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

Lauren Woods was injured in a car accident involving an underinsured motorist and sought benefits from her insurer, Progressive American Insurance Company, under her policy’s underinsured motorist provision. Progressive declined to pay the full policy limit. Woods then sued Progressive for breach of contract and statutory bad faith under Florida law, alleging that Progressive failed to settle her claim in good faith. After serving civil remedy notices, Woods’s case was removed to federal court based on diversity jurisdiction.The United States District Court for the Southern District of Florida first held a jury trial on Woods’s underinsured motorist claim, resulting in a verdict and final judgment in her favor that exceeded the policy limit. Woods then proceeded with her statutory bad faith claim before the same court. Prior to the bad faith trial, the parties stipulated to certain facts, including the existence and amount of the prior verdict and judgment. They also agreed that the magistrate judge would determine damages, and the jury would decide only liability. At the start of the bad faith trial, Woods limited her theory to Progressive’s conduct before the underinsured motorist trial, and the court excluded evidence and instructions regarding the prior verdict and excess judgment. The jury found for Progressive on the bad faith claim, and the court denied Woods’s motion for a new trial.On appeal, the United States Court of Appeals for the Eleventh Circuit held that the district court did not abuse its discretion in excluding the prior verdict and excess judgment from the bad faith trial. The court found that, given Woods’s stipulation limiting the scope of her claim and the parties’ agreement that damages would be determined by the judge, the excluded evidence was irrelevant to the jury’s determination of liability. The Eleventh Circuit affirmed the district court’s judgment in favor of Progressive. View "Woods v. Progressive American Insurance Company" on Justia Law

Several landowners in Walton County, Florida, owned beachfront properties that were affected by a county ordinance enacted during the early stages of the COVID-19 pandemic. In March and April 2020, the county first closed public beaches, then issued a new ordinance that closed all beaches—public and private—making it a criminal offense for anyone, including private owners, to access or use their own beachfront property. The ordinance was enforced by law enforcement officers who entered private property, excluded owners, and threatened arrest for violations. The ordinance remained in effect for about a month, after which it expired and was not renewed.The landowners filed suit in the United States District Court for the Northern District of Florida, raising several claims, including a Takings Clause claim under the Fifth Amendment, and seeking both damages and prospective relief. The district court dismissed the claims for prospective relief as moot, finding the ordinance had expired and was unlikely to recur. On the merits, the district court granted summary judgment to the county on all damages claims, holding that the ordinance was not a per se physical taking but rather a use restriction, and that the government’s actions during a public health emergency were entitled to deference.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It affirmed the dismissal of the claims for prospective relief, agreeing that the ordinance’s expiration rendered those claims moot. However, the court reversed the district court’s judgment on the Takings Clause claim, holding that the ordinance constituted a per se physical taking because it barred owners from their property and allowed government officials to physically occupy and control access. The court remanded for a determination of just compensation, holding that no public emergency, including COVID-19, creates an exception to the Takings Clause. View "Alford v. Walton County" on Justia Law

New South Media Group, LLC, along with other plaintiffs, sought to construct four types of signs—flags, artwork, political messages, and event notices—on private property in Rainbow City, Alabama. The city denied their permit applications, determining that the proposed signs were billboards, which are prohibited under Section 214 of the city’s sign ordinance. The plaintiffs believed their signs qualified for exemptions under Section 213, but the city’s definition of “billboard” encompassed their proposed signs. After receiving the denial, New South requested variances, which were also denied by the city’s zoning board.Following these denials, New South appealed in state court and brought federal and state constitutional challenges, which were dismissed in state court and then refiled in federal court. In the United States District Court for the Northern District of Alabama, New South alleged that several city sign regulations violated the First Amendment and the Alabama Constitution by imposing content-based restrictions, lacking time limits for permit decisions, and granting unbridled discretion to city officials. The district court granted summary judgment to Rainbow City, finding that New South lacked standing because the injury—the denial of the applications—was caused by the unchallenged billboard prohibition, not the provisions New South contested.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s decision de novo. The Eleventh Circuit held that New South lacked standing to challenge the constitutionality of the non-billboard regulations because the injury was not traceable to those provisions and a favorable decision would not redress the harm caused by the billboard prohibition. The court affirmed the district court’s order granting summary judgment to Rainbow City and dismissing the case without prejudice for lack of jurisdiction. View "New South Media Group, LLC v. City of Rainbow City" on Justia Law

