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

In December 2011, Purchasing Power filed suit against Bluestem in Georgia state court. Bluestem, a citizen of Minnesota and Delaware, sought to remove the case to federal court based on diversity jurisdiction. Burr & Forman (B&F) was the law firm representing Purchasing Power. In 2014, the district court granted summary judgment for Bluestem. On appeal, this court noted that the pleadings did not allege Purchase Power's citizenship. B&F had failed to realize, and no one bothered to investigate, that Falcon, one of the LLCs, did not own an interest in Holdings directly. This missing piece of information was essential in destroying diversity jurisdiction because Falcon was incorporated in Delaware, of which Bluestem was a citizen. The district court subsequently found that B&F misrepresented to either the district court or Bluestem on five occasions that diversity of citizenship existed. In this appeal, B&F challenged the district court's sanctions order. The court reversed the district court's imposition of sanctions, concluding that, while the requirements of diversity jurisdiction were complicated, no party in this case acted with bad intentions. View "Purchasing Power, LLC v. Bluestem Brands, Inc." on Justia Law

Petitioner, convicted of murdering a police officer and sentenced to death, suffered strokes in recent years resulting in significant cognitive and physical decline. Petitioner sought habeas relief, arguing that he was mentally incompetent to be executed under Ford v. Wainwright and Panetti v. Quarterman. The Alabama trial court decided that petitioner was competent to be executed. The court agreed with petitioner that the trial court's decision relied on an unreasonable determination of the facts and involved an unreasonable application of Panetti. The court explained that Panetti required courts to look at whether the prisoner was able to rationally understand the connection between the crime he committed and the punishment he was to receive. In this case, one of the experts testified that due to a mental disorder, petitioner was not able to make this connection, and another expert never addressed this question at all. The court concluded that this record was therefore wholly insufficient to support the trial court's decision. Accordingly, the court reversed the district court's denial of habeas relief. View "Madison v. Commissioner, Alabama Department of Corrections" on Justia Law

Defendant pleaded guilty to several drug and firearm charges, and the district court reassigned the case to a new judge for sentencing. Defendant argued that the reassignment was unlawful because the judge initially assigned to the case was neither absent nor disabled. The court rejected this argument and concluded that the text of Rule 25 made clear that the rule does not apply where a defendant pleaded guilty. The court also rejected defendant's arguments that the traffic stop was unlawful, that the district court should have reassigned the case back to the initial judge, and that the district court committed procedural and substantive error when it sentenced defendant. Accordingly, the court affirmed the judgment. View "United States v. McCullough" on Justia Law

Petitioner, a Florida prisoner sentenced to death, filed a motion for a certificate of appealability (COA), seeking to appeal the denial of his motion for relief from judgment under Federal Rule of Civil Procedure 60(b). The court denied petitioner's three motions for a COA where reasonable jurists could not debate whether the district court abused its discretion in denying petitioner's Rule 60(b)(6) motion. In this case, petitioner has litigated and re-litigated variations on the same claims for decades. View "Lambrix v. Secretary, Florida Department of Corrections" on Justia Law

Petitioner, convicted of being a felon in possession of a firearm, petitioned for habeas relief, arguing that his earlier motion to vacate was inadequate to test his objection to his sentence enhancement because the court's caselaw about the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e), has changed. The court concluded that, because the motion to vacate gave petitioner an opportunity to challenge his sentence enhancement, his remedy was not inadequate or ineffective to test the legality of his sentence, regardless of any later change in caselaw. The court joined the Tenth Circuit in applying the law as Congress wrote it and held that a change in caselaw does not make a motion to vacate a prisoner's sentence "inadequate or ineffective to test the legality of his detention," 28 U.S.C. 2255(e). Accordingly, the court overruled the Wofford v. Scott test as applied in Bryant v. Warden, FCC Coleman-Medium and Mackey v. Warden, FCC Coleman-Medium, and affirmed the dismissal of the petition for habeas relief. View "McCarthan v. Director of Goodwill Industries-Suncoast" on Justia Law

