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

The case involves a defendant who was charged with multiple crimes related to the production, possession, and distribution of child pornography involving her fourteen-year-old sister. Law enforcement initially investigated the defendant’s husband, but their attention turned to the defendant after she admitted to possibly sending inappropriate photos of her sister to her husband. Subsequent forensic analysis uncovered additional incriminating evidence. Both the sister and husband testified regarding the abuse. The defendant’s primary defense was that she acted under duress due to severe abuse by her husband.In the United States District Court for the Southern District of Georgia, the defendant sought to introduce statements she made to a psychologist, Dr. Reynolds, as part of her duress defense. Dr. Reynolds, who had not practiced clinical work in a decade and was retained specifically to evaluate the defendant in anticipation of litigation, diagnosed her with a dissociative disorder. The government moved to exclude as hearsay those statements made by the defendant to Dr. Reynolds concerning her husband's alleged abuse, arguing that they did not meet the requirements of Federal Rule of Evidence 803(4). The district court agreed, finding the statements were not made for the purpose of medical diagnosis or treatment, but rather to prepare for trial. The court alternatively excluded the statements under Rule 403 due to prejudicial effect. After this ruling, the defendant entered a conditional guilty plea, preserving her right to appeal the evidentiary ruling.The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s evidentiary ruling for abuse of discretion and its factual findings for clear error. The Eleventh Circuit held that statements made to a medical expert retained for litigation, not for genuine medical diagnosis or treatment, do not qualify for the hearsay exception under Rule 803(4). The court found no error in the district court’s exclusion of the statements and affirmed the lower court’s decision. View "USA v. Keegan" on Justia Law

Several business entities formed two limited partnerships to develop and manage affordable housing complexes in Tampa, Florida. Creative Choice Homes XXX, LLC and Creative Choice Homes XXXI, LLC acted as general partners in these partnerships, with various investor and special limited partners. The partnership agreements required the general partners to follow strict financial protocols, including restrictions on advances to affiliates and requirements for the proper distribution of profits. Over several years, financial audits revealed the general partners had made unauthorized advances to related entities, violating the agreements' terms. Despite repeated warnings from the limited partners, the general partners failed to cure the breaches within the periods specified in the agreements.After the limited partners provided formal notice of default, the general partners did not fully remedy the violations in a timely manner, including continuing improper transfers and attempting to cure by making late and improperly sourced payments. The limited partners consequently removed the general partners from their positions. The general partners filed suit in state court, seeking a declaration that their removal was improper and alleging breach of contract by the limited partners. The limited partners removed the case to the United States District Court for the Middle District of Florida and counterclaimed for breach of contract and declaratory relief.Following a bench trial, the district court ruled in favor of the limited partners, finding that the general partners materially breached the partnership agreements, failed to cure, and that removal did not constitute an impermissible forfeiture, waiver, or estoppel. On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed. The court held that the general partners’ breaches were material, their cure efforts were insufficient, and that enforcing removal under the partnership agreements was proper and not inequitable. The district court’s judgment was affirmed. View "Creative Choice Homes XXX, LLC v. Amtax Holdings 690, LLC" on Justia Law

Congress enacted a law requiring certain business entities to report information about their beneficial owners to the Department of the Treasury, aiming to address financial crimes facilitated by anonymous corporate ownership. The law applies to corporations, LLCs, and similar entities, excluding certain organizations like banks, nonprofits, and large businesses. Reporting companies must disclose identifying information about their owners and applicants. The law contains several exemptions for inactive or specific types of entities and allows for regulatory exemptions. The plaintiffs, a business association and a small business owner, challenged the law, arguing it exceeded Congress’s powers and violated constitutional rights.In the United States District Court for the Northern District of Alabama, the plaintiffs moved for summary judgment, asserting that the law was not justified under the Commerce Clause, Taxing Clause, Necessary and Proper Clause, or Congress’s national security and foreign affairs powers. The district court agreed, finding that the law regulated the act of incorporation—a noncommercial activity—and that the connection to interstate commerce was too remote. As a result, the court held the law exceeded Congress’s enumerated powers and did not address the constitutional rights claims.The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo and reversed the district court’s decision. The Eleventh Circuit held that the law facially regulates economic activity by targeting the ownership and operation of business entities, which are inherently commercial. The court found that Congress had a rational basis for concluding that anonymous business dealings have a substantial aggregate effect on interstate commerce. Additionally, the court held that the law’s uniform reporting requirements do not facially violate the Fourth Amendment, as they are reasonable, limited, and accompanied by privacy protections. The case was remanded for further proceedings. View "National Small Business United v. U.S. Department of the Treasury" on Justia Law

