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

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

A nurse practitioner working in Georgia became involved in a nationwide Medicare fraud scheme between 2018 and 2019. She took part-time telemedicine jobs and reviewed patient charts for durable medical equipment (DME) prescriptions, such as neck and knee braces. The scheme involved submitting thousands of DME orders to Medicare for patients who had not actually been examined or treated as required by law. Federal investigators discovered she was signing orders, attesting to patient assessments and medical necessity, despite never contacting or examining the patients. Several orders were found to be fraudulent, such as prescribing braces to deceased or bedridden patients, or to patients with amputated limbs. She received compensation per chart reviewed, and her records indicated knowledge of the fraudulent nature of the activity.The United States District Court for the Southern District of Georgia presided over her trial, where she was charged with conspiracy, health care fraud, making false statements, aggravated identity theft, and related offenses. The jury found her guilty on sixteen counts but acquitted her of conspiracy to commit health care fraud. At sentencing, the district court applied a two-level enhancement for obstruction of justice based on perjury, citing her false testimony and inconsistencies. Her motion for a new trial was denied as untimely; the court rejected her claim of excusable neglect due to her attorney’s actions.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed four main issues: sufficiency of evidence, the lack of a deliberate ignorance jury instruction, the sentencing enhancement for perjury, and the denial of her new trial motion. The appellate court found sufficient evidence for all convictions, held that the absence of the deliberate ignorance instruction did not prejudice her substantial rights, affirmed the obstruction of justice enhancement, and found no abuse of discretion in the denial of the new trial motion. The Eleventh Circuit affirmed her convictions and sentence. View "USA v. Beaufils" on Justia Law

The case involves a Florida-based title insurer that suffered significant financial setbacks, prompting a series of business restructurings and asset transfers. In 2009, the company entered a joint venture with another title insurance group, forming a new entity to handle certain business functions. Over subsequent years, the original company retained substantial assets and continued operations, but further financial decline led to a 2015 agreement in which it transferred assets and liabilities to its business partner, in exchange for the assumption of its policy liabilities. The Florida insurance regulator scrutinized and ultimately approved the transaction after requiring additional commitments from the acquiring party.The United States Bankruptcy Court for the Middle District of Florida later oversaw the company’s Chapter 11 proceedings. The appointed Creditor Trustee brought an adversary proceeding against the acquiring parties and related entities, alleging that the asset transfer constituted a fraudulent transfer under federal bankruptcy law and Florida statutes, and sought to impose successor liability and alter ego claims. The bankruptcy court held a bench trial, excluding portions of the Trustee’s expert valuation as unreliable, and found that the company had received reasonably equivalent value in the transaction. The court also rejected the successor liability and alter ego theories, finding insufficient evidence of continuity of ownership, improper purpose, or harm to creditors.The United States District Court for the Middle District of Florida affirmed the bankruptcy court’s rulings. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the record and affirmed the district court’s order. The Eleventh Circuit held that the bankruptcy court did not err in excluding the Trustee’s expert, that the asset transfer was for reasonably equivalent value and not fraudulent, and that the successor liability and alter ego claims failed for lack of evidence and legal sufficiency. View "Stermer v. Old Republic National Title Insurance Company" on Justia Law

