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

An individual developed a disabling respiratory condition after working for over fifteen years in coal transportation for two companies. His employment included time as a railroad engineer, during which he transported coal to and from an underground mine and, after that mine's closure, worked at an aboveground preparation plant connected to another underground mine by a long conveyor belt. For much of this period, he was regularly exposed to coal dust. Later, he suffered significant respiratory impairment, leading him to apply for benefits under the Black Lung Benefits Act. After his death, his widow continued the claim for survivor’s benefits.An administrative law judge (ALJ) initially denied the claim, finding that the individual had not worked for the required fifteen years “in an underground coal mine” due to absences and because his work at the preparation plant was not “in an underground mine.” The ALJ concluded that the plant, being over five miles from the underground mine and separated by undeveloped land, was not “appurtenant” to the mine and that conditions at the plant were not substantially similar to an underground mine. The Benefits Review Board reversed, holding that the preparation plant was “appurtenant” to the mine due to functional connection, ownership, and the conveyor system, thus qualifying the employment for the statutory presumption. The Board then awarded benefits based on this presumption.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that aboveground work at an underground coal mine can qualify for the presumption under the Act, but the statutory definition of “coal mine” imposes geographical limits. The court found the Board erred by disregarding the distance between the plant and the mine and by not deferring to the ALJ’s factual determination. The Eleventh Circuit vacated the Board’s decision and remanded for further proceedings. View "Fairfield Southern Company v. Director, Office of Workers' Compensation Programs" on Justia Law

Florida challenged a federal agency document known as the “Informational Bulletin” that interpreted Medicaid’s hold-harmless rule and threatened to claw back billions in Medicaid funds if certain state practices continued. Florida’s Medicaid funding system relies on a Directed Payment Program, under which local governments assess special fees on private hospitals, pool these fees, and transfer the funds to the state agency, which then uses them to secure additional federal matching funds. The state feared the new federal interpretation could jeopardize its program and moved to preliminarily enjoin the Bulletin’s implementation.The United States District Court for the Southern District of Florida, following a magistrate judge’s recommendation, denied Florida’s motion for a preliminary injunction and dismissed the case for lack of subject matter jurisdiction. The district court held that the Bulletin was not a “final agency action” under the Administrative Procedure Act (APA), and therefore not subject to judicial review.The United States Court of Appeals for the Eleventh Circuit reviewed the case and found that, contrary to the district court’s conclusion, the Bulletin was indeed a final agency action subject to judicial review under the APA. However, the Eleventh Circuit held that Florida was unlikely to succeed on the merits of its challenge, concluding that the Bulletin’s interpretation of the Medicaid hold-harmless rule was consistent with the statutory text, was not arbitrary or capricious, and did not require notice-and-comment rulemaking. The court thus reversed the dismissal of the complaint, affirmed the denial of the preliminary injunction, and remanded the case for further proceedings. View "Florida Agency for Health Care Administration v. Administrator for the Centers for Medicare & Medicaid Services" on Justia Law

A company that provides temporary labor to various industries offers daily work opportunities to individuals at its labor halls. Workers can choose whether to accept job assignments, and once they do, they are responsible for arriving at the jobsite on time. The company offers several transportation options—including vans, carpools, and public transit—with a nominal fee deducted from paychecks for those who use company-arranged transportation. Workers can also bring their own tools or use company-provided equipment, with deductions only made for unreturned items.A group of workers filed a class action in the United States District Court for the Southern District of Florida, alleging violations of the Fair Labor Standards Act (FLSA) and the Florida Minimum Wage Act. They claimed that transportation deductions reduced their pay below the minimum wage and that the company failed to pay for travel time, time spent collecting tools, and waiting time. The plaintiffs also raised a claim under the Florida Labor Pool Act regarding excessive transportation charges. The district court granted summary judgment to the company on the FLSA and minimum wage claims, denied the plaintiffs’ summary judgment motion, and declined to certify the subclass related to excessive transportation charges.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that the transportation deductions were lawful because the transportation was optional and for the benefit of employees, not the employer. The court further held that time spent traveling, collecting tools, and waiting was not integral and indispensable to the workers’ principal activities and was thus noncompensable under the FLSA. Finally, the court affirmed the district court’s denial of class certification for the excessive-transportation-charge subclass, finding that individual inquiries would predominate. The judgment of the district court was affirmed. View "Villarino v. Pacesetter Personnel Service, Inc." on Justia Law

