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

After a pretrial detainee, Kenneth Grochowski, was killed by his cellmate, William Alexander Brooks, while both men were detained at the Clayton County Jail, Grochowski's surviving adult children filed a civil rights action against the County and four supervisors at the jail. Plaintiffs alleged that the conditions at the jail violated Grochowski's due process rights under the Fourteenth Amendment and that those conditions caused his death.The Eleventh Circuit affirmed the district court's grant of the jail supervisors' motion for summary judgment based on qualified immunity. The court held that plaintiffs have failed to show that the jail supervisors violated a constitutionally protected right because they failed to show that the Constitution requires in-person security screenings or consideration of violent misdemeanors and that the Constitution requires jail officials to conduct rounds more frequently than once per hour. The court also affirmed the district court's grant of summary judgment in favor of the County, holding that plaintiffs failed to show that either the jail design or its funding and staffing levels violated Grochowski's Fourteenth Amendment rights. Finally, the court granted the district court's order granting the County's motion for a protective order regarding the decision-making process with respect to the design and funding of the jail. View "Grochowski v. Clayton County, Georgia" on Justia Law

Warren, a manufacturer of unitary electric (UE) heaters for HVAC systems, filed suit against its competitor, Tutco and against a Nationally Recognized Testing Laboratory (NRTL), UL. Warren's claims are based on its allegations that, UL certified Tutco's UE heaters as compliant, even though the heaters are not actually compliant. Warren sought damages and injunctive relief under the Lanham Act for false advertising and contributory false advertising, damages under the common law of unfair competition, and declaratory and injunctive relief under the Florida Deceptive and Unfair Trade Practices Act (FDUTPA).The Second Circuit affirmed the district court's grant of Tutco's and UL's joint motion to dismiss. In this case, Warren calls UL's authorization to Tutco to use UL's mark, and Tutco's advertisements to that effect, "misrepresentations," but it really means nothing more than (by its lights) a "misinterpretation" of UL 1995. However, it does not follow, that even a misinterpretation of UL 1995 is a falsity -- or a "deceptive act" within the meaning of the Lanham Act -- rather than a matter of opinion, provided it was made in good faith and in accordance with OSHA's criteria for independence, procedural regularity, etc. The court held that, because all of Warren's claims against UL and Tutco are based upon the same allegation of falsity, they fail for want of a misrepresentation or a deceptive act. View "Warren Technology, Inc. v. UL LLC" on Justia Law

The Eleventh Circuit granted a petition for panel rehearing of this court's opinion reversing defendant's sentence under the Armed Career Criminal Act (ACCA). The court vacated its previous opinion and substituted the following opinion.Defendant pleaded guilty to possessing a firearm and ammunition as a convicted felon under 18 U.S.C. 922(g) and 924(a)(2). Based, in part, on his prior Georgia conviction for making terroristic threats under O.C.G.A. 16-11-37(a) (2010), defendant was sentenced under the ACCA to 180 months in prison.The court held that O.C.G.A. 16-11-37(a) is divisible under Mathis v. United States, 136 S. Ct. 2243, 2249 (2016), and that a threat to commit "any crime of violence" under Georgia law always includes an element requiring threatened violent force against another. Therefore, the court held that defendant's terroristic-threats conviction qualifies as a violent felony under the ACCA's elements clause. The court affirmed the district court's judgment. View "United States v. Oliver" on Justia Law

The Eleventh Circuit joined its sister circuits in holding that a district court may address a sanctions motion based on its inherent powers or 28 U.S.C. 1927 even if it lacks jurisdiction over the underlying case. The court explained that these sanctions, like Rule 11 sanctions, do not require a court to rule on the merits of the underlying case. Furthermore, the purpose of the sanctions outlasts the end of the case.In this case, the court held that the district court did not abuse its discretion by denying defendant's motion for sanctions, because defendant failed to make a showing of bad faith. Defendant's only exhibit submitted to show bad faith could be interpreted in more than one way, and the district court also considered defendant's nearly three-year delay in bringing his sanctions motion. View "Hyde v. Irish" on Justia Law

The Eleventh Circuit affirmed the district court's denial of relief under the First Step Act of 2018 to Defendants Jones and Jackson, holding that the district court did not err in refusing to allow Jones to relitigate his drug-quantity finding and that the district court correctly concluded that it could not reduce Jackson's sentence because his drug-quantity finding meant that he would face the same statutory penalty of life imprisonment under the Fair Sentencing Act.The court vacated the denials of relief to Defendants Allen and Johnson, holding that their orders do not make clear that the district court understood that it could reduce the sentences. Therefore, the court vacated the orders denying Allen and Johnson's motions and remanded for further proceedings. View "United States v. Steven Jones" on Justia Law