Cheriese Johnson began experiencing a range of symptoms, including coughing and pain in her hands and feet, prior to her employment in July 2016 with The William Carter Company. She purchased a long-term disability insurance policy from Reliance Standard that became effective in October 2016. During the three months before her coverage began, Johnson sought medical care for various symptoms and received several diagnoses, but not scleroderma. In early 2017, after her policy was active, she was diagnosed with scleroderma—a rare autoimmune disease—following a lung biopsy. Johnson then filed a claim for long-term disability benefits, which Reliance Standard denied, arguing her disability was caused by a preexisting condition for which she had received treatment during the policy’s lookback period.After her claim was denied and her appeal was unsuccessful, Johnson sued Reliance Standard in the United States District Court for the Northern District of Georgia under the Employee Retirement Income Security Act (ERISA). She moved for judgment on the administrative record, while Reliance Standard sought summary judgment. The district court granted summary judgment to Reliance Standard, finding its decision to deny benefits was correct under the terms of the policy.On appeal, the United States Court of Appeals for the Eleventh Circuit reversed the district court’s judgment. Applying ERISA’s interpretive framework and reviewing the plan administrator’s decision de novo, the Eleventh Circuit held that Reliance Standard’s interpretation of the policy was both incorrect and unreasonable. The court concluded that Johnson had not received medical treatment “for” scleroderma during the lookback period because neither she nor her doctors suspected or intended to treat that specific condition at that time. The court found that Reliance Standard’s interpretation was arbitrary and capricious, and remanded for further proceedings consistent with its opinion. View "Johnson v. Reliance Standard Life Insurance Company" on Justia Law

An individual incarcerated in a county jail in Alabama died after several months in custody, during which his mother, acting as administrator of his estate, alleges he was denied adequate medical care. The county jail had contracted with a private company, Preemptive Forensic Health Solutions, to provide all inmate medical care, even though the company employed no physicians and was allegedly incompetent. Prior to the decedent's death, multiple inmates had died under this company's care, and concerns about inadequate medical treatment became a significant issue in a local sheriff’s election. Despite these concerns and the new sheriff’s efforts to terminate the contract, the county continued and even renewed the agreement with the company, retaining exclusive control over its continuation.The United States District Court for the Northern District of Alabama granted summary judgment to the county, holding that Alabama law limited the county's role to funding inmate healthcare, not providing it, and thus precluded liability under 42 U.S.C. § 1983. The district court determined that only the sheriff was responsible for administering medical care in the jail and that the county had fulfilled its statutory duty by paying for services.The United States Court of Appeals for the Eleventh Circuit reversed this decision. The appellate court held that, under Monell v. Department of Social Services of City of New York and Ancata v. Prison Health Services, Inc., a county can be liable under § 1983 if it adopts or maintains a policy or custom that results in deliberate indifference to inmates' constitutional rights. The court found sufficient evidence for a jury to conclude that the county’s policy of contracting with an incompetent provider—and preventing the sheriff from changing it—could have caused the decedent’s Eighth Amendment violation. The court ruled that Alabama law does not bar such liability and remanded the case for further proceedings. View "Smothers v. Childers" on Justia Law

Jason Starr, following a contentious divorce from his ex-wife Sara Starr, was required to pay substantial monthly support and other financial obligations. Evidence showed Jason was deeply frustrated by these requirements and expressed anger in personal writings. After Sara moved out, she confided to a friend that she feared Jason would kill her. Prior to the murder, Jason suggested to a friend that his brother Darin could “take care of” marital problems for a fee. Darin, living in Texas, purchased a motorcycle with Jason’s financial assistance and received additional payments from Jason through a third party. Cell-site data and witness testimony placed Darin near Sara’s Alabama residence in the days leading up to her murder. Sara was shot and killed outside her home, and surveillance footage showed a motorcycle leaving the scene shortly after. Darin returned to Texas the same day. Later, while in jail for an unrelated offense, Darin made statements implying Jason owed him a significant favor.A federal grand jury in the United States District Court for the Middle District of Alabama indicted Jason and Darin Starr for using interstate commerce facilities in the commission of a murder-for-hire, in violation of 18 U.S.C. § 1958. At trial, the government presented circumstantial evidence linking both brothers to the crime. The jury convicted both Jason and Darin, and the district court imposed mandatory life sentences.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed claims that the district court erred by excluding alternate perpetrator evidence, admitting certain hearsay and investigative testimony, and that the evidence was insufficient to support conviction. The Eleventh Circuit held that the district court properly excluded speculative alternate perpetrator evidence, correctly admitted the challenged statements under evidentiary rules, and found the evidence sufficient for conviction. The court affirmed both convictions and sentences. View "USA v. Starr" on Justia Law