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

Defendant appealed his sentence after pleading guilty to one count of bank robbery. Defendant argued that the district court violated his Sixth Amendment rights, as interpreted by Alleyne v. United States, when it sentenced him to the mandatory minimum sentence on the firearm charge. The court concluded that the district court erred under Alleyne because it sentenced defendant to a mandatory minimum sentence based on its own conclusion about brandishing, instead of defendant's admission or a jury's finding concerning that fact. Nevertheless, the error was harmless beyond a reasonable doubt. Accordingly, the court affirmed the judgment of the district court.View "United States v. Payne" on Justia Law

This dispute arose from violations issued by the Department of Labor's Mine Safety and Health Administration. At issue was whether the word "corporation" includes limited liability companies (LLCs) for purposes of the Federal Mine Safety and Health Act of 1977 (the Mine Act), 30 U.S.C. 801 et seq. The court concluded that the terms "corporation" and "corporate operator" in the Mine Act are ambiguous. Applying Chevron deference, the court concluded that the Secretary's interpretation is reasonable where, most importantly, construing section 110(c) to include agents of LLCs is consistent with the legislative history. Therefore, the court held that an LLC is a corporation for purposes of the Mine Act and that section 110(c) can be used to assess civil penalties against agents of an LLC. Because substantial evidence supported the ALJ's decision to hold petitioners personally liable for the order at issue, the court affirmed on this issue. Finally, the order underlying their civil penalties was not duplicative. Accordingly, the court affirmed the ALJ's decision.View "Sumpter, et al. v. Secretary of Labor, et al." on Justia Law

Travelers filed suit seeking a declaratory judgment that there is no coverage for and thus no duty to indemnify defendant under his employer's commercial automobile insurance policy for an incident which is the subject of underlying tort actions pending in state court. In the underlying actions, plaintiff is being sued for killing one individual and wounding another individual with a shotgun while defendant was chasing them in his employer's van as they were in the process of repossessing defendant's car. The court reversed the district court's grant of summary judgment in favor of defendants where there was no evidence from which a reasonable jury could find that defendant had his employer's permission to use its van as he did. Consequently, he was not insured under the Travelers insurance policy at issue and there can be no indemnity for him under the policy for the claims presented in the underlying state court actions. The court remanded for the district court to grant summary judgment in favor of Travelers and against defendants.View "Travelers Property Casualty Co. v. Moore, et al." on Justia Law

The Hospital filed suit against various federal agencies and officials, seeking a declaratory judgment that 18 U.S.C. 4006(b)(1), where Congress has elected to impose the Medicare rate as full compensation for medical services rendered to federal detainees, is unconstitutional as applied. The court concluded that the Hospital voluntarily opted into the Medicare program and is, as a result, required to provide emergency services to federal detainees. Consequently, the Hospital was foreclosed from challenging this compensation scheme as an unconstitutional taking under the Fifth Amendment. The court noted that the Hospital's most effective remedy may lie with Congress rather than the courts. Accordingly, the court affirmed the district court's dismissal of the action.View "Baker County Medical Services v. U.S. Attorney General, et al." on Justia Law

Plaintiffs, seafarers employed with Cunard Line cruise ships, filed a class action complaint against Carnival Corp. and Carnival PLC, a dual-listed company, alleging failure to provide maintenance and cure in accordance with general United States maritime law and the Jones Act, 46 U.S.C. 50101. The court held that Carnival Corp. & PLC was not properly suable in this action. Plaintiffs could have brought an action against Carnival PLC (the Cunard Line's parent company), but chose not to, instead making a tactical decision to pursue potentially broader claims against Carnival Corp. & PLC. Accordingly, the court affirmed the district court's dismissal of the complaint.View "Sabo, et al. v. Carnival Corp., et al." on Justia Law

Defendant, a business owner, appealed his sentence after being convicted of bribing a state official in order to ensure that his company would continue to receive government contracts. Over a period of four years, defendant doled out over $600,000 in bribes and his company reaped over $5 million in profits as a result of the corrupt payments. The court concluded that the concurrent three-year probationary sentences were substantively unreasonable given the factors set forth in 18 U.S.C. 3553(a): (1) the sentences convey the message "that would-be white-collar criminals stand to lose little more than a portion of their ill-gotten gains and practically none of their liberty," and accordingly do not constitute just punishment for defendant's offenses or promote respect for the law; (2) the sentences do not provide general deterrence; and (3) the sentences were not required to eliminate any sentencing disparity among similarly situated offenders because no such disparity existed. Accordingly, the court vacated and remanded.View "United States v. Hayes" on Justia Law

Plaintiff filed suit against her employer, alleging violations of the Family Medical Leave Act (FMLA), 29 U.S.C. 2601; the Equal Pay Act, 29 U.S.C. 206; Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq.; and the Consolidated Omnibus Budget Reconciliation Act (COBRA), 29 U.S.C. 1161 et seq. Plaintiff's claims stemmed from her employer's denial of her request to take FMLA leave after the birth of her child. The court held that the district court correctly awarded summary judgment to the employer with respect to plaintiffs' claims under Title VII and the Equal Pay Act, and did not abuse its discretion by assessing a statutory COBRA penalty against the employer; the district court erred by dismissing plaintiff's FMLA claim and by refusing to consider her additional litigation-related expenses as part of an attorney's fee award; and, therefore, the court affirmed in part, vacated in part, and remanded in part.View "Evans v. Books-A-Million" on Justia Law

Plaintiff filed suit challenging the decision of an arbitrator that had denied his claim under a crop insurance policy obtained from ProAg. On appeal, ProAg challenged the district court's grant of plaintiff's motion to vacate the award and motion for summary judgment, vacating the arbitrator's decision. The court concluded that the district court erred in vacating the arbitrator's decision because the arbitrator was entitled to conclude that ProAg had the authority under the policy to set a reasonable deadline for the receipt of necessary documentation in support of the claim; plaintiff's failure to comply with the deadline was an adequate basis for ProAg's denial of his claim; the arbitrator was entitled to make his findings without first seeking a formal opinion of the FCIC; and plaintiff waived any argument based upon the arbitrator's failure to deliver his decision and award within the time limitations provided by the policy. Accordingly, the court reversed and remanded.View "Davis v. Producers Agricultural Ins." on Justia Law

Regions appealed the district court's decision to certify a class action based on alleged misrepresentations about Regions' financial health before and during the recent economic recession. The court vacated and remanded for further proceedings in light of Halliburton Co. v. Erica P. John Fund, Inc. to allow consideration of Region's evidence of price impact and for the district court to review the duration of the class period. The court affirmed in all other respects.View "Local 703, et al. v. Regions Financial Corp., et al." on Justia Law

Plaintiffs, anti-abortion advocates, challenged Sections 34-38 of the Code of the City of West Palm Beach, which bans amplified sound within 100 feet of the property line of any health care facility. The court concluded that the district court did not abuse its discretion in denying a preliminary injunction when it found that the Ordinance is a valid time, place, or manner restriction on speech that is content-neutral, is narrowly tailored to advance the City's substantial interest in protecting patients, and leaves open ample alternative avenues of communication. The district court did not abuse its discretion in determining that plaintiffs failed to establish a substantial likelihood of success on their claims that the Ordinance is void for vagueness and is being applied discriminatorily against them. Accordingly, the court affirmed the judgment.View "Pine, et al. v. City of West Palm Beach, FL" on Justia Law