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

Ameritox and Millennium are competitors in the drug-testing industry. Ameritox filed suit against Millennium, alleging in its original complaint that Millennium had “formed a business plan to increase its market share, revenue, and profits” by providing financial inducements and other kickbacks, in violation of both federal and state law. The jury subsequently awarded judgment in favor of Ameritox and the district court denied Millennium’s renewed motion for judgment as a matter of law and granted in part and denied in part its motion for a new trial or reduction in the award of punitive damages; upon reconsideration, the district court reduced the award of punitive damages. In this appeal, the court concluded that the district court's decision to retain supplemental jurisdiction over novel and complex state-law claims hailing from nine different states - claims that the parties either did know or should have known were novel and complex - constituted an abuse of discretion.. Accordingly, the court vacated and remanded with instructions to dismiss the state law claims without prejudice so the parties can litigate their claims in a proper forum. View "Ameritox, Ltd. v. Millennium Labs." on Justia Law

Defendant, originally sentenced to 30 months' imprisonment for failure to register as a sex offender, was sentenced to 24 months' imprisonment after the third revocation of his supervised release. On appeal, defendant contends that his revocation sentence was illegal because it exceeded the 14 months remaining on his then existing term of supervised release. The court followed its sister circuits and held that upon each revocation of supervised release a defendant may be sentenced to the felony class limits contained within 18 U.S.C. 3583(e)(3) without regard to imprisonment previously served for revocation of supervised release. Accordingly, the court affirmed the judgment. View "United States v. Cunningham" on Justia Law

The City filed three separate fair housing lawsuits against Wells Fargo, Bank of America, and Citigroup, alleging that each bank had engaged in a decade-long pattern of discriminatory lending by targeting minorities for predatory loans. Each complaint contained the same two causes of action: one claim arising under the Fair Housing Act (FHA), 42 U.S.C. 3601 et seq., as well as an unjust enrichment claim under Florida law. The district court dismissed the City's FHA claim. The court found that the City has constitutional standing to pursue its FHA claims; under controlling Supreme Court precedent, the “zone of interests” for the FHA extends as broadly as permitted under Article III of the Constitution, and therefore encompasses the City’s claim; while the court agreed with the district court that the FHA contains a proximate cause requirement, the court found that this analysis is based on principles drawn from the law of tort, and that the City has adequately alleged proximate cause; and the court concluded that the “continuing violation doctrine” can apply to the City’s claims, if they are adequately pled. The court concluded that the district court erred in dismissing the City’s federal claims with prejudice and in denying the City’s motion for leave to amend on the grounds of futility because the district court imposed too stringent a zone of interests test and wrongly applied the proximate cause analysis. The court affirmed the dismissal of the state law claim because the benefits the City allegedly conferred on the defendants were not sufficiently direct to plead an unjust enrichment claim under Florida law. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "City of Miami v. CitiGroup Inc." on Justia Law

The City filed three separate fair housing lawsuits against Wells Fargo, Bank of America, and Citigroup, alleging that each bank had engaged in a decade-long pattern of discriminatory lending by targeting minorities for predatory loans. Each complaint contained the same two causes of action: one claim arising under the Fair Housing Act (FHA), 42 U.S.C. 3601 et seq., as well as an unjust enrichment claim under Florida law. The district court dismissed the City's FHA claim. The court found that the City has constitutional standing to pursue its FHA claims; under controlling Supreme Court precedent, the “zone of interests” for the FHA extends as broadly as permitted under Article III of the Constitution, and therefore encompasses the City’s claim; while the court agreed with the district court that the FHA contains a proximate cause requirement, the court found that this analysis is based on principles drawn from the law of tort, and that the City has adequately alleged proximate cause; and the court concluded that the “continuing violation doctrine” can apply to the City’s claims, if they are adequately pled. The court concluded that the district court erred in dismissing the City’s federal claims with prejudice and in denying the City’s motion for leave to amend on the grounds of futility because the district court imposed too stringent a zone of interests test and wrongly applied the proximate cause analysis. The court affirmed the dismissal of the state law claim because the benefits the City allegedly conferred on the defendants were not sufficiently direct to plead an unjust enrichment claim under Florida law. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "City of Miami v. Wells Fargo & Co." on Justia Law

