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

The Eleventh Circuit withdrew its previous opinion and issued this opinion in its place.Plaintiffs, who are valets, filed a putative class action against FCPS, alleging claims under the minimum-wage and overtime provisions of the Fair Labor Standards Act (FLSA). The court held that the district court correctly ruled that the vehicles parked by plaintiffs while working as valets for FCPS were not "materials" under the FLSA. Nonetheless, FCPS was not entitled to summary judgment on the issue of "enterprise" coverage. The court held that, viewing the evidence in the light most favorable to plaintiffs, a jury could find that the valet tickets used by plaintiffs in their work for FCPS constituted "materials" under the FLSA's "handling clause," and thus provided "enterprise" coverage. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Rodriguez Asalde v. First Class Parking Systems, LLC" on Justia Law

The Eleventh Circuit affirmed the district court's dismissal of the case with prejudice for failure to state a claim, but on an alternative ground. The court held that counsel for homeowners filed a multi-count, incomprehensible complaint that flouted the Federal Rules of Civil Procedure and this Circuit's well-established precedent. The court found that plaintiffs obstructed the due administration of justice in the district court by attempting to prosecute an incomprehensible pleading to judgment. Furthermore, plaintiffs were doing the same here by urging this court to uphold the sufficiency of their amended complaint. The court instructed counsel to show cause why the court should not order him to pay defendants double costs and their expenses, including the attorney's fees they incurred in defending these appeals. View "Jackson v. Specialized Loan Servicing LLC" on Justia Law

Plaintiff, who is deaf, filed suit against PGH and its parent organization, Lifemark Hospitals, alleging that they failed to provide an American Sign Language (ASL) interpreter for plaintiff to effectively communicate during an involuntary commitment evaluation. At issue on appeal was whether plaintiff was afforded an equal opportunity, through an appropriate auxiliary aid, to effectively communicate medically relevant information during his involuntary commitment evaluation. The Eleventh Circuit reversed the district court's grant of summary judgment for defendants, holding that genuine issues of material fact existed as to whether plaintiff was able to effectively communicate medically relevant information and whether the hospital personnel were deliberately indifferent. View "Crane v. Lifemark Hospitals, Inc." on Justia Law

At issue in this appeal was the meaning between the term "employer" under the Fair Labor Standards Act (FLSA) and under the general common law. The Eleventh Circuit applied the common law of agency definition of "employer" in this case and held that Consolidated Citrus was not a joint employer for purposes of plaintiffs' breach-of-contract claim since the company was not an "employer" under the common-law definition of that term. In this case, the relevant factors for determining whether Consolidated Citrus was a common law "employer" were control, the source of the instrumentalities and tools, the location of the work, and the provision of employee benefits. Accordingly, the court vacated the district court's judgment and remanded for entry of judgment in favor of Consolidated Citrus on the breach-of-contract claim. View "Garcia-Celestino v. Consolidated Citrus Limited Partnership" on Justia Law

The Eleventh Circuit vacated its previous order and replaced it with the following:The court held that petitioner's application seeking an order authorizing the district court to consider a successive petition for a writ of habeas corpus under 28 U.S.C. 2244(b)(3)(A), failed for two reasons: petitioner raised an ineffective assistance of counsel - biased judge claim in his original section 2254 petition and, thus to the extent that the gravamen of the claims was the same, his current claim was precluded by section 2244(b)(1); and even if petitioner's current claim was not precluded by section 2244(b)(1), he failed to make a prima facie showing that he would be entitled to relief. Therefore, the court dismissed the application to the extent that it was barred by In re Mills and 28 U.S.C. 2244(b)(1), and denied the application to the extent that it was not. View "In re: Octavious Williams" on Justia Law

Andromeda and Internaves entered into a shipping contract that unambiguously required the parties to submit their dispute to arbitration. At issue on appeal was where the parties agreed to arbitrate. The district court was unable to determine the site of arbitration and resorted to the statutory default forum, compelling arbitration in its own district. The court reversed and remanded with instructions to compel arbitration in London under English law. The court held that the parties' intention to arbitrate in London was discernible from the very terms they wrote into the contract and thus the parties provided for the forum, which the district court was obliged to recognize and uphold. View "Internaves de Mexico S.A. de C.V. v. Andromeda Steamship Corp." on Justia Law

