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

A federal prisoner diagnosed with a painful uterine fibroid sought medical treatment, including surgery, while incarcerated. Despite recommendations from two outside physicians for surgical intervention, prison medical staff repeatedly denied her requests for surgery. The prisoner followed the Bureau of Prisons’ four-step administrative grievance process: she attempted informal resolution, filed a formal written request, appealed to the regional director, and then submitted a final appeal (BP-11 form) to the Bureau’s General Counsel. Although she properly completed and mailed the BP-11 form, prison officials claimed they never received or logged it, and the tracking system showed no record of its receipt.The United States District Court for the Northern District of Alabama initially dismissed her Federal Tort Claims Act claims but allowed her to amend her complaint to pursue Eighth Amendment claims against individual medical staff. After further proceedings, the district court dismissed her amended complaint, concluding that she failed to exhaust administrative remedies because her BP-11 form was never logged as received and because she filed her lawsuit before the General Counsel’s response period had expired.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that the prisoner satisfied her obligation to exhaust administrative remedies by properly completing and mailing the BP-11 form, even though prison officials failed to log or process it. The court further held that the administrative remedy process was unavailable to her due to the lack of guidance on how to proceed when officials fail to file a properly submitted grievance, making the process “prohibitively opaque.” The Eleventh Circuit vacated the district court’s dismissal and remanded the case for further proceedings. View "McGuire-Mollica v. Griffin" on Justia Law

A married couple, both citizens of Mexico, have lived in the United States for over twenty years without legal status. They have two U.S.-born children, one of whom, I.L., has a learning disability, ADHD, and requires ongoing medical and educational support. The Department of Homeland Security initiated removal proceedings against the couple, who conceded inadmissibility but sought cancellation of removal, arguing that deportation would cause their son an “exceptional and extremely unusual hardship” due to his special needs and the alleged lack of adequate services in Mexico.An immigration judge found both parents credible and agreed they met the first three statutory requirements for cancellation of removal, but concluded they did not satisfy the hardship requirement. The judge acknowledged the difficulties I.L. would face but determined these did not rise to the high threshold set by the statute. The Board of Immigration Appeals affirmed the judge’s decisions in separate, but materially identical, rulings, agreeing that the hardship standard was not met.The United States Court of Appeals for the Eleventh Circuit reviewed the Board’s application of the hardship standard under the substantial-evidence standard, as clarified by recent Supreme Court precedent. The court held that the Board’s determination was supported by substantial evidence, given the record showed that some medical and educational services were available in Mexico and that the Board applied the correct legal standard. The court denied the petitions for review, holding that the Board’s application of the “exceptional and extremely unusual hardship” standard under 8 U.S.C. § 1229b(b)(1)(D) is reviewable for substantial evidence, and that the Board’s decisions in these cases met that standard. View "Lopez-Martinez v. U.S. Attorney General" on Justia Law

Stanley Watson, a former county commissioner, accused Sheneeka Bradsher and Zarinah Ali of stealing his wallet at a bar. Despite no evidence, he repeatedly demanded their arrest and threatened police officers who did not comply. Bradsher was arrested for disorderly conduct, but later released when Watson's wallet was found in his car. Bradsher and Ali sued Watson for slander, battery, and false imprisonment, winning a $150,500 judgment.Watson filed for bankruptcy, and Bradsher and Ali sought to except their judgment from discharge. The bankruptcy court found Watson genuinely believed the women stole his wallet, discharging the slander and battery debts but ruling the false imprisonment debts nondischargeable. The district court affirmed the nondischargeability of the false imprisonment debts but remanded for further clarification on the slander claim. On remand, the bankruptcy court found the slander debt dischargeable, attributing two-thirds of the damages to false imprisonment and one-third to slander.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that the bankruptcy court did not clearly err in finding Watson willfully and maliciously caused the women’s confinement, making the false imprisonment debts nondischargeable under 11 U.S.C. § 523(a)(6). The court also upheld the bankruptcy court’s allocation of damages, finding it supported by the evidence. The Eleventh Circuit affirmed the judgments in favor of Bradsher and Ali. View "Watson v. Bradsher" on Justia Law

