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

A patient with a long history of severe depression and multiple suicide attempts underwent 95 electroconvulsive therapy (ECT) treatments at a Nebraska hospital between 2014 and 2016. The ECT was administered using a device manufactured by Somatics, LLC. After the treatments, the patient experienced significant memory loss and was diagnosed with a neurocognitive disorder. In 2020, he filed suit against Somatics in the United States District Court for the Middle District of Florida, alleging negligence, strict product liability, breach of warranties, violation of Nebraska’s Consumer Protection Act, and fraudulent misrepresentation, primarily claiming that Somatics failed to adequately warn of the risks associated with ECT.The district court dismissed the claims under Nebraska’s Consumer Protection Act and for fraudulent misrepresentation, merged the strict liability and breach of implied warranty claims, and granted summary judgment to Somatics on the design defect, manufacturing defect, and breach of express warranty claims. The remaining claims for negligence and strict liability, both based on failure to warn, were merged for trial. The jury found that while Somatics failed to provide adequate warnings, this failure was not the proximate cause of the plaintiff’s injuries, and awarded no damages. The district court denied the plaintiff’s post-trial motions, including for a new trial.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s decisions de novo for summary judgment and for abuse of discretion on evidentiary and procedural rulings. The Eleventh Circuit held that the district court properly granted summary judgment on the design defect claim, correctly merged the negligence and strict liability claims, gave an appropriate jury instruction on proximate cause, and did not abuse its discretion in excluding certain evidence and expert testimony. The judgment of the district court was affirmed. View "Thelen v. Somatics, LLC" on Justia Law

A woman was working late at her place of employment, a business located in a commercial cul-de-sac, when she was approached at night by two individuals carrying flashlights. Fearing for her safety, as she did not know they were police officers and they did not identify themselves, she attempted to drive away. The officers, who were investigating a report of a possible break-in at a different address in the same cul-de-sac, fired their weapons at her vehicle as she drove up the driveway. The woman was not physically harmed, but her car was struck by bullets and later declared a total loss. She was detained in a police cruiser for several hours before being released without charges.The United States District Court for the Northern District of Georgia reviewed the woman’s claims under 42 U.S.C. § 1983, alleging unlawful seizure, excessive force, and unlawful property seizure in violation of the Fourth Amendment. The district court granted summary judgment to the officers on state-law claims but denied summary judgment on the federal claims, finding that a reasonable jury could conclude the officers lacked reasonable suspicion or probable cause, and that their actions violated clearly established law. The officers appealed, arguing they were entitled to qualified immunity.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s denial of qualified immunity. The court held that the officers seized the plaintiff both by physical force (when they shot her car) and by a show of authority, that no reasonable officer could have believed there was reasonable suspicion or probable cause to seize or shoot at her, and that the warrantless seizure of her vehicle was not justified by exigent circumstances. The case was remanded for further proceedings. View "Watkins v. Davis" on Justia Law

Law enforcement officers obtained and executed a search warrant for “4279 Violet Circle, Lake Worth, FL,” believing it to be a single-family home occupied by the defendant. In reality, the property included a main residence and three efficiency apartments at the back, one of which was occupied by the defendant. These apartments had no separate addresses, mailboxes, or exterior markings. During the search, officers were directed by other residents to the defendant’s apartment, where they found firearms and drugs. The defendant was subsequently charged with multiple firearm and drug offenses.The defendant moved to suppress the evidence, arguing that the warrant was defective under the Fourth Amendment because it listed only the main address and not his specific apartment. The United States District Court for the Southern District of Florida held an evidentiary hearing, credited the testimony of the investigating officer, and found that the officers reasonably believed the property was a single-family home based on surveillance, property records, and the lack of distinguishing features for the apartments. The magistrate judge recommended denying the motion to suppress, and the district court adopted this recommendation. The defendant was found guilty after a stipulated-facts bench trial and sentenced to 144 months’ imprisonment.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the denial of the motion to suppress. The court held that the search warrant satisfied the Fourth Amendment’s particularity requirement because the officers reasonably believed, after a diligent investigation, that the property was a single-family home. The court found no evidence that the officers knew or should have known about the separate apartments before executing the warrant. The court affirmed the denial of the motion to suppress and remanded for correction of a clerical error in the judgment. View "United States v. Schmitz" on Justia Law