Plaintiff filed suit against her former employer, the Salvation Army (TSA), alleging that the organization had discriminated against her based on her disability when it denied her a reasonable accommodation in violation of the Americans with Disabilities Act (ADA), retaliated against her for statutorily protected activities in violation of the ADA and the Family Medical Leave Act (FMLA), and interfered with her rights under the FMLA. The district court granted summary judgment to TSA on all claims.The Eleventh Circuit held that plaintiff failed to establish that TSA discriminated against her by refusing to accommodate her under the ADA. However, plaintiff was entitled to trial on her ADA and FMLA retaliation claims where she exhausted her administrative remedies and she carried her burden of demonstrating that TSA did not hire her because of her illness, not because of her interview or job performance. Therefore, the employer's explanations to the contrary were pretextual. In regard to the FMLA interference claim, plaintiff established as a matter of law that TSA would have terminated her regardless of her request for or use of FMLA leave. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Batson v. The Salvation Army" on Justia Law

The Eleventh Circuit reversed the district court's dismissal of plaintiff's 42 U.S.C. 1983 complaint, holding that he has exhausted his available administrative remedies under the Prison Litigation Reform Act (PLRA). Plaintiff filed suit alleging use of excessive force and deliberate indifference to his medical needs after he was beaten by prison guards. The court held that the district court properly applied the two-step analysis in Turner v. Burnside, 541 F.3d 1077 (11th Cir. 2008), and the district court did not clearly err in determining that plaintiff never filed a grievance on January 18. The court held, however, that defendants waived their procedural objections to Grievance 80940, and plaintiff fully exhausted his administrative remedies when he pursued Grievance 80940 through each administrative level of review and received merits-based responses at each level. View "Whatley v. Ware SP Warden" on Justia Law

In February 2016, the Mayor of Birmingham signed Birmingham Ordinance No. 16-28, which guaranteed plaintiffs and all other wage earners in the city $10.10 per hour. The following day, the Alabama Governor signed the Minimum Wage and Right-to-Work Act into law, which nullified Ordinance No. 16-28, preempted all local labor and employment regulation, and mandated a uniform minimum wage throughout Alabama ($7.25 per hour).The Eleventh Circuit held that plaintiffs have stated a plausible claim that the Minimum Wage Act had the purpose and effect of depriving Birmingham's black citizens equal economic opportunities on the basis of race, in violation of the Equal Protection Clause of the Fourteenth Amendment. The court affirmed the dismissal of the city from the suit, but reversed the district court's holding that plaintiffs lacked Article III standing to assert their claims against the attorney general and the State. On the merits, the court reversed the dismissal of the intentional discrimination claim, holding that a sensitive but thorough examination of plaintiffs' detailed allegations showed that plaintiffs have plausibly stated a claim of disparate impact and discriminatory intent. The court affirmed the dismissal of plaintiffs' remaining claims. View "Lewis v. Governor of Alabama" on Justia Law

The Eleventh Circuit affirmed the district court's decision affirming the bankruptcy court's denial of debtors' motion to convert their Chapter 7 case to a Chapter 11 proceeding and approving a compromise agreement between the trustee and a judgment creditor (72 Partners, LLC). The court held that the bankruptcy court properly denied the request to convert to Chapter 11 because cause existed to either dismiss the case or convert it back to a Chapter 7, based on substantial or continuing loss to or diminution of the estate and the absence of a reasonable likelihood of rehabilitation under 11 U.S.C. 1112(b)(4)(A). Furthermore, other section 1112(b)(4) causes for denying conversion to Chapter 11 existed, such as failure to comply with an order of the court, failure timely to provide information or attend meetings reasonably requested by the United States trustee, and inability to effectuate substantial consummation of a confirmed plan. Another cause not listed in the statute was debtors' lack of good faith. View "Daughtrey v. Rivera" on Justia Law