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

At issue was the word "retirement" in the Award Terms of stock options granted to plaintiff by his employer E.I. du Pont de Nemours and Company. Under the terms of the award, an employee who leaves the company "due to retirement" keeps the original expiration date of his stock options, but an employee who leaves for other reasons must exercise his stock options by his last day of employment.Applying Delaware law, the Eleventh Circuit held that an employee is eligible for retirement within the meaning of the Award Terms only upon satisfying both the age and years-of-service requirement. Therefore, plaintiff's 10 years of service with DuPont fell short of the years-of-service requirements within Section IV of the Pension Plan. Accordingly, the court affirmed the district court's grant of summary judgment to DuPont. View "Bearden v. E.I. Du Pont De Nemours and Co." on Justia Law

The Eleventh Circuit held that Heck v. Humphrey, 512 U.S. 477, 114 S. Ct. 2364 (1994), did not bar plaintiff's civil action for false arrest under 42 U.S.C. 1983. In this case, plaintiff was arrested as he rode his bicycle through the grounds of a former elementary school and was charged with criminal trespass. Plaintiff was released from jail three weeks later and later pleaded guilty to unrelated charges. The court held that Heck did not apply to the circumstances around plaintiff's plea agreement, and the district court wrongly dismissed plaintiff's section 1983 claim.Determining that the district court had jurisdiction over plaintiff's state claims against Deputy Payne, the court affirmed the dismissal of the malicious arrest and intentional infliction of emotional distress claims. However, the court vacated the dismissal of the false imprisonment claim where plaintiff alleged that he was unlawfully detained for the time between his arrest and when his arrest warrant was procured. Finally, the court affirmed the district court's sua sponte decision to dismiss the claims against Sheriff Millsap under its 18 U.S.C. 1915 authority. View "Henley v. Payne" on Justia Law

The Eleventh Circuit held that petitioner, a convicted drug trafficker who has illegally entered into the United States three times, was not entitled to an emergency stay of removal. The court denied his motion to stay removal and held that, although petitioner presented evidence that he faced a risk of grave harm if he was removed to Jamaica, more was required to prevail on his motion. In this case, petitioner failed to establish a strong showing that he was likely to succeed in proving that the BIA erred when it concluded that he was not entitled to file an untimely motion to reopen. The court granted petitioner's motions to seal his records before this court and will carry his motions for judicial notice with the case. View "Blake v. U.S. Attorney General" on Justia Law

The Eleventh Circuit vacated defendant's sentence for possessing a firearm as a felon, possessing body armor as a violent felon, and distributing methamphetamine. The court held that the district court plainly erred by applying a two-level sentencing enhancement under USSG 3B1.5 for "use" of body armor in the commission of a drug trafficking offense. The court explained that, although the presentencing report asserted that defendant's sale of body armor amounted to use as a means of bartering, selling is an activity that under both common usage and dictionary definition falls outside of bartering. Rather, "barter" means to trade goods or services without using money. View "United States v. Bankston" on Justia Law

Petitioner, a citizen of India, appealed from the denial of his petition for a writ of habeas corpus under 28 U.S.C. 2241. Petitioner has been in ICE custody for 31 months and argued that he was entitled to release under the Supreme Court's ruling in Zadvydas v. Davis, 533 U.S. 678, 121 S. Ct. 2491 (2001). In Zadvydas, the Supreme Court held that the Constitution limits detention of lawfully-admitted noncitizens under 8 U.S.C. 1231(a)(6) to a period reasonably necessary to bring about the alien's removal and does not permit indefinite detention.The Eleventh Circuit held that section 1231(a)(1)(C) requires that petitioner return the incomplete travel document application in bad faith, i.e., petitioner intentionally withheld the necessary information in order to apply. In this case, the court could not evaluate whether petitioner's removal period had been extended by operation of section 1231(a)(1)(C). Because there was insufficient evidence to evaluate the district court's denial of the petition for habeas relief, the court reversed and remanded. View "Singh v. U.S. Attorney General" on Justia Law

The Eleventh Circuit affirmed the district court's denial of defendant's motion to dismiss an indictment charging him with failing to register as a sex offender under the Sex Offender Registration and Notification Act (SORNA). The court held that defendant's prior conviction for sexual battery under Tennessee law qualified as a sex offense under SORNA.The court held that the case law cited by defendant did not support his argument that Tennessee has expanded its definition of sexual contact to include contact with the back or abdomen; the term sexual contact as defined in Tennessee's sexual battery statute categorically matches the plain meaning of sexual contact as used in SORNA; and, although it was clear that the definition of sexual contact used in 18 U.S.C. 2246(3) was inapplicable here, it was equally clear that Tennessee's statutory definition of sexual contact categorically matches section 2246(3) as well. View "United States v. Vineyard" on Justia Law

Two auto body collision repair shops filed a class action against dozens of insurance defendants, alleging claims under the Racketeer Influenced and Corrupt Organizations Act (RICO) and state law fraud and unjust enrichment theories.The Eleventh Circuit affirmed the district court's grant of defendants' motion to dismiss each of plaintiffs' claims. The court held that plaintiffs failed to allege at least two predicate acts of racketeering activity, fraud or extortion. The court also held that plaintiffs have not sufficiently pleaded their state law fraud and unjust enrichment claims; the district court did not err by excluding exhibits E1-E7; and the district court did not err by dismissing the complaint with prejudice. View "Crawford's Auto Center, Inc. v. State Farm Mutual Automobile Insurance Co." on Justia Law

The Eleventh Circuit affirmed the district court's grant of summary judgment to defendants in a putative class action seeking damages and a declaration that vehicle insurance purchased by plaintiffs was not valid. Plaintiffs alleged that the endorsement in the policy was illusory because it only provides coverage for vicarious liability against lessors, and that liability was foreclosed by the Graves Amendment. Determining that plaintiffs had Article III standing, the court held that the endorsement was not illusory because it imposed on defendants a duty to defend lessors from claims of vicarious liability. View "Hallums v. Infinity Insurance Co." on Justia Law

Geico Marine filed suit seeking a declaration that a navigational limit in the policy with defendant that required the vessel to be north of Cape Hatteras, North Carolina, during hurricane season barred coverage. The district court ruled against Geico Marine and declared that the policy covered the loss.The Eleventh Circuit reversed and remanded, holding that the navigational limit barred coverage. In this case, the policy was not ambiguous about whether it contained a navigational limit when the loss occurred, and the plain language of the policy contained a navigational limit. Because the navigational limit was dispositive where the vessel suffered damage while outside the covered navigational area, the court need not address the breach of a duty of uberrimae fidei. View "Geico Marine Insurance Co. v. Shackleford" on Justia Law

Plaintiffs, two African-American minimum-wage employees who work in Birmingham at a rate lower than the $10.10 prescribed by the City's minimum wage ordinance, filed suit alleging that Act No. 2016-18, which nullified the City's minimum-wage ordinance, violated the Equal Protection Clause of the Fourteenth Amendment. Instead of suing their employers, who were refusing to pay the $10.10 minimum wage, plaintiffs chose to file suit against the Alabama Attorney General.The Eleventh Circuit held that plaintiffs did not have Article III standing to sue the Attorney General, because they could not demonstrate that their alleged injuries were fairly traceable to his conduct, or that those injuries would be redressed by the declaratory and injunctive relief plaintiffs have requested. Because the employees lacked standing to sue, the court need not consider the merits of their equal protection claim. Accordingly, the court affirmed in part and remanded to the panel. View "Lewis v. Governor of Alabama" on Justia Law