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

Plaintiff, through his estate, sued Ford Motor Company, inter alia, for wrongful death and product liability pursuant to the Alabama Extended Manufacturer’s Liability Doctrine (AEMLD). He alleged that a faulty seatbelt design in his 2003 Ford Mustang caused his fatal injury. At trial, the jury returned a verdict in favor of Ford. Plaintiff now appealed, arguing that the district court erroneously ruled on several evidentiary issues, a motion for judgment as a matter of law (JMOL), and a motion for a new trial. Ford filed a cross-appeal in anticipation of a possible reversal, challenging the district court’s denial of its motion to exclude expert testimony at trial.   The Eleventh Circuit affirmed the rulings challenged by Plaintiff. As for Ford’s cross-appeal,  the court dismissed for lack of standing. Here, the working seatbelt from the crash was admitted into evidence alongside expert testimony opining that the driver likely caused the excess webbing. A reasonable jury could have weighed this evidence against the evidence introduced by Plaintiff and “might reach different conclusions” about whether Plaintiff was contributorily negligent. Id. Therefore, JMOL is not proper, and the court affirmed the district court’s denial of Plaintiff’s motion. Further, the court explained that although Ford has identified cases where the court has addressed a victorious Plaintiff’s cross-appeal, the court is not bound by a prior decision’s sub silentio treatment of a jurisdictional question. View "Mark Henderson v. Ford Motor Company" on Justia Law

Petitioner, a native and citizen of Peru, appeals the Board of Immigration Appeals’ determination that she is ineligible for relief under 8 U.S.C. Section 1229b(b)(2), a provision whose language was originally adopted as part of the Violence Against Women Act of 1994 and that outlines the conditions under which certain “battered spouses or children” qualify for discretionary cancellation of removal. As relevant here, it requires a petitioning alien to show that she “has been battered or subjected to extreme cruelty” by her spouse or parent. Petitioner contends that the Immigration Judge and the BIA made two errors in refusing her cancellation request. First, she maintains that, as a matter of law, they misinterpreted the statutory term “extreme cruelty” to require proof of physical—as distinguished from mental or emotional—abuse. And second, she asserts that having misread the law, the IJ and the BIA wrongly concluded that she doesn’t qualify for discretionary relief.   The Eleventh Circuit granted her petition for review and remanded it to the BIA for further consideration. The court explained that it agreed with Petitioner—and held— that the BIA misinterpreted 8 U.S.C. Section 1229b(b)(2). The term “extreme cruelty” does not require a petitioning alien to prove that she suffered physical abuse in order to qualify for discretionary cancellation of removal; proof of mental or emotional abuse is sufficient to satisfy the “extreme cruelty” prong of Section 1229b(b)(2)’s five-prong standard. View "Esmelda Ruiz v. U.S. Attorney General" on Justia Law

This appeal arose out of an insurance dispute between Plaintiff and Safeco Insurance Company of Illinois. After an accident in which her vehicle suffered substantial damage, Plaintiff made a claim under her Safeco-issued insurance policy for the damage. Safeco declared her vehicle a total loss and paid her what it deemed to be the actual cash value of her vehicle. The district court granted summary judgment to Safeco.   The Eleventh Circuit affirmed. The court explained that as proof that a policyholder is reasonably likely to need to incur dealer fees, Plaintiff pointed to the facts that (1) she incurred dealer fees in purchasing both the Lexus that was totaled and her Subaru replacement vehicle, (2) approximately 50-70% of Safeco policyholders are likely to purchase a vehicle from a dealer, and (3) approximately 85-95% of dealerships charge dealer fees. These facts, viewed in the light most favorable to Plaintiff, do not give rise to a genuine dispute of material fact. Plaintiff’s three data points show a reasonable likelihood that a policyholder will incur dealer fees if she chooses to purchase her replacement vehicle from a dealer. And they show that a policyholder is reasonably likely to purchase a replacement vehicle from a dealer. But they do not show that a policyholder is reasonably likely to need to purchase a replacement vehicle from a dealer. Plaintiff has failed as a matter of law to satisfy the Mills standard; therefore, the district court correctly awarded Safeco summary judgment on this issue. View "Gina Signor v. Safeco Insurance Company of Illinois" on Justia Law

