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

This case involves a mistaken identification by two sheriff's office investigators, Joseph Bultman and Jon Hixon, who identified George Angel Harris as the individual captured on security camera footage using a stolen debit card. Based on this identification, Hixon obtained two arrest warrants for Harris for financial transaction card fraud. Harris was arrested and held in jail for a few hours before being released. The criminal case against him was eventually dismissed.Previously, Harris filed a lawsuit against the investigators under 42 U.S.C. § 1983, alleging they violated his Fourth Amendment rights by causing him to be falsely arrested and unlawfully detained without probable cause. The district court construed Harris' claims as ones for malicious prosecution and granted summary judgment in favor of the investigators on qualified immunity grounds.In the United States Court of Appeals for the Eleventh Circuit, Harris argued that the investigation leading to his arrest was inadequate, that the district court erred in excluding his expert's testimony about the unreasonableness of the investigation, and that Hixon's arrest affidavit was based on conclusory statements without supporting facts, making the warrants for his arrest constitutionally inadequate.The Court of Appeals affirmed the district court's decision. It held that the investigators' mistaken identification of Harris was a reasonable mistake and did not violate Harris' Fourth Amendment rights. The court also found that the district court did not abuse its discretion in excluding Harris' expert's testimony, as it would not have been helpful to a jury. Finally, the court held that even if the arrest warrant application was insufficient, the investigators had probable cause to arrest Harris based on their own knowledge and the brief period of Harris' detention. View "Harris v. Hixon" on Justia Law

The case revolves around an employment discrimination suit filed by Dr. Tara Loux against her former employers, BayCare Medical Group and St. Joseph’s Hospital. Dr. Loux sought to discover BayCare’s internal documents about the performance of other doctors who were not fired despite also committing errors. BayCare objected to disclosing certain documents, such as its “quality files” and “referral logs,” arguing that they were privileged under the Patient Safety and Quality Improvement Act of 2005. The Act creates a statutory privilege for work product prepared for or reported to patient safety organizations.The district court ordered BayCare to produce the disputed documents, concluding that the Act does not privilege documents if they have a “dual purpose,” only one of which relates to making reports to a patient safety organization. The court held that these documents were not privileged because BayCare used information in the documents for other purposes, such as internal safety analysis and peer review.The United States Court of Appeals for the Eleventh Circuit disagreed with the district court's interpretation of the Act. The appellate court found that the district court had applied an incorrect "sole purpose" standard to assess whether BayCare’s quality files and referral logs fell under the privilege. The court held that the Act does not require that privileged information be kept solely for provision to a Patient Safety Organization. The court granted BayCare's petition for a writ of mandamus, directing the district court to vacate its orders compelling the disclosure of the privileged documents and reconsider BayCare’s assertion of privilege consistent with the appellate court's opinion. View "In re: Baycare Medical Group, Inc." on Justia Law

The case revolves around Anna Lange, a transgender woman employed by the Houston County Sheriff's Office in Georgia. Lange was diagnosed with gender dysphoria in 2017 and her healthcare providers recommended a treatment plan that included hormone therapy and gender-affirming surgery. In 2018, her healthcare providers determined that a vaginoplasty was medically necessary. However, Lange's request for coverage was denied based on the health insurance plan's exclusion of services and supplies for sex change and/or the reversal of a sex change. Lange filed claims against Houston County with the Equal Employment Opportunity Commission and subsequently sued Houston County and the Sheriff of Houston County in the Middle District of Georgia.The district court granted summary judgment to Lange on the Title VII claim, finding the Exclusion facially discriminatory as a matter of law. The Title VII claim then proceeded to trial, and a jury awarded Lange $60,000 in damages. After trial, the district court entered an order declaring that the Exclusion violated Title VII and permanently enjoined the Sheriff and Houston County from any further enforcement or application of the Exclusion.The United States Court of Appeals for the Eleventh Circuit affirmed the district court's decision. The court held that a health insurance provider can be held liable under Title VII of the Civil Rights Act of 1964 for denying coverage for gender-affirming care to a transgender employee because the employee is transgender. The court also held that Houston County is liable under Title VII as an agent of the Sheriff's Office. The court affirmed the district court's order permanently enjoining Houston County and the Sheriff from further enforcement or application of the Exclusion. View "Lange v. Houston County, Georgia" on Justia Law

