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

Christin Bilotti was convicted of second-degree murder in Florida state court. After exhausting her appeals, she sought postconviction relief in Florida, which was denied. Bilotti then filed a federal habeas petition, which the district court also rejected. The Eleventh Circuit granted a certificate of appealability on two claims from Bilotti’s federal habeas petition: ineffective assistance of counsel for failing to preserve a religion-based challenge to a juror strike and for failing to object to jury instructions.The Florida intermediate appellate court initially reversed Bilotti’s conviction, citing a similar case involving her co-defendant, John Pacchiana, where the court found the state’s peremptory strike of a juror pretextual and improper. However, the Florida Supreme Court quashed this decision, ruling that the religion-based objection was not properly preserved at trial. On remand, the intermediate appellate court affirmed Bilotti’s conviction.In state postconviction proceedings, Bilotti argued that her trial counsel was ineffective for not preserving the religion-based Batson challenge and for not objecting to the jury instructions. The state postconviction court denied her claims, adopting the state’s arguments, and the appellate court affirmed without explanation.The Eleventh Circuit reviewed the case and found that even if Bilotti could show prejudice from her counsel’s failure to preserve the religion-based objection, she could not establish deficient performance. At the time of her trial, the law was unsettled on whether Batson extended to religion-based exclusions. The court also found that the jury instructions were substantively identical to Florida’s standard instructions, which had not been invalidated by the Florida Supreme Court. Therefore, counsel’s failure to object to these instructions was not deficient performance, nor was it prejudicial.The Eleventh Circuit affirmed the district court’s judgment, denying Bilotti’s habeas petition. View "Bilotti v. Florida Department of Corrections" on Justia Law

Several college volleyball players accused their coach of physical, verbal, psychological, and sexual abuse. The players alleged that the coach engaged in a pattern of sexual harassment and abuse, including inappropriate touching and forcing players to engage in uncomfortable physical interactions. They also claimed that the coach's misconduct was reported to various university administrators and assistant coaches, who either witnessed or were informed of the abuse.The United States District Court for the Southern District of Alabama dismissed the players' Title IX and § 1983 claims with prejudice for failure to state a claim. The court found that the players had abandoned their breach-of-contract claims and dismissed those with prejudice. The court also declined to exercise supplemental jurisdiction over the remaining state-law claims, dismissing them without prejudice.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's dismissal. The court held that the players failed to state a Title IX claim because only certain university administrators were "appropriate persons" to receive notice of the misconduct, and the players did not provide sufficient actual notice of sexual harassment to those individuals. The court also found that the university did not act with deliberate indifference upon receiving the notice.Regarding the § 1983 claims, the court held that the players did not show that the university employees' conduct violated clearly established substantive-due-process principles. The court concluded that the employees were entitled to qualified immunity because the players did not provide case law with indistinguishable facts, a broad statement of principle, or conduct so egregious that it clearly violated constitutional rights.The Eleventh Circuit affirmed the district court's order dismissing the players' Title IX and § 1983 claims. View "DeMarcus v. University of South Alabama" on Justia Law

Jordan Pulido developed an online relationship with a 14-year-old Croatian girl, I.G., and, with the help of his father, Roberto Jimenez, traveled to Croatia to have sex with her. They later brought her to the United States, where Pulido continued to have sex with her. Pulido was indicted on multiple counts, including using the internet to entice a minor, traveling with intent to engage in illicit sexual conduct, and transporting a minor for sexual activity. Jimenez was indicted for conspiring to transport a minor for sexual activity.The United States District Court for the Middle District of Florida denied Pulido's pre-trial motions to dismiss the indictment, suppress evidence, and exclude testimony. Both defendants were convicted on all counts after a nine-day trial. Post-trial motions for acquittal, a new trial, and a mistrial were also denied. Jimenez received sentence enhancements for exercising undue influence and having custody or supervisory control over I.G.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the case. The court affirmed the district court's decisions on most counts but vacated Pulido's conviction on the enticement count, finding the indictment duplicitous. The court held that the enticement count was not harmless and remanded for resentencing. The court also affirmed the district court's denial of Pulido's motion to suppress evidence from his electronic devices, holding that the border search exception applied. Additionally, the court found no fundamental unfairness in the translation irregularities during I.G.'s mother's testimony.For Jimenez, the court affirmed the denial of his motion for judgment of acquittal, finding sufficient evidence of his intent to transport I.G. for sexual activity. The court also upheld the denial of his motion for a mistrial based on Agent Garcia's testimony about his immigration status, concluding that the curative instruction mitigated any potential prejudice. Finally, the court affirmed the application of the sentencing enhancements for undue influence and custody or supervisory control. View "U.S. v. Pulido" on Justia Law

