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

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A property-insurance dispute arose between a condominium association and its insurer after storms damaged the property. The association demanded an appraisal of the loss, and both parties selected appraisers who then chose an umpire. The association's appraiser disclosed, on the day of final negotiations, that he believed he had a financial stake in the award due to a contingency-fee retainer. The insurer did not object at that time, and the appraisal panel issued an award over a month later. Subsequently, the insurer moved to vacate the award, claiming the appraiser's partiality.The United States District Court for the Southern District of Florida denied the insurer's motion to vacate the award, ruling that the insurer had waived its objection by not raising it sooner. The court also confirmed the appraisal award.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the insurer waived its objection to the appraiser's partiality by failing to object at the time of the disclosure. The court emphasized that a party must timely object to an arbitrator's or appraiser's partiality when it becomes aware of a potential conflict of interest. By waiting over two months and until after the award was issued, the insurer forfeited its right to challenge the appraiser's impartiality. The court did not address other arguments related to the choice of law or the appraiser's partiality, as the waiver issue was dispositive. View "Biscayne Beach Club Condominium Association, Inc. v. Westchester Surplus Lines Insurance Company" on Justia Law

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A high school football coach's contract was not renewed by the Valdosta Board of Education in 2020. The vote split along racial lines, with all white members voting to renew and all black members voting against renewal. The coach believed the decision was racially motivated.In 2020, the coach sued the five black board members individually under 42 U.S.C. §§ 1981 and 1983, seeking monetary damages. The district court denied the board members' motions to dismiss based on qualified immunity, but the Eleventh Circuit reversed, finding the coach failed to state a claim. The case was remanded for dismissal.In 2021, the coach filed a new lawsuit against the same board members and the Board itself, this time under Title VII of the Civil Rights Act of 1964. The new complaint included more detailed allegations but was based on the same core facts. The district court granted summary judgment for the Board, ruling that the new lawsuit was barred by res judicata because the Board was in privity with the individual board members and the two cases involved the same cause of action.The United States Court of Appeals for the Eleventh Circuit affirmed the district court's decision. The court held that the Board was in privity with the individual board members because they acted as the Board when they voted not to renew the coach's contract. The court also found that both lawsuits arose from the same nucleus of operative facts, thus meeting the criteria for res judicata. View "Rodemaker v. City of Valdosta Board of Education" on Justia Law

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The case involves a class of current and former Home Depot employees who alleged that Home Depot failed to prudently manage its 401(k) retirement plan, resulting in excessive fees and subpar returns. The plaintiffs argued that Home Depot did not adequately monitor the fees charged by the plan’s financial advisor and failed to prudently evaluate four specific investment options, leading to financial losses for the plan participants.The United States District Court for the Northern District of Georgia found that there were genuine disputes of material fact regarding whether Home Depot had complied with its duty of prudence in monitoring plan fees and three of the four challenged funds. However, the court concluded that the plaintiffs had not met their burden of proving loss causation for any of their claims. The court also found no genuine dispute regarding the prudence of Home Depot’s monitoring process for the Stephens Fund and ruled that the plaintiffs had forfeited their requests for equitable relief by not arguing them at the summary judgment stage.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The court held that the plaintiffs bear the burden of proving loss causation in ERISA breach-of-fiduciary-duty claims. The court found that the plaintiffs failed to show that the fees charged by the financial advisors were objectively imprudent, given the size and complexity of Home Depot’s plan. The court also determined that the plaintiffs did not provide sufficient evidence to prove that the four challenged funds were objectively imprudent investments. Additionally, the court agreed with the district court that the plaintiffs had forfeited their claims for equitable relief by not raising them at the summary judgment stage. Therefore, the court affirmed the district court’s grant of summary judgment in favor of Home Depot. View "Pizarro v. The Home Depot, Inc." on Justia Law

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A nominee for Lieutenant Governor in Georgia and the Libertarian Party of Georgia challenged a state law that allows only certain political parties to form "leadership committees" capable of accepting unlimited campaign contributions. The Libertarian Party, classified as a "political body" under Georgia law, was excluded from forming such committees, which they argued violated their First Amendment and Equal Protection rights.The United States District Court for the Northern District of Georgia denied the plaintiffs' motion for a preliminary injunction. The court found that the plaintiffs lacked standing because their alleged injury was not traceable to the defendants and could not be redressed by the requested relief. The court also noted that the plaintiffs failed to show that the defendants had enforced or threatened to enforce the law against them. Additionally, the court concluded that the plaintiffs did not meet the prerequisites for a preliminary injunction.The United States Court of Appeals for the Eleventh Circuit reviewed the case and determined it was moot because the 2022 election had already occurred, and the nominee had lost. The court found that the plaintiffs' claims were specific to the 2022 election and did not present a live controversy. The court also rejected the plaintiffs' argument that the case fell under the "capable of repetition yet evading review" exception to mootness, as there was no reasonable expectation that the same controversy would recur involving the same parties.The Eleventh Circuit vacated the district court's judgment, dismissed the appeal, and remanded the case to the district court to dismiss it as moot. View "Graham v. Attorney General" on Justia Law