In 2008, Debtors Mosaic Management Group, Inc., Mosaic Alternative Assets, Ltd., and Paladin Settlements, Inc. filed for Chapter 11 bankruptcy in the Southern District of Florida, a “UST district” in which the U.S. Trustee program operates. In June 2017, the bankruptcy court confirmed a joint Chapter 11 plan, under which most of the Debtors’ assets were transferred to an Investment Trust managed by an Investment Trustee. The issue before the court is the appropriate remedy for the constitutional violation the Supreme Court found in Siegel. The Debtors in this case—being debtors in a U.S. Trustee district—have been required to pay higher fees than a comparable debtor in one of the six BA districts in Alabama or North Carolina.   The Eleventh Circuit vacated and remanded. The court concluded that Reich, Newsweek, Bennett, McKesson, and the long line of similar state tax cases are closely analogous to the instant case and provide strong precedent supporting the refund remedy urged upon us by the Debtors. Accordingly, the court held that the appropriate remedy in this case for the constitutional violation identified in Siegel is the refunds that the Debtors in this case seek. View "United States Trustee Region 21 v. Bast Amron LLP" on Justia Law

The case arose following an insurance dispute between Travelers Property Casualty Company of America (“Travelers”) and Ocean Reef Charters LLC (“Ocean Reef”), a Florida Limited Liability Company. On cross-motions for summary judgment, the district court granted summary judgment for Travelers, agreeing with it that federal law applied and that Ocean Reef, therefore, forfeited its insurance coverage. On appeal, the Eleventh Circuit reversed, holding that under Wilburn Boat Co. v. Fireman’s Fund Insurance Co., Florida law applied. At issue is whether, under Florida’s anti-technical statute, the insurance company must prove that the breach of the Captain Warranty “contribute[d] to” the specific accident. Further, in meeting its burden of proof under Florida law, Travelers needed to introduce expert testimony in its case-in-chief about what would have been different if Ocean Reef had complied with the applicable warranties.   The Eleventh Circuit affirmed on remand. The court held Travelers offered no expert witness— such as a licensed captain competent to speak to the issue—to prove that the lack of a full-time captain and crew played a role in the destruction of the yacht during Irma. The court explained that the Captain—whom Travelers did not disclose as an expert witness—could not provide his opinion on what would have happened to the My Lady if a licensed, professional captain were employed full-time. He could discuss the weather forecasts he observed. But those facts would leave the jury to speculate about what a captain would have done differently to avoid the storm under the specific circumstances of this case. View "Travelers Property Casualty Company of America v. Ocean Reef Charters LLC" on Justia Law

Plaintiff is serving a life sentence in Georgia and is in the custody of the GDC. As an inmate, his communications with those on the outside are governed by GDC policies and regulations. In 2018, Plaintiff filed a pro se civil rights suit pursuant to 42 U.S.C. Section 1983. His complaint named the GDC Commissioner, and Ms. Patterson and Ms. Edgar—the GDC analysts who had intercepted his emails in September and October of 2017—as defendants. It did not name Ms. Keen—the GDC analyst who intercepted the email to the Aleph Institute in February of 2018—as a defendant. The district court granted summary judgment in favor of Defendants. Plaintiff appealed.   The Eleventh Circuit, on Plaintiff’s due process claims, affirmed in part and reversed in part. The court explained that Plaintiff had a First Amendment liberty interest in his outgoing emails. As a result, he was entitled to procedural safeguards when his emails in September and October of 2017 were intercepted. Although Ms. Patterson and Ms. Edgar are entitled to qualified immunity on Plaintiff’s requests for damages on the due process claims, those claims must be tried by a jury. The requests for declaratory relief on the due process claims are not barred by qualified or sovereign immunity, and a reasonable jury could find that Defendants violated Plaintiff’s due process rights. With respect to Plaintiff’s First Amendment claims relating to the forwarding and inmate information policies, the court affirmed. View "Ralph Harrison Benning v. Commissioner, Georgia Department of Corrections, et al" on Justia Law

In the winter of 2020, the Secretary of Health and Human Services (HHS) determined that the threat posed by the novel SARS-CoV-2 virus constituted a public health emergency. The CDC published the rule at issue—the Requirement for Persons to Wear Masks While on Conveyances and at Transportation Hubs, 86 Fed. Reg. 8025-01 (Feb. 3, 2021) (“Mandate”). Plaintiffs initiated this litigation, arguing that the Mandate was unlawful under the Administrative Procedure Act, 5 USC Section 706(2) (APA), and unconstitutional under non-delegation and separation-of-powers tenets.   The Eleventh Circuit vacated the district court’s judgment and instructed the district court to dismiss the case as moot. The court explained that it found Plaintiffs’ contention that there is a reasonable expectation that the CDC will issue another nationwide mask mandate for all conveyances and transportation hubs to be speculative. Conjectures of future harms like these do not establish a reasonable expectation that a mask mandate from the CDC will reissue. Further, the court reasoned that there is no “reasonable expectation or a demonstrated probability that the same controversy will recur involving the same complaining party.” View "Health Freedom Defense Fund, et al v. President of the United States, et al" on Justia Law

