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

Plaintiff brought a three-count maritime negligence action against Royal Caribbean Cruises, Ltd. (“Royal Caribbean”) after she fell aboard one of its cruise ships. She alleged that during the ship’s muster drill, a Royal Caribbean employee rushed her down a set of stairs—causing her to fall and severely injure her neck. The district court granted summary judgment in favor of Royal Caribbean. First, on Count I (general negligence) and Count II (negligent failure to warn), the district court found that Plaintiff failed to show that Royal Caribbean had notice of the dangerous conditions that allegedly caused her fall. Second, on Count III (general negligence against Royal Caribbean for its employee’s conduct under a theory of vicarious liability), the district court determined that Plaintiff put forth insufficient evidence of medical causation.   The Eleventh Circuit affirmed. The court explained that looking to Florida negligence law: non-readily observable injuries require expert medical evidence to prove causation. The court concluded that Plaintiff failed to adduce sufficient medical evidence to satisfy proximate cause. And because proximate cause must be satisfied for each of Plaintiff’s three negligence-based claims to prevail, the court affirmed the district court’s grant of summary judgment to Royal Caribbean. View "Judith Willis v. Royal Caribbean Cruises, LTD." on Justia Law

Two companies filed a lawsuit in federal court against two of their former employees, who had served in executive positions. The former executives responded by suing the companies in Florida state court. They later moved for summary judgment in the federal action. While that motion was pending, the companies moved for a voluntary dismissal without prejudice of their federal action, which the executives opposed. The district court granted the companies’ motion for voluntary dismissal, and it denied the executives’ request for attorney’s fees and costs incurred in defending the federal lawsuit to that point. On remand, the district court again granted the voluntary dismissal. The executives moved to alter or amend that judgment and be awarded fees and costs immediately, which the court denied. The executives appealed.   The Eleventh Circuit affirmed. The court explained that the district court sufficiently protected the executives from the prejudice of duplicative litigation by essentially inviting them to move for payment of their costs and fees if the companies ever refiled their federal lawsuit. The court adequately explained its reasoning for granting the dismissal without prejudice on that condition. In all aspects of the decision, the court acted within its discretion. View "Emergency Recovery, Inc., et al v. Bryan Hufnagle, et al" on Justia Law

Defendant was charged with one count of being a felon in possession of a firearm. He had a two-day trial at which he testified, asserting a justification defense. The jury rejected that defense, finding him guilty. The district court denied his motion for a judgment of acquittal or a new trial. After calculating a guidelines range of 100 to 120 months, the court sentenced him to 80 months imprisonment. He challenged his conviction and his sentence.   The Eleventh Circuit affirmed. The court explained that the district court did not clearly err in finding that Defendant had not established self-defense as a justification for shooting the victim. The court explained that the evidence showed that Defendant escalated the situation and interposed himself when his girlfriend was attempting to handle it. He claimed his actions were justified because he had to defend himself, but it was Defendant who had insisted that his girlfriend get her gun when she did not want to; she wanted to see who was outside and resolve the situation herself. The court reasoned that Defendant also could have called 911 and asked that law enforcement officers be sent to the house. It wasn’t clear error for the district court to find that Defendant, a convicted felon, had possessed a firearm in connection with another felony offense. View "USA v. Hannibal Moore" on Justia Law

In January 2021, many customers of the online financial services company Robinhood were aggressively buying specific stocks known as “meme stocks” in a frenzy that generated widespread attention. Robinhood suddenly restricted its customers’ ability to buy these meme stocks (but not their ability to sell them). Some Robinhood customers who could not buy the restricted stocks brought this putative class action, seeking to represent both Robinhood customers and all other holders of the restricted meme stocks nationwide who sold the stocks during a certain period. As Robinhood customers, they allege that they lost money because Robinhood stopped them from acquiring an asset that would have continued to increase in value.   The Eleventh Circuit affirmed the district court’s dismissal of the claims. The court explained that Plaintiffs failed to state a claim. The court explained that its contract with Robinhood gives the company the specific right to restrict its customers’ ability to trade securities and to refuse to accept any of their transactions. Thus, the court wrote that because Robinhood had the right to do exactly what it did, Plaintiffs’ claims in agency and contract cannot stand. And under basic principles of tort law, Robinhood had no tort duty to avoid causing purely economic loss. View "Andrea Juncadella, et al v. Robinhood Financial LLC, et al" on Justia Law