Sara Watts, an African American woman, sued her former homeowners’ association, Joggers Run Property Owners Association (HOA), alleging racial discrimination under the Fair Housing Act (FHA) and the Civil Rights Act. Watts claimed the HOA interfered with her property enjoyment through unwarranted citations, restricted access to amenities, and discriminatory treatment as a former HOA board member. She cited provisions from the FHA (42 U.S.C. §§ 3604(b), 3617) and the Civil Rights Act (42 U.S.C. §§ 1981, 1982).The United States District Court for the Southern District of Florida dismissed Watts' claims, ruling that the FHA did not cover discriminatory conduct occurring after the purchase of her home and that Watts failed to specify the contractual terms the HOA allegedly violated. The court found her allegations insufficient to support claims under the FHA and the Civil Rights Act.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that Watts presented plausible claims under the FHA and the Civil Rights Act. It found that the FHA's language is broad and inclusive, prohibiting a wide range of discriminatory conduct related to housing. The court concluded that the HOA's actions, including restricted access to amenities and selective enforcement of rules, fell within the scope of the FHA. The court also determined that Watts sufficiently alleged intentional racial discrimination causing contractual injury under Section 1981 and that the HOA's actions violated her right to use property on an equal basis with White citizens under Section 1982.The Eleventh Circuit reversed the district court's dismissal and remanded the case for further proceedings. View "Watts v. Joggers Run Property Owners Association, Inc." on Justia Law

Pemco and Boeing entered into a contractual "teaming arrangement" to bid for a 2008 Air Force contract, which included a master agreement, a work share agreement, and a non-disclosure agreement. The relationship soured, leading Pemco to sue Boeing for breach of contract and trade secret misappropriation under the Missouri Trade Secrets Act. The district court initially dismissed the trade secrets claim as time-barred but allowed the breach of contract claims to proceed, resulting in a jury awarding Pemco $2,132,038 in direct damages.On appeal, the Eleventh Circuit reversed the dismissal of the trade secrets claim, holding that the Missouri statute of limitations applied, not Alabama's. After remand, Pemco filed a new complaint asserting only the trade secrets claim. The district court dismissed this claim, concluding that the contractual limitation of liability provision barred all additional damages since Pemco had already recovered the maximum amount allowed for breach of contract.The Eleventh Circuit reviewed the case de novo and held that the limitation of liability provision in the master agreement applies to Pemco’s trade secrets claim, barring most categories of damages, including incidental, punitive, and consequential damages. However, the court found that the provision does not bar recovery for unjust enrichment, which Pemco had alleged. The court noted that unjust enrichment damages are distinct from the direct, out-of-pocket damages Pemco had already recovered and are not categorically barred by the limitation provision.The court reversed the district court’s dismissal of Pemco’s trade secrets claim and remanded the case for further proceedings, allowing Pemco to pursue recovery based on Boeing’s alleged unjust enrichment. The court denied Pemco’s request to reassign the case to a different district judge. View "Alabama Aircraft Industries Inc. v. Boeing Company, The" on Justia Law

The case involves an FBI investigation into Jeffrey Alan Siegmeister, the State Attorney for the Third Judicial Circuit of Florida, and Marion Michael O'Steen, a defense attorney. The investigation began after Andy Tong, who was being prosecuted by Siegmeister, informed the FBI that O'Steen would have to pay Siegmeister $50,000 for a favorable case disposition. The investigation concluded with a grand jury indictment against Siegmeister and O'Steen, charging them with multiple counts, including conspiracy to engage in bribery and extortion.In the United States District Court for the Middle District of Florida, Siegmeister entered a plea agreement and pled guilty to several counts, including conspiracy and bribery. O'Steen stood trial on four counts. The jury found O'Steen not guilty on Counts One and Two but guilty on Counts Three and Four. The District Court sentenced O'Steen to concurrent prison terms of 44 months, followed by supervised release, and ordered him to pay fines and restitution.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court found that the jury instructions on Count Three were flawed, as they allowed for a conviction based on an incorrect legal theory. The court also determined that the evidence was insufficient to prove that O'Steen knew of the fifteen-day reporting requirement for filing Form 8300, as required by Count Four. Consequently, the Eleventh Circuit reversed the District Court's judgment and instructed the lower court to enter a judgment of acquittal for O'Steen. View "USA v. O'Steen" on Justia Law

Ronald Rubin filed a lawsuit naming Kimberly Grippa as part of a criminal enterprise. His lawyer sent allegedly defamatory letters to state officials, asking them to investigate the alleged criminal enterprise and included copies of the complaint. Grippa sued Rubin for defamation, claiming the letters harmed her reputation and professional standing. Rubin moved for summary judgment, arguing the letters were protected by Florida’s absolute and qualified litigation privileges and that he could not be held vicariously liable for his lawyer’s actions.The United States District Court for the Northern District of Florida denied Rubin’s motion for summary judgment on all grounds. The court found that the letters were not protected by the absolute litigation privilege because they were sent outside the litigation process and included additional statements beyond those in the complaint. The court also determined that there was a genuine dispute of material fact regarding whether the statements were made with express malice, precluding the qualified litigation privilege. Lastly, the court rejected Rubin’s vicarious liability argument, suggesting that Rubin directed his lawyer’s actions.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that the denial of Florida’s absolute litigation privilege is immediately appealable under the collateral order doctrine but lacked jurisdiction to consider the denial of the qualified litigation privilege or the vicarious liability issue. The court affirmed the district court’s denial of the absolute litigation privilege, concluding that the letters were sent outside the judicial process and included additional defamatory statements. The court dismissed the appeal regarding the qualified litigation privilege and vicarious liability for lack of jurisdiction. View "Grippa v. Rubin" on Justia Law

