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

Early one morning, law enforcement officers went to the home of an individual whose son was suspected of assault and possibly being armed. The officers approached the house from different sides, announced their presence, and knocked on the front and side doors. The resident, believing his son was at the door, opened the back door—where no officer had knocked—and walked back inside without seeing or speaking to any officer. An officer then entered the home through the open back door without a warrant or exigent circumstances, only announcing his presence after passing through the kitchen. The resident, who was in his bedroom, was confronted, tased, handcuffed, and detained outside for a period of time.The resident filed suit in the United States District Court for the Northern District of Florida, alleging unlawful entry and unlawful seizure (including excessive force) in violation of the Fourth Amendment. After discovery, the officer moved for summary judgment on the basis of qualified immunity. The district court denied summary judgment on both the unlawful entry and unlawful seizure claims, finding that material factual disputes precluded qualified immunity. The officer appealed.The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo. The court held that, construing the facts in the light most favorable to the plaintiff, a reasonable jury could find that the officer entered the home without consent, in violation of clearly established Fourth Amendment law. The court affirmed the district court’s denial of summary judgment on the unlawful entry claim. However, the court found that the unlawful seizure and excessive force claims were entirely derivative of the unlawful entry claim, and therefore vacated the denial of summary judgment on those claims, remanding for the district court to treat them as subsumed within the unlawful entry claim. View "Dukes v. Gregory" on Justia Law

After Hurricane Harvey, three licensed insurance adjusters were assigned by an outsourcing company to process claims for a Texas state-created insurer. The adjusters were required to complete additional certification and follow specific procedures set by the insurer. Their contracts labeled them as independent contractors, but the assignments lasted between one and a half to two years, during which they worked exclusively for the insurer. The company set their work schedules, required timesheets, and provided necessary equipment, though the adjusters were responsible for some personal and professional expenses. A shift to remote work introduced new monitoring policies, but the company maintained control over work hours and approval for overtime.The United States District Court for the Southern District of Alabama reviewed cross-motions for summary judgment. Applying a six-factor test to determine employment status under the Fair Labor Standards Act (FLSA), the court found that four factors favored independent contractor status and two favored employee status, with one of the latter given little weight. The district court granted summary judgment to the defendants, concluding the adjusters were independent contractors and thus not entitled to FLSA overtime protections.The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo. The appellate court found that, when viewing the facts in the light most favorable to the adjusters, five of the six factors favored employee status. The court held that a reasonable jury could find the adjusters were employees under the FLSA, as they were economically dependent on the companies, had little control over their work, and their services were integral to the business. The Eleventh Circuit reversed the district court’s summary judgment and remanded the case for further proceedings. View "Galarza v. One Call Claims, LLC" on Justia Law

In this case, several former employees of a seafood company participated in an employee stock ownership plan (ESOP) that was funded by a $92 million loan used to purchase all outstanding company stock from four directors and officers. The plaintiffs alleged that these directors and officers manipulated sales projections and inventory figures to inflate the stock’s valuation, causing the ESOP to overpay by tens of millions of dollars. They further claimed that the plan’s trustee failed to conduct proper due diligence before agreeing to the purchase price. The plaintiffs sought restoration of plan losses, disgorgement of profits, and other equitable relief under ERISA, asserting breaches of fiduciary duty.The plaintiffs filed suit in the United States District Court for the Northern District of Georgia without first exhausting the plan’s internal administrative remedies, despite acknowledging that the plan provided such procedures. They argued that exhaustion was not required for their claims and, alternatively, that they were excused from exhausting due to futility and inadequacy of the remedy. The defendants moved to dismiss on exhaustion grounds. The district court granted the motions, finding that Eleventh Circuit precedent required exhaustion for ERISA claims, and rejected the plaintiffs’ arguments for excusal. The court also denied the plaintiffs’ request for a stay to allow exhaustion, but did not specify whether the dismissal was with or without prejudice.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s dismissal. The appellate court held that ERISA plaintiffs must exhaust available administrative remedies before seeking judicial review, including for breach of fiduciary duty claims, and that no valid excuse relieved the plaintiffs of this obligation. The court also remanded the case for the district court to clarify whether the dismissal was with or without prejudice. View "Bolton v. Inland Fresh Seafood Corporation of America, Inc." on Justia Law