The Eleventh Circuit reversed the district court’s judgment dismissing Plaintiff’s claims against Polk County and two employees who worked at the jail, alleging that the Jail and its employees interfered with his right to communicate freely and confidentially with his attorneys by forcing him to scan his legal mail into a computer with a memory chip.  When Plaintiff was a pretrial detainee at that Jail, the Jail required him to scan his legal mail into a computer that contained a memory chip. Though Plaintiff does not know whether anyone other than he read his mail, he worried that the Jail could and may have since it had access to the computer into which he had scanned his mail. Plaintiff sued Polk County and two employees who worked at the Jail. He alleged, among other things, that the Jail and its employees interfered with his right to communicate freely and confidentially with his attorneys by forcing him to scan his legal mail into a computer with a memory chip.   The Eleventh Circuit reversed and remanded. The court held that Plaintiff alleged sufficient facts to allow for the reasonable inference that the Jail’s mail-scanning policy infringed on his free-speech rights. However, the court affirmed the district court’s dismissal of Plaintiff’s claim under the Due Process Clause. The court explained that because Plaintiff was a pretrial detainee and because his claim involves the deprivation of a “basic necessity” like access to recreational activity, he must satisfy the Eighth Amendment’s objective and subjective standards to prevail on his claim under the Fourteenth Amendment’s Due Process Clause. And that’s where his problem arises, as he argues only that the conditions of his confinement were objectively unreasonable. View "Rickey Christmas v. Lieutenant J. Nabors, et al." on Justia Law

Defendant filed an Application for Naturalization (Form N-400), on which she certified under penalty of perjury that she had never “committed a crime or offense for which she was NOT arrested.” Defendant was charged in 2012 with healthcare fraud and conspiracy crimes. In 2012, Lopez pleaded guilty to conspiracy to commit money laundering. In 2021, the United States filed a complaint in the district court to revoke Defendant’s naturalization. The complaint alleged   had illegally procured her naturalization on the ground that she had failed to meet the requirement of “good moral character.” The government moved for judgment on the pleadings on the ground that Defendant had illegally procured her naturalization because she had committed a crime of moral turpitude during the statutory period. The district court granted that motion. It concluded that the conspiracy crime to which Defendant pleaded guilty overlapped with the statutory “good moral character.”   The Eleventh Circuit reversed and remanded. The court explained that structuring a transaction to avoid a reporting requirement, as defined by 18 U.S.C. section 1956(a)(1)(B)(ii), is also not a crime categorically involving moral turpitude. The offense does not necessarily involve fraud. And, although the crime arguably involves deceit, it does not necessarily involve an activity that is “inherently base, vile, or depraved.” Thus, the court held that a violation of section 1956(a)(1)(B) is not categorically a crime of moral turpitude. View "USA v. Lisette Lopez" on Justia Law

Over 20 years ago, a group of Florida wine consumers and an out-of-state winery (collectively, the “Plaintiffs”) sued the Director of the Florida Division of Alcoholic Beverages and Tobacco, alleging that certain provisions of Florida’s beverage laws unconstitutionally discriminated against out-of-state wineries. After the United States Supreme Court ruled a virtually identical statutory scheme unconstitutional, the Division agreed to the entry of a judgment declaring Florida’s direct shipment laws unconstitutional as applied to out-of-state “wineries.” The Division also agreed to an injunction prohibiting it from enforcing its direct shipment laws “against out-of-state vendors and producers.” Significantly, these last five words were absent from the parties’ proposed injunction and were added sua sponte by the district court. No one objected to the court’s addition of this language. However, 16 years later, the Division filed a motion in district court to “clarify and modify” the injunction. Specifically, the Division asked the district court to confirm that the injunction applied only to out-of-state wineries rather than out-of-state wine retailers generally. The district court denied the Division’s motion.   The Eleventh Circuit affirmed. The court explained that here, the district court expressly determined that the injunction the court entered “accurately reflects the intent of the parties and the Court.” Rule 60(a) does not allow a district court to rewrite its decision any time a party later contends that the language is ambiguous. Thus, the court held that the district court did not err by construing the Division’s motion as made under Rule 60(b)(1) instead of Rule 60(a). View "Jerry Bainbridge, et al. v. Director of the Florida Division of Alcoholic Beverages and Tobacco" on Justia Law

