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

The Eleventh Circuit reversed the district court's decision issuing a writ of habeas corpus setting aside petitioner's failure-to-register conviction on the ground that his prior sodomy conviction was invalid under Lawrence v. Texas, 539 U.S. 558, 123 S. Ct. 2472 (2003). The court held that petitioner's claim that Lawrence voided his sodomy conviction was unexhausted and thus the district court erred by entertaining it. The court also held that the Court of Appeals, in light of Georgia state law, correctly found that petitioner suffered no prejudice under Strickland v. Washington, 466 U.S. 668, 104 S. Ct. 2052 (1984). View "Green v. Georgia" on Justia Law

Plaintiffs filed suit against ZOLL, alleging that claims for strict products liability, negligence, fraudulent misrepresentation, fraudulent marketing and promotion, breach of express warranty, negligent misrepresentation, and negligent infliction of emotional distress all related to the operation (or failure to operate) of the deceased's LifeVest. The Eleventh Circuit affirmed the district court's dismissal of plaintiffs' negligent infliction of emotional distress claim. However, in light of developing and binding precedent in this circuit, the court reversed the district court's dismissal of the remaining claims. The court held that these claims were cognizable Florida common law causes of action and were not preempted by federal law. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Godelia v. ZOLL Services, LLC" on Justia Law

The Eleventh Circuit affirmed the district court's judgment in a personal injury case arising from plaintiff's slip and fall at a Publix Supermarket operated by defendant. After the jury returned a verdict for defendant, plaintiff and a third party, ML Healthcare appealed. The court held that the district court did not abuse its discretion by requiring ML Healthcare to produce, and then by admitting at trial, evidence of collateral source payments made by ML Healthcare on plaintiff's behalf. The court held that the district court did not abuse its discretion by denying in part ML Healthcare's motion to quash. Finally, the district court did not abuse its discretion by denying plaintiff's motion for spoliation sanctions, a request for an adverse inference, and a request for exclusion of evidence. View "ML Healthcare Services, LLC v. Publix Supermarkets, Inc." on Justia Law

The Eleventh Circuit affirmed the district court's judgment in a personal injury case arising from plaintiff's slip and fall at a Publix Supermarket operated by defendant. After the jury returned a verdict for defendant, plaintiff and a third party, ML Healthcare appealed. The court held that the district court did not abuse its discretion by requiring ML Healthcare to produce, and then by admitting at trial, evidence of collateral source payments made by ML Healthcare on plaintiff's behalf. The court held that the district court did not abuse its discretion by denying in part ML Healthcare's motion to quash. Finally, the district court did not abuse its discretion by denying plaintiff's motion for spoliation sanctions, a request for an adverse inference, and a request for exclusion of evidence. View "ML Healthcare Services, LLC v. Publix Supermarkets, Inc." on Justia Law

The Rooker-Feldman doctrine can not bar a federal suit regarding events occurring long after the entry of a state court decision. Long after a state court lawsuit had been completed between Specialty Marketing and Target Media, Specialty Marketing mailed out a letter including the state court events and trial testimony. Target Media filed a defamation action against Specialty Marketing, seeking injunctive relief and damages. The Eleventh Circuit reversed the district court's dismissal of the defamation case, holding that the district court improperly denied subject matter jurisdiction and erroneously dismissed Target Media's defamation claim on Rooker-Feldman grounds. The court held there was no reasonable opportunity to raise the instant claim in Alabama's state courts, and the claim was not "inextricably intertwined" with the judgment rendered in Alabama court. View "Target Media Partners v. Specialty Marketing Corp." on Justia Law

The Eleventh Circuit certified a question to the Florida Supreme Court regarding the appropriate limitations period to be applied to post-judgment discovery. The Florida Supreme Court answered: Under Florida law, post-judgment discovery for the purpose of collecting a federal money judgment issued by a federal court in Florida "is permitted for a period of twenty years from the date the judgment was entered." In light of the state court's guidance, the Eleventh Circuit held that plaintiffs' motion to compel post-judgment discovery was timely. Accordingly, the court reversed and remanded for further proceedings. View "Salinas v. Ramsey" on Justia Law

An affidavit which satisfies Rule 56 of the Federal Rules of Civil Procedure may create an issue of material fact and preclude summary judgment even if it is self-serving and uncorroborated. Because this principle applies in all civil cases, including those in the realm of tax law, the Eleventh Circuit, en banc, overruled that portion of Mays v. United States, 763 F.2d 1295, 1297 (11th Cir. 1985), which is (or may be interpreted to be) to the contrary. In this case concerning IRS assessments, the court remanded with instructions for the panel to consider the government's arguments, as well as defendant's answers to them. View "United States v. Stein" on Justia Law

Petitioner sought review of the BIA's decision denying his motion to reopen removal proceedings. The DC Circuit dismissed in part and denied in part, holding that petitioner's constitutional claims challenging the order of removal itself and those addressing the sufficiency of the IJ's order denying the instant motion were not properly exhausted in immigration proceedings or were otherwise not properly before the court. In regard to petitioner's remaining claims challenging the BIA's decision, the court could not say that the BIA abused its discretion or that its opinion lacked reasoned consideration when it denied petitioner's motion to reopen. View "Bing Quan Lin v. U.S. Attorney General" on Justia Law

Winn-Dixie filed suit against Big Lots, Dollar General, and Dollar Tree, to enforce a grocery exclusive provision of its leases. At issue on appeal was the district court's ruling on remand. The district court found that none of the Alabama stores was violating the grocery exclusive provisions. In regard to the Florida stores, the district court ruled that the definitions of "groceries" and "sales area" in Winn-Dixie Stores, Inc. v. 99 Cent Stuff-Trail Plaza, LLC, 811 So. 2d 719 (Fla. 3d DCA 2002), applied. The Eleventh Circuit reversed the district court's judgment as to the Dollar General and Big Lots stores in Florida and remanded with instructions for the district court to apply to those stores, which had leases dated before February 20, 2002, the same definitions of "groceries" and "sales area" that it applied to the Florida stores with leases dated after February 20, 2002. The court affirmed as to the Alabama stores. View "Winn-Dixie Stores, Inc. v. Dolgencorp, LLC" on Justia Law

Relators filed suit under the False Claims Act (FCA), 31 U.S.C. 3729-30, alleging that MD and others misled the Government by providing material false or incomplete information at two points in the transactional relationship, as well as improprieties between the remaining defendants. The Eleventh Circuit held that the district court must revisit whether the relators alleged facts sufficient to support a theory of implied certification as articulated in Universal Health Services, Inc. v. United States ex rel. Escobar, 136 S. Ct. 1989 (2016). The court also held that the complaint did plead fraud in the inducement, and thus the court remanded so that the district court could reexamine the allegations relating to that theory. View "Marstettler v. Tilton" on Justia Law