Plaintiffs, Mexican nationals, filed suit against defendants, international air transportation companies that transport passengers to and from the United States and Mexico, under the Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. 1961-68, alleging that defendants defrauded them by collecting a Mexican tourism tax in which they were exempt. Mexico imposed a tax on certain travelers who arrive in Mexico on flights that originated outside of Mexico, but exempted Mexican nationals and children under the age of two. The district court dismissed the case with prejudice. The court concluded that, although defendants' conduct regarding the tax was very troubling, plaintiffs failed to allege the existence of an express agreement, let alone an "enterprise" under section 1962. Accordingly, the court affirmed the judgment. View "Almanza v. United Airlines" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 against her employer, alleging that she was discriminated against because of her sexual orientation and gender non-conformity, and retaliated against after she lodged a complaint with her employer's human resources department. The district court dismissed her pro se complaint. The court held that discrimination based on failure to conform to a gender stereotype was sex-based discrimination. In this case, a gender non-conformity claim was not "just another way to claim discrimination based on sexual orientation," but instead constituted a separate, distinct avenue for relief under Title VII. Therefore, the court vacated the portion of the district court's order dismissing plaintiff's gender non-conformity claim with prejudice and remanded with instructions to grant plaintiff leave to amend such claim. The court concluded that binding precedent, Blum v. Gulf Oil Corp., foreclosed plaintiff's argument that she had stated a claim under Title VII by alleging that she endured workplace discrimination because of her sexual orientation. The Blum court held that discharge for homosexuality was not prohibited by Title VII. Therefore, the court affirmed the portion of the district court's order dismissing plaintiff's sexual orientation claim. Finally, the court considered any challenge to the district court's treatment of plaintiff's retaliation claim as waived. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Evans v. Georgia Regional Hospital" on Justia Law

Petitioner, convicted of murder and sentenced to death, appealed the district court's denial of his 28 U.S.C. 2254 petition for a writ of habeas corpus. The court agreed with the district court that petitioner failed to establish that the Georgia trial court unreasonably rejected his claim that trial counsel failed to investigate, develop, and present mitigating evidence at sentencing, or that petitioner was prejudiced by appellate counsel's failure to investigate and adequately present that claim during the unified appeal procedure. Accordingly, the court affirmed the judgment. View "Butts v. GDCP Warden" on Justia Law

Plaintiffs filed suit seeking to move or extend the Brick-Kiln Dock to improve its accessibility. Plaintiffs argued that the deed by which plaintiffs conveyed the island property to the government and reserved the right to continue to use the dock permitted them to relocate the dock. Alternatively, plaintiffs contend that the Park Service's denial of permission to relocate or extend the dock was arbitrary and capricious. The court affirmed the district court's determination that, under the plain language of the deed, plaintiffs have no reserved right to unilaterally relocate or extend the dock. The court also concluded that the Park Service's denial of permission to relocate or extend the Dock was not arbitrary or capricious and did not exceed its authority. In this case, the Wilderness Act, 16 U.S.C. 1131(a), foreclosed relocation of the Dock, and the Park Service was authorized to regulate the marshlands. Accordingly, the court affirmed the judgment. View "High Point, LLLP v. National Park Service" on Justia Law

Petitioner was sentenced to life imprisonment and chemical castration after he was convicted of burglary, aggravated kidnapping of a child, and two counts of capital sexual battery. The state court later granted petitioner's motion to correct an illegal sentence on the ground that the trial court failed to comply with the statutory prerequisites for chemical castration. In this appeal, petitioner challenged the district court's dismissal of his petition as second or successive under 28 U.S.C. 2244(b)(1). The court affirmed the dismissal of the petition as second or successive. In this case, because petitioner was not "in custody pursuant to," section 2254(b)(1), the consent order that he not undergo chemical castration did not trigger a new round of federal collateral review. View "Patterson v. Secretary, Florida Department of Corrections" on Justia Law