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

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

A physician licensed in Florida worked at a weight management clinic, where he was responsible for maintaining a federal registration to dispense controlled substances. After a report of missing controlled substances at the clinic, local police and the Drug Enforcement Administration (DEA) began investigating. The investigation revealed that the physician had issued numerous prescriptions for controlled substances without proper documentation of a doctor-patient relationship, failed to maintain required records, did not properly report or store controlled substances, and dispensed medication in violation of labeling requirements. The physician claimed that another clinic employee had forged his signature on some prescriptions and denied personal wrongdoing.The DEA issued an Order to Show Cause, notifying the physician of its intent to revoke his registration and deny pending applications, citing violations of federal and state law. The physician submitted a Corrective Action Plan but did not request a hearing. The DEA Administrator reviewed the evidence, including expert testimony and the physician’s admissions, and found that the physician’s continued registration would be inconsistent with the public interest. The Administrator revoked the registration and denied all pending applications, emphasizing the physician’s failure to accept responsibility and the inadequacy of his proposed corrective measures.The United States Court of Appeals for the Eleventh Circuit reviewed the DEA’s final order under an abuse of discretion standard, deferring to the agency’s factual findings if supported by substantial evidence. The court held that the physician received adequate procedural due process, as he was given notice and an opportunity for a hearing, which he declined. The court also rejected the argument that the DEA was required to find knowing or intentional misconduct under Ruan v. United States, holding that such a mens rea requirement does not apply to administrative revocation proceedings under 21 U.S.C. § 824. The petition for review was denied. View "Ashraf v. Drug Enforcement Administration" on Justia Law

Alan Dershowitz, a prominent law professor and attorney, represented President Donald Trump during his first impeachment trial in January 2020. During the Senate proceedings, Dershowitz made statements regarding the scope of impeachable offenses, suggesting that if a president acts with a mixed motive—including the belief that their reelection is in the public interest—such conduct should not be considered an impeachable offense unless it involves personal financial gain. His remarks were widely criticized and interpreted by various media outlets, including CNN, as asserting that a president could do anything to get reelected if he believed it was in the public interest.Following this coverage, Dershowitz alleged that CNN intentionally misrepresented his statements to defame him, omitting key context and orchestrating a scheme to damage his reputation. He filed a defamation suit in the United States District Court for the Southern District of Florida. The district court granted summary judgment in favor of CNN, finding that Dershowitz, as a public figure, failed to provide evidence that CNN acted with actual malice—meaning knowledge of or reckless disregard for the falsity of its statements.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s decision de novo. The appellate court affirmed the summary judgment, holding that Dershowitz did not present evidence showing that CNN’s commentators or producers entertained serious doubts about the truth of their reporting or acted with reckless disregard for its falsity. The court found that the evidence indicated the commentators sincerely believed their interpretations, and that groupthink or ideological alignment did not amount to actual malice. Thus, Dershowitz’s defamation claim could not proceed. View "Dershowitz v. Cable News Network, Inc." on Justia Law

NCR Corporation established five “top hat” retirement plans to provide supplemental life annuity benefits to senior executives. Each plan promised participants a fixed monthly payment for life, with language allowing NCR to terminate the plans so long as no action “adversely affected” any participant’s accrued benefits. In 2013, NCR terminated the plans and paid participants lump sums it claimed were actuarially equivalent to the promised annuities, using mortality tables, actuarial calculations, and a 5% discount rate. NCR knew that, statistically, about half of the participants would outlive the lump sums if they continued to withdraw the same monthly benefit, resulting in some participants receiving less than they would have under the original annuity.Participants filed a class-action lawsuit in the United States District Court for the Northern District of Georgia, alleging breach of contract and seeking either replacement annuities or sufficient cash to purchase equivalent annuities. The district court certified the class and granted summary judgment for the participants, finding that NCR’s lump-sum payments adversely affected the accrued benefits of at least some participants, in violation of the plan language. The court ordered NCR to pay the difference between the lump sums and the cost of replacement annuities, plus prejudgment and postjudgment interest.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s summary judgment order de novo. The Eleventh Circuit held that the plan language was unambiguous and did not permit NCR to unilaterally replace life annuities with lump sums that reduced the value of accrued benefits for any participant. The court affirmed the district court’s judgment, including the remedy of requiring NCR to pay the cost of replacement annuities and awarding prejudgment interest. View "Hoak v. NCR Corp." on Justia Law

