U.S. Court of Appeals for the Eleventh Circuit - Justia Case Law Summaries

Williams v. Board of Regents of the University System of Georgia

2026-09-04T04:31:00-08:00

Dr. Lesley Williams, a second-year anesthesiology resident at Augusta University, experienced a traumatic assault and was subsequently diagnosed with PTSD. She requested modified duties and accommodations, but the residency program placed her in observer roles and required fitness-for-duty evaluations. Williams filed complaints regarding denial of academic credit and alleged discrimination based on sex and disability. Faculty raised concerns about her professionalism, clinical judgment, and exam conduct. Williams was suspended and ultimately terminated from the residency program after loss of clinical privileges, but an ad hoc committee initially recommended reinstatement with zero tolerance for further unprofessional behavior. Following further faculty concerns, Williams was again suspended and terminated. Williams appealed her termination through Augusta University’s internal procedures. The ad hoc committee found her clinical evaluations were generally adequate, but noted serious concerns about exam misconduct. Dean Hess ordered her reinstatement with strict conditions, but after additional negative evaluations and faculty meetings, Williams was suspended and terminated for patient safety reasons. She appealed to the University President and the Board of Regents of the University System of Georgia, both of whom upheld her termination. The United States Court of Appeals for the Eleventh Circuit reviewed the district court's grant of summary judgment in favor of the Board of Regents on Williams’s claims, which included sex discrimination, retaliation, disability discrimination, whistleblower retaliation, denial of procedural due process, and breach of contract. The Eleventh Circuit held that Williams failed to establish the required elements for each claim, including the lack of similarly situated comparators, absence of evidence supporting discriminatory or retaliatory intent, and insufficient support for procedural or contractual violations. The court affirmed the district court’s grant of summary judgment on all claims. View "Williams v. Board of Regents of the University System of Georgia" on Justia Law

Russo v. Secretary, U.S. Department of Commerce

2026-09-03T06:01:02-08:00

Two commercial fishermen and their family business challenged federal regulations that reduced catch limits for gag grouper in the Gulf of Mexico, a fish central to their livelihood. The fishermen argued that the Gulf of Mexico Fishery Management Council, which played a key role in proposing the catch limits and regulatory framework, was unconstitutionally composed and shielded from removal, violating the Appointments Clause and other constitutional provisions. Their complaint alleged significant financial harm resulting from the reduced catch limits. The United States District Court for the Southern District of Alabama found that certain powers granted to the Council—specifically, three statutory “veto” provisions that allow the Council to block actions by the Secretary of Commerce—rendered Councilmembers “officers” wielding significant federal authority. It determined their appointments violated the Appointments Clause because they were not properly appointed as principal officers. However, instead of vacating the catch limit rule, the district court severed the unconstitutional veto provisions from the governing statute and entered judgment for the plaintiffs. On appeal, the United States Court of Appeals for the Eleventh Circuit largely agreed that the Council’s veto powers confer significant authority, so Councilmembers’ appointments as currently structured are constitutionally deficient. However, the Eleventh Circuit held that the remedy should be limited to invalidating actions taken with those veto powers. Because the gag grouper rule was not promulgated using the Council’s unconstitutional veto authority but rather through an advisory process ratified by the Secretary, the rule itself was not tainted. The court vacated the district court’s judgment for the plaintiffs and remanded for entry of judgment in favor of the government, concluding that vacatur of the challenged rule was unwarranted. View "Russo v. Secretary, U.S. Department of Commerce" on Justia Law

Filipowski v. Commissioner of Internal Revenue

2026-09-02T06:31:20-08:00

Andrew Filipowski, a software entrepreneur, accumulated significant tax liability after selling his company for $3.5 billion in 1999 and claiming $110 million in losses through a partnership later deemed a sham by the U.S. Tax Court. The IRS assessed Filipowski’s individual tax liability, including taxes, penalties, and interest totaling approximately $140 million. Filipowski did not challenge the notice of deficiency or the amount owed, nor did he make substantive payments toward the liability, aside from applying a minor tax credit. When the IRS initiated collection proceedings, Filipowski sought a Collection Due Process hearing, indicating his inability to pay and offering an installment agreement or an offer-in-compromise (OIC). After receiving Filipowski’s OIC proposing to settle his tax debt for $1.5 million, the IRS’s collections department investigated his finances. The investigation raised concerns about Filipowski’s connections to the DePasquale Trust, delayed tax filings, and alleged undisclosed assets. The IRS calculated his reasonable collection potential as $5.9 million, which was less than the owed amount but still higher than the OIC. The IRS ultimately rejected the OIC on public policy grounds, reasoning that acceptance would undermine voluntary compliance. Filipowski challenged this decision in the U.S. Tax Court, arguing that disputed facts remained and that summary judgment was inappropriate. The Tax Court granted summary judgment in favor of the IRS, concluding that the rejection was supported by Filipowski’s tax history and the magnitude of his liability. The United States Court of Appeals for the Eleventh Circuit reviewed the Tax Court’s grant of summary judgment de novo. It held that the IRS did not abuse its discretion in rejecting Filipowski’s OIC on public policy grounds and affirmed the Tax Court’s decision, finding no genuine disputes of material fact that would preclude summary judgment. View "Filipowski v. Commissioner of Internal Revenue" on Justia Law

Zafirov v. Florida Medical Associates, LLC

2026-09-01T12:00:58-08:00

A physician brought a lawsuit on behalf of the United States under the False Claims Act (FCA), alleging that her employer and associated healthcare entities knowingly submitted false diagnosis codes to Medicare in order to obtain inflated payments. The case proceeded for several years. In February 2024, the defendants sought judgment on the pleadings or dismissal, arguing that the FCA’s qui tam provisions—which allow private individuals (relators) to sue on behalf of the government—violated the Constitution’s Appointments Clause, Take Care Clause, and Vesting Clause. The United States District Court for the Middle District of Florida granted the defendants’ motion, concluding that the qui tam provisions violated the Appointments Clause. The district court reasoned that relators are “officers of the United States” because they exercise significant federal authority and occupy a continuing position established by law, but are not appointed by the President as required by Article II. The court dismissed the case, finding the relator lacked authority to proceed on behalf of the United States, and did not address the other constitutional arguments. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s constitutional analysis de novo. The Eleventh Circuit disagreed with the lower court’s conclusion, holding that relators under the FCA are not officers of the United States because they do not occupy a continuing position established by law. The court explained that relators’ roles are temporary, personal, and lack a continuing emolument or transferable duties. Therefore, the FCA’s qui tam provisions do not violate the Appointments Clause. The Eleventh Circuit vacated the district court’s dismissal and remanded the case for consideration of the remaining constitutional arguments. View "Zafirov v. Florida Medical Associates, LLC" on Justia Law

Guthrie v. Coal Bed Services Inc.

2026-09-01T11:31:00-08:00

Two Black employees, Hall and Hughes, worked as laborer-operators for Coal Bed Services, Inc., a subsidiary of Pate Holdings, Inc. They complained to their supervisor about alleged racially discriminatory conduct by another supervisor. About a month later, Hall and Hughes were fired after refusing a drug test on a jobsite. A White coworker, Ramsey, also refused the same test and was initially terminated, but was later allowed to return to work under conditions not imposed on Hall and Hughes. The company paid Ramsey for a full shift but only paid Hall and Hughes for the hours worked. Subsequent hires for their positions were White employees, including one previously fired for failing a drug test. Hall and Hughes alleged these events were motivated by racial discrimination and retaliation. The United States District Court for the Northern District of Alabama granted summary judgment in favor of the defendants, Coal Bed Services and Pate Holdings, on all claims. Hall and Hughes had brought four claims: two under Title VII (race discrimination and retaliation) against Coal Bed Services, and two under 42 U.S.C. § 1981 (race discrimination and retaliation) against both companies. The district court found, among other things, that the White coworker was not a valid comparator under the McDonnell Douglas framework and concluded that Hall and Hughes could not establish causation for their retaliation claims. The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo. It determined that there was a genuine issue of material fact regarding whether the companies discriminated and retaliated against Hall and Hughes. The court held that circumstantial evidence, viewed in the light most favorable to the plaintiffs, was sufficient for a reasonable jury to infer intentional discrimination and retaliation under both Title VII and § 1981. The Eleventh Circuit reversed the district court’s summary judgment and remanded for further proceedings. View "Guthrie v. Coal Bed Services Inc." on Justia Law

USA v. Smith

2026-08-28T10:00:54-08:00

Reginald Smith, previously convicted of multiple cocaine-related felonies in Florida state court, was arrested in December 2019 after officers investigating illegal hunting found him holding a loaded shotgun. During a search, officers discovered additional ammunition, a hunting knife, and MDMA pills. An agent determined that Smith’s shotgun had traveled in interstate commerce, having been manufactured outside Florida. Smith, as a result, was indicted for possession of a firearm as a felon under 18 U.S.C. § 922(g)(1) and possession of MDMA under 21 U.S.C. § 844(a). He pleaded guilty to both counts. The United States District Court for the Middle District of Florida reviewed Smith’s prior convictions to determine whether they triggered the mandatory minimum sentence under the Armed Career Criminal Act (ACCA), 18 U.S.C. § 924(e). The court considered evolving precedent—including United States v. Conage and United States v. Jackson—regarding whether certain Florida drug crimes qualified as “serious drug offenses” under ACCA. After law developments clarified that Smith’s two 1993 convictions for selling cocaine and his 2001 conviction for trafficking cocaine were ACCA predicates under Eleventh Circuit precedent, the court applied the ACCA enhancement. Smith was sentenced to 180 months’ imprisonment for the firearm count and 12 months for MDMA possession, to run concurrently. Smith objected to the ACCA enhancement but acknowledged its applicability under current circuit law. The United States Court of Appeals for the Eleventh Circuit affirmed Smith’s conviction and sentence. The court held that § 922(g)(1) did not violate the Second Amendment or Commerce Clause, Smith invited any error regarding ACCA classification of his convictions, the district court’s error under Erlinger v. United States did not affect Smith’s substantial rights, and any error in calculating his base offense level under the Sentencing Guidelines was harmless. View "USA v. Smith" on Justia Law

Acevedo v. de la Portilla

2026-08-26T09:31:03-08:00

A city’s Chief of Police was recruited for his reformist reputation and soon after his arrival, he observed and reported that several City Commissioners were improperly interfering in police investigations and using police resources to pursue personal vendettas. The Chief communicated his concerns to the Mayor and City Manager, and, believing himself unable to investigate the Commissioners due to a prior City resolution, he sent a whistleblowing memorandum detailing abuses of power to the Mayor, City Manager, the State Attorney’s Office, and the FBI. The memo was subsequently leaked to the media. Following this, the Chief faced public criticism from the Commissioners, had his job responsibilities undermined, was suspended with pay by the City Manager pending a termination hearing, and was ultimately terminated by the City Commission. The Chief filed suit in the United States District Court for the Southern District of Florida against three Commissioners and the City Manager, alleging retaliation for protected First Amendment activity under 42 U.S.C. § 1983. The individual defendants moved to dismiss, asserting legislative and qualified immunity. The district court denied their motions, finding that neither defense shielded the Commissioners or the City Manager at that stage. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s denial of immunity de novo. The Eleventh Circuit held that the Commissioners were not entitled to legislative immunity because terminating an employee is administrative, not legislative, action. The court further held that the Commissioners were not entitled to qualified immunity at the pleading stage because, accepting the complaint’s allegations as true, the Chief’s whistleblower memo was constitutionally protected speech, and binding precedent clearly established that retaliating against such speech is unlawful. However, the court held that the City Manager was entitled to qualified immunity, as it was not clearly established that suspending the Chief with pay, pending further proceedings, constituted an adverse employment action. The panel affirmed the denial of immunity for the Commissioners, reversed as to the City Manager, and remanded for further proceedings. View "Acevedo v. de la Portilla" on Justia Law

All Does v. Conrad & Scherer, LLP

2026-08-26T07:30:58-08:00

A group of Colombian plaintiffs retained two attorneys under a contingency fee agreement to sue a multinational corporation for allegedly funding a paramilitary group that murdered their relatives. The agreement specified that the attorneys would receive one-third of any monetary award obtained before trial. A conflict soon arose between the attorneys after one joined a law firm, leading to disputes over representation and eventual court intervention. The case was consolidated into multidistrict litigation in the United States District Court for the Southern District of Florida, and over time, one attorney was discharged, with the court instructing the discharged attorney’s firm to file a charging lien to preserve its claim for fees and costs. After a settlement was reached that allocated $12.8 million to the plaintiffs and their counsel, the discharged firm moved to enforce its charging lien against the attorney’s share of the recovery. The district court referred the motion to a magistrate judge, who recommended nearly full payment to the firm. The district court adopted this recommendation, ordered the disputed funds to be held in the court registry pending appeal, and required that the funds not be disbursed until appellate review was exhausted. The United States Court of Appeals for the Eleventh Circuit reviewed whether it had jurisdiction to hear an interlocutory appeal of the district court’s order enforcing the charging lien. The Eleventh Circuit held that such orders do not fall within the collateral-order doctrine because they do not resolve important issues separate from the merits and are not effectively unreviewable after final judgment. The court explained that attorneys’ contractual or equitable rights to payment do not implicate substantial public interests or values of a high order and can be adequately reviewed after final judgment. Accordingly, the Eleventh Circuit dismissed the appeal for lack of appellate jurisdiction. View "All Does v. Conrad & Scherer, LLP" on Justia Law

Doe v. Carnival Corporation

2026-08-25T12:01:05-08:00

A passenger aboard a cruise ship alleged that, after becoming inebriated, she was separated from her friends and ended up in a maintenance closet with a crewmember. She stated that she was held against her will and sexually assaulted. Both she and the crewmember gave differing accounts of the incident to FBI agents: she could not recall if she consented to sexual conduct, while the crewmember claimed it was consensual and that he did not know she was intoxicated. The FBI investigator ultimately concluded the encounter was consensual, and prosecutors declined to bring criminal charges. The passenger brought suit in the United States District Court for the Southern District of Florida asserting claims including false imprisonment and sexual assault. In pretrial proceedings, the district court granted her motion for partial summary judgment on the issue of false imprisonment liability, finding that the cruise line had not produced admissible evidence to create a dispute of material fact. The district court excluded the FBI reports as hearsay. At trial, the district court instructed the jury that the cruise line was already liable for false imprisonment and limited the ability of the defendant to challenge the factual basis for that claim. The jury found the cruise line liable for sexual assault but rejected the negligence and intentional infliction of emotional distress claims, awarding over $10 million in damages. On appeal, the United States Court of Appeals for the Eleventh Circuit held that the district court erred in granting partial summary judgment on false imprisonment and in excluding the FBI investigator’s conclusions, which were admissible under the public records exception to the hearsay rule. The appellate court reversed the partial summary judgment on the false imprisonment claim, vacated the judgment as to the false imprisonment and sexual assault claims, and remanded for a new trial on those claims. The negligence and intentional infliction of emotional distress claims remain resolved in favor of the cruise line. View "Doe v. Carnival Corporation" on Justia Law

