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

A passenger aboard a cruise ship alleged that, after becoming inebriated, she was separated from her friends and ended up in a maintenance closet with a crewmember. She stated that she was held against her will and sexually assaulted. Both she and the crewmember gave differing accounts of the incident to FBI agents: she could not recall if she consented to sexual conduct, while the crewmember claimed it was consensual and that he did not know she was intoxicated. The FBI investigator ultimately concluded the encounter was consensual, and prosecutors declined to bring criminal charges.The passenger brought suit in the United States District Court for the Southern District of Florida asserting claims including false imprisonment and sexual assault. In pretrial proceedings, the district court granted her motion for partial summary judgment on the issue of false imprisonment liability, finding that the cruise line had not produced admissible evidence to create a dispute of material fact. The district court excluded the FBI reports as hearsay. At trial, the district court instructed the jury that the cruise line was already liable for false imprisonment and limited the ability of the defendant to challenge the factual basis for that claim. The jury found the cruise line liable for sexual assault but rejected the negligence and intentional infliction of emotional distress claims, awarding over $10 million in damages.On appeal, the United States Court of Appeals for the Eleventh Circuit held that the district court erred in granting partial summary judgment on false imprisonment and in excluding the FBI investigator’s conclusions, which were admissible under the public records exception to the hearsay rule. The appellate court reversed the partial summary judgment on the false imprisonment claim, vacated the judgment as to the false imprisonment and sexual assault claims, and remanded for a new trial on those claims. The negligence and intentional infliction of emotional distress claims remain resolved in favor of the cruise line. View "Doe v. Carnival Corporation" on Justia Law

A physician who operated an addiction clinic was indicted on multiple counts of unlawfully prescribing controlled substances to five undercover law enforcement officers and four actual patients, as well as several counts of obstruction of justice for altering patient records after being indicted. At trial, four former patients testified that the physician prescribed drugs to them following minimal or inadequate medical evaluation, with several testifying to sexual misconduct or exploitation by the physician in connection with their prescriptions. Five undercover officers also testified to receiving prescriptions with little or no medical assessment, and video evidence corroborated their accounts. The prosecution further showed that after his indictment, the physician added false or misleading entries to the medical records of the undercover officers to make it appear that he had conducted more thorough evaluations than he actually had.The United States District Court for the Middle District of Florida granted the physician’s motion for acquittal only as to the conspiracy count but let the case proceed on the remaining charges. A jury convicted the defendant on all remaining counts. At sentencing, the district court adopted a guidelines range of 30 to 37 months but imposed a sentence of 144 months, an upward variance, citing the physician’s sexual misconduct against patients as a significant aggravating factor. The district court explained that the guidelines did not adequately capture the seriousness of the sexual abuse committed in connection with the unlawful prescriptions.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that sufficient evidence supported all convictions for unlawful prescription and obstruction of justice. The court also found that the upward variance in sentencing was reasonable, given the aggravating circumstances, and that the district court did not commit procedural or substantive error. The Eleventh Circuit affirmed the defendant’s convictions and sentence. View "USA v. Hollington" on Justia Law

The key facts concern allegations that Lockheed Martin improperly handled volatile organic compounds at its Orlando facility, resulting in environmental contamination that plaintiffs claim caused neurological illnesses, including multiple sclerosis and Parkinson’s disease, among workers and nearby residents. Plaintiffs relied on expert testimony to show that exposure to specific chemicals could cause the diseases in question.In the United States District Court for the Middle District of Florida, the plaintiffs presented two general causation experts who used epidemiological and other scientific methodologies to link the chemicals to the illnesses. Lockheed Martin challenged the admissibility of these experts’ opinions, arguing they were unreliable. The district court agreed, finding that the first expert failed to adequately explain or reliably apply his “weight of the evidence” methodology and did not sufficiently analyze the Bradford Hill factors. The second expert’s opinions were largely based on the first expert’s report and a statistical analysis that did not properly assess background risk. As a result, the district court excluded both experts’ testimony and granted summary judgment for Lockheed Martin, concluding that plaintiffs lacked admissible general causation evidence. In the related DeMilt case, the summary judgment was partial, but the district court certified it for immediate appeal under Rule 54(b).The United States Court of Appeals for the Eleventh Circuit reviewed whether the district court abused its discretion in excluding the experts and granting summary judgment. The appellate court held that the district court acted within its discretion, as the experts did not adequately explain or reliably apply their methodologies, and their testimony was thus properly excluded. Without this expert evidence, plaintiffs could not establish general causation. The Eleventh Circuit affirmed the district court’s orders excluding the experts and granting summary judgment in favor of Lockheed Martin. View "Davis v. Lockheed Martin Corp." on Justia Law

A political action committee (SMP) created and broadcast a television advertisement during a 2017 Alabama Senate special election. The ad referenced news reports about allegations of sexual misconduct by the Republican nominee. In particular, two key statements appeared in consecutive frames: one stated that the nominee was “banned from the Gadsden Mall . . . for soliciting sex from young girls”; the other noted that “one he approached was 14 and working as Santa’s helper.” The ad ran over 500 times. The nominee, who lost the election, contended that the juxtaposition of these statements created the false and defamatory implication that he had solicited sex from the 14-year-old referenced.In the United States District Court for the Northern District of Alabama, the nominee sued for defamation and false-light invasion of privacy, focusing on the implication created by these two statements together. The case proceeded to a jury trial. The jury found for the plaintiff on both claims and awarded $8.2 million in compensatory damages. The district court denied SMP’s renewed motion for judgment as a matter of law or for a new trial.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed whether there was clear and convincing evidence that SMP acted with “actual malice,” as required under New York Times v. Sullivan, for defamation against a public figure. The court held that, in cases of defamation by implication, the plaintiff must show both that the defendant knew of or recklessly disregarded the falsity of the implication and that the defendant intended to communicate, or recklessly disregarded, the defamatory implication. The court found the evidence insufficient to meet this standard and reversed the district court’s denial of judgment as a matter of law, remanding with instructions to enter judgment for SMP. View "Moore v. Senate Majority PAC" on Justia Law

