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

A business operating a strip club featuring nude dancing and alcohol sales entered into a settlement agreement with DeKalb County, Georgia, in 2001, which was later amended in 2007. The amended agreement granted the club non-conforming status, allowing it to continue its business model for fifteen years, with the possibility of renewal, and required annual licensing fees. In 2013, the City of Chamblee annexed the area containing the club and subsequently adopted ordinances restricting adult entertainment establishments, including bans on alcohol sales, stricter food sales requirements for alcohol licenses, and earlier closing times. The City initially issued alcohol licenses to the club but later denied renewal, citing failure to meet new requirements and the club’s status as an adult establishment.The United States District Court for the Northern District of Georgia dismissed some of the club’s claims for lack of standing and granted summary judgment to the City on the remaining claims. The district court found that the club lacked standing to challenge certain ordinances as it was not an alcohol licensee, and that the City’s ordinances regulating adult entertainment and alcohol sales were constitutional under the secondary-effects doctrine, applying intermediate scrutiny. The court also determined there was no valid contract between the club and the City, rejecting the Contract Clause claims, and found no equal protection violation, as the club failed to identify a similarly situated comparator.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s rulings. The Eleventh Circuit held that the club lacked standing for equitable relief due to its permanent closure, but had standing for damages for a limited period. The court upheld the application of intermediate scrutiny to the ordinances, found no impairment of contract, and agreed that the club failed to establish an equal protection violation. The district court’s judgment in favor of the City was affirmed. View "WBY, Inc. v. City of Chamblee, Georgia" on Justia Law

The case centers on a Florida farm and its owner, who had supplied produce to a local school district for several years. In June 2020, the owner posted controversial statements on his personal Facebook page, describing the COVID-19 pandemic as a “hoax” and making disparaging remarks about the Black Lives Matter movement and George Floyd. The school district, concerned about food safety during the early, uncertain days of the pandemic, requested information about the farm’s COVID-19 protocols. The response provided protocols from a subsidiary, not the farm itself, which the district found inadequate. Shortly after, the superintendent terminated the farm’s contract, citing concerns about the farm’s approach to COVID-19 safety.The farm and its owner sued the school district and board members in the United States District Court for the Middle District of Florida, alleging First Amendment retaliation and raising state law claims. The district court granted summary judgment to the defendants, applying the Pickering balancing test (typically used for government employees and contractors) and finding that the school district’s interests in food safety outweighed the plaintiffs’ free speech rights. The court also granted qualified immunity to individual defendants and dismissed the state law claims without prejudice.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The Eleventh Circuit held that, although the owner’s speech addressed matters of public concern, the evidence showed the contract was terminated due to genuine food safety concerns, not as punishment for the owner’s views on COVID-19 or racial issues. The court found no genuine dispute of material fact regarding the school district’s motivation and concluded that the district’s interest in student safety justified its actions. The summary judgment in favor of the school district was affirmed. View "Oakes Farms Food & Distribution Services, LLC v. Adkins" on Justia Law

A man was arrested by city police officers in Rainsville, Alabama, after exhibiting erratic behavior and resisting arrest. The Chief of Police directed Officer White to transport the arrestee to the county jail in Fort Payne, which had better medical facilities. Upon arrival at the county jail, jailers became frustrated with the arrestee during booking and began to beat him. Officer White witnessed the beating from a few feet away but did not attempt to intervene or protest. The beating continued for several minutes after White left the room, resulting in significant injuries to the arrestee. The jailers involved were later criminally prosecuted and convicted for their conduct.The arrestee filed a lawsuit under 42 U.S.C. § 1983 against Officer White and others, alleging, among other claims, that White’s failure to intervene violated his Fourth Amendment rights. The United States District Court for the Northern District of Alabama granted summary judgment to the officers on the false arrest claim but denied summary judgment to White on the failure to intervene claim, rejecting his qualified immunity defense. White appealed the denial of qualified immunity.The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo. The court held that, under clearly established law as of March 2020, an arresting officer who delivers a helpless arrestee to jailers and witnesses those jailers immediately begin to beat the arrestee in his presence violates the Fourth Amendment if he remains silent and leaves the scene while the assault is ongoing. The court further held that the duty to intervene is not discharged by a phone call to a supervisor who is not in a position to stop the assault. The Eleventh Circuit affirmed the district court’s denial of summary judgment to Officer White on the failure to intervene claim. View "Nute v. White" on Justia Law

