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

Police officers responded to a 911 call about a suspicious individual in a residential neighborhood. Officer Sanchez encountered Victor Grandia Gonzalez, who matched the description given by the complainant. Gonzalez was walking in the street, wearing dark clothing, and carrying a backpack. He appeared nervous and sweaty. Officer Exantus, after speaking with the complainant, learned that Gonzalez had been seen looking into mailboxes and concealing himself between cars. Upon arrival, Exantus patted down Gonzalez and found scissors. Gonzalez admitted to living out of his car and showed a photo of his ID listing a home county 30 minutes away. Based on these observations and the complainant’s report, Gonzalez was arrested for loitering and prowling. A search of his backpack revealed stolen mail.The United States District Court for the Southern District of Florida denied Gonzalez’s motion to suppress the mail evidence and statements, finding that the officers had probable cause for the arrest. Gonzalez pleaded guilty to one count of possessing stolen mail but reserved the right to appeal the suppression ruling. He was sentenced to time served and two years of supervised release.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that the Fourth Amendment does not require a misdemeanor to occur in an officer’s presence for a warrantless arrest. The court found that the officers had probable cause to arrest Gonzalez for loitering and prowling under the totality of the circumstances, including the complainant’s report and the officers’ observations. The court affirmed the district court’s judgment. View "USA v. Gonzalez" on Justia Law

Yorktown Systems Group Inc. and Threat Tec LLC, both defense contractors, entered into a mentor-protégé relationship under the Small Business Administration’s program to jointly pursue government contracts. They formed a joint venture (JV) and were awarded a $165 million contract with the U.S. Army. The JV agreement allocated specific work shares to each company. However, the relationship soured, and Threat Tec attempted to terminate Yorktown’s subcontract, effectively cutting Yorktown out of its share of the contract.The United States District Court for the Northern District of Alabama granted Yorktown a preliminary injunction, preventing Threat Tec from terminating the subcontract and depriving Yorktown of its rights under the JV agreement. The court found that Yorktown had shown a substantial likelihood of success on its breach of contract and breach of fiduciary duty claims and faced irreparable harm. The court noted that Threat Tec’s CEO had made false statements and lacked candor, leading to the belief that Threat Tec’s motives were unethical.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court’s decision. The appellate court found no clear error in the district court’s factfindings and concluded that the district court acted within its discretion. The court held that Threat Tec, as the managing member of the JV, owed fiduciary duties of loyalty and care to Yorktown and likely breached those duties by attempting to cut Yorktown out of its contractually specified workshare. The court also agreed that Yorktown faced irreparable harm, including potential damage to its business reputation and the loss of highly skilled employees, which could not be remedied by monetary damages alone. View "Yorktown Systems Group Inc. v. Threat TEC LLC" on Justia Law

Ashraf Abdulkarim-Ali Alkotof, a Yemeni citizen, entered the U.S. on a B1/B2 visa in 2006 and overstayed. In 2010, the Department of Homeland Security (DHS) issued a notice to appear, alleging he was subject to removal. Alkotof admitted the allegations but sought adjustment of status based on an I-130 petition filed by his U.S. citizen spouse, Tiffany Alfano. After Alfano's petition was denied, Alkotof divorced her and married Hajer Ali Yehia, who filed another I-130 petition, which was initially approved but later revoked due to alleged marriage fraud. Alkotof appealed the revocation and also applied for a U-Visa as a crime victim.The Immigration Judge (IJ) continued Alkotof’s removal proceedings multiple times but ultimately ordered his removal in 2018, citing the lack of an approved I-130 petition and the speculative nature of his U-Visa application. Alkotof appealed to the Board of Immigration Appeals (BIA), which dismissed his appeal and denied his motion to remand for cancellation of removal, citing insufficient evidence to rebut the marriage fraud finding.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court concluded it lacked jurisdiction over the BIA’s denial of Alkotof’s motion to remand for cancellation of removal, as it involved discretionary judgment. The court also found that the BIA did not abuse its discretion in denying Alkotof’s request for administrative closure or a continuance. The court noted that Alkotof was ineligible for adjustment of status due to the revoked I-130 petition and that he could continue to pursue his U-Visa application even after removal. Consequently, the court affirmed in part and dismissed in part Alkotof’s petition for review. View "Ashraf Abdulkarim-Ali Alkotof v. Attorney General" on Justia Law