Three men were prosecuted for their roles in the fatal shooting of Ahmaud Arbery, a Black man, in the Satilla Shores neighborhood of Glynn County, Georgia. On February 23, 2020, Arbery was running through the neighborhood and stopped at a house under construction, which he had visited before. Gregory and Travis McMichael, who lived nearby, saw Arbery and, suspecting him of recent burglaries, armed themselves and pursued him in a truck. William Bryan, a neighbor, joined the chase in his own vehicle. The men used their trucks to block and pursue Arbery through public streets, ultimately leading to a confrontation in which Travis McMichael shot and killed Arbery.After being convicted of murder and other charges in Georgia state court and sentenced to life imprisonment, the defendants were tried in the United States District Court for the Southern District of Georgia. There, they were convicted of interference with rights under 18 U.S.C. § 245(b)(2)(B), attempted kidnapping under 18 U.S.C. § 1201(a)(1), and, for the McMichaels, firearm offenses under 18 U.S.C. § 924(c)(1)(A)(iii). The district court denied their motions for acquittal, finding sufficient evidence that the defendants acted because of Arbery’s race and his use of public streets, that the streets were provided or administered by the county, and that the attempted kidnapping was for a benefit and involved an instrumentality of interstate commerce.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the sufficiency of the evidence de novo. The court held that substantial evidence supported the jury’s findings on all challenged elements, including racial motivation, use of public facilities, and use of an automobile as an instrumentality of interstate commerce. The Eleventh Circuit affirmed all convictions. View "USA v. Bryan" on Justia Law

Elisabeth Koletas, who was four months pregnant, requested a pat-down instead of passing through a body scanner at Southwest Florida International Airport due to concerns about radiation. During the pat-down, Transportation Security Officer (TSO) Sarno conducted a prolonged probe of Koletas’s vaginal area, focusing on material in her underwear. Koletas explained it was toilet paper used to stem pregnancy-related bleeding. Sarno, skeptical, moved Koletas to a private room and brought in Supervising TSO Shane, who further probed Koletas’s underwear and vaginal area. Shane directed Koletas to lift her dress and ultimately removed the toilet paper, finding no prohibited items. Koletas experienced psychological and physical distress from the encounter.After exhausting administrative remedies, Koletas filed suit against the United States in the United States District Court for the Middle District of Florida under the Federal Tort Claims Act (FTCA), alleging battery, false imprisonment, intentional infliction of emotional distress, and negligence. The United States moved to dismiss, arguing that the FTCA’s intentional tort exception preserved sovereign immunity for the alleged battery and false imprisonment. The district court agreed, relying solely on an unpublished Eleventh Circuit decision, and dismissed the case for lack of subject-matter jurisdiction.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the dismissal de novo. The court held that TSOs are “officers of the United States” empowered by law to execute searches under the FTCA’s law enforcement proviso, which waives sovereign immunity for certain intentional torts committed by such officers. The court found the statutory language unambiguous and joined five other circuits in this interpretation. The Eleventh Circuit reversed the district court’s dismissal and remanded the case for further proceedings on the merits. View "Koletas v. USA" on Justia Law

A mass shooting occurred at a Florida high school in 2018, resulting in numerous deaths and injuries. The Sheriff’s Office, which employed a school resource officer at the school, faced 60 lawsuits from victims alleging negligence in failing to secure the premises. The Sheriff’s Office held an excess liability insurance policy with Evanston Insurance Company, which required the Sheriff to pay a $500,000 self-insured retention (SIR) per “occurrence” and a $500,000 annual aggregate deductible before coverage would be triggered. The central dispute was whether the shooting constituted a single “occurrence” under the policy, or multiple occurrences—one for each victim or gunshot.The United States District Court for the Southern District of Florida reviewed the case after the Sheriff filed a declaratory judgment action. The district court denied Evanston’s motion to dismiss, finding that the policy’s definition of “occurrence” was ambiguous under Florida law, and that ambiguity should be construed in favor of the insured. The court determined that the Parkland shooting was a single occurrence, meaning only one SIR applied. The court also found that the Sheriff had satisfied both the SIR and the deductible through legal expenses and other covered claims, and awarded attorney’s fees and costs to the Sheriff.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s rulings. The Eleventh Circuit held that a justiciable controversy existed, as the Sheriff had demonstrated a substantial likelihood of future injury and had satisfied the policy’s prerequisites for coverage. The court further held that, under controlling Florida law, the term “occurrence” was ambiguous and must be construed in favor of the insured, resulting in the Parkland shooting being treated as a single occurrence. The court also upheld the award of attorney’s fees and costs to the Sheriff. View "Sheriff of Broward County v. Evanston Insurance Company" on Justia Law

A married couple, Carlos Del Amo and his wife, opened a joint checking account at TD Bank in Florida. The account’s signature card listed both their names and, in small print, stated that “joint accounts are owned as joint tenants with right of survivorship.” When Mr. Del Amo filed for Chapter 7 bankruptcy, he claimed the account as exempt property, arguing it was owned as a tenancy by the entirety—a form of ownership that protects the account from creditors of only one spouse under Florida law. Storey Mountain, a creditor, objected, contending that the account was not exempt because the signature card’s language created a joint tenancy with right of survivorship, not a tenancy by the entirety.The United States Bankruptcy Court for the Southern District of Florida found the statutory language unclear as to what constitutes “otherwise specified in writing” under Florida Statutes § 655.79(1). Relying on the Florida Supreme Court’s decision in Beal Bank, SSB v. Almand and Associates, the bankruptcy court held that, absent an express disclaimer of tenancy by the entirety on the signature card, the account was presumed to be held as a tenancy by the entirety. The court overruled Storey Mountain’s objection. The United States District Court for the Southern District of Florida affirmed, agreeing that the 2008 amendment to § 655.79(1) did not abrogate Beal Bank’s requirement for an express disclaimer.On further appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the lower courts. The Eleventh Circuit held that, under Florida law, a joint bank account held by a married couple is presumed to be a tenancy by the entirety unless there is an explicit written disclaimer of that form of ownership. The court found that the language on the signature card was insufficient to constitute such a disclaimer, and thus the account was exempt property in the bankruptcy proceedings. View "Storey Mountain v. Del Amo" on Justia Law