Ellis v. Sheriff, Hillsborough County Florida

2026-08-25T09:01:03-08:00

After his termination from the Hillsborough County Sheriff’s Office, Jeremy Ellis, who had worked there since 2007 and as a detention deputy since 2010, filed suit against the Sheriff in his official capacity. Ellis claimed he was fired in retaliation for filing charges of discrimination with both the EEOC and the Florida Commission on Human Relations, which alleged disability and religious discrimination. The Sheriff's Office conducted an internal investigation after Ellis's EEOC filing, focusing on alleged falsehoods and disparagement found in his charge, and asserted his termination was based on these false statements, along with a procedural infraction regarding address notification. Evidence at trial showed that Ellis’s drinking and his statements during the investigation were also considered, but the termination notice expressly cited the EEOC charge as the basis for dismissal. The United States District Court for the Middle District of Florida heard the case. At trial, both sides presented evidence regarding the motivations for Ellis's termination. The jury found in Ellis’s favor on both his retaliation claims under Title VII and Florida law, awarding him significant damages. After the verdict, the Sheriff moved for judgment as a matter of law, arguing insufficient evidence of causation, and separately for a new trial, contending the jury was improperly instructed that an employer cannot fire an employee for statements in an EEOC charge, even if false. The district court denied both motions. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s jury instruction and its denial of judgment as a matter of law. The appellate court held that, under binding precedent, an employer may not terminate an employee for statements made in an EEOC charge, even if believed false, and found sufficient evidence supported the jury’s finding of retaliatory motive. Accordingly, the Eleventh Circuit affirmed the district court’s rulings. View "Ellis v. Sheriff, Hillsborough County Florida" on Justia Law

Burton v. Espino

2026-08-25T05:30:52-08:00

A Florida state inmate alleged that he was severely beaten by prison guards on two occasions and subsequently experienced seizures and ongoing pain in his head, hand, and ribs. After the assaults, he sought medical care and was treated for his head wound by staff, but further injuries were not assessed. When he was later evaluated by a prison doctor, he claimed the doctor refused to provide meaningful treatment for his injuries and dismissed his complaints, allegedly in retaliation for grievances the inmate had filed against him. Over the following months, the inmate’s hand injury worsened, and a later orthopedic evaluation confirmed a deformity that required physical therapy. Despite this recommendation, the doctor again refused treatment, allegedly referencing the inmate’s previous grievances as the reason. The United States District Court for the Middle District of Florida granted summary judgment in favor of the doctor, finding that he was not deliberately indifferent to the inmate’s medical needs and had not retaliated against him for filing grievances. The district court concluded that the doctor neither acted with subjective recklessness nor denied medical care for retaliatory reasons. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed whether genuine disputes of material fact precluded summary judgment. The appellate court found that, crediting the inmate’s verified complaint, there was sufficient evidence for a reasonable jury to find that the doctor was deliberately indifferent to serious medical needs regarding both the head and hand injuries, and that he acted with retaliatory motive in denying care after grievances were filed. The Eleventh Circuit reversed the district court’s summary judgment decision and remanded the case for further proceedings, holding that the inmate’s claims should proceed to a jury. View "Burton v. Espino" on Justia Law

USA v. Thompson

2026-08-24T12:30:56-08:00

A former stadium control room engineer for the Jacksonville Jaguars, who had previously been convicted of child sexual abuse, was suspected of interfering with the stadium’s videoboards after his contract was terminated. Investigators traced unauthorized access to the videoboard computer network to him, and a subsequent FBI search uncovered large volumes of child pornography as well as evidence that he had produced exploitive material involving children. When he learned of the investigation, he fled abroad but was eventually returned to the United States. He faced a ten-count indictment including charges related to child pornography, enticement of minors, computer intrusion, sex offender registration violations, and firearm possession as a felon. The case was first reviewed by the United States District Court for the Middle District of Florida. The defendant chose to represent himself at trial after a Faretta hearing in which he was informed of the risks of self-representation; standby counsel was appointed. Over the course of the proceedings, he challenged the validity of the search warrant, sought to suppress evidence, and requested certain discovery and a trial continuance, all of which were denied. He also objected to a child victim testifying by closed-circuit television, but the court allowed it after making the necessary findings. The jury convicted him on all counts, and he received a sentence of 2,640 months in prison followed by supervised release. The United States Court of Appeals for the Eleventh Circuit reviewed the appeal. It held that the defendant’s waiver of counsel remained valid after new charges were added, that the district court did not err in allowing the child witness to testify remotely, and that the denial of the defendant’s motions for discovery, continuance, and suppression of evidence was proper. The court also upheld the validity of the search warrant and the denial of subpoenas for a Franks hearing. The Eleventh Circuit affirmed the convictions and sentence. View "USA v. Thompson" on Justia Law

USA v. Miller

2026-08-24T11:00:52-08:00

Over a two-week period, the defendant entered four financial institutions in Florida, presenting notes to tellers demanding money. The notes did not explicitly threaten violence and were sometimes phrased politely. In two instances, the defendant succeeded in obtaining cash; in the other two, he left without money. The tellers’ responses varied: some felt intimidated, while others initially perceived the acts as non-threatening but later reconsidered after the defendant’s actions, such as staring and insisting on the return of his note. Law enforcement arrested the defendant the same day as the last incident. The United States District Court for the Southern District of Florida indicted the defendant on two counts of attempted credit-union robbery, one count of credit-union robbery, and one count of bank robbery, all under 18 U.S.C. § 2113(a). At trial, the defendant moved for judgment of acquittal under Rule 29, arguing that the government failed to prove intimidation, a required element of the offenses. The district court denied the motion, referencing persuasive authority that a demand for money alone can constitute intimidation, and found sufficient evidence based on trial testimony. The jury convicted the defendant on all counts, and he timely appealed. The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo. The court held that, in the context of a suspected bank robbery, a demand for cash from a teller—whether verbal or written, threatening or polite—provides sufficient evidentiary grounds to affirm a jury’s finding of intimidation under 18 U.S.C. § 2113(a). The court concluded that the defendant’s actions satisfied the intimidation requirement for both completed and attempted offenses. Accordingly, the Eleventh Circuit affirmed the convictions. View "USA v. Miller" on Justia Law

Ramdial v. U.S. Attorney General

2026-08-21T11:03:34-08:00

A lawful permanent resident originally from Trinidad and Tobago was convicted in a Florida state court of robbery by sudden snatching, along with several drug offenses. The Department of Homeland Security initiated removal proceedings, charging him as removable for committing an aggravated felony, specifically a theft offense for which the term of imprisonment was at least one year. The individual sought cancellation of removal but was found removable by an Immigration Judge (IJ) based on his convictions. The IJ also held that his robbery by sudden snatching conviction qualified as an aggravated felony theft offense, rendering him ineligible for cancellation of removal. The individual appealed to the Board of Immigration Appeals (BIA), arguing that the Florida statute was broader than the generic federal definition of theft because it permitted conviction for temporary takings and for depriving a non-owner victim, and did not require proof of nonconsent. The BIA dismissed his appeal, agreeing with the IJ that the Florida offense matched the generic definition of theft under federal law. He then petitioned the United States Court of Appeals for the Eleventh Circuit for review, raising new arguments about the breadth of the Florida statute. After the case was initially remanded to the BIA for further consideration, the BIA reaffirmed its decision and again dismissed the appeal. The United States Court of Appeals for the Eleventh Circuit reviewed the BIA’s decision de novo and held that Florida robbery by sudden snatching is not broader than the generic definition of theft for aggravated felony purposes under the Immigration and Nationality Act. The court concluded that the statute’s intent and consent elements, as interpreted by Florida courts and reflected in jury instructions, were consistent with generic theft, and that the statute did not criminalize a broader range of conduct. The court denied the petition for review. View "Ramdial v. U.S. Attorney General" on Justia Law

Wilson v. Secretary, Florida Department of Corrections

2026-08-21T07:02:22-08:00

An incarcerated individual in Florida filed a civil rights lawsuit under 42 U.S.C. § 1983, alleging that prison officials failed to protect him from a cellmate with mental illness who subsequently assaulted him, causing serious injury. At the time he filed suit, the plaintiff requested to proceed in forma pauperis because he could not afford the filing fees. However, he had previously filed at least three federal actions that were dismissed as frivolous or for failure to state a claim, triggering the “three-strikes” provision of the Prison Litigation Reform Act (PLRA), which generally bars further filings without prepayment unless the plaintiff demonstrates imminent danger of serious physical injury. A magistrate judge in the United States District Court for the Northern District of Florida screened the initial complaint, determined the plaintiff did not sufficiently allege imminent danger, and recommended dismissal under the PLRA’s three-strikes rule. The plaintiff objected, adding new factual allegations about ongoing threats and the continued presence and violence of his assailant, and formally requested leave to amend his complaint. The district judge adopted the magistrate judge’s recommendation, dismissing the complaint without prejudice and refusing to consider the new allegations or grant leave to amend. The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that the district court abused its discretion by failing to either treat the plaintiff’s objections and supplemental allegations as an amendment to the complaint, which he was entitled to file as a matter of course under Federal Rule of Civil Procedure 15(a), or as a motion to amend. The appellate court vacated the district court’s order of dismissal and remanded for further proceedings. View "Wilson v. Secretary, Florida Department of Corrections" on Justia Law

Brown v. Commissioner, Alabama Department of Corrections

2026-08-21T06:02:10-08:00

The case concerns a man who was convicted by an Alabama jury of murdering his girlfriend and her mother. The key facts established at trial showed that after the murders occurred in the victims’ home, the defendant left the state with the children, the victims’ car, and their checks, traveling to Cleveland, Ohio. Witness testimony placed him at the scene around the time of the murders, and his fingerprints were found on duct tape used to bind one of the victims. Additional evidence included his efforts to obtain cash using the victims’ checks, his lies about needing money for a child’s medical care, and his subsequent standoff with police in Cleveland. Family members of the defendant, including his aunt and uncle, were involved in alerting police to possible trouble at the victims’ home before the bodies were discovered. The Alabama Court of Criminal Appeals, reviewing the conviction and death sentence, agreed that the trial court erred in admitting testimony from a police investigator about a statement the defendant allegedly made to his aunt (“I hurt them girls”) without proper impeachment procedure. However, the appellate court held that this error was harmless beyond a reasonable doubt, given the overwhelming evidence of guilt. After unsuccessful state postconviction proceedings, the defendant sought federal habeas relief in the United States District Court for the Northern District of Alabama, arguing that admission of his alleged statement violated his federal due process rights. The district court denied relief, ruling that any error was not prejudicial in light of the full record. On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed, holding that admission of the statement did not violate due process because it was not a crucial or highly significant factor in the conviction, and any error was harmless under both state and federal standards. View "Brown v. Commissioner, Alabama Department of Corrections" on Justia Law

Kingsolver v. U.S. Attorney General

2026-08-20T12:02:51-08:00

An employee of the Bureau of Alcohol, Tobacco, and Firearms suffered from depression and cardiac arrhythmia. After being promoted to a more demanding position, she reported that the increased stress from her job was worsening her health conditions. She requested several accommodations, including unpaid leave, a lateral transfer to a comparable position, or other unspecified assistance. Her supervisors denied unpaid leave, offering instead flexible use of her accrued paid leave and eventually a demotion to a less stressful position. After ongoing health issues and no suitable positions becoming available, the employee accepted the demotion, which subsequently improved her symptoms. The employee filed a complaint with the Equal Employment Opportunity office, alleging that her demotion constituted disability discrimination and that her supervisors failed to provide reasonable accommodation. An initial administrative judge found the agency had failed to accommodate her, but this was reversed by the Office of Federal Operations upon appeal. She then brought suit in the United States District Court for the Southern District of Georgia. The district court granted summary judgment for the government, holding that the employee had not been coerced into her demotion and that her accommodation requests, except for the demotion, were either not reasonable or would have required the creation of a new position. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s grant of summary judgment de novo. The court held that the government did not have a duty to provide the other requested accommodations because they were either not specific or not reasonable. The court further held that no reasonable jury could find that the employee was coerced into accepting the demotion, and thus, her demotion did not constitute disability discrimination. The judgment of the district court was affirmed. View "Kingsolver v. U.S. Attorney General" on Justia Law

Delta Air Lines, Inc. v. U.S. Department of Transportation

2026-08-20T11:32:29-08:00

Delta Air Lines, Inc. and Aerovias de México, S.A. de C.V. sought approval from the U.S. Department of Transportation (DOT) for a joint venture to provide integrated airline services between the United States and Mexico. DOT approved the joint venture in 2016, granting both approval and antitrust immunity after finding that it would increase competition and public benefits in the U.S.–Mexico aviation market. As part of the approval, DOT required the petitioners to divest certain take-off and landing slots at Mexico City’s airport and imposed a five-year limit on antitrust immunity, citing concerns about slot allocation practices at that airport. After the initial approval, the petitioners operated under these conditions and, in 2022, sought renewal of the joint venture’s approval and immunity. However, DOT issued show-cause orders in 2024, and subsequently a final order in 2025, terminating both the approval and antitrust immunity. The DOT’s decision was based primarily on changes to slot allocation and restrictions on all-cargo carriers by the Mexican government at Mexico City’s airport, which DOT concluded had undermined competition and the public interest. The petitioners challenged this final order in the United States Court of Appeals for the Eleventh Circuit, arguing that DOT’s decision was arbitrary and capricious. The Eleventh Circuit agreed with the petitioners. It found that DOT had departed from its uniform practice of conducting comprehensive market analyses, instead focusing narrowly on a single airport without adequate explanation. The court also determined that DOT had imposed a requirement for open skies agreement implementation on the petitioners that it had not imposed in similar cases involving other countries. The court held that DOT’s final order was arbitrary and capricious, and vacated the order. View "Delta Air Lines, Inc. v. U.S. Department of Transportation" on Justia Law

Peden v. Stephens

2026-08-19T08:32:43-08:00

A deputy sheriff in Gwinnett County, Georgia, was terminated from his position following allegations that he engaged in extramarital affairs during work hours and while using county resources. An anonymous letter triggered an internal investigation, which included a polygraph examination. After being confronted with the charges, the deputy was issued a pre-termination notice and ultimately fired. He appealed his termination but later entered into a settlement in which the Sheriff's Office agreed to treat his departure as a resignation. Subsequently, a local news outlet obtained and reported on his personnel file, and the deputy learned the identity of the person behind the anonymous letter. The former deputy and his wife filed a lawsuit in the United States District Court for the Northern District of Georgia, asserting claims for procedural due process and equal protection violations under the Fourteenth Amendment, as well as state law defamation. The district court granted summary judgment to the Gwinnett County officials on all claims, finding insufficient evidence to proceed. On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s grant of summary judgment on the procedural due process and defamation claims. The court held that the plaintiff could not maintain a procedural due process claim because he failed to exhaust available state remedies before pursuing federal relief. The defamation claim failed due to a lack of evidence connecting the defendants to the alleged leak. However, the court vacated the summary judgment on the equal protection claim and remanded with instructions to dismiss that claim for lack of standing, because private citizens generally have no judicially cognizable interest in whether another individual is prosecuted. The officials’ cross-appeal was dismissed as moot. View "Peden v. Stephens" on Justia Law