Dr. Jeffery D. Milner, a physician, brought a qui tam action under the False Claims Act (FCA) against Baptist Health Montgomery, Prattville Baptist, and Team Health. Milner alleged that while working at a hospital owned by the defendants, he discovered that they were overprescribing opioids and fraudulently billing the government for them. He claimed that he was terminated in retaliation for whistleblowing after reporting the overprescription practices to his superiors.Previously, Milner filed an FCA retaliation lawsuit against the same defendants in the U.S. District Court for the Northern District of Alabama, which was dismissed with prejudice for failure to state a claim. The court found that Milner did not sufficiently allege that he engaged in protected conduct under the FCA or that his termination was due to such conduct. Following this dismissal, Milner filed the current qui tam action in the U.S. District Court for the Middle District of Alabama. The district court dismissed this action as barred by res judicata, relying on the Eleventh Circuit's decisions in Ragsdale v. Rubbermaid, Inc. and Shurick v. Boeing Co.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's dismissal. The court held that Milner's qui tam action was barred by res judicata because it involved the same parties and the same cause of action as his earlier retaliation lawsuit. The court found that both lawsuits arose from a common nucleus of operative fact: the defendants' alleged illegal conduct and Milner's discovery of that conduct leading to his discharge. The court also noted that the United States, which did not intervene in the qui tam action, was not barred from pursuing its own action in the future. View "Milner v. Baptist Health Montgomery" on Justia Law

Kh’Lajuwon Murat was released from prison and began his supervised release. The government petitioned the district court to revoke his supervised release due to seven alleged violations, including failing to submit truthful reports, unauthorized travel, associating with criminals, and committing new offenses. Murat admitted to three violations, and the district court revoked his supervised release, sentencing him to five months’ imprisonment and 54 months’ supervised release. The court held the remaining violations in abeyance.The district court held a second hearing on Murat’s final day of imprisonment to address the remaining violations. Murat challenged the court’s jurisdiction, but the court found for the government on one violation and dismissed the others. Murat was sentenced to an additional four months’ imprisonment and 48 months’ supervised release. Murat appealed, arguing that the district court lacked jurisdiction to adjudicate the remaining violations after the first revocation and that the second sentence was illegal.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that the district court retained jurisdiction to adjudicate the remaining violations because the petition was filed before the first revocation. The court explained that revocation does not terminate the term of supervised release, and the district court’s jurisdiction continues during the defendant’s imprisonment. The court also found that the district court’s procedure of holding violations in abeyance and issuing separate revocation orders did not constitute plain error. The judgment and sentence of the district court were affirmed. View "USA v. Murat" on Justia Law

Several plaintiffs, including United States Sugar Corporation, Okeelanta Corporation, and Sugar Cane Growers Cooperative of Florida, challenged the United States Army Corps of Engineers' approval of the Everglades Agricultural Area Project (EAA Project). The plaintiffs argued that the Corps violated the Administrative Procedure Act by using the wrong water supply baseline in its Savings Clause analysis and by failing to conduct a separate analysis for the standalone operation of the storm water treatment area (STA). They also claimed that the Corps violated the National Environmental Policy Act (NEPA) by not evaluating the effects of the standalone STA operation in its Environmental Impact Statement (EIS).The Southern District of Florida granted summary judgment in favor of the Corps. The district court held that the Corps did not violate the Savings Clause by using the LORS 2008 baseline instead of the year 2000 baseline, as the water supply loss reflected in LORS 2008 was due to structural integrity issues with the Herbert Hoover Dike, not an implementation of the Plan. The court also found that the Corps' decision to use LORS 2008 was reasonable and that the plaintiffs had standing to bring their claims.The United States Court of Appeals for the Eleventh Circuit affirmed the district court's decision on the plaintiffs' first claim, agreeing that the Corps did not violate the Savings Clause. The court also affirmed the district court's decision on the plaintiffs' third claim, holding that the Corps did not violate NEPA by failing to include the standalone STA operation in its EIS, as the standalone STA had independent utility and could be evaluated in a supplemental EIS.However, the Eleventh Circuit reversed the district court's decision on the plaintiffs' second claim, finding that it was not ripe for review because the Corps had not made a final decision authorizing the standalone operation of the STA. The court remanded the case with instructions to dismiss the second claim for lack of finality and ripeness. View "United States Sugar Corp. v. Army Corps of Engineers" on Justia Law