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

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 Eleventh Circuit held that, although the district court correctly ruled that the vehicles parked by plaintiffs were "goods" subject to the ultimate consumer exception, and not "materials" under the FLSA, FCPS was not entitled to summary judgment on the FLSA claims. Viewing the evidence in the light most favorable to plaintiffs, a jury could reasonably find that the uniforms they had to wear as valets for FCPS constituted "materials" under 29 U.S.C. 203(s)(1)(A). Furthermore, the labels on the uniforms, which reflect foreign manufacture, similarly created a jury issue as to whether the uniforms moved in international or interstate commerce under section 203(s)(1)(A)(ii). 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 defendant's conviction and 15 year sentence for being a convicted felon in possession of a firearm. The court held that the district court did not err in finding that an occupant of the house intelligently and voluntarily gave her consent to search the house and that she had authority to do so without defendant's consent. Therefore, the district court did not err by denying the motion to suppress. The court also held that the evidence was sufficient to convict defendant and the district court did not err by denying defendant's motion for judgment of acquittal. Finally, the court held that the application of the armed career criminal enhancement and the application of a sentencing enhancement under USSG 4B1.4 did not violate defendant's Eighth Amendment right to be free from cruel and unusual punishment. Defendant abandoned any challenge to the substantive reasonableness of his sentence. View "United States v. Luis Morales" on Justia Law

In this consolidated appeal, plaintiff alleged that the district court abused its discretion by dismissing his two lawsuits based on the doctrine of judicial estoppel as a result of his failure to disclose them in his bankruptcy proceeding. Applying a two-part test to guide district courts in applying judicial estoppel, the court held that plaintiff took an inconsistent position under oath in a separate proceeding and the inconsistent positions were calculated to make a mockery of the judicial system. In this case, plaintiff not only failed to include the two lawsuits in his initial bankruptcy filings but he also failed to include them in any of the six separate amendments that he made to his schedules and filings during the bankruptcy proceeding. Plaintiff only disclosed the lawsuits after defendants had relied on plaintiff's failure to disclose as grounds for dismissal. View "Weakley v. Eagle Logistics" on Justia Law

The Eleventh Circuit affirmed the district court's grant of summary judgment for the United States and the district court's denial of NextEra's claims seeking a tax refund for net operating losses resulting from fees it paid to the Nuclear Waste Fund for the disposal of nuclear waste. The court held that NextEra was not entitled to a refund under 26 U.S.C. 172(f), because it could not show that its payment of fees under the Nuclear Waste Policy Act of 1982 was for an act that qualified as nuclear decommissioning, was done pursuant to a law that required nuclear decommissioning, and that the act occurred more than three years prior to the claimed loss. View "Nextera Energy, Inc. v. United States" on Justia Law

The Eleventh Circuit affirmed defendant's conviction and sentence for fifty counts of making false statements in connection with the delivery of, or payment for, healthcare services and for one count of knowingly and willfully making a materially false statement to a federal agent. The court held that defendant's convictions were supported by legally sufficient evidence. The court also held that the district court did not clearly err by applying a sentencing enhancement for a theft offense involving the conscious or reckless risk of death or serious bodily injury pursuant to USSG 2B1.1(b)(15)(A). View "United States v. Henderson" on Justia Law

The Eleventh Circuit affirmed defendant's conviction and life sentence for attempting to use a weapon of mass destruction and attempting to provide material support to a foreign terrorist organization. The court held that there was sufficient evidence to support defendant's convictions where he had the requisite intent to coordinate with ISIS and direct his services to ISIS, and he took substantial steps to do so. The court also held that defendant's life sentence did not violate the Eighth Amendment because it was not disproportionate to his crimes, and was procedurally and substantively reasonable. View "United States v. Suarez" on Justia Law

The Eleventh Circuit affirmed the district court's grant of summary judgment to defendants in an action brought by plaintiffs, former sheriff deputies, under the Fair Labor Standards Act (FLSA) and the Florida Minimum Wage Act (FMWA). The court held that the deputies were not entitled to compensation under the FLSA or the FMWA for the time that they spent donning and doffing police gear or the time that they spent driving to and from work in marked patrol vehicles. View "Llorca v. Sheriff, Collier County, Florida" on Justia Law

The Eleventh Circuit affirmed the district court's grant of summary judgment for Wells Fargo, a mortgage servicer, in an action alleging that Wells Fargo failed to conduct a reasonable investigation into the accuracy of its credit reporting of her mortgage loan, in violation of the Fair Credit Reporting Act (FCRA). The court held that plaintiff could not prevail on her claim against Wells Fargo under section 1681s-2(b) of the FCRA without identifying some fact in the record establishing that the information Wells Fargo reported regarding her account was inaccurate or incomplete. In this case, regardless of whether plaintiff may have been confused about how her account would be reported to the credit rating agencies, and whether Wells Fargo could have better explained to her how the account would be reported, she did not meet her payment obligations under the note. Finally, any omissions did not render plaintiff's credit report misleading. View "Felts v. Wells Fargo Bank, N.A." on Justia Law

The International Convention Against the Taking of Hostages provides global notice to the world that the hostage taking criminalized by 18 U.S.C. 1203 can be prosecuted in any signatory nation of which the hostage is a citizen or a national, notwithstanding that the crime occurred elsewhere. The Eleventh Circuit affirmed defendant's conviction for conspiracy to seize or detain, and threaten to kill, injure, or continue to detain, a national of the United States in order to compel a third person to pay ransom (count 1), and hostage taking (count 2). The court held that the relevant statute's requirement that the victim be Americans is jurisdictional only and there was no mens rea requirement for that part of the statute; the conduct of which defendant was convicted clearly fell within the plain meaning of the statutory language of the hostage taking statute; and the court rejected defendant's constitutional challenges to section 1203 where his empowerment argument and due process argument were without merit. View "United States v. Noel" on Justia Law

The Eleventh Circuit granted Everglades' petition for review of the NLRB panel's order concluding that the company violated the National Labor Relations Act (NLRA). In light of Epic Systems Corp. v. Lewis, 584 U.S. __, 138 S. Ct. 1612 (2018), which held that employer-employee agreements did not violate the Act and must be enforced as written, the court reversed the NLRB panel's ruling that Everglades violated the NLRA by maintaining and enforcing an employment agreement requiring that employment disputes be resolved through individualized arbitration. The court vacated the NLRB panel's grant of summary judgment on the claim regarding prohibiting unfair labor charges and remanded it to the NLRB so that it can apply the new standard set forth in The Boeing Co., 365 N.L.R.B. No. 154 (Dec. 14, 2017) (abandoning the "reasonably construe" standard) and any other relevant law. Consequently, the court vacated the NLRB panel's ruling as to the unlawful discharge claim. Therefore, the court denied the NLRB's cross-application for enforcement. View "Everglades College, Inc. v. National Labor Relations Board" on Justia Law