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

Plaintiff filed suit against the Casino, alleging unlawful gender discrimination and retaliation in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., and Florida law. The Seminole Tribe of Florida owns and operates the Casino under the name “Seminole Indian Casino-Immokalee.” The district court dismissed the suit because the Tribe is a federally recognized tribe entitled to sovereign immunity. The court affirmed the judgment, holding that the Tribe is indeed a federally recognized Indian tribe entitled to sovereign immunity. View "Longo v. Seminole Indian Casino-Immokalee" on Justia Law

Plaintiff filed suit under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., and 42 U.S.C. 1983, against the School District and the School Board, alleging that they discriminated and retaliated against her by refusing to renew her employment contract and filing an ethics complaint against her. The district court granted summary judgment for defendants. The court concluded that the proper framework for examining mixed-motive claims based on circumstantial evidence is the approach adopted by the Sixth Circuit in White v. Baxter Healthcare Corp., - not the McDonnell Douglas framework. Applying the proper mixed-motive framework to plaintiff's discrimination claims, the court held that the district court erred in granting summary judgment on her claims against the School District and School Board members Scott Morgan and Mark Nesmith. However, the court found that the district court properly dismissed plaintiff's remaining discrimination claims, as well as all of her retaliation claims. Therefore, the court affirmed in part and reversed in part. View "Quigg v. Thomas Cnty. Sch. Dist." on Justia Law

Plaintiff filed suit under the Fair Housing Act, 42 U.S.C. 3604, against Aimco, on behalf of herself and her son Karl, who was born with Down Syndrome, alleging that Aimco threatened her and her son with eviction and non-renewal of their lease purportedly because Karl had harassed and made threats to members of the apartment complex’s staff. The district court granted defendant's motion to dismiss the complaint. As a preliminary matter, the court noted that this case is not moot despite the fact that plaintiff and her son were ultimately allowed to remain in their apartment. The court concluded that plaintiff sufficiently pled a claim alleging that Aimco discriminated against her and her son by making their apartment unavailable because of Karl's disability; plaintiff stated a claim for disparate treatment in the terms, conditions, or privileges of the rental where she alleged that, because of Karl’s disability, Aimco representatives mistreated him by yelling at him, making him do maintenance work around the complex, and barring him from the community rooms and the office; and plaintiff stated a claim for failure to reasonably accommodate where plaintiff requested Aimco staff to let her and her son remain in their apartment while she made arrangements for Karl to be placed in offsite care to avoid future incidents or misunderstandings. Accordingly, the court reversed and remanded. View "Hunt v. Aimco Properties, L.P." on Justia Law

In these consolidated appeals, plaintiff challenged the regulations implementing the contraceptive mandate of the Affordable Care Act, 42 U.S.C. 300gg-13(a), arguing that the regulations’ accommodation for nonprofit organizations with a religious objection to providing contraceptive coverage violates the Religious Freedom Restoration Act (RFRA), 42 U.S.C. 2000bb, et seq. The court concluded that the regulations do not substantially burden plaintiffs' religious exercise and, alternatively, because (1) the government has compelling interests to justify the accommodation, and (2) the accommodation is the least restrictive means of furthering those interests. The court rejected EWTN’s challenges under the Establishment and Free Exercise Clauses because the accommodation is a neutral, generally applicable law that does not discriminate based on religious denomination. The court also rejected EWTN’s challenge under the Free Speech Clause because any speech restrictions that may flow from the accommodation are justified by a compelling governmental interest and are thus constitutional. View "Eternal Word Television Network v. Secretary" on Justia Law

Plaintiff filed a product liability suit against Remington after her husband, Kenneth Seamon, died from a gunshot wound while deer hunting alone. Plaintiff alleged that Mr. Seamon died as a result of a defect in his Remington Model 700 bolt action rifle. On appeal, defendant challenged the district court's exclusion of the causation opinion of plaintiff's liability expert and the district court's grant of defendant's motion for summary judgment. In this case, the expert provided a reasonable explanation for why the defense's proposed alternative cause - trigger pull - was not in fact the cause of Mr. Seamon's death. In holding that the expert's opinion was based on speculation, rather than facts in the record, the court concluded that the district court also mischaracterized the evidentiary support for the expert’s opinion in several ways. Therefore, the court reversed the district court's judgment regarding the motion to exclude, and consequently the motion for summary judgment, remanding for further proceedings. View "Seamon v. Remington Arms Co." on Justia Law

