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

A deputy sheriff of Arabic descent, employed by the Richmond County Sheriff’s Office, was assigned to an off-duty security position at a local business. During his assignment, he alleged that his supervisor subjected him to repeated racial harassment, including derogatory remarks about his ethnicity. Witnesses at the business supported these allegations, noting that the supervisor frequently made such comments. The deputy was also interested in joining the SWAT team, which the supervisor led, but after failing the SWAT entrance exam, the deputy filed a formal internal complaint about the harassment.Shortly thereafter, the deputy was investigated and ultimately terminated for allegedly violating departmental policy by making personal use of his patrol vehicle, specifically for visiting another county’s sheriff’s office to inquire about job opportunities. The deputy provided evidence that other officers regularly made similar personal use of patrol vehicles without being disciplined, and argued that his termination was in retaliation for his internal complaint. He filed suit under 42 U.S.C. § 1981, claiming retaliatory discharge.The United States District Court for the Southern District of Georgia granted summary judgment for the defendants, finding that the deputy had not shown that the employer’s stated reason for termination was a pretext for retaliation.On appeal, the United States Court of Appeals for the Eleventh Circuit concluded that the District Court erred by conflating the McDonnell Douglas pretext analysis with the “convincing mosaic” standard. The Eleventh Circuit held that a plaintiff may survive summary judgment by presenting circumstantial evidence that creates a triable issue regarding retaliatory intent, even if pretext is not conclusively shown. The court reversed and remanded for the District Court to apply the correct summary judgment standard. View "Ismael v. Roundtree" on Justia Law

A city in Florida established a "vehicular safety zone" outside a medical clinic that performs abortions, which prohibited most pedestrians, including sidewalk counselors, from entering a 38-foot section of public sidewalk that included the clinic's driveway during business hours. The city justified this restriction by citing repeated incidents involving protestors allegedly impeding vehicles and intimidating occupants, and asserted that existing measures like targeted trespass warnings or arrests were insufficient due to the location being public property and violations being misdemeanors not committed in officers’ presence. Four individuals who regularly engaged in sidewalk counseling—offering literature and conversation to those entering the clinic—along with a nonprofit organization, challenged the ordinance, arguing it violated their First Amendment rights by significantly restricting their ability to communicate with clinic patients, particularly by preventing them from handing leaflets to occupants of vehicles entering or exiting the clinic.The United States District Court for the Middle District of Florida denied the plaintiffs’ motion for a preliminary injunction, finding that they were unlikely to succeed on the merits of their First Amendment claim. The court concluded that the ordinance was narrowly tailored to serve the city's significant interest in vehicular safety and that it left open alternative channels for communication.Upon review, the United States Court of Appeals for the Eleventh Circuit held that the plaintiffs were likely to succeed on the merits of their facial First Amendment challenge. Applying the standard from McCullen v. Coakley, the appellate court found that the ordinance was not narrowly tailored because the city had not seriously considered less restrictive alternatives that would further vehicular safety without burdening substantially more speech than necessary. The Eleventh Circuit vacated the district court’s judgment and remanded with instructions to grant the preliminary injunction, finding also that the remaining factors for injunctive relief favored the plaintiffs. View "Florida Preborn Rescue, Inc. v. City of Clearwater" on Justia Law

