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

Compulife Software, which has developed and markets a computerized mechanism for calculating, organizing, and comparing life-insurance quotes, alleges that one of its competitors lied and hacked its way into Compulife's system and stole its proprietary data. At issue was whether defendants crossed any legal lines—and, in particular, whether they infringed Compulife's copyright or misappropriated its trade secrets, engaged in false advertising, or violated an anti-hacking statute.The Eleventh Circuit vacated the judgment as to copyright infringement and trade-secret misappropriation, remanding for new findings of fact and conclusions of law. The court held that the magistrate judge committed errors of law and made insufficient findings, which tainted his conclusion that Compulife's copyright was not infringed. The court also held that the magistrate judge erred in his analysis of trade-secret misappropriation, both by failing to consider the application of several species of misappropriation and by committing legal error. The court found no reversible error in the magistrate judge's rejection of Compulife's other claims, affirming the remainder of the judgment. View "Compulife Software Inc. v. Newman" on Justia Law

Plaintiff filed suit against her employer and its CEO for interference and retaliation under the Family Medical Leave Act (FMLA), and for retaliation under Title VII of the Civil Rights Act and 42 U.S.C. 1981.The Eleventh Circuit affirmed the district court's grant of summary judgment to the employer on the FMLA claim, holding that plaintiff's visit to her counselor did not count as treatment by a health care provider under the statute. In regard to the Title VII claim against the employer, the court held that plaintiff failed to offer any evidence that the CEO knew she had complained about race or sex discrimination, and thus she cannot show a relationship between her firing and that protected activity. Furthermore, plaintiff failed to impeach the CEO's testimony or present circumstantial evidence of his knowledge beyond temporal proximity. Therefore, summary judgment was appropriate on this claim because a jury could find discrimination only based on speculation, rather than on evidence. Finally, plaintiff's section 1981 claims were abandoned on appeal. View "Martin v. Financial Asset Management Systems, Inc." on Justia Law

Harbourside filed suit against the town, moving for a pre-enforcement preliminary injunction against Ordinance 1-16. The ordinance, among other things, established a two-tiered scheme for the use of amplified sound at non-residential properties and contains a separate section relating to outdoor live musical performances. The district court denied injunctive relief.The Eleventh Circuit applied limited review, without definitively addressing the merits, and affirmed the district court's judgment. The court held that the district court did not abuse its discretion in ruling that Harbourside failed to establish a likelihood of success on its claims that it qualifies as an outdoor venue and that the challenged sections of the Jupiter Code are content-based. View "Harbourside Place, LLC v. Town of Jupiter" on Justia Law

ETS filed a trademark infringement action against Scarpello over the "Engineered Tax Services" mark under the Lanham Act. The district court held that the mark lacked distinctiveness and granted summary judgment in favor of Scarpello.The Eleventh Circuit reversed, holding that the district court erred in concluding, as a matter of law, that ETS's mark was not suggestive, but merely descriptive—and thus invalid. Furthermore, the district court failed to consider whether the mark might also have acquired any protectible secondary meaning or whether any actionable infringement occurred. The court held that a jury could reasonably find the mark inherently distinctive and remanded for further proceedings. View "Engineered Tax Services, Inc. v. Scarpello Consulting, Inc." on Justia Law

The Eleventh Circuit vacated the district court's order affirming the Commissioner's denial of plaintiff's application for disability insurance benefits. The court held that the ALJ did not have the benefit of the court's decision in Schink v. Comm'r of Soc. Sec., 935 F.3d 1245 (11th Cir. 2019) (per curiam), which may alter the fourth step of the ALJ's disability analysis. Furthermore, the court agreed with plaintiff that the ALJ's hypothetical to the vocational expert did not sufficiently communicate plaintiff's limitations from bipolar disorder. View "Samuels v. Acting Commissioner of Social Security" on Justia Law

After plaintiff was injured while working as a longshoreman, he filed suit against Seaboard, seeking to hold them liable under the Longshore Workers' Compensation Act (LHWCA). Plaintiff fell from a walkway on the upper deck of the ship where he was working and sustained serious injuries.The Eleventh Circuit affirmed the district court's grant of summary judgment for Seaboard on plaintiff's negligence claim, holding that the exposed walkway was an open and obvious hazard that plaintiff could have avoided with the exercise of reasonable care. Therefore, the district court properly dismissed plaintiff's claim. View "Troutman v. Seaboard Atlantic Ltd." on Justia Law

The Eleventh Circuit vacated the tax court's decision upholding the Commissioner's disallowance of a charitable deduction for taxpayer's donation of a conservative easement over property that included a private golf course and undeveloped land. The court explained that the deduction was proper if the donation was made for "the protection of a relatively natural habitat of fish, wildlife, or plants, or similar ecosystem," or was made for "the preservation of open space . . . for the scenic enjoyment of the general public" under I.R.C. 170(h)(4)(A)(ii) & (iii)(I). The court reasoned that, without the golf course, this easement would easily meet these criteria. The court held that the Code does not disqualify an easement just because it includes a golf course. Accordingly, the court remanded for further proceedings. View "Champions Retreat Golf Founders, LLC v. Commissioner" on Justia Law

Plaintiffs filed suit against Liberty Mutual for breach of contract and bad faith under Alabama law after the insurer denied coverage for an infestation of brown recluse spiders in plaintiffs' home. The court held that the homeowners insurance policy excluded coverage for property damage caused by insects or vermin, and that brown recluse spiders are both "insects" and "vermin" under the ordinary meaning of those terms. Furthermore, the district court did not err by consulting dictionaries to determine these legislative facts. View "Robinson v. Liberty Mutual Insurance Co." on Justia Law

The Eleventh Circuit affirmed defendant's convictions for distributing furanyl fentanyl, a controlled substance analogue, in counterfeit oxycodone pills that caused the death of a 34-year-old woman. The court held that the government introduced sufficient evidence to permit a reasonable jury to find beyond a reasonable doubt that the furanyl fentanyl defendant distributed caused the woman's death; the district court had subject matter jurisdiction over the first two drug counts of the indictment; the district court did not err, much less plainly err, in instructing the jury on scienter; the district court did not clearly err in finding that defendant voluntarily consented to the search of his bags at the airport and in denying the motion to suppress; the district court did not abuse its discretion in declining to further investigate any juror misconduct; and there was no cumulative error requiring reversal. View "United States v. Benjamin" on Justia Law

The Eleventh Circuit affirmed the district court's denial of petitioner's motion to vacate his sentence under 28 U.S.C. 2255. The court held that petitioner cannot prove that his counsel rendered ineffective assistance, because petitioner's prior convictions in Alabama categorically qualify as predicate offenses under both the Armed Career Criminal Act and the career-offender provision of the Guidelines, and his prior conviction in Georgia qualifies as a predicate offense under the Act. Therefore, counsel did not perform deficiently by failing to raise a meritless objection. View "Hollis v. United States" on Justia Law