The case centers on allegations that Okaloosa County, the sponsor of Destin Executive Airport, and Jay Odom, a fixed-base operator, violated federal and Florida False Claims Acts. The dispute arose after Odom, who owned Destin Jet, allegedly acquired the only competing fixed-base operator, Miracle Strip Aviation (later Regal Air), resulting in a single entity controlling all aeronautical services at the airport. Despite this consolidation, the County continued to certify to the Federal Aviation Administration (FAA) that it was not granting any exclusive rights, a requirement for receiving federal funding. In 2019, Robert Smith, a pilot and relator, sought to establish a competing fixed-base operator but was denied by the County, prompting him to file suit alleging false certifications in grant applications.The United States District Court for the Northern District of Florida dismissed Smith’s amended complaint with prejudice. The court found that the False Claims Act’s public disclosure bar applied because the essential allegations had already been reported in two 2014 news articles, which described the consolidation and the resulting grant assurance violations. The district court also determined that Smith’s complaint failed to meet the heightened pleading standard for fraud and denied his request for leave to further amend the complaint.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the dismissal de novo. The Eleventh Circuit held that Smith’s claims were barred by the False Claims Act’s public disclosure provision, as the news articles had already disclosed substantially the same allegations. The court further found that Smith was not an original source of the information, as his additional details did not materially add to the public disclosures. The Eleventh Circuit affirmed the district court’s dismissal and its denial of leave to amend, concluding that any amendment would be futile. View "Smith v. Odom" on Justia Law

Two Florida residents who use medical marijuana in compliance with state law sought to purchase firearms but were denied after disclosing their marijuana use on a federal form. A third individual, a lawful gun owner, wished to participate in Florida’s medical marijuana program but refrained due to concerns about federal prosecution. All three, along with the Florida Commissioner of Agriculture, challenged the constitutionality of federal statutes and regulations that prohibit “unlawful users” of controlled substances—including marijuana—from possessing or purchasing firearms. The complaint did not allege that the plaintiffs had been convicted of any crimes or that their marijuana use rendered them dangerous.The United States District Court for the Northern District of Florida assumed the plaintiffs were protected by the Second Amendment but dismissed the complaint. The court applied the historical analysis required by District of Columbia v. Heller and New York State Rifle & Pistol Association v. Bruen, concluding that the federal prohibitions were consistent with the nation’s tradition of disarming individuals engaged in criminal conduct or deemed dangerous, such as felons, the mentally ill, or habitual drug users.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the case de novo. The court held that, at the motion to dismiss stage, the government failed to show that the plaintiffs—state-law-compliant medical marijuana users—were relevantly similar to either felons or dangerous individuals, the two historical analogues offered to justify the federal restrictions. The court emphasized that the complaint did not allege facts showing the plaintiffs were dangerous or had committed felonies. Accordingly, the Eleventh Circuit vacated the district court’s dismissal and remanded the case for further proceedings, holding that the plaintiffs had plausibly alleged a violation of their Second Amendment rights as applied to them. View "Florida Commissioner of Agriculture v. Attorney General of the United States" on Justia Law