USA v. Mininger

2026-08-18T09:32:44-08:00

Kenneth Mininger, during a visit to his ex-wife’s home over Thanksgiving 2021, placed hidden video cameras in shared areas, specifically his ex-wife’s daughter’s bedroom and a shared bathroom. The daughter, then seventeen, discovered the cameras, removed the SD cards from them, and reviewed footage that included images of herself and a friend, as well as recordings of herself undressing from earlier years. After confronting Mininger and asking him to leave, the daughter and her mother turned the SD cards over to police, who searched them without a warrant. The footage led to a broader investigation, during which law enforcement obtained and executed warrants for Mininger’s residence and devices, discovering extensive child sexual abuse material. In the United States District Court for the Northern District of Alabama, Mininger moved to suppress the evidence obtained from the SD cards and the subsequent searches, arguing a Fourth Amendment violation due to the warrantless search and alleging the warrants for his devices were overbroad. The district court denied the motion, finding Mininger had a reasonable expectation of privacy in the SD cards but that the homeowner had authority to consent to the search. Mininger entered a conditional guilty plea, preserving his right to appeal the suppression ruling, and was sentenced to 600 months in prison. The United States Court of Appeals for the Eleventh Circuit reviewed the denial of the suppression motion, applying a mixed standard of review. The court held that Mininger had no reasonable expectation of privacy in the SD cards because he had placed them, unsecured and without consent, in shared spaces for illicit purposes. The court also held that the warrants for Mininger’s devices were not overbroad, as they were reasonably limited to evidence of child pornography and sexual exploitation. The Eleventh Circuit affirmed Mininger’s convictions. View "USA v. Mininger" on Justia Law

USA v. Chun

2026-08-18T07:02:11-08:00

A physician specializing in pain medicine and a pharmaceutical sales representative were indicted in the Middle District of Florida for their roles in a scheme involving a fentanyl-based drug. The pharmaceutical company launched a speaker program to boost sales of its medication by paying physicians large honoraria for supposedly educational presentations that were, in fact, shams. The physician received significant payments as a speaker, and the sales representative arranged many of these events. Evidence showed that the supposed educational events were poorly attended or attended by inappropriate guests, and that payments were tied to prescription volume, not genuine educational services. After a grand jury indictment, the case proceeded to trial before the United States District Court for the Middle District of Florida. The jury found the physician guilty on conspiracy and substantive anti-kickback counts, while the sales representative was convicted on conspiracy, anti-kickback violations, and identity fraud counts. Both defendants moved for judgments of acquittal, arguing insufficient evidence and other legal grounds, but the District Court denied these motions. Both were sentenced to prison and appealed their convictions and sentences. The appeal also challenged the District Court’s responses to jury questions and the calculation of loss in sentencing. The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the District Court’s judgments. The Eleventh Circuit held that ample evidence supported the convictions for conspiracy and anti-kickback violations, including the physician’s knowledge of the sham nature of the speaker programs and the sales representative’s knowing participation. The Court also held that the District Court did not abuse its discretion in responding to jury questions and that any potential error in calculating the sentencing range was harmless, as the District Court would have imposed the same sentences in any event. The convictions and sentences were therefore upheld. View "USA v. Chun" on Justia Law

Warner v. Hillsborough County Clerk of Courts

2026-08-17T11:32:09-08:00

After being involved in an eviction proceeding in Hillsborough County, Florida, an individual deposited funds into the court registry, as required by state law. Over time, he changed addresses and updated his contact information in the state’s e-filing system, but did not always update his address with the county court. The county clerk attempted to notify him of unclaimed funds by mailing letters to an outdated address (despite repeated returned mailings) and by publishing notice in a local Spanish-language newspaper with very limited circulation in the county. The funds were eventually declared abandoned and forfeited to the county under a Florida statute. The United States District Court for the Middle District of Florida granted summary judgment in favor of the county clerk. The district court found that publication in the local newspaper constituted constitutionally sufficient notice and that the forfeiture did not amount to an unconstitutional taking because statutory schemes for escheatment of abandoned property are generally permissible. The United States Court of Appeals for the Eleventh Circuit reviewed the case. The appellate court held that the statute’s notice procedure is not facially unconstitutional because there are situations where publication alone may suffice—for instance, when the property owner is unknown. However, the court found the clerk’s application of the statute to this individual was unconstitutional. The clerk had access to alternative means of contact (including email and a valid mailing address in the state’s e-file system) but failed to use them, relying instead on methods not reasonably calculated to provide notice. The court also determined that the individual had not abandoned the funds, since he never received constitutionally adequate notice, and thus the county’s appropriation of the funds constituted an unconstitutional taking. The Eleventh Circuit affirmed in part, reversed in part, and remanded for further proceedings. View "Warner v. Hillsborough County Clerk of Courts" on Justia Law

Johnson v. Russell Investments Trust Company

2026-08-17T10:02:04-08:00

An employee of Royal Caribbean participated in the company’s retirement plan and invested in a series of target date funds managed by Russell. She, on behalf of a class, alleged that Royal Caribbean, as plan sponsor and fiduciary under ERISA, breached its duty of prudence by selecting and retaining the Russell Target Date Funds (TDFs) instead of alternatives like those from Vanguard or American Funds. The complaint highlighted that the Russell TDFs underperformed their peers and benchmarks, charged higher fees, and had features—such as a particular glidepath and asset allocation—that allegedly made them a poor fit for plan participants. Internal communications from Russell and Royal Caribbean raised concerns about the performance and cost of the Russell TDFs. The United States District Court for the Southern District of Florida granted summary judgment to Royal Caribbean. It reasoned that, in order to prove the investment was objectively imprudent, the plaintiff was required to present “apples-to-apples” comparator evidence—showing the Russell TDFs were worse than another fund with the same investment strategy and risk profile. The district court found that the plaintiff’s comparators, such as the Vanguard and American Funds TDFs, were not proper because they differed in strategy and structure from the Russell funds. The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that an ERISA plaintiff is not always required to provide an “apples-to-apples” comparator to establish that an investment was objectively imprudent. The court explained that evidence of objective imprudence can be qualitative or quantitative, and the inquiry is context-specific, depending on all relevant facts and circumstances. The Eleventh Circuit reversed the district court’s grant of summary judgment and remanded the case for further proceedings. View "Johnson v. Russell Investments Trust Company" on Justia Law

Finley v. Albritton

2026-08-17T08:32:54-08:00

Two high-ranking officers in a city police department—one the chief and the other the deputy chief of operations—were subject to an internal firearms proficiency assessment. Department policy mandated regular qualifications, and there was confusion over which of two overlapping policies governed discipline for failures. After the deputy chief failed the assessment, she received an extra attempt to qualify, which she passed, and the chief subsequently allowed all failing officers a third attempt. A lieutenant, believing the chief had abused his authority to benefit the deputy chief, filed a complaint with the state ethics commission, prompting an investigation by commission officials. During the investigation, the commission’s special agent and general counsel relied on the allegedly superseded policy, policy 2.311, to argue that the deputy chief faced possible financial penalties and thus had a financial interest in the outcome. There was confusion among department officials and investigators regarding which policy was in effect, and both policies were referenced in departmental communications and disciplinary records. The commission found probable cause of ethics violations by both officers and referred the matter to the state attorney general. However, the attorney general found that the commission officials had relied on false evidence and misrepresentations. An internal review by the commission cleared its officials of wrongdoing. The officers sued the commission’s executive director, special agent, and general counsel in the United States District Court for the Middle District of Alabama under 42 U.S.C. § 1983, alleging due process violations based on fabricated evidence, among other claims. The district court granted summary judgment to the defendants on the federal claims and declined to exercise supplemental jurisdiction over the state-law claims. The United States Court of Appeals for the Eleventh Circuit reviewed the grant of summary judgment de novo. It held that the officials were entitled to qualified immunity, finding no substantial evidence that they fabricated evidence or acted in bad faith. The court affirmed the district court’s grant of summary judgment for the defendants. View "Finley v. Albritton" on Justia Law

USA v. Sheely

2026-08-13T13:02:41-08:00

A man was arrested after police responded to reports of gunshots and found him in the area matching a witness description. He was charged with possession of a firearm and ammunition as a convicted felon, with prior felony convictions including felony battery, attempted robbery, and manslaughter in Florida. The defendant entered a plea agreement, admitting to the facts underlying the charge and his criminal history. The United States District Court for the Southern District of Florida initially calculated his guideline sentence using several prior convictions as “crimes of violence” under the Sentencing Guidelines. The defendant objected, arguing that some of his prior convictions, including felony battery, did not qualify as “crimes of violence” after the Supreme Court’s decision in Borden v. United States. The district court overruled his objections and imposed a sentence, but the United States Court of Appeals for the Eleventh Circuit later vacated the sentence, holding that attempted robbery and manslaughter were not “crimes of violence,” and remanded for resentencing to address whether felony battery still qualified. On remand, the district court recalculated the guideline range using only the felony battery conviction as a predicate “crime of violence” and imposed a new sentence. The defendant again appealed, arguing that Borden abrogated Eleventh Circuit precedent holding Florida felony battery is a “crime of violence.” The United States Court of Appeals for the Eleventh Circuit held that its precedent from United States v. Vail-Bailon, which found Florida felony battery to be a “crime of violence,” remained binding and was not abrogated by Borden. The court affirmed the sentence, holding that a conviction for Florida felony battery still qualifies as a “crime of violence” under the Sentencing Guidelines. View "USA v. Sheely" on Justia Law

Center for Biological Diversity v. U.S. Environmental Protection Agency

2026-08-12T10:02:22-08:00

A nonprofit organization challenged a decision by the U.S. Environmental Protection Agency (EPA), which approved a request by a fertilizer company to use phosphogypsum—a radioactive byproduct of fertilizer production—in the construction of a pilot road on the company’s private property in Florida. Phosphogypsum is typically stored in stacks due to its emission of radon gas, a known carcinogen. Federal regulations issued under the Clean Air Act generally prohibit its use outside of certain exceptions but allow the EPA to approve other uses if public health is protected as much as it would be by storage in stacks or mines. The EPA, after a multi-year review, found that the company's proposal included all necessary information and that the risks to workers, nearby residents, and the environment were below the applicable health thresholds. The EPA concluded that the road’s use of phosphogypsum posed no greater risk than storage and imposed ongoing monitoring requirements. The nonprofit submitted public comments opposing the approval, arguing that EPA’s action violated regulations and was arbitrary and capricious. After considering these comments, the EPA finalized its approval. The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court first determined that it had jurisdiction because the petitioner had associational standing and the case was not moot. On the merits, the court held that the EPA did not violate its regulations, as the relevant rules unambiguously permit case-by-case approval of “other uses” of phosphogypsum, including road construction, provided health protections are adequate. The court also found that the EPA’s technical review and risk assessment were reasonable and well-supported, and any alleged procedural errors were harmless. The court denied the petition. View "Center for Biological Diversity v. U.S. Environmental Protection Agency" on Justia Law

Renfroe v. USAA

2026-08-11T12:03:08-08:00

A father and daughter jointly owned a house in Alabama but had a contentious relationship, with both warning their insurer, USAA General Indemnity Co., that the other might intentionally set fire to the property. Despite these warnings, USAA issued a $500,000 policy covering both as insureds. The policy included an exclusion that denied coverage to all insureds if any one of them intentionally caused a loss, except in certain cases of domestic abuse. Shortly after the policy was issued, the house was destroyed by fire. The father, Martin D. Renfroe, filed a claim, but USAA denied coverage, suspecting arson by either Renfroe or his daughter. The United States District Court for the Northern District of Alabama considered Renfroe’s claims for breach of contract and bad faith. The court ruled that the innocent-insured exclusion was void as against Alabama public policy, allowing Renfroe’s breach of contract claim to proceed to trial, but granted summary judgment for USAA on the bad faith claim due to evidence suggesting Renfroe might have committed arson. At trial, the jury found in favor of Renfroe, awarding him damages, which the court later reduced. The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that Alabama law does not prohibit innocent-insured exclusions in insurance policies unless specifically barred by statute, and found no such bar here. The appellate court concluded the exclusion was enforceable, vacated the district court’s judgment on the breach of contract claim, and remanded for a new trial. The Eleventh Circuit affirmed the district court’s summary judgment for USAA on the bad faith claim, holding that USAA had at least an arguable basis for denying coverage due to evidence implicating Renfroe in arson. View "Renfroe v. USAA" on Justia Law

Florida East Coast Railway LLC v. Federal Railroad Administration

2026-08-11T11:02:31-08:00

Several railroads and industry groups challenged a federal regulation requiring most freight trains to operate with at least two crewmembers unless the use of a one-person crew is shown to be equally safe. The regulation, issued by the Federal Railroad Administration (FRA) in 2024, responded to safety concerns about the reduction of train crew sizes as technology advanced, citing specific accidents and research on the importance of crew redundancy for safety. The rule provides exemptions for smaller railroads with established one-person operations and offers a special approval process for others, especially those transporting hazardous materials. Previously, the FRA had declined to regulate crew size, withdrawing a proposed rule in 2019 based on insufficient evidence that one-person crews were less safe. However, the U.S. Court of Appeals for the Ninth Circuit vacated this withdrawal, criticizing the agency's reasoning and its attempt to preempt state crew-size laws. Following a new rulemaking process, the FRA finalized the 2024 regulation after considering thousands of public comments, a public hearing, and new safety data. The United States Court of Appeals for the Eleventh Circuit reviewed consolidated petitions from several railroads and associations. The petitioners argued, among other points, that the FRA exceeded its authority, acted arbitrarily and capriciously, failed to adequately consider costs, and violated statutory deadlines. The Eleventh Circuit held that the FRA acted within its broad statutory authority to regulate railroad safety, provided reasonable explanations for its policy changes and regulatory choices, adequately considered evidence and public input, and did not violate the law by taking more than twelve months to finalize the rule. The court denied all petitions for review, upholding the Crew Size Rule. View "Florida East Coast Railway LLC v. Federal Railroad Administration" on Justia Law

