substantive compliance with animal welfare standards. Accordingly, the court affirmed the judgment of the district court. View "Animal Legal Defense Fund v. USDA" on Justia Law

The issue in this case arose from alleged anticompetitive conduct in the ductile iron pipe fittings ("DIPF") market by McWane, Inc., a family-run company headquartered in Birmingham, Alabama. In 2009, following the passage of federal legislation that provided a large infusion of money for waterworks projects that required domestic pipe fittings, Star Pipe Products entered the domestic fittings market. In response, McWane, the dominant producer of domestic pipe fittings, announced to its distributors that (with limited exceptions) unless they bought all of their domestic fittings from McWane, they would lose their rebates and be cut off from purchases for 12 weeks. The Federal Trade Commission ("FTC") investigated and brought an enforcement action under Section 5 of the Federal Trade Commission Act, 15 U.S.C. sec. 45. The Administrative Law Judge ("ALJ"), and a divided Commission, found that McWane's actions constituted an illegal exclusive dealing policy used to maintain McWane's monopoly power in the domestic fittings market. The Commission issued an order directing McWane to stop requiring exclusivity from distributors. McWane appealed, challenging nearly every aspect of the Commission's ruling. After thorough review, the Eleventh Circuit found the Commission's factual and economic conclusions were supported by substantial evidence in the record. Accordingly, the Court affirmed the Commission's ruling. View "McWane, Inc. v. Federal Trade Commission" on Justia Law

Petitioner Rachel Parks appealed an administrative law judge's denial of her application for supplemental security income on behalf of her minor son, D.P. D.P. suffered from attention deficit hyperactivity disorder and borderline intellectual functioning. An administrative law judge denied Parks’s application because D.P. did not suffer from a condition that entitled him to supplemental security income. Parks filed a request for review with the Appeals Council, and she submitted new evidence of D.P.’s academic struggles. The Appeals Council supplemented the record with the new evidence, but denied review. Parks then filed a complaint in the district court, which affirmed the denial of her application. She argued on appeal to the Eleventh Circuit: (1) the administrative law judge's denial of Parks's application was not supported by substantial evidence; and (2) the Social Security Appeals Council needed to make explicit findings of fact about new evidence that it added to the record when it denied review. Because the administrative law judge’s decision was supported by substantial evidence and the Appeals Council was not required to make specific findings about Parks’s new evidence, the Eleventh Circuit affirmed. View "Parks v. Commissioner, Social Security Administration" on Justia Law

The issue this case presented for the Eleventh Circuit's review centered on whether a Florida inmate satisfied the requirements set forth in the Prison Litigation Reform Act. Moliere Dimanche, Jr. sued 16 prison officials in federal court, alleging that he was subjected to harsh treatment in retaliation for filing grievances about prison conditions. The district court dismissed the suit because Dimanche did not file an internal grievance raising this complaint at the institutional level but instead submitted it directly to the Secretary. The court also dismissed for failure to state a claim under 28 U.S.C. 1915(e)(2). The Eleventh Circuit's review showed that Dimanche did satisfy the exhaustion requirement because he met the conditions for filing a grievance directly with the Secretary. Furthermore, the Court concluded that his complaint stated at least some claims that should not have been dismissed without either explanation or leave to amend. Accordingly, the Court reversed and remanded. View "Dimanche v. Brown" on Justia Law