The City filed suit against the Bank, alleging that the Bank engaged in a decade-long pattern of discriminatory lending in the residential housing market that caused the City economic harm. The City asserts a claim arising under the Fair Housing Act (FHA), 42 U.S.C. 3601 et seq., as well as an unjust enrichment claim under Florida law. The district court dismissed the City's FHA claim with prejudice. The court found that the City has constitutional standing to pursue its FHA claims; under controlling Supreme Court precedent, the “zone of interests” for the FHA extends as broadly as permitted under Article III of the Constitution, and therefore encompasses the City’s claim; while the court agreed with the district court that the FHA contains a proximate cause requirement, the court found that this analysis is based on principles drawn from the law of tort, and that the City has adequately alleged proximate cause; and the court concluded that the “continuing violation doctrine” can apply to the City’s claims, if they are adequately pled. The court concluded that the district court erred in dismissing the City’s federal claims with prejudice and in denying the City’s motion for leave to amend on the grounds of futility because the district court imposed too stringent a zone of interests test and wrongly applied the proximate cause analysis. The court affirmed the dismissal of the state law claim because the benefits the City allegedly conferred on the defendants were not sufficiently direct to plead an unjust enrichment claim under Florida law. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "City of Miami v. Bank of America Corp." on Justia Law

Plaintiff filed suit against Clarendon, alleging that Clarendon acted in bad faith in handling the claims against its insured. The district court granted Clarendon’s motion for summary judgment and subsequently entered judgment in favor of Clarendon. The court concluded that no reasonable juror could conclude that Clarendon acted in bad faith because Clarendon was diligent in its efforts to settle the claims against its insured and there exists no causal connection between the actions of Clarendon and the entry of the excess judgment against its insured. Accordingly, the court affirmed the judgment. View "Mesa v. Clarendon Nat'l Ins. Co." on Justia Law

In this appeal, the court considered whether Florida’s Rental Tax and Florida’s Utility Tax, as applied to matters occurring on Seminole Tribe lands, violate the tenets of federal Indian law. The court held that Florida’s Rental Tax is expressly precluded by 25 U.S.C. 465, and, in the alternative, is preempted by the comprehensive federal regulation of Indian land leasing. Therefore, the court affirmed the district court's order as to this issue. The court concluded, however, that the district court erred in placing the legal incidence of the Utility Tax on the Tribe and find that, on this record, the Tribe has not demonstrated that the Utility Tax is generally preempted by federal law. Therefore, the court reversed as to this issue and remanded for further proceedings. View "Seminole Tribe v. Stranburg" on Justia Law

Defendant appealed his conviction for being a convicted felon in possession of a firearm and the Government cross-appealed. The court affirmed the conviction, concluding that the district court did not abuse its discretion in denying defendant’s request to modify the jury instruction for constructive possession. However, the court vacated defendant's sentence, concluding that defendant's prior Florida conviction for resisting an officer with violence constitutes a violent felony under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e)(1). The court remanded for further proceedings. View "United States v. Hill" on Justia Law

Defendant, convicted of seven felony counts of theft of public money, in violation of 18 U.S.C. 641, asks the court to hold that her seven felony convictions are actually misdemeanor convictions because each separate conviction involves a sum that does not exceed $1,000. Defendant also argued that the district court committed legal error and that it clearly erred when it imposed the sophisticated means enhancement in determining her guidelines level. The court concluded that the unambiguous language of the statute designates all section 641 convictions felonies first and reduces them to misdemeanors second only if the sum of the amounts charged in all of the section 641 convictions in the defendant’s case equals $1,000 or less. The court also concluded that the district court correctly determined defendant's section 641 convictions to be felonies and it did not err or clearly err in applying the sophisticated-means enhancement. Accordingly, the court affirmed the judgment. View "United States v. Feaster" on Justia Law

Petitioner, a citizen of Honduras, appealed the district court's dismissal of his pro se federal habeas petition challenging his conviction for illegal reentry after deportation. The court concluded that the district court’s judgment must be affirmed, because petitioner raised his claim in an improper procedural vehicle. Rather than filing a motion to vacate his sentence under 28 U.S.C. 2255, the usual way for a federal prisoner to challenge a federal conviction, petitioner chose to file a habeas petition under 28 U.S.C. 2241. In the court's view, the district court wisely declined to recharacterize his section 2241 petition as a section 2255 motion. The district court was not obliged to recast petitioner’s section 2241 petition over his express wishes, especially in light of the adverse consequences that can stem from filing a section 2255 motion. Nor did the district court err in dismissing petitioner's section 2241 petition. View "Zalaya v. Secretary, FL Dep't of Corrections" on Justia Law