Charles Johnson, Jr. was arrested by Officer Garrett Rolfe for driving while intoxicated. Johnson alleged that Rolfe used excessive force during the arrest, resulting in a broken collarbone. Johnson sued Rolfe and the City of Atlanta under 42 U.S.C. § 1983 and Georgia state law, claiming excessive force and battery. Johnson's complaint stated that he was respectful and did not resist arrest, but Rolfe threw him to the ground, causing his injury.The United States District Court for the Northern District of Georgia reviewed the case. The City moved to dismiss the complaint, arguing it failed to state a claim for Monell liability. Rolfe moved for judgment on the pleadings, submitting body camera and dashcam footage showing Johnson resisting arrest. The district court considered the video evidence, determining it was central to Johnson's claims and its authenticity was not disputed. The court found that Rolfe did not use excessive force and was entitled to qualified immunity on the federal claims and official immunity on the state law claims. Consequently, the court dismissed the Monell claim against the City, as there was no underlying constitutional violation.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court affirmed the district court's decision, holding that the video evidence was properly considered under the incorporation-by-reference doctrine. The court found that Rolfe's use of force was objectively reasonable given the circumstances, including Johnson's resistance and the dangerous location of the arrest. Therefore, Rolfe was entitled to qualified immunity on the federal claims and official immunity on the state law claims. The court also affirmed the dismissal of the Monell claim against the City, as no constitutional violation occurred. View "Johnson v. City of Atlanta" on Justia Law

The case involves Gretchen Buselli, who was convicted of a murder-for-hire plot targeting her estranged husband, Bradley Buselli, and for making false statements to a federal agent. The evidence presented at trial included recorded phone calls where Buselli discussed hiring someone to kill Bradley, and surveillance footage showing her leaving $5,000 in a lunch box as payment. Buselli had reported Bradley for abusing their daughter, but investigations found no evidence supporting her claims. She was arrested after an undercover FBI agent, posing as a hitman, confirmed the murder-for-hire plot.The United States District Court for the Northern District of Florida handled the initial trial. Buselli was indicted on two counts: use of interstate commerce with intent to commit murder-for-hire and making materially false statements. She contested the jury instructions related to the murder-for-hire charge, arguing that the jury should be instructed on Florida’s defenses to murder, such as justifiable and excusable homicide. The district court declined to include these instructions, finding no evidence to support them.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court affirmed the district court’s decision, holding that the statutory language in 18 U.S.C. § 1958(a) does not require incorporating state law defenses into federal murder-for-hire prosecutions. The court also found that any error in the jury instructions was harmless, as no reasonable jury would have found Buselli’s actions justified under Florida law. Additionally, the court rejected Buselli’s constitutional challenge to her false-statements conviction and found no error in the jury instructions related to this charge. The Eleventh Circuit affirmed both of Buselli’s convictions. View "United States v. Buselli" on Justia Law

The case involves two Georgia non-profit organizations, New Georgia Project and New Georgia Project Action Fund (collectively referred to as "New Georgia"), and the Georgia Government Transparency and Campaign Finance Commission. New Georgia was accused of violating the Georgia Government Transparency and Campaign Finance Act by failing to register with the Commission and disclose their campaign expenditures and sources. The Commission initiated an investigation and found "reasonable grounds" to conclude that New Georgia had violated the Act.New Georgia then filed a federal lawsuit claiming that the Act violated the First and Fourteenth Amendments. The district court granted a preliminary injunction preventing the state from enforcing the Act against New Georgia. The state appealed, arguing that the district court should have abstained from exercising its jurisdiction under the doctrine established in Younger v. Harris.The United States Court of Appeals for the Eleventh Circuit held that the district court should have abstained under the Younger doctrine. The court found that the state's enforcement action against New Georgia was ongoing and implicated important state interests, and that New Georgia had an adequate opportunity in the state proceeding to raise constitutional challenges. The court vacated the district court's decision and remanded with instructions to dismiss New Georgia's action. View "New Georgia Project, Inc. v. Attorney General" on Justia Law

The case involves two brothers, Levi and Benjamin Goldfarb, who sought payment of a $500,000 claim under an Accidental Death & Dismemberment insurance policy after their father, Dr. Alexander Goldfarb, died while mountain climbing in Pakistan. The insurer, Reliance Standard Life Insurance Company, denied the claim because the cause of Dr. Goldfarb’s death was unknown, and therefore, his beneficiaries could not show that he died by accident. The Goldfarb brothers challenged the denial in district court under the Employee Retirement Security Act.The district court ruled in favor of the Goldfarbs, stating that Dr. Goldfarb’s death was accidental and that Reliance Standard’s failure to pay the Accidental Death & Dismemberment claim was arbitrary and capricious. The court granted summary judgment to the Goldfarbs and denied Reliance Standard’s cross motion for summary judgment. Reliance Standard appealed this decision.The United States Court of Appeals for the Eleventh Circuit disagreed with the district court's decision. The appellate court found that Reliance Standard’s decision that Dr. Goldfarb’s death was not accidental under the insurance policy was supported by reasonable grounds, and the denial of the Goldfarbs’ claim for benefits was not arbitrary and capricious. Therefore, the court reversed the district court’s grant of summary judgment to the Goldfarbs and directed the court to enter judgment in Reliance Standard’s favor. View "Goldfarb v. Reliance Standard Life Insurance Co." on Justia Law