Plaintiff filed a maritime negligence action against Carnival on her daughter's behalf after her daughter, three years old at the time, either fell over or through a guard rail on one of Carnival's cruise ships. Plaintiff filed suit alleging that Carnival negligently created and maintained the guard rail, and failed to warn of the danger posed by the guard rail. The district court granted summary judgment to Carnival.The Eleventh Circuit held that the district court erred when it concluded that there was no genuine issue of material fact as to Carnival's notice of the alleged risk-creating condition because it failed to view the evidence in a light most favorable to plaintiff and to draw reasonable inferences in her favor. In this case, a witness testified that Carnival warned passengers not to climb up rails, try to sit on them, or try to get selfies or lean over them because accidents can happen and passengers have fallen off. The court also held that the district court erred when it resolved the failure-to-warn claim on a basis that Carnival did not raise, without providing plaintiff notice or an opportunity to respond. Accordingly, the court reversed the district court's judgment and remanded for further proceedings. View "Amy v. Carnival Corp." on Justia Law

The Eleventh Circuit held that the district court erred in issuing an injunction against the County and the Director of the Miami-Dade Corrections and Rehabilitations Department (MDCR), requiring defendants to employ numerous safety measures to prevent the spread of COVID-19 and imposing extensive reporting requirements. Metro West inmates had filed a class action challenging the conditions of their confinement under 42 U.S.C. 1983 and seeking habeas relief under 28 U.S.C. 2241 for the named plaintiffs with a "medically vulnerable" subclass of inmates.The court held that plaintiffs failed to show a substantial likelihood of success on the merits of their constitutional claim for deliberate indifference. The court explained that the district court erred in relying on the increased rate of infection, and in concluding that defendants' inability to ensure adequate social distancing constituted deliberate indifference. In this case, the court simply could not conclude that, when faced with a perfect storm of a contagious virus and the space constraints inherent in a correctional facility, defendants acted unreasonably by "doing their best." The court also agreed with defendants that the district court erred in its likelihood-of-success-on-the-merits analysis because it failed to consider "two threshold issues": (1) the heightened standard for municipal liability under Monell v. Department of Social Services, 436 U.S. 658 (1978), and (2) exhaustion under the Prison Litigation Reform Act. Finally, the court held that the district court erred in holding, without any meaningful analysis, that plaintiffs would suffer irreparable injury absent an injunction. Furthermore, the district court erred in its determination of the balance-of-the-harms and public-interest factors. View "Swain v. Junior" on Justia Law

The Eleventh Circuit reversed the district court's grant of defendant's motion to suppress evidence obtained after officers, pursuant to arrest warrants, arrested defendant and his wife, secured them outside of their home, and then reentered the home to conduct a protective sweep without a warrant. The court found that the totality of the circumstances demonstrates that the officer had a reasonable suspicion that a dangerous person might have been in the house and that the protective sweep was justified. In this case, multiple cars indicated multiple people on the property; the tips about the drugs indicated multiple people who may have had access to weapons; and the wife's refusal to follow police directions indicated that, if other people were in the house, they might have likewise been non-compliant. View "United States v. Yarbrough" on Justia Law

Plaintiff appealed the district court's grant of summary judgment in Trees's favor on his hostile work environment and national origin discrimination claims under Title VII of the Civil Rights Act of 1964 and the Florida Civil Rights Act (FCRA).The Eleventh Circuit affirmed the district court's grant of summary judgment for Trees on plaintiff's national origin discrimination claim, holding that the claim fails as a matter of law where the supervisor's statement, although reprehensible, was not direct evidence that plaintiff was fired because of his national origin. The court reversed the district court's grant of summary judgment for Trees on the hostile work environment claim, holding that plaintiff provided evidence sufficient to raise a material issue of fact as to whether the harassment was objectively severe or pervasive. In this case, plaintiff provided ample evidence that the harassment he faced was frequent; a reasonable jury could conclude that the harassment was sufficiently severe; the supervisor's conduct was sufficiently humiliating to support a hostile work environment claim; and, although more attenuated than typical interference-with-job-performance arguments, the court could not say on this record that plaintiff's on-the-job suicide attempt was wholly unrelated to his job performance. View "Soto Fernandez v. Trees, Inc." on Justia Law

Plaintiff filed a 42 U.S.C. 1983 action against three police officers after plaintiff was shot and seriously injured while he was assisting the police apprehend a fugitive. Plaintiff alleged a section 1983 claim for involuntary servitude under the Thirteenth Amendment to the U.S. Constitution and a violation of substantive due process under the Fourteenth Amendment, as well as claims for negligence, wantonness, failure to train/supervise, and false imprisonment under Alabama state law. In this case, the officers told plaintiff that they would "throw some charges on [him]" if he did not agree to participate in a ruse to capture the fugitive. Plaintiff claimed that the threat of physical violence is what ultimately overcame his will and forced him to participate in the ruse.The Eleventh Circuit affirmed the district court's grant of summary judgment in favor of the officers based on qualified immunity, holding that the officers did not violate the Thirteenth or Fourteenth Amendment. Even assuming that there was a constitutional violation, the court held that it was not clearly established at the time that all objectively reasonable officers in their position would have known that what they said to plaintiff violated the Constitution's prohibition against involuntary servitude or its "nebulous" doctrine of substantive due process. Likewise, the court held that the officers are entitled to discretionary-function immunity on the state law claims. View "King v. Pridmore" on Justia Law