The dispute involved multiple parties and claims arising from business dealings between a printing company and several associated entities and individuals. The plaintiff brought four claims, including breach of contract and fraud, against four defendants. The defendants responded with various counterclaims, including breach of contract, unjust enrichment, and others. Over the course of the litigation, some claims were resolved through motions, while others remained pending.The United States District Court for the Northern District of Georgia dismissed the fraud claim and one defendant early in the proceedings. Later, the court granted summary judgment on certain breach of contract claims but did not issue a final judgment or certify its order under Federal Rule of Civil Procedure 54(b). The parties then attempted to dismiss the remaining claims between some of them using a joint motion under Rule 41(a)(2), believing that the summary judgment order had fully resolved the other claims. The court granted this motion and subsequently dismissed the settled claims between two parties with prejudice. The plaintiff then filed a notice of appeal, seeking review of the summary judgment and denial of reconsideration.The United States Court of Appeals for the Eleventh Circuit reviewed the case and determined that it lacked jurisdiction. The court held that, under the Federal Rules of Civil Procedure, Rule 41(a) allows for voluntary dismissal only of an entire action, not individual claims, and that partial summary judgment orders are not final or appealable unless certified under Rule 54(b). Because the district court had not entered a Rule 54(b) certification and unresolved claims remained, the attempted partial dismissal was ineffective, and the action was not fully resolved. As a result, there was no final decision to appeal, and the appeal was dismissed for lack of jurisdiction. View "CMYK Enterprises, Inc. v. Advanced Print Technologies, LLC" on Justia Law

Ephren Taylor, II, formerly CEO of City Capital Corporation, was indicted in 2014 for orchestrating a fraudulent investment scheme that targeted African American and Christian communities. Taylor promoted investments and promissory notes, misrepresenting their returns and using new investor funds to pay business expenses, resulting in losses exceeding $16 million for over 400 victims. He pleaded guilty to conspiracy to commit wire and mail fraud and was sentenced to 235 months in prison, later reduced to 223 months, with restitution ordered.Taylor filed a pro se motion under 28 U.S.C. § 2255 in the United States District Court for the Northern District of Georgia, alleging ineffective assistance of counsel and various judicial errors. The District Court, after adopting a magistrate judge’s report and recommendation, denied the motion, finding Taylor’s claims either procedurally defaulted, waived, or unsupported by the record. Taylor’s subsequent Rule 59(e) and Rule 60(b) motions were also denied, and he filed multiple additional motions, including to amend or supplement his § 2255 petition and to modify conditions of supervised release. The District Court denied these later motions, determining they were unauthorized second or successive filings under 28 U.S.C. §§ 2244(b) and 2255(h), and that it lacked jurisdiction due to Taylor’s pending appeal.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the District Court’s denial of Taylor’s motions to reopen, supplement, and amend his original § 2255 motion, holding they were unauthorized second or successive filings barred by AEDPA’s gatekeeping provisions. The Eleventh Circuit also affirmed that Taylor’s challenges to the legality or constitutionality of his supervised release conditions could not be raised under 18 U.S.C. § 3583(e)(2). However, the court vacated the District Court’s denial of Taylor’s motion to modify conditions of supervised release and remanded for consideration of the relevant statutory factors. View "United States v. Taylor" on Justia Law

Joshua Gaines pleaded guilty in Alabama state court to receiving stolen property in the third degree, a Class D felony under Alabama law. Due to his criminal history, Alabama statutes at the time prohibited the court from sentencing him to any actual prison time for this offense. Instead, Gaines received a 24-month suspended sentence and was placed on probation for two years, with the possibility of community corrections or other non-prison alternatives, but not incarceration in a prison or jail. After his conviction, Gaines was notified that federal law prohibited him from possessing a firearm. Six months later, he was found in possession of a gun and admitted ownership.The United States District Court for the Northern District of Alabama tried Gaines on two counts: possession of a firearm by a person convicted of a crime punishable by imprisonment for a term exceeding one year, in violation of 18 U.S.C. § 922(g)(1), and possession of an unregistered firearm. After the government rested, Gaines moved for a judgment of acquittal, arguing that his prior conviction did not meet the federal statute’s requirement. The district court denied the motion, and the jury convicted him on the § 922(g)(1) count but acquitted him on the other. Gaines was sentenced to 51 months in prison and three years of supervised release.The United States Court of Appeals for the Eleventh Circuit reviewed the case and held that § 922(g)(1) requires a defendant-specific inquiry: the statute applies only if the defendant was actually subject to a sentence of more than one year of imprisonment in a prison or jail. Because Alabama law precluded any prison time for Gaines’s offense, his conviction did not qualify. The Eleventh Circuit vacated Gaines’s conviction and remanded with instructions to grant his motion for judgment of acquittal. View "USA v. Gaines" on Justia Law

An inmate in Georgia, who practices veganism as part of his religious beliefs, was enrolled in a prison program that provided vegan meals to accommodate religious diets. He was removed from this program twice after prison officials discovered he had purchased non-vegan food items from the prison store, such as chicken soup and Cheetos. The inmate claimed he bought these items to sell to other prisoners and would have stopped if he had known it could result in removal from the program. At the time of his removals, the prison’s policy did not explicitly list non-vegan purchases as grounds for removal, though this was later added. The inmate also alleged that only Black inmates were removed from the program, while similarly situated white inmates were not.The United States District Court for the Middle District of Georgia granted summary judgment to the prison officials on the inmate’s claims under the First, Eighth, and Fourteenth Amendments, as well as most of his claims under the Religious Land Use and Institutionalized Persons Act (RLUIPA). The court found that the officials were entitled to qualified immunity on the First Amendment and due process claims, that there was no evidence of discriminatory intent or similarly situated comparators for the equal protection claim, and that the non-vegan meals provided were nutritionally adequate. The court also dismissed the remaining RLUIPA claim as moot after the inmate was reenrolled in the vegan meal program.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that the officials were entitled to qualified immunity, that there was insufficient evidence to support the equal protection and Eighth Amendment claims, and that the RLUIPA claims either failed on the merits or were moot because the inmate had been reinstated in the vegan meal program. View "Sumrall v. Georgia Department of Corrections" on Justia Law

