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

Plaintiff filed suit under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., alleging that LINA violated the disability insurance policy's terms and ERISA requirements - in part because LINA ignored the SSA process and the information it generated. The district court granted summary judgment in favor of LINA. Because LINA did not have the evidence presented to the SSA when it denied her last appeal - and in fact could not have had that evidence when it initially denied her claim - the court vacated the district court's judgment and remanded the case with instructions to remand plaintiff's claims to LINA for its consideration of the evidence presented to the SSA. View "Melech v. Life Ins. Co. of North America, et al." on Justia Law

Petitioner, a death row inmate convicted of murder, appealed the denial of his Federal Rule of Civil Procedure 60(b)(6) Motion for Relief from Judgment, arguing that the Supreme Court's decision of Martinez v. Ryan constituted an extraordinary circumstance sufficient to justify the reopening of the final judgment of his prior 28 U.S.C. 2254 habeas petition. Martinez involved the procedural default doctrine as to an ineffective-trial-counsel claim in initial-review state collateral proceedings. The court concluded that Martinez did not apply to petitioner's section 2254 petition that was barred by the Antiterrorism and Effective Death Penalty Act's (AEDPA), 28 U.S.C. 2244(d), statute of limitations. Even assuming that the Martinez rule changed or affected in some way the decisional law about AEDPA's statute of limitations and equitable tolling, any such change in law was not an extraordinary circumstance warranting relief under Rule 60(b)(6). Accordingly, the court affirmed the judgment of the district court. View "Arthur v. Thomas" on Justia Law

Relator filed a qui tam action under the False Claims Act (FCA), 31 U.S.C. 3729-3733, against the District, alleging that the District violated the FCA by fraudulently claiming FEMA reimbursements for ineligible canal repairs. The court held that, as an arm of the State of Florida, the District was not a "person" that could be subjected to suit by a qui tam relator under the FCA. Accordingly, the court affirmed the district court's dismissal of relator's claims. View "Lesinski v. South Florida Water Mgmt." on Justia Law

After appellants failed to pay their medical debts, Urology and UAB West referred the accounts to Franklin Collection Service and added to appellants' accounts a charge for collection fees. The court held that Franklin violated the Fair Debt Collection Practices Act (FDCPA), 15 U.S.C. 1692-1692p, when it collected from appellants a debt that included a 33-and-1/3% "collection fee" when appellants only agreed to pay the actual costs of collection. Accordingly, the court reversed the district court's grant of summary judgment in favor of Franklin on appellants claims under section 1692f of the FDCPA. The court affirmed the remaining federal and state law claims. View "Bradley, et al. v. Franklin Collection Service, Inc." on Justia Law

Defendant pleaded guilty to illegally reentering the United States after removal for committing an aggravated felony. At issue was whether second-degree sexual battery under Florida law was a crime of violence under U.S.S.G. 2L1.2(b)(1)(A). The court concluded that the district court erred by applying only an 8-level enhancement to defendant's base offense level by relying on the Supreme Court precedent, Johnson v. United States, which held that a defendant's prior battery conviction under Florida law was not a violent felony under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e). However the Supreme Court in Johnson was dealing with a different issue under the ACCA, not the amended definition of "crime of violence" under U.S.S.G. 2L1.2, cmt. n.1(B)(iii). Accordingly, the court vacated the sentence and remanded for resentencing. View "United States v. Contreras" on Justia Law

The Federal Acquisition Regulation, 48 C.F.R. 9.407-4(b), governs the acquisition of supplies and services by all federal agencies. At issue was whether a federal agency may suspend two affiliates of an indicted government contractor for the duration of the legal proceedings against the indicted contractor under the Regulation. Because the suspension of an affiliate was included as part of the suspension of the indicted government contractor, the court concluded that legal proceedings initiated against the indicted government contractor tolled the 18-month time limit for the suspension of the affiliates. Accordingly, the court reversed the grant of summary judgment in favor of the affiliates and rendered a judgment in favor of defendants. View "Agility Defense & Gov't Svcs, et al. v. U.S. Dept. of Defense, et al." on Justia Law

Petitioner pled guilty to one count of knowingly possessing firearms and ammunition while being a convicted felon in violation of 18 U.S.C. 933(g)(1) and 924(e). On appeal, petitioner challenged the district court's dismissal of his 28 U.S.C. 2241 habeas petition, brought pursuant to the "savings clause" in 28 U.S.C. 2255(e). The court concluded that defendant has proven that his prior section 2255 motion was "inadequate or ineffective to test the legality of his detention" and that his 2241 petition could not proceed under section 2255(e) because: (1) from the time of his initial sentencing in 2002 throughout his first section 2255 proceeding in 2005, the court's binding precedent in United States v. Hall held that a concealed-firearm offense under Fla. Stat. 790.01 was a "violent felony" under section 924(a); (2) subsequent to petitioner's first 2255 proceeding, the Supreme Court's decision in Begay v. United States set forth a new standard to evaluate which crimes constituted violent felonies under section 924(e), and Begay, as interpreted by United States v. Archer overturned the court's precedent in Hall; (3) Begay's new rule is substantive and applies retroactively to petitioner's section 924(e) claim on collateral review; (4) as a result of pure section 924(a)-Begay error and retroactive application of Begay, petitioner's 235-month sentence exceeds the 10-year statutory minimum authorized by Congress in section 924(a); and (5) the savings clause in section 2255(e) reaches his claim of illegal detention above the statutory maximum penalty. Accordingly, the court vacated and remanded with instructions. View "Bryant, Jr. v. Warden, FCC Coleman - Medium" 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

Defendant appealed his conviction and 420-month sentence for, inter alia, conspiring to distribute and possess with intent to distribute cocaine. The court concluded that when the officers in this case installed GPS trackers on defendant's vehicles without a warrant, they acted in reasonable reliance upon the court's then-binding precedent. Suppression of reliable, competent, and probative evidence was a last resort justified only where the benefits of deterrence outweigh the substantial social costs of exclusion. Therefore, the good-faith exception to the exclusionary rule applied in this case and the district court properly denied defendant's motion based on United States v. Jones. The court also rejected defendant's evidentiary claims. Accordingly, the court affirmed the conviction and judgment. View "United States v. Smith" on Justia Law

This interlocutory appeal arose from an action filed by the FDIC, as receiver for Integrity Bank, against former Bank directors and corporate officers (defendants). The FDIC sought to recover losses that the Bank suffered as a result of defendants' alleged negligent conduct. The court certified questions of state law regarding the standard of care established in O.C.G.A. 7-1-490 and Georgia's business judgment rule to the Supreme Court of Georgia. Because the FDIC has failed to demonstrate the existence of an established and long-standing common law rule barring defendants' affirmative defenses, and because the court must decline to create a barring rule, the FDIC was unentitled to partial summary judgment. Accordingly, the court affirmed in part and certified questions in part. View "FDIC v. Skow, et al." on Justia Law