Perfection Bakeries Inc. paid into the Retail, Wholesale and Department Store International Union’s Industry Pension Fund for its employees in Michigan and Indiana. The company later ceased contributions, first in Michigan and then in Indiana, incurring "withdrawal liability" under the Multiemployer Pension Plan Amendments Act of 1980. The Fund calculated this liability using a four-step formula outlined in 29 U.S.C. § 1381. Perfection Bakeries challenged the Fund's calculation, arguing that a specific calculation was performed at the wrong step.The United States District Court for the Northern District of Alabama reviewed the case. The district court granted summary judgment in favor of the Fund, holding that the statutory text unambiguously required the credit to be applied as part of the second adjustment step.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court affirmed the district court's judgment, agreeing that the Fund correctly applied the partial-withdrawal credit at step two of the four-step formula. The court concluded that the statute's language and structure supported the Fund's interpretation, which incorporated all of section 1386, including the credit for previous partial withdrawals, at step two. The court found that this interpretation was consistent with the statutory context and the repeated cross-references to section 1386 throughout the four-step formula. The court rejected Perfection Bakeries' arguments, including the contention that the partial-withdrawal credit should be applied after all four steps, and upheld the Fund's calculation method. View "Perfection Bakeries Inc v. Retail Wholesale & Dept Store International Union" on Justia Law

A transgender prisoner, Robert Bayse, who identifies as a woman named Robbin, is serving two concurrent life sentences in a Georgia prison. Bayse suffers from gender dysphoria and borderline personality disorder and receives hormone therapy and mental-health counseling. Previously, Bayse was allowed to follow female grooming and cosmetic standards at another prison. However, at the current prison, these accommodations were denied, leading Bayse to file a lawsuit against several prison officials, alleging that the denial violated the Eighth Amendment's prohibition against cruel and unusual punishment.The United States District Court for the Southern District of Georgia denied the officials' motion for summary judgment based on qualified immunity. The court found that there was a genuine dispute of material fact regarding whether the social transitioning accommodations were medically necessary and whether the officials acted with deliberate indifference. The court also concluded that the officials were not entitled to qualified immunity because it was clearly established that denying medically necessary treatment for gender dysphoria constituted deliberate indifference.The United States Court of Appeals for the Eleventh Circuit reviewed the case and vacated the district court's decision. The appellate court held that the burden of proving medical necessity for the social transitioning accommodations was on Bayse, and Bayse failed to provide sufficient evidence to meet this burden. The court also determined that the district court erred in its analysis of clearly established law by relying on nonprecedential decisions. Consequently, the Eleventh Circuit instructed the district court to grant qualified immunity to the prison officials. View "Bayse v. Philbin" on Justia Law

A plaintiff, Alin Pop, filed a putative class action against LuliFama.com LLC and other defendants, including several social media influencers, alleging a violation of the Florida Deceptive and Unfair Trade Practices Act (FDUTPA). Pop claimed he purchased Luli Fama swimwear after seeing influencers endorse the products on Instagram without disclosing they were paid for their endorsements. Pop argued that this non-disclosure was deceptive and violated FDUTPA.The case was initially filed in Florida state court but was removed to the United States District Court for the Middle District of Florida. The defendants moved to dismiss the complaint, and the district court granted the motion, dismissing the complaint with prejudice. The court held that because Pop's FDUTPA claim sounded in fraud, it was subject to the heightened pleading standards of Federal Rule of Civil Procedure 9(b). The court found that Pop's complaint failed to meet this standard as it did not specify which posts led to his purchase, which defendants made those posts, when the posts were made, or which products he bought. The court also found that the complaint failed to state a claim under the ordinary pleading standards.Pop appealed to the United States Court of Appeals for the Eleventh Circuit. The Eleventh Circuit affirmed the district court's dismissal, agreeing that Rule 9(b)'s particularity requirement applies to FDUTPA claims that sound in fraud. The court found that Pop's allegations closely tracked the elements of common law fraud and thus required particularity in pleading. The court also held that Pop failed to properly request leave to amend his complaint, and therefore, the district court did not err in dismissing the complaint with prejudice. View "Pop v. LuliFama.com LLC" on Justia Law

Federal agents discovered that an individual was sharing files containing child pornography over a peer-to-peer network. After obtaining a search warrant, law enforcement searched his residence and seized several digital devices. Forensic analysis revealed that he had downloaded and shared over 300 images and 150 videos depicting minors engaged in sexually explicit conduct. He was indicted in the United States District Court for the Middle District of Florida on one count of possessing and accessing with intent to view child pornography involving a minor under twelve years of age. The defendant waived his right to a jury trial and proceeded to a bench trial based on stipulated facts, after which the district court found him guilty.Prior to sentencing, the United States Probation Office prepared a Presentence Investigation Report, which calculated his total offense level as 30, including a five-level enhancement for offenses involving 600 or more images. The calculation treated each video as equivalent to 75 images, based on Sentencing Commission commentary. The defendant objected, arguing that the guideline’s text did not support this interpretation, but the district court overruled the objection and imposed a sentence of 97 months’ imprisonment and 15 years of supervised release. The court also ordered restitution of $3,000 to each of thirteen victims, totaling $39,000, and denied the defendant’s request for a jury to determine restitution. The written judgment included standard conditions of supervised release, which were not individually enumerated at sentencing.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s judgment. The court held that the sentencing guideline unambiguously requires each video frame containing child pornography to be counted as one image, but since the defendant conceded that his conduct exceeded the threshold for the highest enhancement, the sentence was affirmed. The court also held that neither the Fifth nor Sixth Amendments require a jury to determine restitution amounts, and that the district court was not required to disaggregate losses caused by the initial abuse. Finally, the court found no error in the district court’s pronouncement of supervised release conditions. View "USA v. Kluge" on Justia Law