USA v. Hollington

2026-08-11T08:32:35-08:00

A physician who operated an addiction clinic was indicted on multiple counts of unlawfully prescribing controlled substances to five undercover law enforcement officers and four actual patients, as well as several counts of obstruction of justice for altering patient records after being indicted. At trial, four former patients testified that the physician prescribed drugs to them following minimal or inadequate medical evaluation, with several testifying to sexual misconduct or exploitation by the physician in connection with their prescriptions. Five undercover officers also testified to receiving prescriptions with little or no medical assessment, and video evidence corroborated their accounts. The prosecution further showed that after his indictment, the physician added false or misleading entries to the medical records of the undercover officers to make it appear that he had conducted more thorough evaluations than he actually had. The United States District Court for the Middle District of Florida granted the physician’s motion for acquittal only as to the conspiracy count but let the case proceed on the remaining charges. A jury convicted the defendant on all remaining counts. At sentencing, the district court adopted a guidelines range of 30 to 37 months but imposed a sentence of 144 months, an upward variance, citing the physician’s sexual misconduct against patients as a significant aggravating factor. The district court explained that the guidelines did not adequately capture the seriousness of the sexual abuse committed in connection with the unlawful prescriptions. The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that sufficient evidence supported all convictions for unlawful prescription and obstruction of justice. The court also found that the upward variance in sentencing was reasonable, given the aggravating circumstances, and that the district court did not commit procedural or substantive error. The Eleventh Circuit affirmed the defendant’s convictions and sentence. View "USA v. Hollington" on Justia Law

Mt. Hawley Insurance Company v. H&M Builders, LLC

2026-08-11T06:01:58-08:00

An individual was fatally electrocuted while installing rebar at a construction site where H&M Builders, LLC served as a subcontractor. H&M was insured by Mt. Hawley Insurance Company, which had issued a commercial general liability policy valid on the date of the incident. The decedent’s estate, represented by Gloria Escalante, filed a wrongful death lawsuit in Florida state court against H&M and others, alleging their negligence led to the fatality. Mt. Hawley undertook H&M’s legal defense in the state proceeding, but did so under a reservation of rights, disputing its obligation to defend or indemnify H&M. Subsequently, Mt. Hawley initiated a federal action in the United States District Court for the Southern District of Florida, seeking a declaratory judgment that it owed no duty to defend or indemnify H&M in the underlying state litigation. The district court granted summary judgment in favor of H&M and Escalante on the duty-to-defend issue, while reserving judgment on the duty to indemnify until the state case concluded. Mt. Hawley appealed this summary judgment order before the district court entered a final judgment. While the federal appeal was pending, the parties settled the state wrongful death case, which was then dismissed. The district court then dismissed the indemnification claim as moot and entered final judgment. The United States Court of Appeals for the Eleventh Circuit held that it lacked jurisdiction over Mt. Hawley’s appeal for three separate reasons: the underlying state-court action had been settled and dismissed, eliminating any live controversy; the summary judgment order appealed from did not possess injunctive qualities necessary for interlocutory appellate jurisdiction under 28 U.S.C. § 1292(a)(1); and, finally, the district court had entered a final judgment, so any appeal should be from that judgment rather than an interlocutory order. The appeal was therefore dismissed for lack of jurisdiction. View "Mt. Hawley Insurance Company v. H&M Builders, LLC" on Justia Law

Owoc v. The Liquidating Trustee on Behalf of the Liquidating Trust

2026-08-10T11:02:19-08:00

The case concerns the founder and sole shareholder of a corporation (VPX), who elected to treat the company as a Subchapter S Corporation for federal tax purposes. After VPX and affiliated entities filed for Chapter 11 bankruptcy, a reconstituted board removed the founder from his executive and board positions, though he remained the sole shareholder. The company’s assets were later sold, and its remaining interests were vested in a trust under the reorganization plan. The founder then sought confirmation that the bankruptcy automatic stay did not prohibit him from revoking the corporation’s Subchapter S status or, alternatively, for relief from the stay to do so. The United States Bankruptcy Court for the Southern District of Florida denied his motions, holding that the Subchapter S election constituted property of the bankruptcy estate and was therefore protected by the automatic stay. The founder appealed this decision to the United States District Court for the Southern District of Florida, which denied the trustee’s motion to dismiss the appeal as moot, consolidated the appeals, and certified a direct appeal to the United States Court of Appeals for the Eleventh Circuit. The United States Court of Appeals for the Eleventh Circuit addressed several issues, including mootness, the law of the case, and whether Subchapter S status is property of the bankruptcy estate. The court held that a corporate debtor’s Subchapter S election is not property of the bankruptcy estate because the election belongs to the shareholder, not the corporation. The court found the appeal neither constitutionally nor equitably moot, determined that procedural hurdles were met, and reversed the bankruptcy court’s denial of the founder’s motions. The case was remanded for further proceedings consistent with the Eleventh Circuit’s opinion. View "Owoc v. The Liquidating Trustee on Behalf of the Liquidating Trust" on Justia Law

Waller v. Board of Regents of the University System of Georgia

2026-08-10T08:02:51-08:00

A student enrolled in a respiratory therapy program at a public university in Georgia was disciplined following an incident during his clinical externship, where he was found responsible for endangering the health or safety of a patient. As a result, the university assigned him a failing grade in his clinical class. The student, who has attention deficit disorder, anxiety, and depression, alleged that university personnel were aware of his conditions. He claimed that prior to the disciplinary hearing, he was denied access to evidence and that the hearing procedures did not comply with the university’s written policies. After exhausting internal university appeals, the student filed a lawsuit in Georgia state court against the Board of Regents and several employees, asserting breach of contract and disability discrimination under the Americans with Disabilities Act and the Rehabilitation Act, among other claims. The case was removed to the United States District Court for the Middle District of Georgia. The district court dismissed the breach of contract claim on the basis of state sovereign immunity, finding no enforceable written contract that would waive immunity. The court also dismissed the disability discrimination claims for failure to state a claim, holding that the complaint did not plausibly allege adverse action taken because of the student’s disability. The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that neither the admission letter nor the student handbook, alone or together, constituted a written contract sufficient to waive Georgia’s sovereign immunity, as neither document set forth all essential terms, especially as to consideration. The court further held that the student’s complaint failed to plausibly allege that the university’s actions were taken because of his disabilities. Accordingly, the Eleventh Circuit affirmed the district court’s dismissal of the student’s breach of contract and disability discrimination claims. View "Waller v. Board of Regents of the University System of Georgia" on Justia Law

USA v. Ponce

2026-08-07T12:02:17-08:00

The case centers on a drug-related shootout in Orlando, Florida, in which Cristian Ponce, a convicted felon, was involved. On November 2, 2022, Ponce was a passenger in a vehicle with his co-conspirator, Savier Hernandez, when two rival drug dealers approached. A gunfight ensued, resulting in the deaths of Hernandez and one of the rivals, Eminem Esquilin. Evidence, including drugs and firearms, linked Ponce to ongoing drug distribution. After the incident, additional searches recovered more drugs, firearms, and communications indicating Ponce’s involvement in drug sales and awareness of rival territories. A grand jury indicted Ponce on four counts related to drug distribution and firearms offenses, but not murder. He pleaded guilty to all counts. The United States District Court for the Middle District of Florida, during sentencing, applied the murder cross-reference under U.S.S.G. § 2D1.1(d)(1), which increased Ponce’s offense level by referencing the guideline for second-degree murder. The court found that the shooting, as part of a drug conspiracy, was reasonably foreseeable and that Ponce had negligently placed himself in a situation requiring criminal conduct. Ponce objected, arguing the shooting was in self-defense and that he was not the aggressor. The district court overruled his objections and sentenced him to 240 months in prison. The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that the murder cross-reference was properly applied because Ponce was accountable for the actions of his co-conspirator under the relevant conduct guidelines. The court also concluded that Ponce could not claim self-defense, as he negligently placed himself in a dangerous situation by bringing firearms to sell drugs on a rival’s turf, thereby failing to meet the requirements for a justification defense. View "USA v. Ponce" on Justia Law

Key v. Dynamic Security, Inc.

2026-08-05T12:01:58-08:00

A woman applied for a mailroom position with a security company that provided services at an automobile manufacturing plant. The company had a grooming policy prohibiting certain hairstyles, including locs. During her interview, concerns about her hairstyle were raised, but she was hired after showing a picture of her hair styled in an "updo." She began work with her locs, but was sent home because of her hair. After subsequent discussions and expressing concerns about discrimination, she was ultimately not allowed to return to work. She filed complaints with the Equal Employment Opportunity Commission (EEOC), naming individuals involved, and later received a right-to-sue letter for one of her charges, but maintains she never received the letter for the other. She filed suit in the United States District Court for the Middle District of Alabama, alleging race and pregnancy discrimination and retaliation under Title VII and 42 U.S.C. § 1981 against several defendants. The district court dismissed disparate-impact claims and all Title VII claims against one defendant, then granted summary judgment on all claims against two defendants, and on all but one retaliation claim against the security company. That retaliation claim went to a jury, which awarded substantial damages. The district court denied the security company’s motion to strike her jury demand, finding no knowing and intentional waiver of her right to a jury trial. The United States Court of Appeals for the Eleventh Circuit affirmed dismissals and summary judgment for two defendants and on the race discrimination claim against the security company. However, it held that the district court erred by presuming timely receipt of the right-to-sue letter at summary judgment and by failing to properly instruct the jury on the protected activity element of retaliation. The court vacated the judgment against the security company and remanded for a new trial on the remaining claims. View "Key v. Dynamic Security, Inc." on Justia Law

USA v. Romain

2026-08-05T08:32:13-08:00

Several individuals affiliated with an organization headquartered in Florida, which advocates for the rights of African people worldwide, developed a close relationship with a Russian citizen who directed a Russian government-backed group. Over the course of several years, this Russian contact funded trips to Russia for organization leaders, sponsored events, and directed them to produce and disseminate pro-Russian statements and media. These individuals participated in activities at the direction of the Russian contact, including authoring petitions, organizing demonstrations, publishing statements, recording videos, and protesting at the request of their Russian counterpart. None of them notified the U.S. Attorney General as required by law for acting as agents of a foreign government. A federal grand jury indicted three organization members and one former member for acting as unregistered agents of a foreign government under 18 U.S.C. § 951(a), and for conspiracy to do so under 18 U.S.C. § 371. After a jury trial in the United States District Court for the Middle District of Florida, the defendants were found guilty of conspiracy but not of the substantive offense. The district court sentenced the former member to 60 months’ probation and the other three to 36 months’ probation. The defendants raised several arguments on appeal, including claims that the statute was unconstitutional as applied, that the evidence was insufficient, that evidentiary and jury instruction errors occurred, and that there was prosecutorial misconduct. The United States Court of Appeals for the Eleventh Circuit held that 18 U.S.C. §§ 951 and 371 are constitutional as applied, as they are content-neutral and survive intermediate scrutiny. The Court found sufficient evidence to support the conspiracy convictions, ruled that the district court did not abuse its discretion regarding jury instructions or evidentiary rulings, and found no prosecutorial misconduct. The convictions were affirmed. View "USA v. Romain" on Justia Law

L.E. v. Superintendent of Cobb County School District

2026-08-05T07:02:36-08:00

Four students with disabilities, who attended public schools in Cobb County, Georgia, challenged the school district’s COVID-19 masking policy. Initially, the district required masks, but later implemented a policy prohibiting mask mandates, allowing voluntary mask-wearing only. The students’ disabilities made them particularly vulnerable to respiratory viruses. When the district declined their requests for stricter COVID accommodations, including mandatory masks, all four switched to virtual learning; eventually, two left for private schools due to the district’s refusal. The students alleged that the district’s blanket ban prevented individualized consideration of their health needs, causing them to lose access to in-person education. The students filed suit in the United States District Court for the Northern District of Georgia under Title II of the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act (RA), seeking damages and a preliminary injunction to require the district to consider their masking requests. The district court dismissed two students (A.Z. and C.S.) for lack of standing after they unenrolled, and denied injunctive relief for the remaining two (B.B. and L.E.), finding they were unlikely to succeed on the merits because the district had already provided reasonable accommodations. On a prior appeal, the United States Court of Appeals for the Eleventh Circuit remanded for reconsideration, emphasizing the need to focus on access to in-person schooling. On appeal again, the United States Court of Appeals for the Eleventh Circuit held that all four students had standing, including those who had switched to private schools, because standing is determined at the time of filing and claims for past damages remain viable. The court affirmed denial of the preliminary injunction for B.B. and L.E., concluding the district’s accommodations had been effective and mandatory masking was not necessary for equal access. The court reversed the dismissal of A.Z. and C.S. for lack of standing and remanded for the district court to address the merits of their claims. View "L.E. v. Superintendent of Cobb County School District" on Justia Law

USA v. Alli

2026-08-05T05:31:55-08:00

During the COVID-19 pandemic, Congress established a program to provide emergency loans and grants to small businesses impacted by the crisis. Almar Sales and Services, Inc.—with Alexander Alli as its principal owner—submitted a loan application to the Small Business Administration (SBA) under this program, falsely stating it was based in Minnesota, had two employees, and claimed $250,000 in gross revenues. The SBA approved the application, granting $2,000 and later issuing an $80,500 loan. Alli signed the loan documents and received the funds, which he used in part to purchase two trucks, but only made one payment before the loan was charged off. Subsequent investigation revealed numerous false representations in the application, including business location, revenue, and citizenship status. The United States District Court for the Middle District of Florida reviewed the case after a grand jury indicted Alli on one count of conspiracy to commit wire fraud and two counts of wire fraud. Before trial, the prosecution sought to exclude certain portions of Alli’s interviews with a Homeland Security agent. The district court ruled that most of Alli’s requested excerpts were inadmissible hearsay, though it allowed some additional context where needed. The court also instructed the jury on Pinkerton liability and deliberate ignorance over Alli’s objections. After trial, the jury convicted Alli on all counts, and he was sentenced to 13 months’ imprisonment and ordered to pay restitution. The United States Court of Appeals for the Eleventh Circuit reviewed the evidentiary rulings, sufficiency of evidence, and jury instructions. The court held that the district court did not err in its application of the rule of completeness regarding Alli’s interviews, found sufficient evidence supported the conspiracy conviction, and upheld the jury instructions on Pinkerton liability and deliberate ignorance. The Eleventh Circuit affirmed Alli’s convictions. View "USA v. Alli" on Justia Law

USA v. Lambert

2026-08-04T12:32:19-08:00

At a daycare facility located on a military base in Georgia, two teachers in a toddler classroom abused children over several months. The director of the facility, who had access to video monitors of all classrooms and regularly used them to monitor staff, received multiple reports from workers about inappropriate conduct by the teachers, including cursing at children and playing profane music. One worker specifically expressed discomfort, reported the behavior to the director, and refused to work in the classroom further out of concern for the children’s safety. The director did not make a report of suspected child abuse until prompted by a later conversation with another employee, by which time the abuse had been ongoing and captured on video. After the abuse came to light, the United States District Court for the Middle District of Georgia presided over the criminal case. The two teachers pled guilty to cruelty to children. The director was indicted for failure to report suspected child abuse, among other charges. A jury acquitted her of being an accessory after the fact and making false statements, but convicted her of failing to report, and the district court imposed a sentence of probation. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed whether the evidence was sufficient to support the director’s conviction under 18 U.S.C. § 2258. The Eleventh Circuit held that a reasonable jury could infer the director had reason to suspect children suffered mental injury, given the reports she received and her access to video evidence. The court concluded the evidence was sufficient and affirmed the conviction. View "USA v. Lambert" on Justia Law