A Saudi military officer, Mohammed Saeed Al-Shamrani, who was a member of the Royal Saudi Air Force, carried out a mass shooting at the Pensacola Naval Air Station in Florida in December 2019, resulting in the deaths of three U.S. servicemembers and injuries to several others. The officer had a documented history of expressing extremist and anti-American views on social media prior to his arrival in the United States for flight training, which was part of a broader U.S.-Saudi military training program. The victims and their families brought suit against the Kingdom of Saudi Arabia, alleging various tort and contract claims, including gross negligence in vetting and sending Al-Shamrani to the U.S., failure to supervise, vicarious liability for his actions, support for terrorism, and breach of contract.The United States District Court for the Northern District of Florida dismissed all claims, finding that the plaintiffs’ allegations were facially insufficient to overcome Saudi Arabia’s sovereign immunity under the Foreign Sovereign Immunities Act (FSIA) and the Justice Against Sponsors of Terrorism Act (JASTA). The district court also denied the plaintiffs’ request for jurisdictional discovery, concluding that the complaint did not plausibly allege facts that would support an exception to sovereign immunity.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed in part, reversed in part, and remanded. The court held that most claims were properly dismissed for lack of subject matter jurisdiction, as they either involved discretionary functions, acts of omission, or failed to establish proximate cause or a waiver of immunity. However, the court found that the plaintiffs’ claims based on grossly negligent acts of commission by Saudi Arabia in vetting, hiring, and sending Al-Shamrani to the United States were facially sufficient under JASTA to survive a jurisdictional challenge. The case was remanded for further proceedings on these claims. View "Watson v. Kingdom of Saudi Arabia" on Justia Law

The case concerns a defendant who pleaded guilty to being a felon in possession of a firearm and ammunition after he and others entered a victim’s home, threatened him with a firearm, and stole his truck. When apprehended, law enforcement found ammunition on his person and a firearm in the stolen vehicle. The defendant had three prior Florida state convictions for delivery of cocaine, each involving small amounts sold to a confidential informant in early 2017.The United States District Court for the Middle District of Florida sentenced the defendant to 180 months in prison, applying the Armed Career Criminal Act (ACCA) enhancement. The court determined that his three Florida convictions for delivery of cocaine qualified as “serious drug offenses” under ACCA, using the version of Florida law in effect at the time of his convictions in August 2017, which excluded ioflupane from the definition of cocaine, thus matching federal law.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed whether the ACCA enhancement was properly applied. The appellate court held that, under Supreme Court precedent, the relevant comparison for the categorical approach is between the state law in effect at the time the defendant committed the state offenses and the federal drug schedules in effect at that time. In early 2017, Florida law defined cocaine to include ioflupane, while federal law did not, making Florida’s definition broader than the federal definition. Because Florida’s saving provision prevented the later narrowing of the law from applying retroactively, the mismatch remained. The Eleventh Circuit concluded that the defendant’s Florida convictions did not qualify as ACCA predicates, vacated the sentence, and remanded for resentencing without the ACCA enhancement. View "USA v. Miller" on Justia Law

The case concerns a defendant who was charged with four federal sex-trafficking offenses involving two victims, one an adult and the other a minor. The defendant, who identified himself as a pimp, transported both victims from Atlanta to Miami in advance of the 2020 Super Bowl, intending for them to perform sex work. The adult victim testified that she was threatened and coerced into working for the defendant, while the minor victim, who was seventeen, did not testify at trial. Evidence included social media posts, communications between the defendant and the victims, and testimony about the defendant’s control over the victims. The minor victim was apprehended during a police sting operation in Miami, and her statements to police were admitted at trial despite her absence as a witness.The United States District Court for the Southern District of Florida presided over the trial. The jury convicted the defendant on all four counts: sex trafficking of the adult victim by force and coercion, transporting the adult victim to engage in sexual activity, sex trafficking of the minor victim, and transporting the minor victim to engage in sexual activity. The defendant was sentenced to 300 months in prison and ten years of supervised release. He appealed, arguing that the admission of the minor victim’s statements violated the Confrontation Clause and hearsay rules, that the jury instructions for two counts constructively amended the indictment, and that the evidence was insufficient for two counts.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that the minor victim’s statements were nontestimonial and thus did not violate the Confrontation Clause, and that any hearsay error was harmless. The court found that while the jury instructions for two counts constructively amended the indictment, these errors did not amount to plain error. The court also concluded that sufficient evidence supported all convictions. The Eleventh Circuit affirmed the convictions. View "USA v. Carter" on Justia Law