Plaintiff sued the United States under the Federal Tort Claims Act, seeking to recover damages he allegedly suffered in an accident with a U.S. Postal Service truck. To meet his burden to show that the crash caused his injuries, Plaintiff planned to rely on expert testimony from several doctors who treated him after the crash. the district court granted the government’s motion for summary judgment. Both the “Court’s orders and Florida law are clear,” it said, that “to prove causation, prognosis, and/or future implications of the injury, the Plaintiff must satisfy Rule 26(a)(2)(B)’s requirements.” The district court held that none of Plaintiff’s filings satisfied those requirements and conducted no analysis on whether they satisfied Rule 26(a)(2)(C).   The Eleventh Circuit vacated the district court’s grant of summary judgment for the government. The court remanded this case to the district court for further proceedings. On remand, the court wrote that the district court should address whether Plaintiff’s disclosures complied with Rule 26(a)(2)(C), or it should issue a new scheduling order invoking its discretionary authority to adjust the default requirements of Rule 26(a)(2). The court affirmed the denial of Plaintiff’s motion for summary judgment. The court explained that no rule requires any non-retained expert witness to file a written report under Rule 26(a)(2)(B). And whether a doctor is retained (or not) depends on whether she was hired to testify or to treat. But district courts retain the discretionary power to tailor disclosure requirements. The court wrote that here, the district court misunderstood that its power to require detailed submissions from Plaintiff’s witnesses was discretionary. View "Cajule Cedant v. USA" on Justia Law

Barges around Pensacola Bay were slammed around during Hurricane Sally, leading to significant damage—including to the Pensacola Bay Bridge, which was closed for months. Skanska, the construction company that owned the barges (and was working on replacing the Bay Bridge) faced hundreds of potential lawsuits. Some were directly related to property damage, but most were economic loss claims from nearby businesses that lost customers during the months-long closure of the bridge. Skanska filed what are called petitions for limitation of liability, one for each of its 28 barges. These petitions invoked the Limitation Act. the district court decided that Skanska could not limit its liability because its own corporate officials were responsible for the negligent acts that led to the barges getting loose in the storm. It dismissed the Limitation Act petitions—freeing the claimants to pursue litigation in state court. Skanska says the district court acted too fast and also disputed several of the district court’s other decisions.   The Eleventh Circuit affirmed. The court explained that Limitation Act allows a federal court to take over all negligence claims to preserve the vessel owner’s right to limit its liability and then proportionally distribute the available assets to the successful claimants. But only to the extent necessary to protect the right to limitation; it does not create an independent right to have the full merits of each individual claim decided in federal court when no limitation is available. Further, the court concluded that it saw no reversible error in the district court’s evidentiary rulings, its findings of fact, or its spoliation sanctions. View "Skanska USA Civil Southeast, Inc. and Skanska USA v. Bagelheads, Inc., et al." on Justia Law

Defendant appeals his sentence for possession with intent to distribute 100 grams or more of heroin and 50 grams or more of methamphetamine. There are four issues on appeal: whether (1) the district court erred in imposing a two-level enhancement for maintaining a premises for the purpose of manufacturing or distributing a controlled substance, under Section 2D1.1(b)(12) of the Sentencing Guidelines, (2) Defendant’s sentence is procedurally and substantively unreasonable, (3) technical malfunctions during Defendant’s sentencing hearing conducted remotely via videoconference violated his Sixth Amendment right to counsel at a critical stage of criminal proceedings, and (4) the district court erred by imposing conditions of supervised release in the written judgment that were not orally pronounced at the sentencing hearing.   The Eleventh Circuit affirmed Defendant’s sentence in part, vacated in part, and remanded for limited resentencing as to the conditions of supervised release. The court held that the district court properly applied the enhancement for maintaining a premises for the purpose of manufacturing or distributing a controlled substance. Further, the court held that the district court did not impose a sentence that was procedurally or substantively unreasonable. Moreover, the court held that Defendant is not entitled to resentencing because of the videoconference malfunctions. Finally, the district court erred by imposing conditions of supervised release not included in Defendant’s oral sentence. The court explained that the district court’s pronouncement here failed to reference the administrative order or otherwise indicate that the court was adopting conditions of supervised release beyond those mandated by statute. View "USA v. Jesus Rodriguez" on Justia Law