A jury determined that the Broward County Sheriff’s Office discriminated and retaliated against helicopter pilot (Plaintiff) in violation of the Uniformed Services Employment and Reemployment Rights Act and awarded Plaintiff $240,000 in lost wages. The verdict form also asked whether the sheriff’s office “willfully violated the law,” and the jury answered, “Yes.” Based on a statutory provision that awards double damages for willful violations, Plaintiff moved to alter the judgment. But the district judge decided that the jury finding on willfulness was “advisory” and denied Plaintiff’s motion. The district judge also denied the sheriff’s office’s motion for judgment as a matter of law or a new trial.   The Eleventh Circuit affirmed the denial of the sheriff’s office’s motion for judgment as a matter of law or a new trial and reversed the denial of Plaintiff’s motion for an altered judgment. The court held that there was sufficient evidence supporting the verdict against the sheriff’s office. But the court reversed the denial of Plaintiff’s motion to alter the judgment because the parties consented to have the jury decide the issue of willfulness. View "Scott Thomas v. Broward County Sheriff's Office" on Justia Law

NuVasive, Inc. manufactures medical products and equipment to treat spinal diseases. In central Florida, NuVasive sold its products through an exclusive distribution agreement with Absolute Medical, LLC. Under the agreement, Absolute Medical employed independent-contractor sales representatives who marketed and sold NuVasive’s products to doctors and medical practices in the region. NuVasive sued Absolute Medical, Soufleris, AMS, and two of Absolute Medical’s sales representatives who began working for AMS for breaching the exclusive. The district court enforced a dispute resolution clause in the agreement, ordering NuVasive and Absolute Medical to arbitrate NuVasive’s breach-of-contract claim seeking money damages. Absolute Medical, Soufleris, AMS, and the sales representatives appealed the district court’s order granting NuVasive’s motion to vacate the arbitration panel’s final award.   The Eleventh Circuit affirmed. The court held that the district court did not err by equitably tolling the three-month filing deadline and considering NuVasive’s motion as timely. The court explained that the district court’s findings of fact were not clearly erroneous, and they supported the district court’s conclusion that NuVasive satisfied both prongs of the equitable tolling analysis. Defendants’ conduct presented extraordinary circumstances, and NuVasive was diligent once it learned that there was reason to pursue vacatur. Further, the court held that the district court did not err by vacating the final award. The district court correctly concluded that the fraud was materially related to that issue. Finally, the court held that the district court did not abuse its discretion by declining to direct a rehearing by the arbitration panel. View "Nuvasive, Inc. v. Absolute Medical, LLC, et al." on Justia Law

Pursuant to a plea agreement, Defendant pled guilty in 2005 to possessing 50 grams or more of cocaine base (i.e., crack cocaine) with intent to distribute, in violation of 21 U.S.C. Sections 841(a)(1) and (b)(1)(A)(iii). The district court sentenced him to 240 months in prison and 120 months of supervised release. In 2014, the district court reduced Defendant’s term of imprisonment to 151 months pursuant to the government’s substantial assistance motion. In 2015, the district court reduced Defendant’s term of imprisonment to 76 months under 18 U.S.C. Section 3582(c)(2). In April 2019, Defendant, proceeding pro se, sought to modify his 57-month sentence under Section 404(b) of the First Step Act. He argued that his original narcotics conviction was now classified as a Class B felony instead of a Class A felony, and as a result, his maximum prison term for a violation of supervised release was three years rather than five. The government opposed a reduction under the First Step Act.   The Eleventh Circuit affirmed. The court explained that the district court here did not abuse its discretion in denying Defendant’s requested sentence reduction because it provided a brief statement of reasons that was clear and supported by the record (explaining that Defendant’s conduct while he was in prison and while on supervision, which involved drug offenses and numerous incidences of insubordination, demonstrated an unwillingness or an inability to abide by the law). As a result, the district court’s explanation of its refusal to reduce Defendant’s sentence due to his “continued lawless behavior” did not violate Concepcion. View "USA v. Antonio Soul Gonzalez" on Justia Law