Curry v. Warden

2026-08-04T12:02:41-08:00

The case involves a fatal car crash in Escambia County, Alabama, in which Estella Curry, while driving at a high speed and under the influence of multiple medications, collided with Richard Walker’s vehicle. The crash caused Walker’s death, and Curry was indicted for reckless murder. Prior to trial, Curry expressed dissatisfaction with her appointed counsel and made several pro se motions seeking his removal and requesting to represent herself. The trial court denied these motions, finding her requests equivocal and ultimately deciding she had not made a clear, unequivocal demand for self-representation. Curry was tried in the Circuit Court of Escambia County, Alabama, where the jury found her guilty of reckless murder, based on evidence including her excessive speed and impairment due to drugs. The trial court denied Curry’s motions for judgment of acquittal. On appeal to the Alabama Court of Criminal Appeals, Curry challenged her conviction, arguing errors in the denial of self-representation, competency rulings, and sufficiency of the evidence. The appellate court affirmed the conviction. Curry then pursued post-conviction relief under Rule 32 of the Alabama Rules of Criminal Procedure, which was dismissed, and that dismissal was affirmed by the appellate courts, with the Alabama Supreme Court denying certiorari. The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s denial of Curry’s federal habeas corpus petition. The Eleventh Circuit affirmed the district court’s judgment, holding that Curry did not qualify for the Martinez v. Ryan exception for procedurally defaulted ineffective-assistance-of-counsel claims, that she did not make a clear and unequivocal request for self-representation, and that the evidence supporting her conviction was not based on an unreasonable determination of the facts or law. The district court’s denial of habeas relief was affirmed. View "Curry v. Warden" on Justia Law

Phillips v. City of Hanceville

2026-08-04T12:02:40-08:00

Joshua Phillips visited a police station in Hanceville, Alabama, intending to file a complaint against an officer. During his visit, he had an argument with Officers Kyle Duncan and Josh Howell, leading to his arrest. Phillips alleged that excessive force was used during his arrest and that Deputy Chief Adam Hadder assaulted him later while Phillips was in jail. The events were largely captured on body-worn and closed-circuit cameras, with some details based on Phillips’s account where no video existed. Phillips was initially charged with disorderly conduct and resisting arrest, but the charges were later dropped. The United States District Court for the Northern District of Alabama reviewed Phillips’s claims under 42 U.S.C. § 1983, which included false arrest, retaliatory arrest, and excessive force under the Constitution. The district court granted summary judgment in favor of the officers and the City of Hanceville, finding that the officers had probable cause for the arrest and only used de minimis force. The district court also found no basis for municipal liability because it concluded there was no underlying constitutional violation. Reviewing the appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s summary judgment. The appellate court held that the officers were entitled to qualified immunity because they had probable cause to arrest Phillips for disorderly conduct and trespass, and any force used was de minimis and reasonable under the circumstances. The court also concluded that Phillips’s retaliatory arrest claim failed due to the existence of probable cause, and there was no evidence of excessive force by any officer. Because there was no constitutional violation, the City could not be held liable. The court therefore affirmed the judgment for the officers and the City. View "Phillips v. City of Hanceville" on Justia Law

Pasqual-Andres v. U.S. Attorney General

2026-08-04T11:31:57-08:00

A Guatemalan citizen entered the United States as a minor and was subsequently charged with removability for being present in the country without authorization. Represented by counsel, he conceded his inadmissibility and applied for asylum, withholding of removal, and relief under the Convention Against Torture. After a merits hearing, the immigration judge denied all forms of relief, finding the applicant not credible and concluding that he had not sufficiently alleged persecution or established membership in a cognizable social group. The judge also found he was ineligible for withholding of removal and CAT relief. The applicant appealed to the Board of Immigration Appeals (BIA), submitting a brief that was labeled pro se but had been prepared by his former counsel. The brief inadequately challenged the judge’s findings and contained errors. The BIA dismissed the appeal, agreeing with the immigration judge’s reasoning and noting the applicant failed to contest several key findings. Subsequently, new counsel filed a motion to reopen based on ineffective assistance of prior counsel, arguing that the prior brief was so deficient as to be functionally no representation at all. The applicant documented that he had filed a complaint with the Executive Office for Immigration Review (EOIR) Disciplinary Counsel regarding his former counsel’s conduct. The BIA denied the motion, holding that he failed to comply with the third Lozada requirement because he did not file a complaint with the state bar. The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that reporting prior counsel to the EOIR Disciplinary Counsel satisfies the requirement in Matter of Lozada to file a complaint with “appropriate disciplinary authorities.” The court concluded that the BIA abused its discretion in requiring a state bar complaint as the only means of compliance. The Eleventh Circuit vacated the BIA’s decision and granted the petition for review. View "Pasqual-Andres v. U.S. Attorney General" on Justia Law

Deltona Transformer Corporation v. The Noco Company

2026-08-04T09:03:07-08:00

A manufacturer of battery chargers, which owns the registered trademarks “Battery Tender” and “Deltran Battery Tender,” discovered that a competitor began advertising its own similar chargers using those terms. The competitor used the marks in multiple ways: purchasing them as keywords to trigger ads on Amazon, including the marks in the text of its Amazon ads and product descriptions, and referring to its own products as “battery tenders” in communications with marketing firms and consumers. The trademark owner sent several cease-and-desist letters, but the conduct continued. The company then sued the competitor for trademark infringement, unfair competition, false designation of origin, and related state law claims. In the United States District Court for the Middle District of Florida, a jury found in favor of the trademark owner on all counts, including trademark infringement and false advertising, and awarded damages. The district court denied the competitor’s motions for judgment as a matter of law and for a new trial, and later ordered disgorgement of profits and issued a permanent injunction prohibiting the competitor from using the marks, as well as the term “tender,” in connection with its products. The competitor appealed, challenging the jury’s findings, the district court’s legal rulings, and the scope of the injunction and damages. The United States Court of Appeals for the Eleventh Circuit held that the “Battery Tender” marks were not generic, but at least descriptive with secondary meaning, and affirmed the finding of trademark infringement for visible uses of the marks. However, the court held that purchasing the marks as keywords alone does not constitute infringement, reversed the jury’s verdict on false advertising, and vacated the damages award for a new trial, as the amount could not be separated from improper theories. The court affirmed the injunction and disgorgement order. View "Deltona Transformer Corporation v. The Noco Company" on Justia Law

HM Florida-ORL, LLC v. Secretary of the Florida Department of Business

2026-08-04T07:32:22-08:00

A restaurant in Florida that hosts drag performances challenged the constitutionality of a state law known as the Protection of Children Act. The Act makes it a misdemeanor to knowingly admit a child to an “adult live performance,” defined as shows depicting nudity, sexual conduct, or lewd conduct, and meeting additional criteria based on prurient appeal, offensiveness to community standards for the age of the child present, and lack of serious value for that age. The restaurant argued that the Act’s use of the word “lewd” and its age-variable standards rendered the law unconstitutionally vague and overbroad, alleging harm to its business and chilling of its performances. The United States District Court for the Middle District of Florida granted a preliminary injunction, finding the Act unlikely to survive strict scrutiny and to be unconstitutionally vague and overbroad. The injunction barred the Secretary of the Florida Department of Business and Professional Regulation from enforcing the Act against anyone in the state. This decision was affirmed by a divided panel of the United States Court of Appeals for the Eleventh Circuit, but the full court granted rehearing en banc, stayed the injunction as to nonparties, and requested briefing on the scope and merits of the case. The United States Court of Appeals for the Eleventh Circuit, on en banc review, vacated the preliminary injunction in its entirety. The court held that the district court lacked authority to issue a universal injunction barring enforcement of the Act statewide, as such relief exceeds a federal court’s equitable power. Furthermore, the court found the Act’s language, as construed by Florida precedent, did not render it unconstitutionally vague or overbroad, and Hamburger Mary’s was not substantially likely to succeed on the merits. The matter was remanded for further proceedings consistent with this opinion. View "HM Florida-ORL, LLC v. Secretary of the Florida Department of Business" on Justia Law

City of Brunswick v. Honeywell International, Inc.

2026-08-03T11:31:54-08:00

A city in Georgia experienced ongoing pollution of its property from hazardous substances, including mercury and PCBs, allegedly released as a result of historical industrial operations at a nearby plant site. Georgia Power initially owned the site and later sold it to a Honeywell predecessor, with both companies involved in activities that contributed to the contamination. Over decades, these pollutants migrated into the city’s property and surrounding waterways. In the 1990s, the Environmental Protection Agency (EPA) intervened and required the companies to investigate and remediate the site’s contamination under its oversight, culminating in a consent decree that obligated the companies to implement EPA’s official remediation plan. The city filed suit in Georgia’s Superior Court of Glynn County, asserting state-law claims for continuing nuisance and trespass, seeking damages and remediation costs. The defendants removed the case to the United States District Court for the Southern District of Georgia, arguing several grounds for federal jurisdiction, including federal officer removal under 28 U.S.C. § 1442(a)(1). The district court rejected all removal grounds and remanded the case to state court, finding that the defendants were not “acting under” a federal officer. The defendants appealed the remand order while litigation continued in state court. The United States Court of Appeals for the Eleventh Circuit held that it had jurisdiction to review the remand order, finding that the defendants’ notice of appeal triggered an automatic stay of the district court’s remand, rendering subsequent state court proceedings void for these purposes. On the merits, the court held that federal officer removal was proper because the defendants’ remediation obligations arose from and were controlled by the EPA under a consent decree. The court reversed the district court’s remand order, allowing the case to proceed in federal court. View "City of Brunswick v. Honeywell International, Inc." on Justia Law

USA v. Pineda-Torres

2026-08-03T11:01:47-08:00

Coast Guardsmen intercepted two stateless vessels in international waters, each carrying large quantities of cocaine traveling from Colombia to Mexico. Alonso Pineda-Torres, a Colombian citizen and resident, was involved in planning and preparing these smuggling operations, including paying crewmembers and assisting with a launch from Colombia. After his extradition to the United States, he was indicted under the Maritime Drug Law Enforcement Act for conspiracy to distribute and possess cocaine on a vessel subject to U.S. jurisdiction. In the United States District Court for the Middle District of Florida, Pineda-Torres initially pleaded not guilty, but later entered a plea agreement, admitting involvement in the operation. He moved to dismiss the indictment, arguing the court lacked jurisdiction because his conduct occurred abroad and he was not captured in international waters. The district court denied his motion, and he subsequently pleaded guilty. The United States Court of Appeals for the Eleventh Circuit reviewed the constitutionality of the statute as applied to Pineda-Torres. He argued the statute was invalid because his acts lacked a nexus to the United States and occurred solely in Colombia. The Eleventh Circuit rejected these arguments, relying on its precedent that the Act’s extraterritorial reach is supported by universal and protective principles, and that no nexus to the United States is required. The court held that, even if the Felonies Clause alone did not provide authority, the Necessary and Proper Clause empowered Congress to criminalize conspiracies to commit drug trafficking on the high seas, including land-based conduct like Pineda-Torres’s. Accordingly, the Eleventh Circuit affirmed the conviction, holding Congress had constitutional authority to punish this kind of conspiracy involving drug trafficking in international waters. View "USA v. Pineda-Torres" on Justia Law

USA v. Hernandez

2026-07-31T11:32:31-08:00

A nurse practitioner was accused of orchestrating a large-scale Medicare fraud scheme beginning in 2018. The evidence showed that she signed prescriptions for durable medical equipment and genetic testing that were medically unnecessary, often without examining patients or verifying their needs. She worked with telemarketers who cold-called Medicare beneficiaries, fabricated records, and sold prescriptions to medical providers who then billed Medicare. The practitioner received significant kickbacks for her participation and later recruited others to help. When government investigations targeted similar schemes, she attempted to cover her tracks but continued fraudulent conduct by billing for nonexistent telemedicine appointments, at times claiming over twenty-four hours of appointments in a single day. Ultimately, she received more than $1.66 million from these activities, and law enforcement discovered a written confession during a search of her residence. A grand jury indicted her on conspiracy, health care fraud, and false statement charges. Pretrial, the United States District Court for the Southern District of Florida denied her motion to exclude her written statement, finding the attorney-client privilege was waived. During jury selection, her request to strike a potentially biased juror for cause was denied, forcing her to use a peremptory challenge. At trial, disputes arose over the introduction of her inculpatory statement, and the court allocated more time for the government’s closing argument than for her defense. The jury found her guilty, and she was sentenced based on intended loss, not just actual billed amounts, despite her objections. The United States Court of Appeals for the Eleventh Circuit reviewed her claims, including the unequal allocation of closing argument time, a misstatement in oral jury instructions, jury selection issues, the handling of her statement, and sentencing calculations. The court held that although the district court abused its discretion by giving the government more closing argument time based solely on its burden of proof, this error was harmless due to overwhelming evidence of guilt. The court found no reversible error on the other grounds and affirmed her conviction. View "USA v. Hernandez" on Justia Law

Jones v. USA

2026-07-30T09:02:36-08:00

Two individuals were bowfishing on Lake Guntersville in Alabama when their boat collided with an unmarked, partially submerged duck blind, resulting in severe injuries. The duck blind, built by unknown persons prior to 2007, was affixed to land owned by the Tennessee Valley Authority (TVA), a federally owned corporation. The United States Coast Guard, the U.S. Army Corps of Engineers, and the TVA all have regulatory responsibilities over the lake, which is a navigable waterway. The plaintiffs alleged negligence and wantonness, claiming that the United States and the TVA failed to mark, remove, or warn about the hazard. The plaintiffs filed suit in the United States District Court for the Northern District of Alabama under two statutes: the Suits in Admiralty Act (SAA) and the TVA Act. Defendants moved to dismiss, arguing that the discretionary-function exception from the Federal Tort Claims Act (FTCA) shielded them from liability. The district court granted the motion, finding that the SAA's waiver of sovereign immunity was subject to the FTCA’s discretionary-function exception and that the conduct at issue was discretionary. On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s dismissal of all claims against the United States, holding that binding circuit precedent recognizes a discretionary-function exception under the SAA, which bars such claims. However, the Eleventh Circuit reversed the dismissal of the claims against the TVA under the TVA Act. The court held that the TVA’s sue-and-be-sued clause is not subject to the discretionary-function exception, allowing the plaintiffs’ claims against the TVA to proceed. The case was remanded for further proceedings against the TVA only. View "Jones v. USA" on Justia Law