The case concerns a federal prisoner who was convicted of Hobbs Act robbery, conspiracy to commit Hobbs Act robbery, and brandishing a firearm during a crime of violence. He pleaded guilty to all counts. In preparing for sentencing, the presentence investigation report classified him as a career offender, which increased his guideline sentencing range. At sentencing, the district court imposed a sentence below the career-offender guideline range—414 months in total, including a mandatory minimum of 384 months for the firearm offenses.After his conviction, the defendant sought to vacate his sentence in the United States District Court for the Middle District of Florida, arguing that his trial counsel was ineffective for failing to object to the career-offender classification. The district court found that the presentence report had mistakenly listed his robbery offenses as controlled substance offenses, but determined that, at the time, binding precedent permitted Hobbs Act robbery to be used as a predicate for the career-offender enhancement. The court concluded that counsel was not ineffective for failing to anticipate later precedent, and also found that the defendant had not suffered prejudice because an objection would have been overruled. The district court denied the motion and a certificate of appealability.The United States Court of Appeals for the Eleventh Circuit granted a certificate of appealability limited to the ineffective assistance issue. Reviewing the case, the Eleventh Circuit held that, even if counsel’s performance was deficient, the defendant could not show prejudice. The court found that the sentencing judge had imposed a sentence based on factors independent of the erroneous guideline calculation, and explained his reasoning in detail. Because there was no reasonable probability that the sentence would have been different absent the alleged error, the Eleventh Circuit affirmed the denial of the motion to vacate. View "Buckner v. USA" on Justia Law

Karen Perez and Jovan Rivera Rodriguez were indicted and convicted for their involvement in a conspiracy to distribute large quantities of fentanyl in the Orlando area. Both played minor roles but were responsible for distributing several kilograms of fentanyl, which subjected them to a mandatory minimum sentence of ten years in prison under federal law. After pleading guilty, both defendants sought sentences below the statutory minimum, citing general sentencing factors and their cooperation with authorities.The United States District Court for the Middle District of Florida received government motions under 18 U.S.C. § 3553(e) and Sentencing Guidelines § 5K1.1 to reduce the sentences based on substantial assistance provided by Perez and Rivera Rodriguez. The government requested modest reductions limited to the assistance factors, but the district court granted further reductions based on the general sentencing factors in 18 U.S.C. § 3553(a), ultimately sentencing Perez to 66 months and Rivera Rodriguez to 60 months in prison. The government appealed, arguing the reductions should have been based solely on assistance-related considerations.The United States Court of Appeals for the Eleventh Circuit reviewed the legality of the sentences de novo. The court held that departures from statutory minimum sentences under 18 U.S.C. § 3553(e) must be based exclusively on substantial-assistance factors, not on the general sentencing factors in § 3553(a). The court found that the district court exceeded its authority by considering non-assistance factors in its downward departures. Accordingly, the Eleventh Circuit vacated both sentences and remanded the cases with instructions to resentence the defendants in accordance with its opinion, limiting any downward departure to substantial assistance only. View "USA v. Perez" on Justia Law

A pharmacist in Florida, serving as the pharmacist-in-charge at a pharmacy called NH Pharma, was indicted for conspiracy to commit health-care fraud and several counts of health-care fraud. The indictment alleged that he defrauded Medicare by billing for drugs different than those he dispensed and for prescriptions never filled. The pharmacy’s owner cooperated with the government after pleading guilty to conspiracy. At trial, the prosecution presented evidence that the pharmacist and the owner prepared compounded medications using unreimbursable ingredients while billing Medicare for more expensive, reimbursable ones, and attempted to cover up the discrepancies during audits. There was also evidence, including video and witness testimony, that the pharmacist had stolen about $200,000 in cash from the pharmacy. Three Medicare beneficiaries testified that they never received or believed they were prescribed the medications billed in their names.The United States District Court for the Middle District of Florida admitted evidence of the uncharged cash theft, ruling it was intrinsic to the case. The court also excused a potential defense witness, a part-owner and pharmacy technician, from testifying after she invoked her Fifth Amendment right against self-incrimination, and declined to recommend immunity for her. After a jury found the pharmacist guilty on all counts, he moved for a new trial based on statements made by the pharmacy owner in her own sentencing memorandum, arguing they constituted newly discovered evidence. The district court denied this motion.The United States Court of Appeals for the Eleventh Circuit affirmed the convictions. It held that the district court did not abuse its discretion by denying a new trial because the statements were not new evidence, nor material, nor likely to produce a different result. The appellate court also found no abuse of discretion in admitting the theft evidence, declining to compel witness immunity, and not conducting an in-camera hearing, and rejected constitutional claims raised by the defendant. View "USA v. Beasley" on Justia Law