The case revolves around W.P. Productions, Inc. (WPP), a company owned by Sydney Silverman, and Sam's West, Inc. WPP, which sold kitchen products under the Wolfgang Puck brand to Sam's Club, owed significant debt to Sam's West. Despite this, WPP initiated a tort lawsuit against Tramontina U.S.A., Inc. and Sam's West. After a final judgment was entered against WPP, Sam's West filed a supplemental lawsuit to pierce WPP's corporate veil and hold Silverman personally liable for WPP's unpaid judgments. Silverman, who used a shared bank account for his personal and WPP's corporate funds, allegedly spent over $3 million from the shared account on personal expenses and transfers to himself and his relatives.The United States District Court for the Southern District of Florida granted summary judgment in favor of Sam's West, piercing the corporate veil and holding Silverman personally liable for the judgments against WPP. The court adopted a Report and Recommendation (R&R) that determined Silverman was the alter ego of WPP, but did not establish the remaining elements of improper conduct or causing an injury. Both parties then moved for summary judgment regarding these elements. The court adopted a second R&R stating that the undisputed facts showed Sam's West was entitled to judgment as a matter of law on its veil piercing claim.In the United States Court of Appeals for the Eleventh Circuit, Silverman appealed the district court's decision, alleging that the court improperly pierced the corporate veil on summary judgment. After reviewing the case, the appellate court affirmed the district court's decision. The court found no genuine dispute of material fact regarding the three elements for piercing the corporate veil in Florida: Silverman was the alter ego of WPP; Silverman used WPP for the improper purpose of evading Florida's Rule of Priorities; and this improper use of WPP's corporate form caused injury to Sam's West. Therefore, the court held that the district court correctly granted summary judgment in favor of Sam's West and pierced the corporate veil. View "Sam's West, Inc. v. Silverman" on Justia Law

The Center for a Sustainable Coast and its member, Karen Grainey, filed a lawsuit against the U.S. Army Corps of Engineers, alleging that the Corps had issued a dock permit without a full environmental review under the National Environmental Policy Act (NEPA). The Center claimed that several of its members regularly visit Cumberland Island, where the dock is located, and suffer an ongoing aesthetic injury due to the dock's presence. The Center argued that the environmental review the Corps skipped could have protected that interest.The district court dismissed the lawsuit, concluding that the Center did not have standing because its harm was not redressable. The court reasoned that since the dock had already been built, the court’s ability to provide relief had ended along with construction.The United States Court of Appeals for the Eleventh Circuit disagreed with the district court's decision. The appellate court held that the Center had standing to bring at least one of its procedural rights claims. The court reasoned that the Center had identified a concrete aesthetic interest and pleaded that the NEPA process would protect that interest. Directing full NEPA review would thus redress the Center’s procedural injury. Furthermore, the permit issued by the Corps authorized not just the construction of the dock, but also its continued existence. Therefore, the case was not moot because the challenged project was already completed. However, the court affirmed the dismissal of the Seashore Act claim, as the Center abandoned that argument on appeal. View "Center for a Sustainable Coast v. U.S. Army Corps of Engineers" on Justia Law

The case involves a dispute between J.C. Penney Corporation, Inc. and Oxford Mall, LLC. Oxford Mall purchased a shopping center in a 2017 foreclosure sale and began a significant redevelopment plan. J.C. Penney, a tenant at the mall since 1968, had a lease that included the right to approve certain changes to the mall’s site plan. When J.C. Penney sought to exercise one of its remaining contractual options, Oxford denied the request, claiming that J.C. Penney was out of extension options. This led to a lawsuit filed by J.C. Penney in 2019, invoking the district court’s diversity jurisdiction.The case proceeded for two years under the assumption that diversity jurisdiction existed. However, in 2020, Oxford discovered that it was a citizen of Delaware, the same as J.C. Penney, which destroyed the court’s diversity jurisdiction. Despite this, Oxford continued to litigate in federal court and did not inform the court of the lack of jurisdiction until April 2021, after several unfavorable rulings.The United States Court of Appeals for the Eleventh Circuit affirmed the district court's decision to impose sanctions on Oxford Mall, LLC for its bad faith conduct. The court found that Oxford had actual knowledge that it was a citizen of Delaware, which destroyed the court’s diversity jurisdiction, and that Oxford's delay in disclosing the lack of diversity jurisdiction was strategic. The court also concluded that the district court did not abuse its discretion in determining the amount of fees owed to J.C. Penney and in refusing to consider an irrelevant and untimely affidavit from Oxford's attorney. View "J.C. Penney Corporation, Inc. v. Oxford Mall, LLC" on Justia Law