The Town of Pine Hill, Alabama v. 3M Company

2026-07-29T07:31:42-08:00

A municipality in Alabama brought a lawsuit against a chemical manufacturer, alleging that the company’s products containing per- and poly-fluoroalkyl substances (PFAS) contaminated the Alabama River. The contamination allegedly originated from PFAS-containing wastewater discharged by paper mills, which used the manufacturer’s products. The municipality relies on water from the river for its drinking supply, and PFAS are difficult to remove with its current filtration system, necessitating expensive upgrades. After being sued in Alabama state court for negligence, nuisance, and trespass, the manufacturer removed the case to the United States District Court for the Southern District of Alabama, asserting jurisdiction under the federal officer removal statute. The municipality expressly disclaimed any claims related to PFAS contamination from aqueous film forming foam (AFFF), a firefighting product produced by the manufacturer for the military. The district court found that the heart of the claims was the supply of PFAS products to paper mills, not federal conduct, and remanded the case to state court. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court's decision de novo. The appellate court held that the manufacturer sufficiently alleged facts supporting federal officer removal jurisdiction. It concluded that the manufacturer plausibly acted under a federal officer when producing AFFF and that the complaint’s gravamen encompassed PFAS contamination generally, not just from paper mills. The court found the municipality’s disclaimers to be mere artful pleading that did not sever the causal connection required for removal. The manufacturer also plausibly asserted a colorable federal government contractor defense. Accordingly, the Eleventh Circuit vacated the district court’s remand order and remanded the case for further proceedings. View "The Town of Pine Hill, Alabama v. 3M Company" on Justia Law

African People's Education and Defense Fund, Inc. v. Pinellas County

2026-07-29T05:01:41-08:00

A nonprofit organization in Florida, serving the Black community in St. Petersburg, applied twice for COVID-19 relief grants from funds distributed by Pinellas County. The group’s first grant application was initially approved, but after a newly seated Board member raised concerns about the group’s association with the “Uhuru Movement” and its perceived ties to Black empowerment and alleged antisemitic organizations, the Board revoked the grant. The group’s second application, for a backup generator, was later denied despite being highly ranked by an independent review foundation. The nonprofit alleged that similar grants were awarded to other organizations serving predominantly white communities for comparable purposes. After the denial, the nonprofit sued Pinellas County in the United States District Court for the Middle District of Florida, alleging violations of the First Amendment (retaliation for expressive association), the Equal Protection Clause (racial discrimination), and the Due Process Clause (lack of notice and opportunity to be heard). The district court dismissed all claims with prejudice, concluding there was no actionable First Amendment or equal protection violation and that the nonprofit did not have a property interest protected by due process. The United States Court of Appeals for the Eleventh Circuit reviewed the appeal. It held that the nonprofit plausibly alleged First Amendment retaliation, as the facts showed the county may have revoked and denied grants based on the group’s expressive association, and that the organization was entitled to full First Amendment protection as a grant applicant. The court also held that the nonprofit stated a plausible claim for intentional racial discrimination under the Equal Protection Clause. However, the panel affirmed dismissal of the due process claim, finding the nonprofit lacked a constitutionally protected property interest in the grants. The case was affirmed in part, reversed in part, and remanded for further proceedings. View "African People's Education and Defense Fund, Inc. v. Pinellas County" on Justia Law

Davis v. Lockheed Martin Corp.

2026-07-28T11:32:05-08:00

The key facts concern allegations that Lockheed Martin improperly handled volatile organic compounds at its Orlando facility, resulting in environmental contamination that plaintiffs claim caused neurological illnesses, including multiple sclerosis and Parkinson’s disease, among workers and nearby residents. Plaintiffs relied on expert testimony to show that exposure to specific chemicals could cause the diseases in question. In the United States District Court for the Middle District of Florida, the plaintiffs presented two general causation experts who used epidemiological and other scientific methodologies to link the chemicals to the illnesses. Lockheed Martin challenged the admissibility of these experts’ opinions, arguing they were unreliable. The district court agreed, finding that the first expert failed to adequately explain or reliably apply his “weight of the evidence” methodology and did not sufficiently analyze the Bradford Hill factors. The second expert’s opinions were largely based on the first expert’s report and a statistical analysis that did not properly assess background risk. As a result, the district court excluded both experts’ testimony and granted summary judgment for Lockheed Martin, concluding that plaintiffs lacked admissible general causation evidence. In the related DeMilt case, the summary judgment was partial, but the district court certified it for immediate appeal under Rule 54(b). The United States Court of Appeals for the Eleventh Circuit reviewed whether the district court abused its discretion in excluding the experts and granting summary judgment. The appellate court held that the district court acted within its discretion, as the experts did not adequately explain or reliably apply their methodologies, and their testimony was thus properly excluded. Without this expert evidence, plaintiffs could not establish general causation. The Eleventh Circuit affirmed the district court’s orders excluding the experts and granting summary judgment in favor of Lockheed Martin. View "Davis v. Lockheed Martin Corp." on Justia Law

Bay United Holdings, LLC. v. INXS VII, LLC

2026-07-24T09:33:04-08:00

A company filed for Chapter 11 bankruptcy, which was later converted to Chapter 7. The trustee identified multiple parcels of real property that had been transferred to affiliated entities for no consideration, claiming these transfers were fraudulent. The parties settled, and it was agreed that the properties would be treated as assets of the bankruptcy estate and sold free and clear of liens, claims, and interests. The Bankruptcy Court approved the settlement and sale, ordering that any claims against the sale proceeds must be filed within thirty days. Cloud 9 Properties, LLC filed three claims related to the properties, attaching mortgage documents but initially lacking promissory notes. After an objection was raised due to insufficient evidence of debt owed to Cloud 9, Cloud 9 submitted the notes, but they showed the debts were actually owed to other entities at the relevant time. The United States Bankruptcy Court for the Middle District of Florida granted summary judgment for the objector, INXS VII, LLC, disallowing all of Cloud 9’s claims because Cloud 9 did not own the notes at the time the claims were filed. The District Court for the Middle District of Florida affirmed this decision, holding that only a party with an enforceable right to payment at the time of filing could assert a valid claim in bankruptcy. Bay United Holdings, LLC, which had been assigned Cloud 9’s claims, appealed, arguing that the existence of the mortgages justified the claims and that strict foreclosure standards should not apply in bankruptcy. The United States Court of Appeals for the Eleventh Circuit affirmed the District Court’s ruling. The court held that in bankruptcy, a creditor must demonstrate it has the right to enforce its claim at the time of filing. If a claimant cannot establish its entitlement to payment when the claim is filed, the claim is properly disallowed. The court rejected arguments for equitable relief and clarified that the validity of a claim in bankruptcy depends on enforceability under applicable state law. View "Bay United Holdings, LLC. v. INXS VII, LLC" on Justia Law

Carrin v. Smiledge

2026-07-23T11:32:32-08:00

Raymond Carrin was a federal detainee diagnosed with Hepatitis C who sought medical treatment while in custody at the Federal Detention Center in Tallahassee, Florida. Despite Carrin’s repeated requests and visible deterioration over more than a year—including emergency hospitalizations and symptoms consistent with advanced liver disease—medical staff did not provide him with the direct-acting antiviral treatment prescribed for his condition. The facility’s staff indicated that treatment would only begin once Carrin was transferred to his designated institution, a transfer that was delayed for various reasons. Carrin eventually died from hepatic cirrhosis without receiving the necessary medication. He did not file a formal grievance or seek relief under the prison’s Administrative Remedy Program (ARP) before his death. Carrin’s estate brought suit in the United States District Court for the Northern District of Florida against two federal prison officials, alleging violations of Carrin’s Fifth and Eighth Amendment rights and seeking damages under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 (1971). The district court initially denied the defendants’ motions to dismiss and for summary judgment. However, after the Eleventh Circuit’s decision in Johnson v. Terry, 119 F.4th 840 (11th Cir. 2024), the court granted judgment on the pleadings for the defendants, holding that the presence of the ARP constituted a special factor counseling against extending Bivens to these claims, and that Carrin’s case differed meaningfully from prior Supreme Court Bivens precedents. On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s dismissal. The court held that both the Eighth and Fifth Amendment claims arose in a new context distinct from Carlson v. Green, 446 U.S. 14 (1980), and that the existence of the ARP—regardless of its adequacy or accessibility to the estate—was a special factor precluding the extension of Bivens remedies. View "Carrin v. Smiledge" on Justia Law

Rodriguez v. Imperial Brands, PLC.

2026-07-23T05:01:45-08:00

Several U.S. nationals, descendants of Ramón Rodriguez Gutiérrez, alleged that their family’s property in Cuba was confiscated by the Cuban government in 1961. They claimed ownership of a significant interest in a Havana cigarette factory and an adjacent mixed-use building, both seized as part of the nationalization of the tobacco industry. The plaintiffs sued multiple corporations, including two British companies, asserting that these entities had trafficked in the confiscated property in violation of the Helms-Burton Act by marketing and publicizing Cuban tobacco products made at the seized factory, including activities on U.S.-based social media platforms. The United States District Court for the Southern District of Florida reviewed the case after the plaintiffs filed a second amended complaint. Following jurisdictional discovery, a magistrate judge recommended dismissal for improper venue for some defendants, and for lack of personal jurisdiction for others, specifically Imperial Brands and WPP. The district court adopted the recommendation to dismiss the claims against these British corporations, finding that the plaintiffs had failed to establish personal jurisdiction under Federal Rule of Civil Procedure 4(k)(2), as their alleged U.S.-related activities were insufficient to confer jurisdiction. The United States Court of Appeals for the Eleventh Circuit examined whether federal courts could exercise personal jurisdiction over Imperial Brands and WPP in light of the Supreme Court’s decision in Fuld v. Palestine Liberation Organization. The Eleventh Circuit held that the Fifth Amendment imposes a “reasonableness” standard for personal jurisdiction over foreign defendants. Applying this standard, the court found that neither Imperial Brands nor WPP had sufficient notice, meaningful U.S. connections, or presence to justify jurisdiction. The court concluded that subjecting these companies to U.S. jurisdiction would be unreasonable and affirmed the district court’s dismissal for lack of personal jurisdiction. View "Rodriguez v. Imperial Brands, PLC." on Justia Law

USA v. Rivera

2026-07-22T12:31:45-08:00

A man became involved with a woman who had a minor daughter. After the woman and her daughter moved in with him, the man’s relationship with the daughter deteriorated, especially after he assaulted her mother. Despite the girl’s reluctance to engage with him, he persistently attempted to discuss her personal and sexual life and offered her gifts. Unbeknownst to her, these gifts—a Bluetooth speaker, a USB charger, and a digital picture frame—each contained hidden recording devices, which he installed in her bedroom. The girl’s mother discovered the hidden cameras after breaking up with the man and notified authorities. Investigators found evidence on the man’s phones linking him to the purchase and use of the devices, as well as sexually explicit images and videos of the girl changing clothes, which were recovered from his devices. The United States District Court for the Middle District of Florida presided over the trial. The government provided notice of its intent to introduce evidence of prior similar acts, specifically testimony from another woman who alleged that the defendant had sexually abused her as a minor. During trial, this witness’s testimony included a statement that went beyond what was disclosed in the government’s pretrial notice. The defense objected, moved for a mistrial, and requested that all of the witness’s testimony be stricken, arguing it was unreliable and unduly prejudicial. The district court struck only the unexpected portion, issued curative instructions to the jury, and denied the motions for mistrial and to strike all testimony. The jury convicted the defendant on all counts, and he was sentenced to 262 months’ imprisonment. On appeal, the United States Court of Appeals for the Eleventh Circuit held that the district court did not abuse its discretion in admitting the prior-act evidence, denying a mistrial, or refusing to strike all of the witness’s testimony. The court also held that the evidence was sufficient to support the convictions under 18 U.S.C. § 2251. The convictions were affirmed. View "USA v. Rivera" on Justia Law

Savannah Shoals, LLC v. Commissioner of Internal Revenue

2026-07-16T12:02:07-08:00

A developer purchased approximately 430 acres in Georgia and later sold a 103-acre tract to an investment company. This company, Savannah Shoals, LLC, planned to donate a conservation easement over the 103-acre tract. Expert testing determined that the property contained materials suitable for use as crushed rock aggregate, and an expert report valued the potential of an aggregate quarry on the property at $23.1 million. Savannah Shoals then completed a series of transactions to acquire and transfer membership interests in the property, after which it granted the conservation easement and claimed a $23 million tax deduction for its donation. The Internal Revenue Service (IRS) disallowed the deduction, arguing that Savannah Shoals had grossly overstated the value of the easement. The IRS issued a Final Partnership Administrative Adjustment, finding the deduction unsupported and imposing a 40% penalty for gross valuation misstatement. Savannah Shoals challenged these findings in the United States Tax Court. After a four-day trial with expert testimony, the Tax Court concluded that the property’s highest and best use was not as an aggregate quarry, but rather for low-density residential and recreational purposes. Relying on comparable sales and the actual transaction value, the Tax Court determined the easement’s value to be $480,000 and upheld the 40% penalty. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the Tax Court’s decision. The Eleventh Circuit held that the Tax Court was not required to apply a specific four-factor test for highest and best use and that its focus on market demand and feasibility was appropriate under the law and regulations. The appellate court also found no abuse of discretion in the admission of expert testimony and concluded that the Tax Court’s factual findings were not clearly erroneous. The judgment of the Tax Court was affirmed. View "Savannah Shoals, LLC v. Commissioner of Internal Revenue" on Justia Law

Estate of Caviness v. Atlas Air, Inc.