Two minor plaintiffs, A.G. and G.W., were sex trafficked as teenagers by traffickers who repeatedly brought them to United Inn, a hotel in Decatur, Georgia, owned and operated by Northbrook Industries, Inc. Their traffickers spent time each day at the hotel interacting with staff, and on two occasions, hotel employees allowed the minors back into their room at the trafficker’s request even though they had no identification and were not on the reservation. The hotel was in a high-crime area with frequent prostitution arrests, and it failed to post required anti-trafficking notices. Another plaintiff, C.B., a minor, was sex trafficked at The Hilltop Inn, owned by Naseeb Investments, Inc., by a registered sex offender who was a long-term guest. The hotel placed this offender in an area with other sex offenders, rented him a second room, and complied with his request not to clean it. Employees testified to a pattern of sex trafficking and prostitution at the hotel.In the United States District Court for the Northern District of Georgia, all three plaintiffs brought civil beneficiary claims under the Trafficking Victims Protection Reauthorization Act (TVPRA) against the hotel operators, alleging the hotels knowingly benefited from and participated in trafficking ventures. A.G. and G.W. also asserted state law negligence claims. The district court granted summary judgment to the defendants, finding insufficient evidence of participation in a trafficking venture or knowledge, and concluded A.G. and G.W. were not invitees for their negligence claims.On appeal, the United States Court of Appeals for the Eleventh Circuit held that the TVPRA’s “participation in a venture” element requires more than an arms-length transaction but does not require knowledge of a specific victim. The court found sufficient evidence for a jury to infer the hotels provided personal support to the traffickers, satisfying both the participation and knowledge elements. The court also found disputes of fact regarding invitee status under Georgia law. The Eleventh Circuit vacated the grants of summary judgment and remanded the cases for further proceedings. View "C.B. v. Naseeb Investments, Inc." on Justia Law

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

The case involves a dispute over discovery between two companies engaged in mining operations in Peru and a group of law firms representing Peruvian plaintiffs who allege injuries from toxic exposure. The companies, seeking to defend themselves against these claims and pursuing a related criminal complaint in Peru alleging document falsification and other misconduct by a former attorney, Victor Careaga, filed an ex parte application under 28 U.S.C. § 1782 in the Southern District of Florida. They sought discovery from Careaga, who had worked for the law firms and played a key role in recruiting plaintiffs. The law firms intervened, seeking protective orders to prevent disclosure of certain documents, asserting attorney-client privilege and work product protection.Previously, the United States District Court for the Eastern District of Missouri, where the underlying personal injury cases (Reid and Collins) were pending, had denied the companies' discovery requests as to the active plaintiffs. When the companies sought discovery in Florida, the Southern District of Florida granted the application, which led to the disputed subpoena. The law firms then moved for protective orders, but the magistrate judge and the district judge found that the privilege claims were insufficiently supported—citing vague, bundled privilege logs, lack of individualized document identification, and inadequate supporting affidavits. The district court denied the motions for protective orders.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed only the Halpern law firm's appeal after the other intervenors voluntarily dismissed their appeals. The Eleventh Circuit affirmed, holding that the district court did not abuse its discretion in denying the protective order because Halpern failed to substantiate its privilege and work product claims with adequate evidence and document-specific explanations. The court also found that Halpern was not entitled to further process, such as in camera review or amendment of the privilege log, given these deficiencies. View "The Renco Group Inc. v. Napoli Shkolnik PLLC" 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

Kevil Wingo, a pretrial detainee at the Cobb County Adult Detention Center, died from a perforated gastric ulcer after repeatedly complaining of severe abdominal pain, nausea, and vomiting. Jail nurses employed by WellStar Health Systems misdiagnosed his symptoms as drug withdrawal ("detox") and assured the sheriff’s deputies overseeing security that Wingo was medically stable. Despite Wingo’s persistent requests to be sent to a hospital and his deteriorating condition, the deputies deferred to the medical staff’s judgment, consistent with their training not to make independent medical decisions. Wingo was eventually moved to a padded cell for observation, where he died within hours.The United States District Court for the Northern District of Georgia granted summary judgment in favor of the sheriff’s deputies on the plaintiffs' 42 U.S.C. § 1983 claims, finding that they were protected by qualified immunity because they reasonably relied on medical professionals’ assessments. The district court also granted summary judgment to Deputy Wilkerson on a state law negligence claim, concluding that the plaintiffs’ expert could not establish causation with medical certainty regarding whether Wilkerson’s actions affected Wingo’s chance of survival.The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo and affirmed the district court’s judgment. The Eleventh Circuit held that nonmedical jail officers cannot be found liable for deliberate indifference to a detainee’s serious medical needs when they reasonably rely on the advice of medical professionals. The court further found that the absence of expert testimony establishing causation prevented the state law negligence claim against Deputy Wilkerson from surviving summary judgment. Thus, all claims against the defendant deputies were disposed of in their favor, and the district court’s rulings were affirmed. View "Wingo v. Harris" 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