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David Efron and Madeleine Candelario were involved in a divorce proceeding in Puerto Rico, during which Efron was ordered to pay Candelario $50,000 per month. After the divorce was finalized, Candelario began a relationship with Judge Cordero, and Efron alleges that Candelario, her attorney, and Judges Cordero and Aponte conspired to reinstate the payments through a corrupt scheme. Efron claims this resulted in Candelario receiving approximately $7 million. Efron filed a federal lawsuit against Candelario and her attorney, asserting claims for deprivation of procedural due process, conspiracy to deny civil rights, civil conspiracy, and unjust enrichment.The United States District Court for the Southern District of Florida dismissed Efron’s complaint for lack of subject matter jurisdiction, citing the Rooker-Feldman doctrine. The court found that Efron’s claims were inextricably intertwined with the Puerto Rico court’s judgment and that granting relief would effectively nullify that judgment. The district court also rejected Efron’s argument that his claims fell under a fraud exception to the Rooker-Feldman doctrine.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court’s dismissal. The Eleventh Circuit held that the Rooker-Feldman doctrine barred Efron’s claims because they essentially sought to challenge the state court’s judgment. The court concluded that Efron’s claims for damages were not independent of the state court’s decision but were directly related to it, as they required the federal court to review and reject the state court’s judgment. Therefore, the district court correctly dismissed the complaint for lack of subject matter jurisdiction. View "Efron v. Candelario" on Justia Law

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Constantin, an accounting firm, performed an audit for Schratter Foods Incorporated, a food services company. The audit allegedly went wrong, leading to liability. Constantin had a professional services insurance policy from Chubb Insurance Company of New Jersey, which covered services directed toward expertise in banking finance, accounting, risk and systems analysis, design and implementation, asset recovery, and strategy planning for financial institutions. Constantin assigned its rights under the policy to ECB USA, Inc., Atlantic Ventures Corp., and G.I.E. C2B (collectively, the ECB parties).The ECB parties sued Chubb in the United States District Court for the Southern District of Florida, seeking to enforce Constantin’s assigned contractual rights, alleging a breach of contract based on Chubb’s duty to defend or indemnify in the earlier lawsuit. The district court granted summary judgment to Chubb, ruling that the insurance policy did not cover the audit because it was not performed for a financial institution. The court also granted reformation of the 2017–18 contract to include Constantin as a named insured.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that the phrase “for financial institutions” in the insurance policy modified all the terms in the list, including “accounting.” The court applied the series-qualifier canon of interpretation, which suggests that a postpositive modifier like “for financial institutions” modifies all the terms in a list of parallel items. The court found that the surrounding language of the policy supported this interpretation. The court rejected ECB’s arguments based on the last-antecedent canon and contra proferentem, concluding that the policy unambiguously required the services to be for financial institutions. Therefore, the court affirmed the district court’s grant of summary judgment to Chubb. View "ECB USA, Inc. v. Chubb Insurance Company of New Jersey" on Justia Law

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Compulife Software, Inc. created software to generate life insurance quotes using a proprietary database of insurance rates. The defendants, Moses Newman, Aaron Levy, Binyomin Rutstein, and David Rutstein, were accused of copying Compulife’s software code and misappropriating its trade secret by scraping its database to use on their own websites. Compulife alleged that this led to a decline in its sales and revenue.The United States District Court for the Southern District of Florida initially ruled against Compulife on the copyright infringement claim but in favor of Compulife on the trade secret misappropriation claim. The court found that the defendants had not infringed on Compulife’s copyright because the copied elements were not protectable. However, it concluded that the defendants had misappropriated Compulife’s trade secret by acquiring the database through improper means, specifically scraping. The court awarded Compulife compensatory and punitive damages and held the defendants jointly and severally liable.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It found that the district court erred by not considering the arrangement of Compulife’s code as a potentially protectable element under copyright law. The appellate court reversed the district court’s ruling on the copyright claim and remanded for further fact-finding on whether the arrangement of the code was protectable. The appellate court affirmed the district court’s ruling on the trade secret misappropriation claim, agreeing that the defendants had used improper means to acquire the trade secret. It also upheld the joint and several liability for the defendants, noting that this is standard for trade secret claims under Florida law. The case was affirmed in part, reversed in part, and remanded for further proceedings. View "Compulife Software Inc. v. Moses Newman" on Justia Law