2026-07-10T05:31:52-08:00

A group of employees in the commercial aviation sector challenged their employers’ COVID-19 policies, which required vaccination unless a religious or medical exemption was obtained. Those with exemptions had to comply with periodic testing and mask-wearing. The plaintiffs objected to the requirements on religious and personal grounds, alleging that the accommodations for religious objectors were inadequate and burdensome. While the complaint did not claim anyone was terminated, it did allege some employees were assigned to less desirable flights due to these policies. The United States District Court for the Southern District of Florida dismissed all claims against Flight Services International and certain claims against Atlas Air for lack of personal jurisdiction. The court also dismissed the remaining claims against Atlas Air for failure to state a claim. The plaintiffs then appealed to the United States Court of Appeals for the Eleventh Circuit. The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The appellate court held that there was no personal jurisdiction over Flight Services International because it was neither incorporated nor headquartered in Florida, and the alleged contacts with Florida were insufficient for either general or specific jurisdiction. Regarding Atlas Air, the court found that the plaintiffs failed to state a plausible claim under Title VII, as there were no facts suggesting religious discrimination or hostile intent. The court held that the plaintiffs could not bring claims under the Federal Food, Drug, and Cosmetic Act, as enforcement is limited to the federal government. Constitutional claims under § 1983 and Bivens failed because Atlas Air is a private entity. Additionally, the state law tort claims for invasion of privacy, negligent disclosure, and intentional infliction of emotional distress were found insufficiently pleaded or unsupported by the alleged facts. The judgment of dismissal was affirmed. View "Estate of Caviness v. Atlas Air, Inc." on Justia Law

USA v. Brillhart

2026-07-09T12:02:08-08:00

A man was investigated after Google and Yahoo flagged several of his email accounts for sending and storing what appeared to be child pornography. Both companies identified the user through information like a shared recovery phone number, birthdate, and selfies associated with the accounts. Yahoo manually reviewed and confirmed the images as child pornography before reporting them to the National Center for Missing and Exploited Children (NCMEC). Google used both human review and a hash-value matching protocol, whereby a file’s unique digital fingerprint was compared against a database of previously identified illegal images. One of the files in the defendant’s account matched the hash of a known child pornography image. Law enforcement, after receiving tips from NCMEC, conducted warrantless searches and confirmed the illicit nature of the files, leading to search warrants for the defendant’s residence and devices, which yielded more incriminating evidence. The United States District Court for the Middle District of Florida denied the defendant’s motions to suppress the evidence (arguing a Fourth Amendment violation), to dismiss one of the charges on double jeopardy grounds, and to exclude certain evidence. The court also rejected his arguments concerning the admissibility of defense evidence, the sufficiency of the evidence, and the jury instructions. The defendant was convicted by a jury on both distribution and possession charges and given an enhanced sentence based on a finding of a pattern of activity involving abuse or exploitation. His subsequent motions for psychological evaluation and sentencing continuance were also denied. On appeal, the United States Court of Appeals for the Eleventh Circuit held that Google’s use of hash-value matching constituted a valid private search under the Fourth Amendment, so the government’s warrantless review did not violate the defendant’s rights. The court also held that possession and distribution of child pornography are separate offenses for double jeopardy purposes. The appellate court affirmed all district court decisions except for the application of a pattern-of-activity sentencing enhancement, which it found improper; it vacated the sentence and remanded for resentencing. View "USA v. Brillhart" on Justia Law

Clayton v. Essentia Insurance Company

2026-07-08T06:01:59-08:00

The case concerns an Alabama resident who was injured by an uninsured motorist while riding his motorcycle. At the time, he held two separate insurance policies: a standard auto insurance policy from GEICO covering his motorcycle, and a specialty policy from Essentia Insurance Company covering his antique truck. The GEICO policy provided uninsured motorist coverage as required by Alabama law, and the insured collected $25,000 under it. Essentia’s policy, which covered only the antique vehicle, excluded uninsured motorist coverage for accidents involving vehicles other than the covered antique truck. The policy also required the insured to maintain a separate insurance policy that satisfied Alabama’s minimum coverage requirements. After Essentia denied his claim for uninsured motorist coverage, the insured brought suit in the United States District Court for the Middle District of Alabama. Essentia moved for summary judgment, arguing that its specialty policy’s coverage exclusion was valid because the insured had other coverage meeting Alabama’s requirements. The district court denied Essentia’s motion in part, holding Essentia liable for uninsured motorist benefits, but limited the liability to the statutory minimum of $25,000, and entered judgment accordingly. Essentia appealed. The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s summary judgment de novo and reversed. The Eleventh Circuit held that Alabama law permits insurers to fulfill mandatory coverage requirements through multiple policies, and that Essentia’s exclusion is enforceable so long as the insured has other coverage meeting statutory requirements. The court remanded the case for further proceedings consistent with its opinion. View "Clayton v. Essentia Insurance Company" on Justia Law

Marbury v. Warden

2026-07-07T11:02:05-08:00

An inmate at St. Clair Correctional Facility in Alabama brought suit under 42 U.S.C. § 1983 after he was assaulted by another prisoner in 2018. Previously, he had been attacked in 2016 and had requested transfer to segregation due to safety concerns but was denied by prison officials. Upon his return to St. Clair in 2017, he again sought protective housing, citing ongoing threats and hazardous conditions, including frequent violence, unauthorized inmate movement, and periods of absent supervision. Despite these requests, he remained in the general population and was ultimately assaulted, resulting in serious injuries. The United States District Court for the Northern District of Alabama first dismissed most of his claims, allowing only the Eighth Amendment deliberate-indifference claim based on a generalized risk of violence to proceed. After discovery, the district court granted summary judgment to the prison officials, finding that the plaintiff had failed to establish a genuine dispute of material fact as to whether he faced a substantial risk of serious harm. In an earlier appeal, the United States Court of Appeals for the Eleventh Circuit vacated the summary judgment due to improper denial of discovery, remanding for further proceedings. On remand, the district court again granted summary judgment, reasoning that the plaintiff had not sufficiently contextualized the violence statistics or provided adequate support for his allegations. Upon review, the United States Court of Appeals for the Eleventh Circuit held that the plaintiff had provided sufficient evidence—including statistical data on inmate assaults, contextual information about prison conditions, and sworn allegations of specific dangerous features—to create a genuine dispute of material fact regarding exposure to a substantial risk of serious harm. The court vacated the district court’s grant of summary judgment and remanded for further proceedings. View "Marbury v. Warden" on Justia Law

Pernell v. Commissioner of the FL State Board of Education

2026-07-07T06:31:44-08:00

Florida enacted a law prohibiting public university professors from endorsing or promoting certain ideas related to race, color, sex, and national origin in classroom instruction. The law, known as the Individual Freedom Act, identifies eight specific concepts that professors are barred from espousing, such as claims of moral superiority based on race or sex, inherent racism or oppression, and the idea that virtues like merit or colorblindness are themselves racist or sexist. The law allows professors to discuss these concepts in a neutral way, but not to advocate for them, and imposes severe penalties on both individual professors and universities for violations, including the loss of significant funding and potential termination of employment. Groups of professors and students from several Florida public universities filed lawsuits in the United States District Court for the Northern District of Florida, arguing that the Act violated their First Amendment rights by restricting viewpoint-based expression and was unconstitutionally vague. The district court granted preliminary injunctions in both cases, enjoining enforcement of the Act’s classroom restrictions against the plaintiffs, finding that at least one plaintiff had standing to challenge each prohibited concept. The court concluded the Act was likely unconstitutional as applied to public university professors. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s grant of a preliminary injunction. The Eleventh Circuit affirmed, holding that the Act’s restrictions amount to unconstitutional viewpoint discrimination in violation of the First Amendment. The court distinguished between permissible curricular control by universities and the broad, legislative ban imposed by the state’s political branches. It concluded that neither public-employee speech doctrine nor government speech doctrine justified the law’s suppression of disfavored ideas in the university classroom, and that the Act impermissibly infringed on academic freedom and open inquiry. The preliminary injunction was affirmed. View "Pernell v. Commissioner of the FL State Board of Education" on Justia Law

State of Florida v. Secretary, US Department of Education

2026-07-06T09:32:09-08:00

The dispute centers on whether the U.S. Department of Education may constitutionally rely on private educational accreditors in disbursing federal education funds. Under the Higher Education Act, colleges and universities must be accredited by a recognized accreditor for their students to be eligible for federal financial aid. Accreditors are private, voluntary organizations funded by the schools they accredit. Florida challenged this arrangement, alleging that it unconstitutionally delegates government power to private accreditors and violates both the Appointments Clause and the Spending Clause, claiming the accreditation requirement is an unascertainable condition for federal funds. The United States District Court for the Southern District of Florida reviewed the suit after Florida brought four claims: a private nondelegation doctrine challenge, an Appointments Clause challenge, a Spending Clause challenge, and a now-abandoned Administrative Procedure Act challenge. The federal government moved to dismiss, and the district court granted the motion. The district court found no unlawful delegation of government power, noted that Title IV funds are directed to students and not institutions, determined the accreditation requirement is unambiguous, and dismissed the Appointments Clause claim because accreditors do not determine eligibility for federal funds. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s dismissal de novo. The Court held that private accreditors do not exercise government authority that could violate the Vesting Clauses or the Appointments Clause. The Court also determined that the accreditation requirement is an ascertainable condition for federal funds, as it is a well-understood, longstanding practice and does not amount to an ambiguous or novel restriction. The Eleventh Circuit affirmed the district court’s dismissal of Florida’s suit. View "State of Florida v. Secretary, US Department of Education" on Justia Law

Henry v. Sheriff of Tuscaloosa County, Alabama

2026-07-06T07:32:30-08:00

A man who was convicted of possessing child pornography in 2013 served his sentence and later married and had a son. Despite completing sex offender treatment and complying with supervised release conditions, he remained subject to Alabama’s Sex Offender Registration and Community Notification Act (“the Act”). This law prohibits him, for life, from residing with or conducting overnight visits with any minor—including his own child—because his conviction involved a child-related offense. The Act contains no mechanism for relief or individualized assessment, even for parents who have shown rehabilitation. After the birth of his son, the man sued the Sheriff and District Attorney of Tuscaloosa County and the Alabama Attorney General under 42 U.S.C. § 1983, seeking to enjoin enforcement of the Act’s prohibition against living with his child. The United States District Court for the Middle District of Alabama granted summary judgment in his favor, declaring the Act’s prohibition facially unconstitutional and issuing a universal injunction. On appeal, a panel of the United States Court of Appeals for the Eleventh Circuit affirmed in part, reversed in part, and vacated and remanded in part, finding the Act unconstitutional as applied to the plaintiff but vacating the universal injunction. The panel’s opinion was then vacated, and the case was reheard en banc. The United States Court of Appeals for the Eleventh Circuit held that all parents—including those with past convictions or “misconduct”—enjoy a fundamental right to live with their children under the Fourteenth Amendment. The court rejected Alabama’s argument that certain classes of parents lack this right due to prior offenses. The court remanded the case to the panel for further proceedings under strict scrutiny, requiring Alabama to show its law is narrowly tailored to serve a compelling state interest. The court affirmed in part and remanded in part. View "Henry v. Sheriff of Tuscaloosa County, Alabama" on Justia Law

USA v. Carter

2026-07-06T05:02:05-08:00

The case concerns a defendant who pleaded guilty to possessing a firearm as a convicted felon, in violation of federal law. The defendant had four prior convictions under Georgia law for drug offenses involving cocaine, all committed on separate occasions. These prior convictions were used to classify him as an “armed career criminal,” triggering a mandatory minimum sentence of 15 years under the Armed Career Criminal Act (ACCA). The defendant did not dispute the existence of these convictions or that they occurred on different occasions. However, he argued that Georgia’s definition of cocaine is broader than the federal definition, contending that this difference should prevent his prior convictions from qualifying as ACCA predicate offenses. The United States District Court for the Middle District of Georgia overruled the defendant’s objection to the ACCA enhancement. The court concluded that the Georgia convictions counted as “serious drug offenses” under the ACCA and sentenced him to 210 months in prison. During sentencing, the court rejected arguments based on an expert’s declaration claiming a definitional mismatch between state and federal cocaine laws. Upon review, the United States Court of Appeals for the Eleventh Circuit considered whether Georgia law, by defining cocaine more broadly than federal law, rendered the prior convictions ineligible for ACCA enhancement. The appellate court held that for a substance to be a controlled substance under Georgia law, it must be listed on both Georgia and federal drug schedules. Thus, even if Georgia’s statutory language is broader, a conviction could not be based on conduct outside the federal definition. The court also rejected an argument based on changes to the federal schedules concerning “ioflupane.” The Eleventh Circuit affirmed the district court’s application of the ACCA enhancement. View "USA v. Carter" on Justia Law

Edwards v. Grubbs

2026-06-30T10:02:15-08:00

A 65-year-old homeless man was encountered by two Atlanta police officers near a highway on-ramp after he was observed receiving money from a driver. When approached, he fled on foot, and one officer pursued him across traffic. The man, unarmed and non-threatening, crossed a guardrail and began descending a steep embankment toward a highway. Without giving a verbal warning, the officer fired his taser in dart mode, striking the man in the back, causing him to fall down the embankment and suffer catastrophic injuries, including traumatic brain injury and quadriplegia. The man’s guardian filed suit in the United States District Court for the Northern District of Georgia against the officer and the City under 42 U.S.C. § 1983, alleging excessive force, as well as related state-law claims. The district court granted partial summary judgment on certain state claims and dismissed others by stipulation. At trial, the jury found in favor of the plaintiff, awarding $60 million against the City and $40 million against the officer (split between compensatory and punitive damages). The district court later set aside the verdict against the City, holding there was insufficient evidence of municipal liability, and reduced the punitive damages against the officer to $1 million. The United States Court of Appeals for the Eleventh Circuit reviewed these outcomes. It held that the officer was not entitled to qualified immunity, because tasing an unarmed, non-dangerous suspect fleeing on foot in a highly dangerous location, without warning, constituted excessive force under clearly established law. The appellate court affirmed setting aside the verdict against the City, finding insufficient evidence that any City policy or failure to enforce the body camera policy was the moving force behind the violation. The reduction of punitive damages to $1 million was upheld as constitutional. The court also affirmed the district court’s rulings on medical expenses and attorney’s fees. View "Edwards v. Grubbs" on Justia Law

Scott v. City of Daytona Beach

2026-06-25T12:31:58-08:00

Four individuals who regularly engage in panhandling in Daytona Beach, Florida, challenged the city’s 2019 ordinance that imposed wide-ranging restrictions on panhandling. They argued that the law, which defined panhandling as in-person requests for immediate donations, and which banned or restricted this conduct in various locations and circumstances, violated their First Amendment rights. Each plaintiff relied on panhandling for basic needs and had faced threats, arrests, or other enforcement actions as a result of the ordinance. The United States District Court for the Middle District of Florida reviewed the case and granted summary judgment in favor of the plaintiffs. The court found that the ordinance’s challenged provisions were content-based, failed strict scrutiny, and thus violated the First Amendment. It issued a declaratory judgment, a universal injunction against enforcement of the challenged provisions, and awarded damages as agreed by the parties. The City of Daytona Beach appealed these decisions. On appeal, the United States Court of Appeals for the Eleventh Circuit held that the ordinance imposed content-based restrictions on speech by targeting only in-person requests for immediate donations, distinguishing them from other types of solicitation. The court found that several provisions could not withstand strict scrutiny, as the city had less speech-restrictive means to achieve its public health and safety goals. However, the Eleventh Circuit determined that the plaintiffs had standing to challenge only some, not all, of the ordinance’s provisions and that the district court’s remedy was overbroad. The appellate court affirmed the district court’s ruling as to the provisions where at least one plaintiff had standing, vacated it in other respects, and remanded for further proceedings consistent with its opinion. The damages award was affirmed because at least one provision was found unconstitutional. View "Scott v. City of Daytona Beach" on Justia Law

Braggs v. Commissioner, Alabama Department of Corrections

2026-06-24T10:32:51-08:00

A group of inmates incarcerated within Alabama’s state prison system filed a class action challenging the adequacy of mental health care provided by the Alabama Department of Corrections (ADOC). The plaintiffs, who suffer from serious mental illnesses, alleged that overcrowding, understaffing, and a series of systemic failures resulted in constitutionally deficient mental health services, contributing to a suicide rate far above the national average. Key alleged deficiencies included improper identification and classification of mental health needs, inadequate treatment plans, insufficient psychotherapy, lack of proper suicide risk management, improper use of segregation for mentally ill inmates, and the imposition of disciplinary sanctions for manifestations of mental illness. The United States District Court for the Middle District of Alabama managed the litigation in multiple phases. After a seven-week bench trial, the court found the ADOC liable under the Eighth Amendment for deliberate indifference to inmates’ serious mental health needs. The court then held extensive remedial proceedings, including further hearings and negotiations, and entered a comprehensive, system-wide remedial injunction. The court made detailed factual findings and, to comply with the Prison Litigation Reform Act (PLRA), issued particularized findings that the relief ordered was necessary, narrowly drawn, and the least intrusive means to remedy the constitutional violations. The court also adopted a monitoring plan to ensure compliance, involving external experts and a transition to internal oversight. On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s liability findings and most aspects of the remedial and monitoring orders, holding that system-wide relief was appropriate given the systemic nature of the violations. However, the appellate court reversed certain remedial provisions where it found the relief exceeded what was necessary to correct the constitutional violations, particularly with respect to suicide-proofing cells and some staffing requirements, and as applied to a women’s facility where violations were not established. The case was remanded for modification in those limited respects. View "Braggs v. Commissioner, Alabama Department of Corrections" on Justia Law