The dispute centers on a real estate transaction in which a buyer agreed to purchase a property in Miami for $5,450,000 from two sellers, with a closing set for October 2021. The sellers subsequently discovered a mortgage restriction preventing them from closing until January 2022, which resulted in their failure to close on time. They acknowledged the breach, but subsequent negotiations to revive the deal fell through because the buyer wanted a discounted price to account for damages incurred from the delay, which the sellers refused.The matter proceeded to litigation. The buyer sued for specific performance and damages in state court; the sellers removed the action to federal court and also brought their own federal suit seeking a declaratory judgment that the buyer, not they, had breached. The United States District Court for the Southern District of Florida dismissed the sellers’ declaratory action and granted summary judgment to the buyer on breach of contract, reserving the amount of damages for trial. After a bench trial, the district court awarded the buyer specific performance and damages, ordering the sale to proceed. The parties closed the transaction as ordered.On appeal, the United States Court of Appeals for the Eleventh Circuit held that the issue of specific performance was moot because the sale had already occurred and the property was now owned by third parties not before the court, making further relief impossible. However, the court found the damages issue remained live. It affirmed the district court’s damages award in all respects except for damages for lost tax savings, which it reversed due to insufficient evidence that the buyer itself suffered those losses. The case was remanded for recalculation of damages consistent with the appellate decision. View "Marmol v. Kalonymus Development Partners, LLC" on Justia Law

A police officer responded to a complaint of littering at a McDonald’s parking lot in DeFuniak Springs, Florida, where he encountered John Thomas in a gray Acura matching the reported description. Thomas admitted to littering, exited his vehicle to pick up the trash, and then returned to the driver’s seat. When asked for identification, Thomas produced a Louisiana driver’s license that appeared false, given the age discrepancy. After confirming with the dispatcher that the license information did not match, the officer attempted to arrest Thomas, who resisted, pepper-sprayed the officer, and fled. Thomas abandoned his car nearby and was later apprehended. Police obtained a search warrant for the car, discovering methamphetamine, counterfeit bills, and numerous fraudulent identification documents.The United States District Court for the Northern District of Florida denied Thomas’s motion to suppress the evidence recovered from his car. Thomas argued the warrant was based on information obtained during an illegal stop, asserting that Florida law does not permit officers to detain someone for a noncriminal violation such as littering. The district court found the initial stop lawful, reasoning that the officer had authority to detain Thomas based on the littering complaint and to request identification. It further held that the subsequent arrest for providing false identification was supported by probable cause, validating the search warrant and denying suppression.Upon appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The appellate court held that the initial encounter was consensual and did not implicate the Fourth Amendment, and that the officer had probable cause to arrest Thomas for possession of a fraudulent driver’s license under Florida law. Therefore, the evidence obtained from the car search was admissible, and Thomas’s conviction was affirmed. View "United States v. Thomas" on Justia Law

Kevil Wingo, a pretrial detainee at the Cobb County Adult Detention Center, died from a perforated gastric ulcer after repeatedly complaining of severe abdominal pain, nausea, and vomiting. Jail nurses employed by WellStar Health Systems misdiagnosed his symptoms as drug withdrawal ("detox") and assured the sheriff’s deputies overseeing security that Wingo was medically stable. Despite Wingo’s persistent requests to be sent to a hospital and his deteriorating condition, the deputies deferred to the medical staff’s judgment, consistent with their training not to make independent medical decisions. Wingo was eventually moved to a padded cell for observation, where he died within hours.The United States District Court for the Northern District of Georgia granted summary judgment in favor of the sheriff’s deputies on the plaintiffs' 42 U.S.C. § 1983 claims, finding that they were protected by qualified immunity because they reasonably relied on medical professionals’ assessments. The district court also granted summary judgment to Deputy Wilkerson on a state law negligence claim, concluding that the plaintiffs’ expert could not establish causation with medical certainty regarding whether Wilkerson’s actions affected Wingo’s chance of survival.The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo and affirmed the district court’s judgment. The Eleventh Circuit held that nonmedical jail officers cannot be found liable for deliberate indifference to a detainee’s serious medical needs when they reasonably rely on the advice of medical professionals. The court further found that the absence of expert testimony establishing causation prevented the state law negligence claim against Deputy Wilkerson from surviving summary judgment. Thus, all claims against the defendant deputies were disposed of in their favor, and the district court’s rulings were affirmed. View "Wingo v. Harris" on Justia Law

