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

Wright filed suit in federal court against Pilot, alleging that Pilot and certain Pilot employees systematically shortchanged some trucking companies with whom Pilot had discount agreements by failing to give them the agreed-upon benefits. Wright filed claims under both state and federal law. At issue here is whether federal courts that are given original subject-matter jurisdiction over state-law claims by the Class Action Fairness Act (CAFA), 28 U.S.C. 1332(d), retain that jurisdiction even when the class claims are dismissed before the class is certified. The district court found that CAFA does not vest the federal courts with original jurisdiction over state-law claims after the class claims are dismissed. Pilot argues that CAFA conferred original jurisdiction over all of Wright’s claims at the time Wright filed them, such that the jurisdiction could not have divested when the class claims were later dismissed. Here, Wright first filed directly in federal court under CAFA but now wishes to refile in state court. When the post-filing action that did away with the class claims is not an amendment to the complaint, the court saw no basis for distinguishing cases originally filed in federal court under CAFA from those removed to federal court. Therefore, the court concluded that CAFA continues to confer original federal jurisdiction over the remaining state-law claims in this suit. Because CAFA vested the district court with original jurisdiction over the remaining claims, there was no need for it to analyze supplemental jurisdiction. Accordingly, the court reversed and remanded. View "Wright Transportation, Inc. v. Pilot Corporation" on Justia Law

Defendants were charged and found guilty of several counts in an eight-count superseding indictment. The verdict forms that were given to the jury mistakenly listed one of the counts as “robbery” instead of “using a firearm during and in relation to [a robbery].” After the district court learned of the error, it gave the parties notice and amended the judgments under Rule 36 of the Federal Rules of Criminal Procedure. However, defendants argue that the amendment was improper and that the original (erroneous) judgments should be reinstated, consistent with what the jurors found. Applying the district court's application of Rule 36 de novo, the court concluded that, consistent with its analysis in United States v. Diaz, the verdict form error was harmless on the facts of this case, and amending the judgments that were based on those verdict forms is the sort of clerical correction contemplated by Rule 36. Accordingly, the court affirmed the judgment. View "United States v. Davis" on Justia Law

Defendant was convicted of being a felon in possession of a firearm. The district court sentenced defendant under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e), in part, based on his two convictions for burglary under Florida law. The court concluded, and the government agrees, in light of the Supreme Court’s decisions in Johnson v. United States and Mathis v. United States, that defendant's burglary convictions cannot support such a sentence. As a categorical matter, a Florida burglary conviction is not a “violent felony” under the ACCA. Accordingly, the court vacated the sentence and remanded for resentencing without the ACCA enhancement. View "United States v. Esprit" on Justia Law

Petitioner seeks review of the Commissioner's determination that he owes income tax deficiencies and related penalties for 2004, 2005, and 2006. Petitioner was the president, director, and sole shareholder of a Florida “S” corporation called Paragon Homes Corporation. I.R.C. 165(a) allows a deduction for “any loss sustained during the taxable year and not compensated for by insurance or otherwise.” The court concluded that the tax court did not clearly err in determining that Paragon did not abandon the properties at issue in 2008, and that the evidence amply supports this finding, along with the finding that the properties were not worthless to Paragon at the end of 2008. Accordingly, the court concluded that the tax court properly determined that petitioner had not met his burden of demonstrating that the Commissioner’s disallowance of the section 165(a) loss deduction was incorrect. The court affirmed the tax court's decision. View "Tucker v. Commissioner of Internal Revenue" on Justia Law

Plaintiff, formerly a pretrial detainee, filed suit against defendants under 42 U.S.C. 1983, alleging that defendants were deliberately indifferent to his serious medical needs. The district court granted summary judgment for defendants. The court concluded that, viewing the record in the light most favorable to plaintiff, there is evidence that defendant had a serious medical need for treatment after he fell, broke his left humerus, dislocated the hardware in his arm, and began to experience severe pain. The court affirmed the district court's grant of summary judgment for Dr. Fowler and Deputy Booth; reversed the grant of summary judgment for Nurse Ray, Dr. Sullivan, Sheriff Abston, Deputy Abston, Chief Deputy Carr, and Deputy Ellis; and held that Sheriff Abston and the deputy defendants are immune from suit in their official capacities as Alabama state officials. View "Melton v. Abston" on Justia Law