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John Doe, a student at Emory University, was accused of sexual misconduct by Jane Roe following an encounter in April 2019. Roe alleged that Doe engaged in nonconsensual intercourse and choked her. Doe denied the allegations, asserting that the encounter was consensual. Emory conducted an investigation, during which Roe changed parts of her story. Despite inconsistencies in Roe's account, Emory found Doe responsible for sexual misconduct and suspended him for a semester. Doe appealed internally without success.Doe then filed a lawsuit in the United States District Court for the Northern District of Georgia, claiming that Emory violated Title IX by discriminating against him based on sex and breached a contractual obligation to conduct the investigation fairly. The district court dismissed Doe's Title IX claim, reasoning that his allegations suggested pro-complainant bias rather than gender bias. The court also dismissed his contract claims, finding no mutual assent to the terms of the university's sexual misconduct policy.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court affirmed the dismissal of Doe's Title IX claim, holding that his allegations did not plausibly indicate gender bias but rather suggested pro-complainant bias, which is not prohibited under Title IX. However, the court reversed the dismissal of Doe's breach-of-contract claims. It concluded that Doe plausibly alleged mutual assent to an implied contract based on Emory's sexual misconduct policy and found no basis to determine that Emory retained a unilateral right to amend the policy that would preclude mutual assent. The case was remanded for further proceedings on the contract claims. View "Doe v. Emory University" on Justia Law

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In 2017, Roy Moore, a Republican candidate for a U.S. Senate seat in Alabama, faced allegations of sexual misconduct with minors. Following his election loss, Moore filed a defamation lawsuit against Guy Cecil, Priorities USA, and Bully Pulpit Interactive LLC. The claims involved tweets by Cecil, a press release by Priorities USA, and a digital ad. Moore argued that the tweets were defamatory and that the press release and digital ad falsely labeled him a "child molester" and "child predator."The United States District Court for the Northern District of Alabama dismissed the tweet-based claims for lack of personal jurisdiction, as Cecil had no significant contacts with Alabama. The court also dismissed the press release and digital ad claims for failure to state a claim, concluding that Moore did not sufficiently allege actual malice, a requirement for defamation claims involving public figures. The court allowed Moore to amend his complaint, but the amended complaint was also dismissed for the same reasons.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court affirmed the district court's dismissal of the tweet-based claims, agreeing that Cecil's tweets were not aimed at Alabama but rather at a national audience. The court also upheld the dismissal of the press release and digital ad claims, finding that Moore failed to allege facts showing that the defendants acted with actual malice. The court noted that ill-will or improper motive does not equate to actual malice, which requires knowledge of falsity or reckless disregard for the truth.The Eleventh Circuit concluded that the district court correctly dismissed the claims for lack of personal jurisdiction and failure to state a claim, affirming the lower court's decision. View "Moore v. Cecil" on Justia Law

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Roland McCarthy, a white man, was hired as Finance Director by the City Commission of Cordele, Georgia, in 2017 and promoted to City Manager in January 2021. During his tenure, Joshua Deriso campaigned for chairman of the City Commission, expressing intentions to replace white employees with African Americans and to have an all-black City Commission. After winning the election, Deriso and other black commissioners voted to fire McCarthy and replace him with a black City Manager, Angela Henderson Redding. McCarthy was warned by Deriso and another commissioner, Royce Reeves, that he would be replaced due to his race and could not return to his former position because he did not "look like" them.The United States District Court for the Middle District of Georgia dismissed McCarthy's complaint, ruling that he failed to state plausible claims of racial discrimination against the City. The court found that McCarthy did not sufficiently allege that the Commission acted with a racially discriminatory motive, as only one voting commissioner was alleged to have racial animus. The court also dismissed claims against Deriso in his official capacity as duplicative of claims against the City and dismissed claims against Deriso in his individual capacity, citing qualified immunity.The United States Court of Appeals for the Eleventh Circuit reviewed the case and vacated the district court's dismissal of McCarthy's claims against the City. The appellate court found that McCarthy plausibly alleged that the Commission discriminated against him because of his race, based on Deriso's and Reeves's statements and the racial composition of the vote. However, the court affirmed the dismissal of claims against Deriso in his individual capacity, as he did not have the authority to make the official decision to fire McCarthy. The case was remanded for further proceedings. View "McCarthy v. City of Cordele Georgia" on Justia Law