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

SJH sued HMA for breach of contract and, in the alternative, under the doctrine of promissory estoppel, after HMA reneged on its "promise" to purchase the assets of SJH. By filing the Premerger Notifications, the parties represented the following as true: (1) the Asset Sale Agreement would not become a binding, enforceable contract until signed by the parties; (2) the Letter of Intent superseded any agreements - whether written or oral - that could have existed between the parties regarding HMA's acquisition of the hospital assets; and (3) the parties had a good faith intention to complete the transaction and were not using the notification process to vet a purely hypothetical transaction with the agencies. To this end, the parties were obligated to attend the hearing the Georgia Attorney General had scheduled and to cooperate with each other in presenting the case of HMA's acquisition. In light of these findings, the court found no error in the district court's decision to grant HMA summary judgment on the breach of contract claim (Count 1). The court also held that SJH's promissory estoppel claim (Count 4) failed because the Letter of Intent "clearly reflected the parties' intentions not to be bound until a definitive and binding [Asset Sale Agreement] was finalized and executed." View "St. Joseph Hospital, Augusta, et al v. Health Mgmt. Assoc., Inc." on Justia Law

Petitioner, a Florida prison inmate awaiting execution, petitioned for a writ of habeas corpus. After the district court denied the petition, it issued a certificate of appealability with respect to certain issues. At issue was whether the Indictment Clause of the Fifth Amendment required that an aggravating factor relied on as the basis for the imposition of the death sentence in a state prosecution for capital murder be alleged in the indictment; whether the Sixth Amendment required that such aggravating factor be found by a jury beyond a reasonable doubt; and whether the Sixth Amendment required that the aggravating factor relied on by the State for the imposition of a death sentence be alleged in a state court indictment charging the defendant with capital murder. The court held that, in rejecting petitioner's Indictment Clause claim, the Florida Supreme Court did not hand down a decision contrary to a Supreme Court holding; Evans v. Sec'y, Fla. Dep't of Corrs., which was indistinguishable from the case here, required that the court affirm the district court's resolution of the Sixth Amendment issue; and there was no reason to require the State to notify defendants of the aggravating factors that it intended to prove. View "Grim, Jr. v. Secretary, FL DOC" on Justia Law

United Fire, as subrogee for Robert and Theresa Corral, brought a strict products liability suit against Whirlpool, alleging that a Whirlpool-manufactured clothes dryer caused a fire in the Corrals' home. United Fire appealed the district court's orders excluding the proffered testimony of two expert witnesses, Mr. Arms and Dr. Clarke, and granting Whirlpool's motion for summary judgment on United Fire's sole claim of relief. The court held that excluding the part of Mr. Arms' testimony regarding the physical origin of the fire was an abuse of discretion where the testimony was based on a widely accepted methodology and grounded in the available physical evidence. While Dr. Clarke's ultimate conclusions could be contested, it was an abuse of discretion to conclude that the basic methodology applied to analyze the metal dryer duct lacked minimum scientific reliability. Applying the "Cassisi inference," the court held that there were genuine issues as to whether a manufacturing defect within the dryer caused the fire. Accordingly, the court affirmed in part and reversed in part the exclusion of Mr. Arms' expert testimony; reversed the exclusion of Dr. Clarke's expert testimony; reversed the grant of summary judgment; and remanded for further proceedings. View "United Fire and Casualty Co. v. Whirlpool Corp." on Justia Law

Plaintiff claimed that his former employer discriminated against him on account of his age when it terminated his employment, in violation of the Age Discrimination in Employment Act of 1967 (ADEA), 29 U.S.C. 621 et seq. The employer argued that the reason for plaintiff's discharge was due to a reduction in force (RIF), not his age, 71-years-old. After thorough review of the record with benefit of oral argument, the court affirmed the district court's grant of summary judgment in favor of the employer, concluding that no reasonable fact finder could find that the employer's decision was "but-for" his age and plaintiff had not established that the project manager acted as a mere cat's paw for the assistant project manager's discriminatory animus. View "Sims, Jr. v. MVM, Inc." on Justia Law

Defendant pled guilty to conspiracy to commit bank fraud, conspiracy to commit identity theft and access device fraud; and wrongfully obtaining and transferring individually identifiable health information for personal gain. On appeal, defendant challenged her sentence. The court held that the plain language of the sentencing guideline at issue did not apply to defendant's mere sale or transfer of the patient's identifying information. The U.S.S.G. 2B1.1(b)(2)(A) enhancement was the appropriate one in defendant's sentencing because the purpose of the conspiracy was realized when the conspirators used the 12 patients' identifying information to obtain the fraudulent credit cards. Thus, the district court procedurally erred in imposing defendant's sentence. Because it was not clear in this case whether the error affected the district court's sentence, the court vacated and remanded for resentencing. View "United States v. Hall" on Justia Law