A tenured English professor at a public university objected to the administration’s decision to resume in-person instruction during the Covid-19 pandemic. The professor, who had health concerns and was partially vaccinated, communicated his opposition by emailing students about his forced return to the classroom, attaching correspondence with his department chair, and using an unconventional email signature. The university responded by reassigning his courses, placing him on paid leave, and proposing a five-day suspension without pay, along with requirements for improved email professionalism. The professor then filed a lawsuit alleging violations of his First Amendment and procedural due process rights.The United States District Court for the Northern District of Florida dismissed the complaint. The court found that the professor’s email did not constitute protected speech under the First Amendment, as it was gratuitous information in a logistical message sent in his professional capacity. The court also rejected the procedural due process claim for failure to exhaust state-law remedies. The court’s dismissal order allowed the professor until July 3 to amend his complaint, instructing the clerk to enter judgment if no amendment was filed. The professor did not amend, and the clerk did not immediately enter judgment. On July 14, the court issued another order directing entry of judgment, which the clerk entered that day. The professor filed his notice of appeal on August 10.The United States Court of Appeals for the Eleventh Circuit reviewed whether the appeal was timely. Applying its precedent from Schuurman v. Motor Vessel Betty K V, the court held that the thirty-day appeal period began on the last day set for amending the complaint, not the later date when judgment was entered. Because the notice of appeal was filed more than thirty days after the amendment deadline, the court dismissed the appeal for lack of jurisdiction. View "Burt v. President of University of Florida" on Justia Law

A defendant was indicted for his role in a drug-trafficking organization operating across California, Georgia, and Nevada. He pleaded guilty to illegal reentry but not guilty to other charges, including conspiracy to possess with intent to distribute marijuana and possession with intent to distribute marijuana. At trial, the district court, over the defendant’s objection, empaneled an anonymous jury, concealing jurors’ names but allowing some personal information to be shared during voir dire. The government presented evidence of the defendant’s involvement in transporting cash and marijuana, and the defendant testified in his own defense, admitting to marijuana sales in California but denying involvement in the broader conspiracy alleged.The United States District Court for the Northern District of Georgia presided over the trial. The jury convicted the defendant of conspiracy to possess with intent to distribute less than 100 kilograms of marijuana and possession with intent to distribute marijuana, but acquitted him on money-laundering and firearm charges. At sentencing, the court attributed a significant drug quantity to the defendant, considered evidence including conduct for which he was acquitted, and imposed concurrent sentences of 120 months on each count, below the calculated guideline range. The defendant objected to the use of acquitted conduct and the calculation of the guideline range, but the court overruled these objections.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that any error in empaneling an anonymous jury was harmless because several factors justified the measure and the court minimized prejudice. The appellate court also found no abuse of discretion in refusing a multiple-conspiracies instruction, held that considering acquitted conduct at sentencing was permissible under existing precedent, and concluded that the sentence imposed was both substantively and procedurally reasonable. The Eleventh Circuit affirmed the convictions and sentence. View "United States v. Touray" on Justia Law

An Army veteran serving a lengthy prison sentence in Florida applied for and received disability benefits for service-related post-traumatic stress disorder. Initially, the Veterans Benefits Administration approved his claim at a 70 percent rate, later increasing it to 80 percent. However, after his felony conviction and incarceration, the Administration reduced his monthly benefits to a 10 percent rate pursuant to 38 U.S.C. § 5313, which limits disability payments for veterans incarcerated for more than 60 days due to a felony.The veteran filed a pro se complaint in the United States District Court for the Middle District of Florida, naming the United States Congress as defendant. He alleged that the statute reducing his benefits violated the Bill of Attainder Clause and the Equal Protection component of the Fifth Amendment, seeking both prospective and retroactive relief. A magistrate judge recommended dismissal, assuming without deciding that the court had jurisdiction over facial constitutional challenges, but finding the claims frivolous. The district court adopted this recommendation, dismissing the complaint and declining to address the plaintiff’s general objections.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that sovereign immunity barred the suit against Congress, as Congress has not waived immunity for constitutional claims arising from its enactment of legislation. The court further held that any amendment to name a different defendant would be futile because the Veterans’ Judicial Review Act provides an exclusive review scheme for challenges to veterans’ benefits decisions, channeling all such claims—including constitutional challenges—through the administrative process and ultimately to the Court of Appeals for Veterans Claims and the Federal Circuit. The Eleventh Circuit vacated the district court’s judgment and remanded with instructions to dismiss the case without prejudice for lack of jurisdiction. View "Johnson v. United States Congress" on Justia Law