Angela Poer, a white woman, was employed as an Administrative Services Manager by the Jefferson County Commission. She alleged that her supervisor, a black woman, discriminated against her based on her race. Poer claimed that her request for a lateral transfer or reassignment was denied and that she was ultimately terminated due to her race. She sought damages including reinstatement and back pay.The district court granted summary judgment in favor of the Commission, finding that Poer failed to present any evidence showing that she was terminated or discriminated against because of her race. The court also declined to consider Poer’s argument that the Commission’s employment decisions were forms of retaliation in response to her grievances, as this argument was raised for the first time at summary judgment.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s judgment. The court found that Poer had not presented a convincing mosaic of circumstantial evidence that would support even an inference at summary judgment, let alone a jury finding at trial, that the Commission terminated her because of her race. The court also agreed with the district court that Poer could not raise a retaliation claim for the first time at summary judgment. View "Poer v. Jefferson County Commission" on Justia Law

This case involves a dispute between two tribally owned businesses, AQuate II, LLC and Kituwah Services, LLC, both of which compete for federal contracts under the Small Business Administration’s 8(a) Business Development Program. AQuate alleges that Kituwah and its employee, Jessica Myers, stole trade secrets related to a government contract that AQuate had won in the past. AQuate claims that Myers, a former employee, breached her employment agreements and violated both the Defend Trade Secrets Act of 2016 and the Alabama Trade Secrets Act. Kituwah, however, argues that it is shielded by tribal sovereign immunity, while Myers contends that her employment contract mandates that any claims against her can only be brought in a designated tribal court.The United States District Court for the Northern District of Alabama dismissed the case, finding that Kituwah had not waived sovereign immunity for the trade secrets claims and that the claims against Myers should be resolved in the Alabama-Quassarte Tribal Town court, as stipulated in her employment contract. AQuate appealed the decision, arguing that the tribal court did not exist.The United States Court of Appeals for the Eleventh Circuit reversed the district court’s decision. The appellate court found that Kituwah had waived sovereign immunity for claims related to the federal contracting program and could be sued. Regarding Myers, the court determined that the district court failed to consider whether the clause naming the allegedly nonexistent tribal court as the appropriate forum was valid and enforceable. The case was remanded for further consideration. View "Aquate II, LLC v. Myers" on Justia Law

The case involves a Venezuelan couple, Carlos Cuenca Figueredo and Yauri Rojas, who had a son, C.R. After their separation and divorce, they shared custody of C.R. in Venezuela. However, Rojas took C.R. to the United States without Figueredo's knowledge or permission. Twenty months after Rojas left Venezuela with C.R., Figueredo filed a petition in the Middle District of Florida seeking his son’s return under the Hague Convention on the Civil Aspects of International Child Abduction.The Middle District of Florida found that C.R. was settled in his new environment in the United States. The court considered factors such as C.R.'s stable residence, school attendance, community participation, and Rojas's employment and financial stability. The court also took into account C.R. and his mother's immigration status, noting that Rojas had been granted authorization to remain and work in the United States while her asylum application was pending. Consequently, the court denied Figueredo's petition for C.R.'s return.The United States Court of Appeals for the Eleventh Circuit affirmed the lower court's decision. The appellate court held that a child's immigration status is one relevant factor in determining whether a child is settled in a new environment. The court found that the district court did not err in finding that C.R. was settled in his new environment and did not abuse its discretion in refusing to order his return to Venezuela. View "Alberto Cuenca Figueredo v. Del Carmen Rojas" on Justia Law

Derrick Morley was convicted of conspiracy to possess with intent to distribute five hundred grams or more of cocaine, and possession with intent to distribute five hundred grams or more of cocaine. Morley was sentenced to 60 months’ imprisonment for each count, to be served concurrently. He appealed his convictions and sentence, arguing that the district court erred in denying his motion to suppress evidence, the trial evidence was insufficient to support his convictions, the district court erred in providing a deliberate ignorance jury instruction, and the district court erred in denying him a safety valve sentence reduction.The United States District Court for the Southern District of Florida denied Morley's motion to suppress the cocaine that was taken from his vehicle without a warrant. The court found that there was probable cause to believe Morley’s car contained contraband or evidence of a crime and that apparent authority existed under the circumstances. Morley proceeded to a four-day jury trial and was found guilty as charged in the indictment. The district court denied Morley's motion for a judgment of acquittal notwithstanding the verdict.The United States Court of Appeals for the Eleventh Circuit affirmed Morley’s convictions and sentence. The court found that the district court did not abuse its discretion in finding that the automobile exception applied, allowing for a warrantless search of Morley's car. The court also found that the trial evidence was sufficient to support Morley's convictions and that the district court did not err in providing a deliberate ignorance jury instruction. Finally, the court affirmed the district court's denial of Morley's request for a reduced sentence, finding that Morley was ineligible for the safety valve reduction in light of a recent Supreme Court decision. View "USA v. Morley" on Justia Law