Investors in a major energy company alleged that the company and several executives misled them about involvement in a Florida election-interference scheme. The alleged scheme included tactics such as supporting “ghost” candidates in state and local elections, bribery, covert payments, and manipulating media outlets. These actions were reportedly orchestrated by the company’s main subsidiary and its CEO, with assistance from a political consulting firm. When reports of the scheme began to surface, the company and its executives publicly denied any involvement or wrongdoing, including direct statements to the press and investors. However, after further scrutiny and media coverage, the company’s leadership changed course, abruptly terminating the subsidiary’s CEO and filing updated risk disclosures with the Securities and Exchange Commission (SEC) that acknowledged potential legal and reputational risks associated with the allegations. On the same day as these disclosures, the company’s stock price fell sharply, resulting in significant losses for investors.Previously, the United States District Court for the Southern District of Florida dismissed the investors’ complaint, concluding that the plaintiffs failed to adequately plead loss causation—a necessary element of securities fraud. The District Court found that the investors did not identify a sufficient corrective disclosure linking the alleged fraud to the stock price decline.The United States Court of Appeals for the Eleventh Circuit reviewed the case and disagreed with the District Court. The Eleventh Circuit held that the plaintiffs plausibly alleged loss causation by identifying corrective disclosures—namely, the company’s risk disclosures, the CEO’s abrupt departure, and a unique compensation claw-back provision—that collectively revealed enough truth to the market to undermine prior denials. The court found the alleged sequence of disclosures, price drop, and market analyst reactions sufficient at the pleading stage. The Eleventh Circuit reversed the District Court’s dismissal and remanded for further proceedings. View "City of Hollywood Police Officers Retirement Syst v. NextEra Energy, Inc." on Justia Law

Donald J. Trump filed a lawsuit in the United States District Court for the Southern District of Florida against dozens of defendants, including Hillary Clinton, the Democratic National Committee, several law firms, and individuals, alleging that they conspired to spread false claims of his collusion with Russia during the 2016 presidential campaign. Trump asserted multiple claims, including two under the Racketeer Influenced and Corrupt Organizations Act (RICO) and three under Florida law, such as injurious falsehood and conspiracy to commit malicious prosecution. He alleged that these actions caused him substantial financial harm and loss of business opportunities.After extensive pleadings, the district court dismissed Trump’s amended complaint with prejudice, holding that his federal racketeering claims were untimely and legally insufficient, and that his state law claims either failed to state a claim or were also untimely. The court found the complaint to be a “shotgun pleading” and cited numerous factual inaccuracies and implausible legal theories. The court also dismissed claims against certain defendants for lack of personal jurisdiction, but did so with prejudice. Subsequently, the district court imposed sanctions on Trump and his attorneys for filing frivolous claims and pleadings, based both on its inherent authority and Rule 11, and denied Trump’s motions for reconsideration and to disqualify the judge.Upon appeal, the United States Court of Appeals for the Eleventh Circuit affirmed most of the district court’s orders. The appellate court held that Trump’s racketeering claims were untimely and meritless, and that his state law claims failed for both procedural and substantive reasons. However, the Eleventh Circuit found that the district court lacked personal jurisdiction over one defendant, Orbis, and therefore vacated the dismissal with prejudice as to Orbis, remanding with instructions to dismiss those claims without prejudice. The sanctions orders and other rulings were affirmed, and requests for appellate sanctions were denied. View "Trump v. Clinton" on Justia Law