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

In this appeal arising from an allegedly defective surgical mesh implant, the Eleventh Circuit certified the following question to the Supreme Court of Texas: In a product liability case, does Texas' discovery rule require a plaintiff to have some knowledge of possible wrongdoing on the part of the manufacturer—i.e., a causal connection between the injury and the manufacturer's conduct—before the plaintiff's claims can accrue? View "Bergin v. Mentor Worldwide LLC" on Justia Law

When a plaintiff takes inconsistent positions by pursuing in district court a civil claim that he failed to disclose as an asset in his bankruptcy proceedings, a district court may apply judicial estoppel to bar the plaintiff's civil claim if it finds that the plaintiff intended to make a mockery of the judicial system. When determining whether a plaintiff who failed to disclose a civil lawsuit in bankruptcy filings intended to make a mockery of the judicial system, a district court should consider all the facts and circumstances of the case. The Eleventh Circuit reasoned that the court should look to factors such as the plaintiff's level of sophistication, his explanation for the omission, whether he subsequently corrected the disclosures, and any action taken by the bankruptcy court concerning the nondisclosure. The court overruled portions of Barger v. City of Cartersville, 348 F.3d 1289 (11th Cir. 2003), and Burnes v. Pemco Aeroplex, Inc., 291 F.3d 1282 (11th Cir. 2002), that permit a district court to infer intent to misuse the courts without considering the individual plaintiff and the circumstances surrounding the nondisclosure. Accordingly, the court remanded for consideration of whether the district court abused its discretion in light of this new standard. View "Slater v. United Steel Corp." on Justia Law

The Eleventh Circuit reversed the dismissal of five complaints filed by automobile body shops, asserting federal antitrust and state tort claims against insurance companies. The court held that the shops pleaded enough facts to plausibly support their federal antitrust and state tort claims. In this case, the body shops argued that the insurance companies engaged in two lines of tactics in pursuit of a single goal: to depress the shops' rates for automobile repair. The body shops have supplied enough allegations to raise a reasonable expectation that discovery will reveal evidence of an illegal agreement; the body shops have consistently alleged the existence of parallel conduct and of plus factors allowing a plausible inference of an illegal agreement; and the allegations have sufficiently established the body shops' state tort claims of unjust enrichment, quantum meruit, and tortious interference. Accordingly, the court remanded for further proceedings. View "Quality Auto Painting Center of Roselle, Inc. v. State Farm Indemnity Co." on Justia Law

The plain reading of the Pregnancy Discrimination Act (PDA) covers discrimination against breastfeeding mothers. Plaintiff filed suit against the police department under the PDA and the Family and Medical Leave Act (FMLA) after her reassignment and constructive discharge. The Eleventh Circuit affirmed the jury verdict in favor of plaintiff and held that there was sufficient evidence of intentional discrimination when plaintiff was reassigned from the narcotics task force to the patrol division; the denial of accommodations for a breastfeeding employee violated the PDA when it amounted to a constructive discharge; a reasonable person in plaintiff's position would have felt compelled to resign; and the City's remaining arguments were unavailing. View "Hicks v. Tuscaloosa, Alabama" on Justia Law

Defendants Larry and Dixie Masino were indicted for conspiracy to commit wire fraud, operating an illegal gambling business, conspiracy to commit money laundering, and money laundering. A federal grand jury returned a superseding indictment that added predicate offenses to Count Two, operating an illegal gambling business. The Eleventh Circuit declined to exercise pendant jurisdiction over Larry's cross-appeal of a denial of a motion to dismiss the indictment; Count Two of the indictment was legally sufficient to state an offense; because a violation of the Florida bingo statute could satisfy the essential element about state law required to prove Count Two, the court need not address Florida gambling house statutes as a basis for upholding the indictment; and thus the indictment stated the essential element about state law because the bingo statute provides at least some violations that would make a gambling business illegal. Accordingly, the court dismissed the cross-appeal for lack of jurisdiction, reversed the order dismissing part of Count Two of the indictment, and remanded for further proceedings. View "United States v. Masino" on Justia Law

This appeal involved four of a group of twelve cases filed by death row inmates challenging the constitutionality of the State's lethal injection protocol. The Eleventh Circuit reversed the dismissal of the four cases, holding that the ADOC's law-of-the-case argument failed. The court also held that the complaint stated a claim sufficient to survive a Rule 12(b)(6) motion to dismiss. In this case, the complaint alleged that if midazolam fails to render the inmates insensate, the severe pain caused by the second and third drugs would represent a "substantial risk of serious harm," and each of the inmate's three proposed alternatives would be obtainable by the ADOC and would completely eliminate the risk of suffocation and pain the second and third drugs create. The court remanded for further proceedings. View "West v. Commissioner, Alabama DOC" on Justia Law

The Eleventh Circuit affirmed defendant's conviction and sentence for dealing in firearms without a federal firearms license, in violation of 18 U.S.C. 922(a)(1)(A), and selling firearms to unlicensed residents of states other than his own without having a license to do so, in violation of 18 U.S.C. 922(a)(5). The court held that the evidence was sufficient to convict defendant; the district court did not abuse its discretion in failing to include defendant's proposed language in the jury instructions regarding Count 1; defendant's Second Amendment challenge to section 922(a)(1)(A) failed, and the district court did not err in denying his motion to dismiss Count 1 on this basis; the district court did not err in denying defendant's motion to dismiss Counts 2 and 3; and the court rejected defendant's challenges to the application of three sentencing enhancements for possession of various firearms, the international transfer of firearms, and obstructing justice, because a 51 month sentence was reasonable after considering the 18 U.S.C. 3553(a) factors. View "United States v. Focia" on Justia Law

The Eleventh Circuit affirmed the district court's denial of defendant's motion for a new trial after he was convicted of importing a controlled substance and of possessing a controlled substance with the intent to distribute. Defendant argued that the district court committed several errors by failing to continue his trial and allowing the case to proceed before he had a chance to watch a video that filmed the seizure of defendant's drugs at the airport for a television show called, "Drug Wars." The court held that the tape was not exculpatory and defendant failed to establish specific and substantial prejudice from this omission. The court found no other errors in the record. View "United States v. Jeri" on Justia Law

Plaintiffs, death row inmates, filed suit challenging the constitutionality of Alabama's execution protocol. The Eighth Circuit vacated the district court's grant of summary judgment for the ADOC and held that genuine issues of material fact preclude summary judgment; plaintiff's Eighth Amendment claims were not barred by the law-of-the-case doctrine; and in regard to the ADOC's limitations argument, because it was not raised and the district court did not consider it, the court could not address it in the absence of a factual determination as to whether the substitution of midazolam for pentobarbital constituted a substantial change to Alabama's execution protocol. The court remanded for further proceedings. View "Grayson v. Warden, ADOC" on Justia Law

Plaintiff filed suit against a sheriff's deputy for improperly accessing and viewing her private information on Florida driver's license databases. The district court granted plaintiff's motion for judgment as a matter of law and held the deputy liable under the Driver's Privacy Protection Act (DPPA) and 42 U.S.C. 1983. The Eleventh Circuit affirmed the liquidated damages award where the district court did not abuse its discretion in shaping a damages award appropriate for the facts of this case. The court held, however, that the district court failed to start with the lodestar and gave too much weight to the eighth Johnson factor (the amount involved and the results obtained). Accordingly, the court reversed and remanded for the district court to recalculate an appropriate amount of attorneys' fees. View "Ela v. Destefano" on Justia Law