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

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 The purchaser argued that the contract’s obligations ended when Congress repealed the statute that created the original agency and authorized such agreements.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

The case involves two Georgia non-profit organizations, New Georgia Project and New Georgia Project Action Fund (collectively referred to as "New Georgia"), and the Georgia Government Transparency and Campaign Finance Commission. New Georgia was accused of violating the Georgia Government Transparency and Campaign Finance Act by failing to register with the Commission and disclose their campaign expenditures and sources. The Commission initiated an investigation and found "reasonable grounds" to conclude that New Georgia had violated the Act.New Georgia then filed a federal lawsuit claiming that the Act violated the First and Fourteenth Amendments. The district court granted a preliminary injunction preventing the state from enforcing the Act against New Georgia. The state appealed, arguing that the district court should have abstained from exercising its jurisdiction under the doctrine established in Younger v. Harris.The United States Court of Appeals for the Eleventh Circuit held that the district court should have abstained under the Younger doctrine. The court found that the state's enforcement action against New Georgia was ongoing and implicated important state interests, and that New Georgia had an adequate opportunity in the state proceeding to raise constitutional challenges. The court vacated the district court's decision and remanded with instructions to dismiss New Georgia's action. View "New Georgia Project, Inc. v. Attorney General" on Justia Law

The case involves Purpose Built Families Foundation, a Florida nonprofit that received federal grants from the Department of Veterans Affairs to serve veterans and their families. In 2022, the Department notified the Foundation that activities and payments under five grants would be terminated or withheld due to "major fiscal mismanagement activities". The Foundation sued the Secretary of Veterans Affairs under the Administrative Procedure Act and received a temporary restraining order. Subsequently, the Department withdrew the challenged notices and the Secretary moved to dismiss the action as moot. The district court granted the motion.The United States Court of Appeals for the Eleventh Circuit affirmed the decision of the district court. The court held that the case was moot, as the Department's withdrawal of the notices meant the Foundation's claims could not provide meaningful relief. It also ruled that neither the voluntary-cessation nor the capable-of-repetition-yet-evading-review exceptions to mootness applied. The court stated that the Department's subsequent actions, including a more robust process and new termination notices, were materially different from the original notices. Therefore, a lawsuit challenging the new termination notices would involve materially different allegations and answers. The court concluded that the Foundation would have ample opportunity for judicial review of the legality of the new terminations, once the administrative process was completed. View "Purpose Built Families Foundation, Inc. v. USA" on Justia Law