L Squared Industries, Inc., a Florida-based operator of gas stations, purchased a storage tank liability insurance policy from Nautilus Insurance Company to cover cleanup costs resulting from pollution caused by underground storage tank discharges. In 2018, after a consultant’s report identified groundwater contamination at one of its stations, L Squared did not notify Nautilus of the pollution condition until eight months later, despite a policy requirement to provide notice within seven days of becoming aware of such a condition. L Squared subsequently sought indemnification from Nautilus for cleanup and defense costs, but Nautilus denied coverage.L Squared filed suit in Florida state court, seeking a declaration of coverage and damages for breach of contract. The case was removed to the United States District Court for the Middle District of Florida. Both parties moved for summary judgment. The district court granted summary judgment to Nautilus, finding that L Squared failed to comply with the policy’s seven-day notice provision, and thus Nautilus had no duty to defend or indemnify. L Squared’s motion for reconsideration was denied, and it appealed.The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s summary judgment order de novo. The appellate court held that, under Florida law, when an insured breaches a prompt-notice provision but provides notice within the policy period, coverage is not automatically forfeited; rather, the insurer is presumed prejudiced, but the insured may rebut this presumption. In this case, L Squared failed to timely raise arguments or evidence to rebut the presumption of prejudice. The Eleventh Circuit affirmed the district court’s grant of summary judgment in favor of Nautilus, holding that L Squared’s failure to comply with the seven-day notice provision barred coverage. View "L. Squared Industries, Inc. v. Nautilus Insurance Company" on Justia Law

A city commissioner in Coffee County, Georgia, who was active in assisting voters, became involved in a heated exchange with the county’s Elections Supervisor at a polling site during early voting for the 2020 general election. After the confrontation, the police were called, and the commissioner left. Later that day, she returned to the polling site to assist another voter, prompting another police response. A City of Douglas police sergeant then issued her a criminal trespass warning, banning her from all county polling places for the remainder of the election period. When she refused to leave, she was arrested.The commissioner filed a lawsuit in the United States District Court for the Southern District of Georgia against the Elections Supervisor and Coffee County, alleging that the trespass warning violated her First Amendment rights and that her arrest violated the Fourth Amendment. The district court granted summary judgment to the defendants, finding that the police sergeant, not the Elections Supervisor or the County, had issued the trespass warning and made the arrest. The court concluded that the plaintiff failed to show that the defendants caused her alleged injuries, as required under 42 U.S.C. § 1983.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The Eleventh Circuit held that the plaintiff did not present sufficient evidence for a reasonable jury to conclude that the Elections Supervisor, rather than the police sergeant, caused her injuries. The court explained that the sergeant acted as a deliberative and autonomous decision-maker, conducting his own investigation and independently deciding to issue the trespass warning and make the arrest. Because causation is a necessary element of a § 1983 claim, and the plaintiff failed to establish it, summary judgment for the defendants was affirmed. View "Coley-Pearson v. Martin" on Justia Law

In the summer of 2017, an individual and two accomplices committed a series of armed robberies at Walmart stores in Florida, following a consistent pattern of masked, armed entry, coercion of store managers to access cash, and escape in stolen vehicles. The group obtained approximately $100,000 in total. After law enforcement apprehended the accomplices, one of whom was the individual’s cousin, evidence including cell phone data and testimony from a cooperating accomplice implicated the individual. He was indicted on five robbery and firearm charges.The case proceeded to trial in the United States District Court for the Middle District of Florida. The defendant, represented by an attorney who was later disbarred, rejected two plea offers and maintained his innocence, asserting alibis for each incident. His attorney unsuccessfully attempted to secure the cousin’s testimony and sought continuances, which the court denied. At trial, the government presented testimony from the cooperating accomplice and cell phone evidence. The defendant testified in his own defense, denying involvement. The jury convicted him on all counts, and he was sentenced to 319 months’ imprisonment. His direct appeal was affirmed by the United States Court of Appeals for the Eleventh Circuit, which found no arguable issues for review.Subsequently, the defendant filed a motion under 28 U.S.C. § 2255, alleging ineffective assistance of counsel for misadvising him about plea offers and failing to call his cousin as a witness. The district court denied the motion without an evidentiary hearing. On appeal, the United States Court of Appeals for the Eleventh Circuit held that, although counsel’s performance was deficient, the defendant failed to show prejudice as required by Strickland v. Washington. The court affirmed the district court’s denial of relief, concluding there was no reasonable probability that the outcome would have been different absent counsel’s errors. View "Catrell Ivory v. USA" on Justia Law

Jay Gould served as CEO of Interface, Inc., a carpet manufacturer. After an incident at an annual sales meeting in which Gould allegedly became intoxicated and verbally abused an employee, Interface’s board of directors terminated his employment for cause. This followed a prior warning and an investigation by King & Spalding LLP, which corroborated the allegations. Under Gould’s employment agreement, termination for cause resulted in significantly reduced compensation compared to termination without cause.Gould filed suit in the United States District Court for the Northern District of Georgia, alleging breach of contract and arguing that Interface’s determination of cause was made in bad faith. Interface moved for summary judgment, asserting that the contract gave it absolute discretion to determine cause, or, alternatively, that it had acted in good faith. Gould’s arguments in the district court focused on the company’s alleged lack of good faith, contending that the investigation was a sham. The magistrate judge recommended granting summary judgment to Interface, finding both that the company had absolute discretion and, alternatively, that Gould had not shown bad faith. The district court adopted this recommendation and denied Gould’s subsequent motion for reconsideration, ruling that Gould had waived a new argument that Interface had no discretion to determine cause.On appeal to the United States Court of Appeals for the Eleventh Circuit, Gould advanced the new theory that Interface had no discretion to determine cause under the contract. The Eleventh Circuit held that this theory was a new issue, not a subsidiary argument, and that Gould had forfeited it by failing to raise it in the district court. The court affirmed the district court’s judgment, concluding that Gould’s remaining claims did not warrant reversal. View "Gould v. Interface, Inc." on Justia Law

