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

The Eleventh Circuit affirmed the denial of the City's motions for judgment as a matter of law and for a new trial in an inverse condemnation action. In this case, the underlying dispute involved a beachfront parcel owned by plaintiffs, which experienced significant public usage. The court held that the evidence at trial supported the jury's finding that a physical taking occurred through the continuous occupation of plaintiffs' property by members of the general public where the City encouraged public occupation by placing beach access signs, clearing vegetation, creating nearby parking spaces, hosting events at the property, and refusing to remove trespassers. The court also held that there was no basis to grant a new trial. Finally, on the City's request for fee simple ownership of the beach parcel upon payment of the judgment—the court held that such relief was not warranted under Florida law and the district court did not abuse its discretion in denying the City's request to transfer title. The court held that the City has paid for, and was entitled to, a permanent easement across plaintiffs' beach property for the benefit of the public and directed the district court to amend its judgment to reflect this permanent easement. View "Chmielewski v. City of St. Pete Beach" on Justia Law

The Eleventh Circuit affirmed defendant's convictions for the use of an unauthorized access device and aggravated identity theft. The court held that the district court abused its discretion by excluding lay identification testimony from a defense witness while admitting similar testimony from a government witness, but the error was harmless because the defense presented identification testimony from other witnesses. View "United States v. Knowles" on Justia Law

The Eleventh Circuit affirmed the district court's grant of summary judgment for Mosaic in this toxic tort action. Plaintiff alleged that toxic substances emitted from a factory operated by Mosaic caused or exacerbated various medical conditions from which she suffers. The court held that the district court did not abuse its discretion in excluding the opinions of plaintiff's expert because the expert's methodology was undermined by multiple defects. The court found no error in the district court's analysis and agreed with the district court that, among other things, the expert failed to properly assess dose-response with regard to plaintiff, to meaningfully rule out other potential causes of plaintiff's medical conditions, and to account for the background risk of her conditions. View "Williams v. Mosaic Fertilizer, LLC" on Justia Law

The Eleventh Circuit affirmed the district court's grant of summary judgment for Mosaic in this toxic tort action. Plaintiff alleged that toxic substances emitted from a factory operated by Mosaic caused or exacerbated various medical conditions from which she suffers. The court held that the district court did not abuse its discretion in excluding the opinions of plaintiff's expert because the expert's methodology was undermined by multiple defects. The court found no error in the district court's analysis and agreed with the district court that, among other things, the expert failed to properly assess dose-response with regard to plaintiff, to meaningfully rule out other potential causes of plaintiff's medical conditions, and to account for the background risk of her conditions. View "Williams v. Mosaic Fertilizer, LLC" on Justia Law

Plaintiff filed suit against Venezuela, seeking payment for or return of the Bolivar Collection, asserting jurisdiction under the commercial activity exception to the Foreign Sovereign Immunities Act of 1976 (FSIA), 28 U.S.C. 1605(a)(2). Plaintiff inherited the Bolivar Collection, personal items belonging to Simon Bolivar that were gifted to Joaquin de Mier, which was passed down through generations of de Mier's family. The Eleventh Circuit affirmed the district court's denial of Venezuela's motion to dismiss on the basis of sovereign immunity. The court held that jurisdiction over plaintiff's action came from the third clause of the FSIA's commercial activity exception because his action was based on Venezuela's act outside the United States in connection with commercial activity, and that act had a direct effect in the United States. View "Devengoechea v. Bolivarian Republic of Venezuela" on Justia Law

Fair notice at a relatively early stage of litigation was a primary factor in considering whether a party has acted consistently with its arbitration rights. In appeals stemming from class actions brought by bank customers, Wells Fargo challenged the district court's denial of its motion to compel arbitration with the unnamed plaintiffs comprising the classes. The Eleventh Circuit held that the district court's finding that Wells Fargo waived its arbitration rights as against those unnamed plaintiffs was erroneous. In this case, Wells Fargo did not act inconsistently with its arbitration rights and thus did not waive those rights with its express reservation of its arbitration rights as to future plaintiffs in response to the district court's scheduling order. Accordingly, the court vacated the district court's order. View "Gutierrez v. Wells Fargo Bank" on Justia Law

Defendant appealed the district court's grant of summary judgment in favor of the United States for unpaid federal income taxes, late penalties, and interest accrued. The Eleventh Circuit initially affirmed but then later granted rehearing en banc and overruled Mays v. United States, 763 F.2d 1295 (11th Cir. 1985). On remand to the original panel, the parties raised arguments that no longer resemble the arguments they had made to the district court. Therefore, the court vacated the judgment of the district court and remanded to the district court to consider the new arguments in the first instance. View "United States v. Stein" on Justia Law

After police officers interrupt what they reasonably believe to be a residential burglary and detain two suspects just outside of the house, they can thereafter lawfully enter the home—without a warrant, and without further suspicion of wrongdoing—to briefly search for additional perpetrators and potential victims. The Eleventh Circuit held that the suspected burglary presented an exigent circumstance that justified a warrantless entry and search. Accordingly, the officers in this case did not violate the Fourth Amendment, and the court reversed the district court's denial of summary judgment and remanded with instructions to grant the officers' motion for summary judgment. View "Montanez v. Carvajal" on Justia Law

The Airline Deregulation Act preempts a cause of action against an air ambulance provider based on a provision of the Florida Motor Vehicle No Fault Law, Florida Statutes 627.730–627.7405. The Eleventh Circuit held that the insured in this case sought to restrict the prices of the air carrier and the ADA preempted it from doing so. The court explained that the McCarran-Ferguson Act did not interfere with preemption because the balance billing provision, on which the action rests, has nothing to do with the relationship between an insurer and an insured and therefore does not regulate the business of insurance. View "Bailey v. Rocky Mountain Holdings, LLC" on Justia Law

The Eleventh Circuit held that this action claiming that the City violated the Establishment Clause when it approved the construction of a religious center near plaintiffs' homes was moot and no longer justiciable. In this case, a state court barred the construction of the center after the lawsuit was commenced. View "Gaglilardi v. City of Boca Raton Florida" on Justia Law