This appeal concerns whether a Georgia statute exempts the assets in a health savings account (HSA) from inclusion in a bankruptcy estate. The court certified the following questions to the Supreme Court of Georgia: (1) Does a debtor’s health savings account constitute a right to receive a “disability, illness, or unemployment benefit” for the purposes of O.C.G.A. 44-13-100(a)(2)(C)? (2) Does a debtor’s health savings account constitute a right to receive a “payment under a pension, annuity, or similar plan or contract” for the purposes of O.C.G.A. 44-13-100(a)(2)(E)? (3) Is a debtor’s right to receive a payment from a health savings account “on account of illness [or] disability” for the purposes of O.C.G.A. 44-13-100(a)(2)(E)? View "Mooney v. Webster" on Justia Law

The County petitioned for review of the Board's ruling reversing the ALJ's findings and conclusions in a proceeding under the Federal Water Pollution Control Act, 33 U.S.C. 1367. The parties agreed that the Board incorrectly applied a de novo rather than substantial-evidence standard to the ALJ's findings. The court denied the petition for review, concluding that reviewing for substantial evidence would not have changed the result because the Board reversed the ALJ on matters of law, not fact. View "DeKalb Cnty. v. U.S. Dept. of Labor" on Justia Law

This case stems from a dispute regarding Palmer Ranch's residential development (B-10). Palmer Ranch argued that B-10’s highest and best use was residential development under a Moderate Density Residential (“MDR”) zoning designation, which would allow between two and five units per acre, or 164 to 410 units total. Based on this highest and best use, Palmer Ranch stuck to its initial $25,200,000 valuation. The IRS countered with a maximum highest and best use of 100 units and a corresponding valuation of $7,750,000. The tax court held in favor of Palmer Ranch. The parties cross-appealed. The court affirmed the tax court's determination of B-10's highest and best use. However, the court reversed the ensuing valuation and directed the tax court on remand to either stick with the comparable-sales analysis or explain its departure. Whatever the tax court chooses to do, the tax court must keep its sights set strictly on the evidentiary record for purposes of selecting an appreciation rate, and ensure that it crunches the numbers correctly. View "Palmer Ranch Holdings v. Commissioner" on Justia Law

Plaintiff, M.N.'s mother, made several threats against M.N.'s father during a contentious custody battle in Venezuela. At issue is whether significant threats and violence directed against a parent can constitute a grave risk of harm to a child under the Hague Convention on the Civil Aspects of International Child Abduction through the International Child Abduction Remedies Act of 1988 (ICARA), 22 U.S.C. 9001–9011. The district court ruled that, although plaintiff had made a prima facie case for return by showing that M.N. had been wrongfully removed from Venezuela, return would be inappropriate because an exception to the Convention applied where the district court found by clear and convincing evidence that there is a grave risk that M.N.’s return to Venezuela would expose her to physical or psychological harm. The court held that the district court correctly found that the grave risk of harm exception to the Convention applied in this case. Here, although a pattern of threats and violence was not directed specifically at M.N., serious threats and violence directed against a child’s parent can, and in this case did, nevertheless pose a grave risk of harm to the child. Accordingly, the court affirmed the judgment. View "Gomez v. Fuenmayor" on Justia Law

A jury concluded that defendant violated the Store Communications Act (SCA), 18 U.S.C. 2701-2712, when, in accordance with her lawyer’s advice, she viewed her ex-husband's (plaintiff) emails in an effort to prove to the divorce court that plaintiff was lying about and hiding assets. The jury did not award damages to plaintiff. Plaintiff appealed to the district court and the district court awarded a more modest amount than the requested $450,000 and refused to award attorney's fees. Plaintiff appealed. The court concluded that it has no authority to award actual or punitive damages when the jury has rejected the entry of such an award. Further, under the SCA, the court does not have the authority to award statutory damages in the absence of actual damages. Accordingly, the court affirmed the district court's determination not to award punitive damages; vacated the award of statutory damages in the absence of actual damages; and affirmed the denial of attorney's fees. View "Vista Marketing, LLC v. Burkett" on Justia Law