Several participants in a terminated employee stock ownership plan asserted claims under the Employee Retirement Income Security Act (ERISA) following the sale and dissolution of their plan. The plan, created by A360, Inc. in 2016, purchased all company stock and became its sole owner. In 2019, A360 and its trustee sold the plan’s shares to another entity, amending the plan at the same time to include an arbitration clause that required all claims to be resolved individually and prohibited representative, class, or group relief. The plan was terminated shortly thereafter, and the proceeds were distributed to participants. The plaintiffs alleged that the defendants undervalued the shares and breached fiduciary duties, seeking plan-wide monetary and equitable relief.The United States District Court for the Northern District of Georgia considered the defendants’ motion to compel arbitration based on the plan’s amended arbitration provisions. The district court determined that although the plan itself could assent to arbitration, the arbitration provision was unenforceable because it precluded plan-wide relief authorized by ERISA. The court found that the provision constituted a prospective waiver of statutory rights and concluded that, per the plan amendment’s own terms, the arbitration provision was not severable and thus entirely void.The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s denial of the motion to compel arbitration de novo. The Eleventh Circuit held that the arbitration provision was unenforceable under the effective vindication doctrine because it barred participants from seeking plan-wide relief for breaches of fiduciary duty, as provided by ERISA. The court joined other circuits in concluding that such provisions violate ERISA’s substantive rights and affirmed the district court’s invalidation of the arbitration procedure and denial of the motion to compel arbitration. View "Williams v. Shapiro" on Justia Law

Victor Yoel Perez Cremades was indicted for conspiracy to possess with intent to distribute, and possession with intent to distribute, large quantities of methamphetamine and fentanyl. Law enforcement intercepted a FedEx package containing nearly four pounds of methamphetamine and over 1,200 fentanyl-laced pills, addressed to a Tampa residence linked to Cremades. Upon searching the home, agents found additional drugs, cash, receipts for wire transfers to Nogales, Arizona (the package's origin), and a handwritten note referencing the transfer. Most identifying documents and mail within the house belonged to Cremades, and only he and his daughter were known to reside there.Following trial in the United States District Court for the Middle District of Florida, the jury found Cremades guilty on both counts. The district court denied his motion for judgment of acquittal based on insufficiency of the evidence and sentenced him to 180 months’ imprisonment on each count, to run concurrently. Cremades appealed, arguing the evidence was insufficient to support his convictions and that the district court abused its discretion by admitting a “drug ledger” into evidence without proper foundation or relevance.The United States Court of Appeals for the Eleventh Circuit reviewed the case. Applying the de novo standard for sufficiency of evidence and abuse of discretion for evidentiary rulings, the court held that the evidence was sufficient for a reasonable jury to convict Cremades on both possession and conspiracy counts. The court further determined that, even if admitting the drug ledger was error, it was harmless given the overwhelming evidence of guilt. The Eleventh Circuit affirmed both convictions and the district court’s rulings. View "USA v. Cremades" on Justia Law

On November 14, 2020, Officer David Collier and his partner arrived at a residence in Escambia County, Florida, to serve arrest warrants on Jacob Settle and his wife. Settle was in his truck parked closely alongside the house in a dark, debris-filled backyard. When the officers approached and identified themselves, Settle refused to exit the vehicle. After Collier threatened to break the truck’s windows, Settle started the engine and shifted the transmission into gear. Collier, believing he and his partner were in imminent danger due to his proximity to the truck, fired his gun into the vehicle, fatally wounding Settle. Settle’s estate sued Collier for excessive force under the Fourth Amendment and for battery under Florida law.The United States District Court for the Northern District of Florida considered Collier's motion for summary judgment, in which he asserted qualified immunity and state law immunity. The district court denied the motion, finding that a reasonable jury could conclude Collier violated Settle’s constitutional rights by using deadly force on a non-moving vehicle that did not pose a risk to the officers. The district court also denied state immunity for the battery claim, reasoning that a jury could find Collier acted with wanton disregard for Settle’s safety.The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s decision de novo. The appellate court held that Collier was entitled to qualified immunity, concluding that his use of deadly force was objectively reasonable because Settle’s actions—starting the engine and shifting the truck into gear while resisting arrest—could reasonably be perceived as an immediate threat. The court further held that Collier was entitled to state statutory immunity from the battery claim, as his conduct met the standards for justified use of force under Florida law. The Eleventh Circuit reversed the district court’s decision and remanded with instructions to enter judgment for Collier. View "Settle v. Collier" on Justia Law

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