Brandon Fulton alleged that Fulton County took his horses without justification and without paying for them, violating the Fifth Amendment's Takings Clause. He initially sought relief under 42 U.S.C. § 1983 but could not establish that the County acted under an official policy or custom, as required by Monell v. Department of Social Services of New York City.The United States District Court for the Northern District of Georgia dismissed Fulton’s § 1983 claim and denied his motion to amend his complaint to sue directly under the Takings Clause. The district court reasoned that plaintiffs must sue under § 1983 for constitutional takings claims against municipalities and that Fulton failed to allege an official policy or custom causing the violation.The United States Court of Appeals for the Eleventh Circuit reviewed the case and concluded that the Takings Clause of the Fifth Amendment directly authorizes a suit for "just compensation" in federal court. The court held that the Takings Clause is self-executing and guarantees a monetary remedy when the government takes private property. The court emphasized that the Takings Clause provides a direct cause of action independent of § 1983, especially when no other adequate remedy exists. The court vacated the district court's order and remanded the case for further proceedings, allowing Fulton to amend his complaint to sue directly under the Takings Clause. View "Brandon Fulton v. Fulton County Board of Commissioners" on Justia Law

The case involves José Ramón López Regueiro, who filed a lawsuit against American Airlines, Inc. under Title III of the Helms-Burton Act. Regueiro alleged that his father purchased Cuba’s main airport, which was later confiscated by Fidel Castro’s regime. Regueiro inherited his father’s interest in the airport and became a U.S. citizen in 2015. He claimed that American Airlines trafficked in the confiscated property by operating flights in and out of the airport.The United States District Court for the Southern District of Florida dismissed the case. The court agreed with American Airlines that the Helms-Burton Act implicitly required the property owner to be a U.S. citizen when the property was confiscated and the plaintiff to be a U.S. citizen when they acquired an interest in the property. Since Regueiro’s father was not a U.S. citizen when the airport was confiscated and Regueiro became a U.S. citizen only after inheriting the property, the court ruled that Regueiro failed to state a claim.The United States Court of Appeals for the Eleventh Circuit reviewed the case and disagreed with the district court’s interpretation. The appellate court concluded that the Helms-Burton Act does not impose the preconditions that American Airlines argued. The Act provides a cause of action to any U.S. national who owns a claim to confiscated property, regardless of the owner’s citizenship status at the time of confiscation or acquisition. The court also rejected American Airlines’s argument that Regueiro’s ownership of shares in the company that owned the airport did not constitute an ownership interest in the airport itself. The appellate court vacated the district court’s dismissal and remanded the case for further proceedings. View "Regueiro v. American Airlines, Inc." on Justia Law

Todd Joseph Harbuck was charged with possessing a firearm as a convicted felon and possessing a stolen firearm. The indictment alleged that Harbuck qualified for an enhanced sentence under the Armed Career Criminal Act (ACCA) due to his prior convictions, including a South Carolina conviction for assault with intent to kill. Harbuck pleaded guilty to possessing a firearm as a convicted felon but contested the ACCA enhancement, arguing that his South Carolina conviction should not qualify as a "violent felony" and that the ACCA is unconstitutionally vague.The United States District Court for the Southern District of Georgia reviewed Harbuck's objections. The court examined the South Carolina conviction and determined that it qualified as a felony under the ACCA. The court also concluded that the crime was a violent felony under the ACCA, leading to a sentence of fifteen years and eight months in prison. Harbuck appealed the sentence.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court applied the categorical approach to determine whether the South Carolina conviction for assault with intent to kill qualified as a violent felony under the ACCA. The court concluded that the crime's elements, which include an unlawful attempt to commit a violent injury with malicious intent, met the ACCA's definition of a violent felony. The court also rejected Harbuck's argument that the ACCA's elements clause is unconstitutionally vague, citing Supreme Court precedent that upheld the clarity of the elements clause.The Eleventh Circuit affirmed the district court's sentence and judgment, holding that Harbuck's South Carolina conviction for assault with intent to kill qualifies as a predicate violent felony under the ACCA and that the ACCA's elements clause is not unconstitutionally vague. View "USA v. Harbuck" on Justia Law