Codefendants appealed the district court's order awarding damages to the FTC for engaging in deceptive marketing practices, in violation of section 5(a) of the Federal Trade Commission Act, 15 U.S.C. 45(a), and the FTC's Telemarketing Sales Rule (TSR), 16 C.F.R. 310.1-.9. The court held that the amount of net revenue, rather than the amount of profit, was the correct measure of unjust gains under section 13(b). Accordingly, the court held that the district court did not err when it considered defendants' net revenues, instead of their profits, in its calculation for damages. Accordingly, the court affirmed the judgment. View "Federal Trade Commission v. Bishop, et al" on Justia Law

Plaintiffs challenged Florida's "Patient Self-Referral Act of 1992" (the Florida Act), Fla. Stat. 456.053, which prohibited Florida physicians from referring their patients for services to business entities in which the referring physicians have a financial interest. The court concluded that the conflict preemption doctrine did not apply, and the exemptions in federal law allowing physicians serving end-stage renal disease patients to engage in self-referral did not preempt Florida's more restrict law prohibiting such conduct. The court also concluded that the Florida Act did not discriminate against interstate commerce, nor did it impose a burden on interstate commerce that was clearly excessive when compared with the law's putative local benefits. Therefore, the Florida Act did not violate the dormant Commerce Clause. Further, plaintiffs' substantive due process claim failed to survive rational basis scrutiny, and an equal protection claim would fail as well. Accordingly, the court affirmed the judgment. View "Fresenius Medical Care Holding, et al v.Tucker, et al" on Justia Law

This dispute stemmed from WaMu's lease agreement with Interface, the lessor. WaMu subsequently closed as a "failed bank" and entered into receivership under the direction of the FDIC. The FDIC then entered into a Purchase and Assumption Agreement (P&A Agreement) with JPMorgan, which set forth the terms and conditions of the transfer of WaMu's assets and liabilities to JPMorgan. Interface filed a breach of lease claim against JPMorgan. On appeal, Interface challenged two district court orders that granted JPMorgan's motion for summary judgment, denied Interface's motion for summary judgment, and granted the FDIC's, the intervenor, request for declaratory relief. The court concluded that Interface was not an intended third-party beneficiary of the P&A Agreement executed between FDIC and JPMorgan, and, as a result, Interface lacked standing to enforce its interpretation of that agreement. The court also concluded that the district court lacked jurisdiction to award declaratory relief to the FDIC. Consequently, the court vacated and remanded the judgment. View "Interface Kanner, LLC v. JPMorgan Chase Bank, N.A., et al" on Justia Law

Plaintiffs sought damages for terrorist acts committed while they were held hostage in the jungles of Columbia. Plaintiffs suffered repeated acts of international terrorism at the hands of the Revolutionary Armed Forces of Columbia (FARC). In an effort to collect their default judgment against FARC, plaintiffs filed a motion for a Writ of Garnishment in the district court against Mercurio's frozen assets. At issue was whether assets frozen pursuant only to the Foreign Narcotics Kingpin Designation Act, 21 U.S.C. 1901 et seq., qualified as "blocked assets" under the Terrorism Risk Insurance Act of 2002 (Terrorism Act), Pub. L. No. 107-297, 116 Stat. 2322. Under the plain language of the statute, the court held that such assets were not "blocked assets" and thus, the district court's judgment in favor of plaintiffs relied on an erroneous interpretation of the Terrorism Act. Accordingly, the court reversed and remanded. View "Stansell, et al v. Mercurio International S.A., et al" on Justia Law

Due to a technical error in the original indictment and a more substantial mistake by the government in its handling of that error, no indictment was pending against defendant at the time of his sentencing. This caused defendant to challenge the power of the district court to sentence him at all. Defendant also challenged the length of his sentence due to the enactment of the Fair Sentencing Act of 2010 (FSA), Pub. L. 111-120, 2(a), 124 Stat. 2372, after he committed his offenses but before his sentencing. The court concluded that the district court retained the power to sentence defendant, and that the exercise of that power did not violate any of his constitutional rights or run afoul of the Federal Rules of Criminal Procedure. The sentence imposed, however, must be vacated because the district court did not apply the Sentencing Guidelines as revised by the FSA. View "United States v. McIntosh" on Justia Law