In March 2020, seven crewmembers of the M/V Greg Mortimer cruise ship filed a lawsuit against several companies, including CMI Leisure Management, Inc., Cruise Management International, Inc., and Vikand Medical Solutions, LLC. The crewmembers alleged that the decision to sail during the COVID-19 pandemic exposed them to foreseeable harms, resulting in six of them contracting the virus. The crewmembers had signed employment agreements with other companies that contained forum-selection and choice-of-law clauses requiring disputes to be brought in the Bahamas under Bahamian law.The United States District Court for the Southern District of Florida dismissed the action based on the forum-selection clause. The court ruled that the defendants, who were not parties to the employment agreements, could invoke the forum-selection clause under the doctrine of equitable estoppel.Upon review, the United States Court of Appeals for the Eleventh Circuit vacated and remanded the decision. The appellate court held that the defendants could not invoke the forum-selection clause in the employment agreements under the doctrine of equitable estoppel. The court reasoned that the crewmembers' claims did not rely on the terms of their employment agreements, and thus, equitable estoppel did not apply. The court remanded the case for further proceedings consistent with its opinion. View "Usme v. CMI Leisure Management, Inc." on Justia Law

The case involves Greater Birmingham Ministries, a multi-faith, multi-racial organization that promotes voter registration efforts in Alabama, and the Secretary of State for the State of Alabama. The organization requested electronic production of several voter lists, including records of individual felons disqualified from voting by Alabama, invoking the public disclosure provision of the National Voter Registration Act. The organization argued that the records should be produced electronically and at no cost. The Secretary of State agreed to provide an electronic version of the first list of voter records at a cost of one cent per name but refused to provide any records related to felony disqualifications, asserting that the request exceeded the scope of the Act.The district court ruled that the National Voter Registration Act entitled Greater Birmingham Ministries to both sets of records and that electronic disclosure was required in the specific circumstances of this case. The court also ruled that the Act entitled the Secretary to charge a “reasonable fee,” connected “to the actual costs he incurs in producing responsive voter records.”The United States Court of Appeals for the Eleventh Circuit reversed the district court's order. The court held that the voter records that Greater Birmingham Ministries requested are covered by the National Voter Registration Act’s public disclosure provision. However, the court ruled that the Act does not require the Secretary to turn those records over in an electronic format. Therefore, the district court’s injunction ordering the Secretary to produce the records electronically was improper. The same is true for its direction that the parties reach agreement on a reasonable fee. The case was remanded for proceedings consistent with this opinion. View "Greater Birmingham Ministries v. Secretary of State for the State of Alabama" on Justia Law

The case revolves around William Spears, a front desk clerk at hotels operated by Rick Patel Sr. and his son, Rick “Sunny” Patel Jr. Spears was compensated with monthly paychecks and onsite lodging. He sued the Patels and the hotel entities under the Fair Labor Standards Act for wages owed and unpaid overtime. The district court ruled that Sunny was an employer individually liable for the violations. In calculating Spears’s damages, the court considered the stipulated value of Spears’s lodging for unpaid overtime but declined to include it in the minimum-wage calculation.The case went to a bench trial before a magistrate judge. The judge found that Spears was not paid the legally required minimum wage or overtime. The judge ruled that Rick and Sunny were employers under the Act individually liable for those violations. The judge also found that Spears was entitled to damages for unpaid overtime and minimum wages. The judge included the stipulated $630 lodging value to determine Spears’s overtime pay rate but did not give the Patels credit for the value of Spears’s lodging when calculating Spears’s unpaid minimum wages.The United States Court of Appeals for the Eleventh Circuit affirmed the ruling that Sunny was an employer under the Act due to his involvement in the day-to-day operation of the hotels and some financial control. However, the court vacated and remanded for recalculation of damages. The court held that the magistrate judge erred in excluding the stipulated value of Spears’s lodging from the calculation of his unpaid minimum wages but including it for the calculation of Spears’s overtime damages. The court reasoned that the stipulation to the value of Spears’s lodging relieved the Patels of the burden to prove at trial the reasonable cost of lodging. View "Spears v. Patel" on Justia Law