A deputy sheriff of Arabic descent, employed by the Richmond County Sheriff’s Office, was assigned to an off-duty security position at a local business. During his assignment, he alleged that his supervisor subjected him to repeated racial harassment, including derogatory remarks about his ethnicity. Witnesses at the business supported these allegations, noting that the supervisor frequently made such comments. The deputy was also interested in joining the SWAT team, which the supervisor led, but after failing the SWAT entrance exam, the deputy filed a formal internal complaint about the harassment.Shortly thereafter, the deputy was investigated and ultimately terminated for allegedly violating departmental policy by making personal use of his patrol vehicle, specifically for visiting another county’s sheriff’s office to inquire about job opportunities. The deputy provided evidence that other officers regularly made similar personal use of patrol vehicles without being disciplined, and argued that his termination was in retaliation for his internal complaint. He filed suit under 42 U.S.C. § 1981, claiming retaliatory discharge.The United States District Court for the Southern District of Georgia granted summary judgment for the defendants, finding that the deputy had not shown that the employer’s stated reason for termination was a pretext for retaliation.On appeal, the United States Court of Appeals for the Eleventh Circuit concluded that the District Court erred by conflating the McDonnell Douglas pretext analysis with the “convincing mosaic” standard. The Eleventh Circuit held that a plaintiff may survive summary judgment by presenting circumstantial evidence that creates a triable issue regarding retaliatory intent, even if pretext is not conclusively shown. The court reversed and remanded for the District Court to apply the correct summary judgment standard. View "Ismael v. Roundtree" on Justia Law

A city in Florida established a "vehicular safety zone" outside a medical clinic that performs abortions, which prohibited most pedestrians, including sidewalk counselors, from entering a 38-foot section of public sidewalk that included the clinic's driveway during business hours. The city justified this restriction by citing repeated incidents involving protestors allegedly impeding vehicles and intimidating occupants, and asserted that existing measures like targeted trespass warnings or arrests were insufficient due to the location being public property and violations being misdemeanors not committed in officers’ presence. Four individuals who regularly engaged in sidewalk counseling—offering literature and conversation to those entering the clinic—along with a nonprofit organization, challenged the ordinance, arguing it violated their First Amendment rights by significantly restricting their ability to communicate with clinic patients, particularly by preventing them from handing leaflets to occupants of vehicles entering or exiting the clinic.The United States District Court for the Middle District of Florida denied the plaintiffs’ motion for a preliminary injunction, finding that they were unlikely to succeed on the merits of their First Amendment claim. The court concluded that the ordinance was narrowly tailored to serve the city's significant interest in vehicular safety and that it left open alternative channels for communication.Upon review, the United States Court of Appeals for the Eleventh Circuit held that the plaintiffs were likely to succeed on the merits of their facial First Amendment challenge. Applying the standard from McCullen v. Coakley, the appellate court found that the ordinance was not narrowly tailored because the city had not seriously considered less restrictive alternatives that would further vehicular safety without burdening substantially more speech than necessary. The Eleventh Circuit vacated the district court’s judgment and remanded with instructions to grant the preliminary injunction, finding also that the remaining factors for injunctive relief favored the plaintiffs. View "Florida Preborn Rescue, Inc. v. City of Clearwater" on Justia Law

The case concerns a federal prisoner who was convicted of Hobbs Act robbery, conspiracy to commit Hobbs Act robbery, and brandishing a firearm during a crime of violence. He pleaded guilty to all counts. In preparing for sentencing, the presentence investigation report classified him as a career offender, which increased his guideline sentencing range. At sentencing, the district court imposed a sentence below the career-offender guideline range—414 months in total, including a mandatory minimum of 384 months for the firearm offenses.After his conviction, the defendant sought to vacate his sentence in the United States District Court for the Middle District of Florida, arguing that his trial counsel was ineffective for failing to object to the career-offender classification. The district court found that the presentence report had mistakenly listed his robbery offenses as controlled substance offenses, but determined that, at the time, binding precedent permitted Hobbs Act robbery to be used as a predicate for the career-offender enhancement. The court concluded that counsel was not ineffective for failing to anticipate later precedent, and also found that the defendant had not suffered prejudice because an objection would have been overruled. The district court denied the motion and a certificate of appealability.The United States Court of Appeals for the Eleventh Circuit granted a certificate of appealability limited to the ineffective assistance issue. Reviewing the case, the Eleventh Circuit held that, even if counsel’s performance was deficient, the defendant could not show prejudice. The court found that the sentencing judge had imposed a sentence based on factors independent of the erroneous guideline calculation, and explained his reasoning in detail. Because there was no reasonable probability that the sentence would have been different absent the alleged error, the Eleventh Circuit affirmed the denial of the motion to vacate. View "Buckner v. USA" on Justia Law

Karen Perez and Jovan Rivera Rodriguez were indicted and convicted for their involvement in a conspiracy to distribute large quantities of fentanyl in the Orlando area. Both played minor roles but were responsible for distributing several kilograms of fentanyl, which subjected them to a mandatory minimum sentence of ten years in prison under federal law. After pleading guilty, both defendants sought sentences below the statutory minimum, citing general sentencing factors and their cooperation with authorities.The United States District Court for the Middle District of Florida received government motions under 18 U.S.C. § 3553(e) and Sentencing Guidelines § 5K1.1 to reduce the sentences based on substantial assistance provided by Perez and Rivera Rodriguez. The government requested modest reductions limited to the assistance factors, but the district court granted further reductions based on the general sentencing factors in 18 U.S.C. § 3553(a), ultimately sentencing Perez to 66 months and Rivera Rodriguez to 60 months in prison. The government appealed, arguing the reductions should have been based solely on assistance-related considerations.The United States Court of Appeals for the Eleventh Circuit reviewed the legality of the sentences de novo. The court held that departures from statutory minimum sentences under 18 U.S.C. § 3553(e) must be based exclusively on substantial-assistance factors, not on the general sentencing factors in § 3553(a). The court found that the district court exceeded its authority by considering non-assistance factors in its downward departures. Accordingly, the Eleventh Circuit vacated both sentences and remanded the cases with instructions to resentence the defendants in accordance with its opinion, limiting any downward departure to substantial assistance only. View "USA v. Perez" on Justia Law

