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

Plaintiff filed suit against defendants under the Family Medical Leave Act (FMLA), 29 U.S.C. 2615, alleging that defendants wrongfully denied his request for eleven weeks of vacation time and terminated his employment. At trial, the jury found that plaintiff was not terminated because he requested leave, but nevertheless awarded him $200,000 in damages. The court concluded that the district court erred by denying defendants' motion for judgment as a matter of law on both plaintiff's claims because plaintiff was not eligible for leave under the FMLA where plaintiff admitted that his leave was not for a period of incapacity. Accordingly, the court reversed and remanded with instructions for the district court to vacate its order awarding attorney fees and to enter judgment in favor of defendants. View "Hurley v. Kent of Naples, Inc., et al." on Justia Law

Plaintiffs filed a putative class action under the Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. 1961-68, alleging, inter alia, that Sanderson payed depressed wages to all genuinely work-authorized employees at its chicken processing plant. The court concluded that plaintiffs have failed to plausibly establish two of the elements of a civil RICO cause of action - that they suffered an injury in the form of wage depression, or that, even if the court were to assume that they had plausibly shown injury and but-for cause, their injury was directly and proximately caused by Sanderson's pattern of 18 U.S.C. 1546 violations. Accordingly, the court affirmed the judgment of the district court. View "Simpson, et al. v. Sanderson Farms, Inc., et al." on Justia Law

Plaintiff, a Honduran citizen who suffered a back injury while employed as a mason aboard one of Carnival's ships, filed suit against Carnival in state court asserting claims of Jones Act, 46 U.S.C. 30104, negligence, unseaworthiness, and failure to provide adequate maintenance and cure. Plaintiff alleged that the physician chosen and paid by Carnival negligently performed his back surgery. Carnival removed to federal court. On appeal, plaintiff appealed the district court's order compelling arbitration of his claims under the Convention on the Recognition and Enforcement of Foreign Arbitral Awards (CREFAA), 9 U.S.C. 201-208. Plaintiff argued that his Jones Act claim did not fall within his employment contract ("Seafarer's Agreement") with Carnival and, therefore, was not within the scope of the contract's arbitration clause. The court concluded that the order compelling plaintiff to arbitrate his claims was "a final decision with respect to arbitration," and the court had appellate jurisdiction. The court also concluded that plaintiff's dispute with Carnival clearly arose out of or in connection with the Seafarer's Agreement and was subject to arbitration. Accordingly, the court affirmed the district court's order. View "Martinez v. Carnival Corp." on Justia Law

Plaintiff filed suit alleging that a corrections officer at the county jail sexually assaulted her. Officers other than the accused moved for dismissal on the basis of qualified immunity. The district court denied the motion. The court concluded that, in determining whether plaintiff alleged a constitutional violation, the district court made two related errors: it applied an incorrect legal standard and it allowed plaintiff to satisfy the standard it applied with conclusory allegations. Accordingly, the court held that plaintiff had failed to plead a constitutional violation and that the officers were therefore entitled to qualified immunity. View "Franklin v. Curry, et al." on Justia Law

Plaintiffs, seafarers who worked aboard cruise ships operated by NCL, filed suit under the Seaman's Wage Act, 46 U.S.C. 10313 et seq. Plaintiffs alleged that NCL did not pay them their full wages because their compensation did not take into account the amounts they were required to pay their helpers to complete their work on embarkation days. On appeal, plaintiffs argued that the district court erred in not awarding penalty wages under the Act. The court concluded that the district court made findings of fact which were supported by the record and the district court did not err by failing to award penalty wages based upon these findings. There was simply no evidence of willful, arbitrary, or willful misconduct on the part of NCL. Accordingly, the court affirmed the judgment of the district court. View "Wallace, et al. v. NCL (Bahamas) Ltd." on Justia Law

Plaintiff filed suit under the Family Medical Leave Act, 29 U.S.C. 2601, against defendants, alleging that defendants demoted her from a ninety-day temporary assignment in retaliation for leaving work to care for an ailing uncle. On appeal, plaintiff contended that defendants were equitably estopped under federal common law from disputing her FMLA eligibility because her manager approved her FMLA leave. The court concluded that plaintiff failed to provide evidence or even assert that she relied on any misrepresentation. Assuming that federal common law equitable estoppel applied to the FMLA, plaintiff failed to assert a prima facie case of estoppel. Accordingly, the court affirmed the district court's grant of summary judgment for defendants. View "Dawkins v. Fulton County, et al." on Justia Law

Plaintiff filed suit against her employer for gender discrimination, racial discrimination, and national origin discrimination under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000 et seq., as well as hostile work environment, unlawful retaliation claims, and state law claims. On appeal, plaintiff challenged the district court's grant of summary judgment in the employer's favor. The court concluded that plaintiff has made out a prima facie case of employment discrimination, but it remained unclear as to whether she created a dispute of material fact regarding whether the reason the employer offered for hiring another employee over her was a pretext for discriminatory animus. Accordingly, the court vacated the district court's grant of summary judgment in favor of the employer regarding plaintiff's employment discrimination claim, remanding for further proceedings. The court affirmed in all other respects. View "Kidd v. Mando American Corp." on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 against the City and others after he was fired from the police department for violating department policies. On appeal, plaintiff challenged the district court's grant of summary judgment in favor of defendants. The court concluded that the district court correctly concluded that plaintiff failed to establish that any of the personnel, internal affairs, or disciplinary decisions about which he complained was made by a final policy maker for the City such that municipal liability attached; plaintiff's First Amendment claims failed because he could not establish that his speech played a substantial part in the police department's decision to conduct internal affairs investigations or terminate him; and plaintiff's false arrest, imprisonment, and malicious prosecution claims also failed because he has not presented any evidence that he was arrested without probable cause and the evidence could not be read to establish that there was a causal connection between either of the individual defendants' actions and plaintiff's arrest, imprisonment, and prosecution. Accordingly, the court affirmed the grant of summary judgment to all defendants. View "Carter, Jr. v. City of Melbourne, FL, et al." on Justia Law

This case arose when three former employees of ASU alleged that they were subjected to a hostile work environment and retaliation during their employment. ASU appealed the district court's judgment. The court concluded that the district court did not err in denying ASU's motion to sever where the district court had broad discretion to deny the severance in the interest of judicial economy; the court did not have jurisdiction to hear ASU's appeal of the district court's denial of its Rule 50(b) and 59(b) motion where ASU had not filed a notice of appeal with the district court clerk; and the district court did not abuse its discretion in awarding front pay. Accordingly, the court affirmed in part and dismissed in part. View "Weatherly, et al. v. Alabama State University" on Justia Law

Employees of MCGP filed suit under the Worker Adjustment and Retraining Act of 1988 (WARN Act), 29 U.S.C. 2101-2109, alleging that MCGP thrice violated the WARN Act's requirement that an employer provide employees 60-days' notice prior to a plant closing or mass layoff. The court affirmed the district court's classification of the February and August layoffs as plant closings; affirmed the district court's determination that MCGP was not entitled to invoke the unforeseeable business circumstances defense; and reversed in part and remanded so that the district court could properly determine whether the employees that MCGP laid off in January were "affected employees" as a result of the February plant closing under the WARN Act, and were thus entitled to notice. View "Weekes-Walker, et al. v. Macon County Greyhound Park, Inc." on Justia Law