A white man, after a dinner in Palm Harbor, Florida, targeted a Black man, his girlfriend, and his four-year-old daughter as they drove on a county-administered public road. The defendant, whom the victims did not know, repeatedly attempted to run their car off the road, shouted racial slurs, and made threatening gestures. At a red light, he exited his vehicle and physically confronted the Black man, continuing his racial abuse. Witnesses and police confirmed the defendant’s aggressive and racially charged conduct, and the defendant made further racist statements to law enforcement after his arrest. The defendant’s ex-girlfriend testified that such behavior was typical for him.A grand jury in the United States District Court for the Middle District of Florida indicted the defendant on two counts of violating 18 U.S.C. § 245(b)(2)(B), which prohibits racially motivated interference with the use of public facilities. The defendant moved to dismiss the indictment, arguing that the statute exceeded Congress’s authority under the Thirteenth Amendment and the Commerce Clause, and that the indictment violated the Double Jeopardy Clause. The district court denied these motions. At trial, the court instructed the jury that to convict, it must find the defendant acted “because of” the victim’s use of the public road, applying a “but-for” causation standard. The jury found the defendant guilty on one count and not guilty on the other. The district court denied the defendant’s motions for acquittal and a new trial, and sentenced him to 24 months in prison.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that 18 U.S.C. § 245(b)(2)(B) is a constitutional exercise of Congress’s power under the Thirteenth Amendment, as Congress may rationally prohibit racially motivated violence interfering with public facilities as a badge or incident of slavery. The court also found no error in the jury instructions, the handling of jury questions, or the sufficiency of the evidence. The conviction was affirmed. View "United States v. Leahy" on Justia Law

An athletic trainer employed by a rehabilitation services provider was assigned to work at a local high school under a contract between her employer and the school. Over several years, she reported concerns about the conduct and performance of other athletic trainers at the school, which led to personnel changes. In 2020, after a new head football coach was hired, the trainer was briefly given additional responsibilities but was soon told to return to her original role. Shortly thereafter, the school’s principal requested her removal, citing workplace issues unrelated to her sex. The trainer was then removed from her assignment at the school and offered several alternative positions by her employer, some with reduced pay or less desirable conditions. She ultimately accepted a new assignment but later resigned, alleging that her removal and reassignment were due to sex discrimination and retaliation for her complaints.The United States District Court for the Northern District of Alabama granted summary judgment in favor of the employer, finding that although there was a factual dispute about the employer’s control over the removal, the trainer failed to show that the employer discriminated or retaliated against her in violation of Title VII. The court concluded there was insufficient evidence that the employer knew or should have known the school’s removal request was based on sex, or that the reassignment options were offered for discriminatory reasons.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The appellate court held that the trainer’s discrimination claim failed because there was no evidence the employer knew or should have known the school’s request was sex-based, and no evidence that the reassignment was motivated by sex. The retaliation claim also failed, as there was no evidence the employer removed or reassigned her because she engaged in protected activity. The court affirmed summary judgment for the employer. View "Vincent v. ATI Holdings LLC" on Justia Law

Katherine Martinez was severely injured as a passenger in a multi-vehicle accident in Florida. The driver of the truck that struck the SUV, Diana Guevara, was insured by GEICO, but the truck was not listed on her policy, raising a coverage issue. GEICO investigated the accident, requested medical information from the victims, and, thirty-two days after receiving notice, tendered the full $20,000 policy limit for a global settlement. Martinez rejected the offer and sued Guevara in state court, ultimately obtaining a stipulated final judgment for $2,000,000. Guevara assigned her claims against GEICO to Martinez, who then sued GEICO in federal court for bad faith, seeking to recover the excess judgment.The U.S. District Court for the Southern District of Florida granted summary judgment to GEICO, adopting the magistrate judge’s finding that GEICO did not act in bad faith as a matter of law. The court found that Martinez failed to present sufficient evidence for a reasonable jury to infer bad faith, particularly regarding GEICO’s investigation and settlement efforts. Martinez appealed, arguing that the totality of the evidence could support a finding of bad faith due to alleged delays and handling of the claim.The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo and affirmed the district court’s decision. The Eleventh Circuit held that, under Florida law and the federal summary judgment standard, Martinez did not present sufficient evidence for a reasonable jury to find that GEICO acted in bad faith in investigating or settling the claim. The court clarified that mere negligence or delay does not meet the standard for bad faith and found GEICO’s actions reasonable given the circumstances, including the coverage dispute and multiple claimants. The district court’s summary judgment for GEICO was affirmed. View "Martinez v. GEICO Casualty Company" on Justia Law

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