A pharmacist in Florida, serving as the pharmacist-in-charge at a pharmacy called NH Pharma, was indicted for conspiracy to commit health-care fraud and several counts of health-care fraud. The indictment alleged that he defrauded Medicare by billing for drugs different than those he dispensed and for prescriptions never filled. The pharmacy’s owner cooperated with the government after pleading guilty to conspiracy. At trial, the prosecution presented evidence that the pharmacist and the owner prepared compounded medications using unreimbursable ingredients while billing Medicare for more expensive, reimbursable ones, and attempted to cover up the discrepancies during audits. There was also evidence, including video and witness testimony, that the pharmacist had stolen about $200,000 in cash from the pharmacy. Three Medicare beneficiaries testified that they never received or believed they were prescribed the medications billed in their names.The United States District Court for the Middle District of Florida admitted evidence of the uncharged cash theft, ruling it was intrinsic to the case. The court also excused a potential defense witness, a part-owner and pharmacy technician, from testifying after she invoked her Fifth Amendment right against self-incrimination, and declined to recommend immunity for her. After a jury found the pharmacist guilty on all counts, he moved for a new trial based on statements made by the pharmacy owner in her own sentencing memorandum, arguing they constituted newly discovered evidence. The district court denied this motion.The United States Court of Appeals for the Eleventh Circuit affirmed the convictions. It held that the district court did not abuse its discretion by denying a new trial because the statements were not new evidence, nor material, nor likely to produce a different result. The appellate court also found no abuse of discretion in admitting the theft evidence, declining to compel witness immunity, and not conducting an in-camera hearing, and rejected constitutional claims raised by the defendant. View "USA v. Beasley" on Justia Law

The dispute centers on a real estate transaction in which a buyer agreed to purchase a property in Miami for $5,450,000 from two sellers, with a closing set for October 2021. The sellers subsequently discovered a mortgage restriction preventing them from closing until January 2022, which resulted in their failure to close on time. They acknowledged the breach, but subsequent negotiations to revive the deal fell through because the buyer wanted a discounted price to account for damages incurred from the delay, which the sellers refused.The matter proceeded to litigation. The buyer sued for specific performance and damages in state court; the sellers removed the action to federal court and also brought their own federal suit seeking a declaratory judgment that the buyer, not they, had breached. The United States District Court for the Southern District of Florida dismissed the sellers’ declaratory action and granted summary judgment to the buyer on breach of contract, reserving the amount of damages for trial. After a bench trial, the district court awarded the buyer specific performance and damages, ordering the sale to proceed. The parties closed the transaction as ordered.On appeal, the United States Court of Appeals for the Eleventh Circuit held that the issue of specific performance was moot because the sale had already occurred and the property was now owned by third parties not before the court, making further relief impossible. However, the court found the damages issue remained live. It affirmed the district court’s damages award in all respects except for damages for lost tax savings, which it reversed due to insufficient evidence that the buyer itself suffered those losses. The case was remanded for recalculation of damages consistent with the appellate decision. View "Marmol v. Kalonymus Development Partners, LLC" on Justia Law

A police officer responded to a complaint of littering at a McDonald’s parking lot in DeFuniak Springs, Florida, where he encountered John Thomas in a gray Acura matching the reported description. Thomas admitted to littering, exited his vehicle to pick up the trash, and then returned to the driver’s seat. When asked for identification, Thomas produced a Louisiana driver’s license that appeared false, given the age discrepancy. After confirming with the dispatcher that the license information did not match, the officer attempted to arrest Thomas, who resisted, pepper-sprayed the officer, and fled. Thomas abandoned his car nearby and was later apprehended. Police obtained a search warrant for the car, discovering methamphetamine, counterfeit bills, and numerous fraudulent identification documents.The United States District Court for the Northern District of Florida denied Thomas’s motion to suppress the evidence recovered from his car. Thomas argued the warrant was based on information obtained during an illegal stop, asserting that Florida law does not permit officers to detain someone for a noncriminal violation such as littering. The district court found the initial stop lawful, reasoning that the officer had authority to detain Thomas based on the littering complaint and to request identification. It further held that the subsequent arrest for providing false identification was supported by probable cause, validating the search warrant and denying suppression.Upon appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The appellate court held that the initial encounter was consensual and did not implicate the Fourth Amendment, and that the officer had probable cause to arrest Thomas for possession of a fraudulent driver’s license under Florida law. Therefore, the evidence obtained from the car search was admissible, and Thomas’s conviction was affirmed. View "United States v. Thomas" on Justia Law