Defendant was found guilty of three counts of attempting to cause a financial institution to not file a required currency transaction report (a CTR), in violation of 31 U.S.C. 5324(a)(1). For the first time on appeal, defendant contends that the government and the district court constructively amended the indictment, allowing her to be tried and convicted of violating section 5324(a)(3), and not section 5324(a)(1). Defendant also argues for the first time that the evidence was insufficient to sustain her convictions. The court concluded that, although the instructions given by the district court were not perfect, they did not, under plain error analysis, amount to a constructive amendment of the indictment. The court also concluded, under a plain error analysis, that the evidence was sufficient to convict defendant. Accordingly, the court affirmed the judgment. View "United States v. Leon" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983, alleging unlawful seizure by Officers Allen and Crews, false imprisonment by Officer Allen, and municipal liability against the City for the officers' actions. The district court granted qualified immunity to Officer Allen with respect to plaintiff's federal and state claims. The district court also granted summary judgment to Officer Crews and the City. The court affirmed in part, reversed in part, and remanded. The court concluded that Officer Allen had arguable probable cause to seize plaintiff and found that the district court’s erroneous conclusion that the standard was not clearly established was harmless error. Accordingly, the court affirmed the district court's ultimate holding as to the propriety of Officer Allen’s initial decision to seize and transport plaintiff to the hospital. The court similarly concluded that Officer Allen is entitled to qualified immunity on plaintiff's 1983 false imprisonment claim. However, the court concluded that the district court erred in granting Officer Allen qualified immunity for his conduct during the seizure. Therefore, the court reversed and remanded on the question of whether Officer Allen’s conduct during the seizure was done in an extraordinary manner unusually harmful to plaintiff's privacy interests. View "May v. City of Nahunta, Georgia" on Justia Law

Plaintiffs filed suit against defendants, alleging that the five letters sent to them between May 16 and December 13, 2013 violated the Fair Debt Collection Practices Act (FDCPA), 15 U.S.C. 1692 et seq., and/or the Florida Consumer Collection Practices Act (FCCPA), Fla. Stat. 559.55 et seq. The district court granted summary judgment to defendants. The court concluded, however, that the district court erred in concluding that the HOA fine at issue is not a debt for FCCPA purposes and granting summary judgment on that basis. The court did not decide whether under Florida law Marbella could be vicariously liable for the FCCPA violations of its agent because the district court failed to apply Florida law in the first instance. Accordingly, the court reversed the district court’s grant of summary judgment to Affinity, vacated the grant of summary judgment to Marbella, and remanded to the district court for further proceedings. View "Agrelo v. The Meloni Law Firm" on Justia Law

Relator filed a qui tam action under the False Claims Act (FCA), 31 U.S.C. 3729-3733, claiming that Fresenius violated the FCA by billing the government for overfill that it received for no cost—allegedly a violation of the statutes governing Centers for Medicare and Medicaid Services (CMS) billing. The district court granted Fresenius's motion for summary judgment. Because the allegations that are the basis of this complaint were publicly disclosed and relator is not an original source, the court lacks jurisdiction to hear this case. The court did not reach the merits of the motion for summary judgment. Accordingly, the court reversed the district court's grant of summary judgment on the merits and remanded for entry of an order dismissing the case for lack of subject matter jurisdiction. View "United States ex. rel. Saldivar v. Fresenius Medical Care Holdings, Inc." on Justia Law

Defendant appealed his 180 month sentence after pleading guilty to three counts of being a felon in possession of a firearm. The district court sentenced defendant under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e), based on his prior convictions. The court concluded that defendant's prior convictions for Florida armed robbery categorically qualifies as a "violent felony" under the ACCA's elements clause. Accordingly, the court affirmed the sentence. View "United States v. Fritts" on Justia Law