A patient with a long history of severe depression and multiple suicide attempts underwent 95 electroconvulsive therapy (ECT) treatments at a Nebraska hospital between 2014 and 2016. The ECT was administered using a device manufactured by Somatics, LLC. After the treatments, the patient experienced significant memory loss and was diagnosed with a neurocognitive disorder. In 2020, he filed suit against Somatics in the United States District Court for the Middle District of Florida, alleging negligence, strict product liability, breach of warranties, violation of Nebraska’s Consumer Protection Act, and fraudulent misrepresentation, primarily claiming that Somatics failed to adequately warn of the risks associated with ECT.The district court dismissed the claims under Nebraska’s Consumer Protection Act and for fraudulent misrepresentation, merged the strict liability and breach of implied warranty claims, and granted summary judgment to Somatics on the design defect, manufacturing defect, and breach of express warranty claims. The remaining claims for negligence and strict liability, both based on failure to warn, were merged for trial. The jury found that while Somatics failed to provide adequate warnings, this failure was not the proximate cause of the plaintiff’s injuries, and awarded no damages. The district court denied the plaintiff’s post-trial motions, including for a new trial.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s decisions de novo for summary judgment and for abuse of discretion on evidentiary and procedural rulings. The Eleventh Circuit held that the district court properly granted summary judgment on the design defect claim, correctly merged the negligence and strict liability claims, gave an appropriate jury instruction on proximate cause, and did not abuse its discretion in excluding certain evidence and expert testimony. The judgment of the district court was affirmed. View "Thelen v. Somatics, LLC" on Justia Law

A woman was working late at her place of employment, a business located in a commercial cul-de-sac, when she was approached at night by two individuals carrying flashlights. Fearing for her safety, as she did not know they were police officers and they did not identify themselves, she attempted to drive away. The officers, who were investigating a report of a possible break-in at a different address in the same cul-de-sac, fired their weapons at her vehicle as she drove up the driveway. The woman was not physically harmed, but her car was struck by bullets and later declared a total loss. She was detained in a police cruiser for several hours before being released without charges.The United States District Court for the Northern District of Georgia reviewed the woman’s claims under 42 U.S.C. § 1983, alleging unlawful seizure, excessive force, and unlawful property seizure in violation of the Fourth Amendment. The district court granted summary judgment to the officers on state-law claims but denied summary judgment on the federal claims, finding that a reasonable jury could conclude the officers lacked reasonable suspicion or probable cause, and that their actions violated clearly established law. The officers appealed, arguing they were entitled to qualified immunity.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s denial of qualified immunity. The court held that the officers seized the plaintiff both by physical force (when they shot her car) and by a show of authority, that no reasonable officer could have believed there was reasonable suspicion or probable cause to seize or shoot at her, and that the warrantless seizure of her vehicle was not justified by exigent circumstances. The case was remanded for further proceedings. View "Watkins v. Davis" on Justia Law

Law enforcement officers obtained and executed a search warrant for “4279 Violet Circle, Lake Worth, FL,” believing it to be a single-family home occupied by the defendant. In reality, the property included a main residence and three efficiency apartments at the back, one of which was occupied by the defendant. These apartments had no separate addresses, mailboxes, or exterior markings. During the search, officers were directed by other residents to the defendant’s apartment, where they found firearms and drugs. The defendant was subsequently charged with multiple firearm and drug offenses.The defendant moved to suppress the evidence, arguing that the warrant was defective under the Fourth Amendment because it listed only the main address and not his specific apartment. The United States District Court for the Southern District of Florida held an evidentiary hearing, credited the testimony of the investigating officer, and found that the officers reasonably believed the property was a single-family home based on surveillance, property records, and the lack of distinguishing features for the apartments. The magistrate judge recommended denying the motion to suppress, and the district court adopted this recommendation. The defendant was found guilty after a stipulated-facts bench trial and sentenced to 144 months’ imprisonment.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the denial of the motion to suppress. The court held that the search warrant satisfied the Fourth Amendment’s particularity requirement because the officers reasonably believed, after a diligent investigation, that the property was a single-family home. The court found no evidence that the officers knew or should have known about the separate apartments before executing the warrant. The court affirmed the denial of the motion to suppress and remanded for correction of a clerical error in the judgment. View "United States v. Schmitz" on Justia Law