A Florida minister and licensed clinical Christian psychologist, who had provided court-mandated batterers’ intervention program (BIP) services for decades, sought certification from the Florida Department of Children and Families (DCF) to continue offering these services to individuals ordered by courts to attend BIPs following domestic violence convictions. The DCF denied his application because his curriculum incorporated a faith-based approach and addressed issues such as substance abuse and anger management, which conflicted with state regulations prohibiting faith-based ideology and requiring a specific psychoeducational model. The provider had previously operated without proper certification and had been denied certification in the past for similar reasons.After the DCF’s 2022 denial, the provider filed suit in the United States District Court for the Northern District of Florida, alleging that the regulation violated his rights under the Free Speech and Free Exercise Clauses of the First Amendment. The District Court granted summary judgment in favor of DCF, holding that court-ordered BIPs constitute government speech, and thus the state could set their content without implicating the First Amendment.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the District Court’s decision de novo. The Eleventh Circuit affirmed, holding that the curriculum and presentation of court-ordered BIPs are government speech. The court found that the state has historically used BIPs to communicate its own message, that participants would reasonably associate the program’s content with the government, and that the state exercises substantial control over the content. Because the programs are government speech, the provider’s Free Speech and Free Exercise claims could not proceed. The court also rejected the facial challenge to the regulation and affirmed the District Court’s judgment. View "Nussbaumer v. Secretary, Florida Dept of Children and Families" on Justia Law

A manufacturer of fasteners and related parts entered into a long-term supply agreement with a home appliance company, which later spun off its outdoor products division into a separate entity. The agreement, intended to make the manufacturer the exclusive supplier for a broad range of parts, quickly became the subject of disputes over its scope and the parties’ obligations. The parties attempted to resolve their disagreements through a settlement memorandum and a consent order, but further conflicts arose regarding price increases, performance, and payment for inventory.The United States District Court for the Southern District of Georgia was first asked to interpret the scope of the parties’ agreements. It found the original contract too indefinite to enforce in its entirety but held that subsequent agreements and the parties’ course of performance clarified which parts were covered. The district court also sanctioned the manufacturer for discovery violations, specifically for failing to produce product-level cost data, and struck its lost profits claim. The court denied the manufacturer’s motion for sanctions against the defendants for alleged spoliation, finding the motion untimely and the missing evidence irrelevant. The court granted summary judgment to the defendants on the manufacturer’s price increase claim, finding insufficient evidence to support the requested increases, and denied the manufacturer’s motion to amend its complaint to add a claim for prejudgment interest due to undue delay.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed each of the manufacturer’s challenges. The court held that the district court properly interpreted the scope of the agreements, did not abuse its discretion in imposing or denying discovery sanctions, correctly granted summary judgment on the price increase claim, and appropriately excluded certain evidence at trial. The Eleventh Circuit affirmed all orders and the final judgment in favor of the defendants. View "Whitesell Corporation v. Husqvarna Outdoor Products, Inc." on Justia Law

A woman who had a long history of calling her local sheriff’s office—often to complain about gunfire she believed was coming from private property near her home—called both the non-emergency number and 911 on Thanksgiving Day 2018 to report gunshots. Dispatchers informed her that deputies had previously investigated and determined the gunfire was lawful and that no further response would be made. Despite these explanations, she persisted, escalating her complaint to a 911 call. She declined offers to speak with deputies and refused contact when a deputy came to her home. Based on her repeated calls and refusal to accept the dispatchers’ explanations, two sheriff’s office employees initiated an investigation and swore out an affidavit for her arrest under a Georgia statute prohibiting disruptive or harassing conduct during 911 calls. The local district attorney later dismissed the charge.The woman then filed a civil suit in the United States District Court for the Southern District of Georgia, alleging violations of her First and Fourth Amendment rights, including claims of retaliatory arrest and malicious prosecution. The district court denied qualified immunity to the two officers on the First Amendment retaliation and malicious prosecution claims, finding genuine disputes of material fact regarding probable cause and the officers’ conduct in seeking the arrest warrant.On appeal, the United States Court of Appeals for the Eleventh Circuit considered whether the officers were entitled to qualified immunity. The court held that the officers were entitled to rely on the collective knowledge of the sheriff’s office dispatchers, who were aware of the plaintiff’s history of similar calls and the lawful nature of the gunfire. The court concluded that, given this collective knowledge, the officers had at least arguable probable cause to seek the plaintiff’s arrest under the relevant Georgia statute. As a result, the Eleventh Circuit reversed the district court’s denial of qualified immunity. View "Prospero v. Sullivan" on Justia Law