U.S. All Star Federation, Inc. v. Open Cheer & Dance Championship Series, LLC

2026-06-24T10:32:51-08:00

Two organizations involved in competitive cheerleading became embroiled in a dispute over the use of two marks: “THE CHEERLEADING WORLDS,” which is registered on the Supplemental Register with the U.S. Patent and Trademark Office, and “WORLDS,” which is claimed as an unregistered common law mark. The plaintiff, a governing body for competitive cheerleading, has held an annual event under these marks since 2004. The defendants, including a group of former members of the plaintiff organization, began hosting a similarly named event in the same region, allegedly causing confusion among participants and the public. The United States District Court for the Middle District of Florida granted summary judgment for the defendants, concluding that both marks were generic as a matter of law and thus not entitled to trademark protection. The court found that the terms described the basic nature of the plaintiff’s services and discounted evidence showing non-generic use, reasoning that the plaintiff’s event had long been the only one of its kind. The court also rejected the plaintiff’s argument that the defendants were barred from contesting the marks’ distinctiveness due to an earlier dismissal of an affirmative defense with prejudice. On appeal, the United States Court of Appeals for the Eleventh Circuit reversed. The appellate court held that the issue of distinctiveness was properly before the district court, as distinctiveness is an element of the plaintiff’s claim and not an affirmative defense. The Eleventh Circuit found that there were genuine disputes of material fact as to whether the marks were descriptive or had acquired secondary meaning, based on evidence of public association with the plaintiff’s event. The court remanded the case for trial, holding that summary judgment was inappropriate because a reasonable jury could find the marks protectable. The court also declined to decide issues of likelihood of confusion and individual liability without factual findings. View "U.S. All Star Federation, Inc. v. Open Cheer & Dance Championship Series, LLC" on Justia Law

Hayles v. U.S. Attorney General

2026-06-22T08:31:56-08:00

A Jamaican citizen entered the United States unlawfully, claiming fear of political persecution in his home country. While in the United States, he was convicted of voluntary manslaughter and battery, resulting in a 20-year prison sentence. After completing his sentence, the Department of Homeland Security (DHS) detained him for administrative removal proceedings based on his aggravated felony convictions. The individual expressed fear of torture if returned to Jamaica, prompting referral to withholding-only proceedings to determine eligibility for deferral of removal under the Convention Against Torture (CAT). The immigration judge denied CAT relief, and the Board of Immigration Appeals affirmed that decision. DHS issued a final administrative removal order separately. The petitioner, acting pro se, filed for judicial review in the United States Court of Appeals for the Eleventh Circuit, challenging only the denial of CAT relief and not the underlying removal order. He acknowledged the petition was untimely and cited procedural issues, such as not receiving necessary legal resources. Subsequently, appointed counsel raised additional due process claims and contested the adverse CAT determination. The Eleventh Circuit ordered supplemental briefing to address jurisdiction. The United States Court of Appeals for the Eleventh Circuit held that it lacked jurisdiction to review the denial of CAT relief unless the petition for review also challenged a final order of removal. The court reasoned that under the relevant statutes, including the Illegal Immigration Reform and Immigrant Responsibility Act, the Foreign Affairs Reform and Restructuring Act, and the REAL ID Act, judicial review of CAT claims is only available as part of a review of a final removal order. Because the petition did not challenge the removal order, the court dismissed it for lack of jurisdiction. View "Hayles v. U.S. Attorney General" on Justia Law

Akel v. USA

2026-06-18T12:31:55-08:00

The petitioner was convicted after a jury trial of conspiracy to distribute and possess MDMA, marijuana, and cocaine; possession with intent to distribute marijuana; and possession of a firearm by a convicted felon. He was sentenced to concurrent terms of 480 months’ imprisonment for each count, with enhancements including one under the Armed Career Criminal Act. The original judgment erroneously included a cocaine charge for Count Two, although the jury only found marijuana involvement. The district court’s judgment reflected this mistake. On direct appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the convictions and sentences. Later, the petitioner filed an initial motion to vacate his sentence under 28 U.S.C. § 2255, challenging the ACCA enhancement. The district court denied the motion, and the Eleventh Circuit denied a certificate of appealability. The Supreme Court subsequently vacated that denial and remanded in light of Mathis v. United States. On remand, the district court found the ACCA enhancement was improper and that the sentence for Count Two exceeded the statutory maximum, so it resentenced the petitioner and entered an Amended Judgment with reduced sentences for Counts Two and Seven and corrected the charge for Count Two. After exhausting direct appeal of the Amended Judgment, the petitioner filed a new § 2255 motion raising claims relating both to the original trial and the resentencing. The district court for the Northern District of Florida dismissed eight claims as unauthorized “second or successive” claims. The petitioner appealed. The United States Court of Appeals for the Eleventh Circuit held that the new § 2255 motion was not “second or successive” because it challenged a new, intervening Amended Judgment. The court vacated the district court’s dismissal and remanded for further proceedings. View "Akel v. USA" on Justia Law

USA v. Spearman

2026-06-18T06:01:35-08:00

The case concerns a man who served as lead administrator for a large, international child pornography network operating via a dark web site, “Website A.” The website used the Tor network to mask users’ IP addresses and facilitate the sharing of child pornography through links and chat rooms, with elaborate systems to reward participation. The defendant rose from a regular user to the main administrator, supervising other staff and overseeing the website’s operations. In 2022, after a separate investigation and arrest of another high-ranking website member, the FBI received tips from a foreign law enforcement agency (FLEA) identifying an IP address associated with the website’s management, which was traced to the defendant’s address in Alabama. The FBI obtained a warrant, searched the home, found extensive evidence, and obtained incriminating admissions from the defendant. Following his arrest and arraignment in the United States District Court for the Southern District of Florida, the defendant moved to suppress the evidence, arguing that the FBI’s collaboration with the FLEA amounted to a “joint venture,” meaning the foreign search should be subject to Fourth Amendment scrutiny. He claimed he was entitled to an evidentiary hearing on this issue. The district court denied the motion without a hearing, finding the allegations speculative and not sufficiently detailed to require one. The defendant subsequently pled guilty and was sentenced to life imprisonment, despite presenting mitigating evidence including significant military service and mental health history. On appeal, the United States Court of Appeals for the Eleventh Circuit held that the district court did not abuse its discretion in denying an evidentiary hearing or in refusing to suppress the evidence. The court found the defendant’s allegations did not establish the necessary FBI involvement in the foreign search to trigger Fourth Amendment protections. The court also held that the life sentence was substantively reasonable, given the nature of the offense and the district court’s consideration of mitigating factors. The conviction and sentence were affirmed. View "USA v. Spearman" on Justia Law

C. W. v. Smith

2026-06-17T12:31:49-08:00

A male freshman football player at a public high school in Alabama was subjected to repeated acts of harassment by older teammates, including physical and verbal abuse with sexual overtones and an attempted sexual assault known as “keying,” where a car key is forced into a player’s anus. The harassment was meant to emasculate him and included slurs and other conduct suggesting hostility toward his perceived failure to conform to masculine stereotypes. The student reported these incidents to school officials, including the head coach, but the school’s response was minimal and did not stop the harassment. The student ultimately transferred to a different school as a result. Afterward, the student, through his representative, sued the school district and the head coach in the United States District Court for the Northern District of Alabama. He alleged violations of Title IX and the Equal Protection Clause, as well as state tort claims. The district court dismissed the federal claims, concluding that the harassment was motivated by anti-freshman bias rather than sex, that the conduct did not qualify as actionable same-sex sexual harassment under Title IX or the Equal Protection Clause, and that the coach was entitled to qualified immunity. The court declined to exercise supplemental jurisdiction over the state claims. The United States Court of Appeals for the Eleventh Circuit reviewed the dismissal de novo. It held that the student plausibly alleged sex-based harassment actionable under Title IX and the Equal Protection Clause because the alleged conduct targeted him for failing to conform to sex stereotypes and involved inherently sexual acts. The court concluded that the allegations supported a finding of deliberate indifference by the school district and the coach and that the coach was not entitled to qualified immunity. The Eleventh Circuit vacated the district court’s dismissal and remanded for further proceedings. View "C. W. v. Smith" on Justia Law

USA v. Pinkston

2026-06-12T13:01:33-08:00

The case concerns a defendant who committed a string of bank robberies in Miami in 2021. On two separate occasions, he entered banks and handed tellers threatening notes demanding large sums of money. After these incidents, the defendant confessed to the robberies and pleaded guilty to two counts of federal bank robbery. He had two prior felony convictions: one for federal bank robbery and another for Florida aggravated assault. A probation officer prepared a presentence report recommending that the defendant be classified as a career offender under the United States Sentencing Guidelines. This classification was based on the defendant’s age at the time of the new offenses, the fact that the current offense and his two prior convictions qualified as “crimes of violence,” and the resulting increased guideline sentencing range. The United States District Court for the Southern District of Florida agreed with the presentence report, found the defendant to be a career offender, and imposed a sentence consistent with the enhanced guideline range. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed de novo whether the defendant’s prior convictions for federal bank robbery and Florida aggravated assault were “crimes of violence” under the Guidelines. The court held that federal bank robbery qualifies as a crime of violence under both the elements clause and the enumerated crimes clause, based on its requirement of knowing intimidation. The court also reaffirmed that Florida aggravated assault is a crime of violence, as it requires intentional or knowing conduct, not recklessness. The Eleventh Circuit rejected the defendant’s arguments that changes in case law or statutory interpretation affected the status of these offenses. The court affirmed the district court’s sentencing decision. View "USA v. Pinkston" on Justia Law

Jackson v. Jones

2026-06-12T11:31:33-08:00

A candidate for the Republican nomination for Governor of Georgia, who was not the incumbent, challenged a unique provision of Georgia’s campaign finance law. This law allows only the incumbent Governor and Lieutenant Governor to establish and control so-called “leadership committees” with the ability to receive unlimited contributions and coordinate spending directly with their campaigns, advantages not available to challengers or other candidates. The challenger entered the 2026 gubernatorial primary and quickly discovered that his opponent, the sitting Lieutenant Governor, had amassed substantial campaign resources through such a leadership committee, while the challenger remained subject to standard contribution limits. After filing suit in the United States District Court for the Northern District of Georgia, the challenger sought a preliminary injunction to stop the Lieutenant Governor’s leadership committee from raising or spending further funds in support of his campaign. The district court initially issued a temporary restraining order, then, after further proceedings, granted a preliminary injunction, holding that the challenger was likely to succeed on his claim that the law violated the First Amendment’s guarantee of free speech and that the leadership committee’s actions could be fairly attributed to state action. The district court determined that the law’s favoritism toward select officials could not be justified and that the harm to the challenger was irreparable. However, the injunction was stayed pending appeal. On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s grant of a preliminary injunction. The court held that the selective fundraising advantage granted to certain incumbents by the leadership committee statute was unconstitutional under the First Amendment, as it imposed different contribution limits on candidates for the same office without sufficient justification. The court also found that the leadership committee’s conduct constituted state action, making it subject to suit under 42 U.S.C. § 1983. The preliminary injunction was affirmed. View "Jackson v. Jones" on Justia Law

iCare Child Development Center LLC v. Cicero-Brown

2026-06-11T11:31:35-08:00

A childcare provider operating multiple daycare centers in Georgia participated in the state’s childcare voucher program, which is funded primarily by a federal grant and administered by the Georgia Department of Early Care and Learning. The provider agreement requires daycare centers to maintain arrival and departure records for each child and to make these records immediately available during on-site audits. In 2023, the Department conducted simultaneous audits at four of the provider’s locations. Only one location produced the required records during the audits, and the Department determined that the provider failed to comply with the investigation. The Department dismissed all of the provider’s centers from the voucher program, issuing notice that the dismissal was not appealable but allowing a grievance process. The provider attempted to contest the dismissal, but was repeatedly told it had no right to appeal. The provider brought suit in the United States District Court for the Northern District of Georgia against several Department officials, alleging a violation of due process and seeking a preliminary injunction for reinstatement in the program. The district court found that while the provider might suffer irreparable harm, it was unlikely to succeed on the merits of its due process claim because it lacked a property interest in continued participation in the program, and denied the motion for a preliminary injunction. The United States Court of Appeals for the Eleventh Circuit reviewed the denial of the preliminary injunction. Assuming without deciding that the provider had a property interest in continued participation, the court held that the provider was not entitled to a pre-deprivation hearing under the Due Process Clause. Applying the balancing test from Mathews v. Eldridge, the court concluded that additional procedural safeguards would not significantly reduce the risk of erroneous deprivation in this context. The court affirmed the denial of the preliminary injunction. View "iCare Child Development Center LLC v. Cicero-Brown" on Justia Law

USA v. Alberto Morilla

2026-06-11T05:31:34-08:00

The defendant was charged with one count of conspiracy to commit money laundering and three counts of money laundering, alongside several co-conspirators. He pleaded guilty to the conspiracy charge in exchange for dismissal of the substantive money laundering counts. The factual proffer established that, during his brief involvement in the conspiracy, he knowingly laundered approximately $550,000 in what he believed to be drug proceeds, receiving a fee for his services. His participation consisted of three wire transfers over roughly one month, using his own bank account. The United States District Court for the Southern District of Florida accepted his plea and adjudicated him guilty. At sentencing, the court adopted the Presentence Investigation Report’s recommendation to apply a two-level enhancement for “sophisticated laundering” and denied a two-level reduction for playing a minor role in the offense. The district court determined a Guidelines range of 57 to 71 months and imposed a 57-month sentence. The defendant objected to both the enhancement and the denial of the reduction, and argued the court’s statement under United States v. Keene, 470 F.3d 1347 (11th Cir. 2006), could not shield any Guidelines error from appellate review. On appeal, the United States Court of Appeals for the Eleventh Circuit held that the district court erred in applying the sophisticated-laundering enhancement because the record did not support a finding that the defendant’s own conduct involved complex or intricate transactions, nor did the court make individualized findings as required. However, the appellate court affirmed the denial of a minor-role reduction, finding the district court’s conclusion supported by the record. The Eleventh Circuit found the district court’s Keene statement ineffective because it was made before hearing arguments on sentencing factors and before allocution. The sentence was affirmed in part, vacated in part, and remanded for resentencing. View "USA v. Alberto Morilla" on Justia Law

USA v. Crespo

2026-06-10T13:01:44-08:00

A federal special agent in South Florida was involved in a scheme to obtain and distribute oxycodone for profit, alongside other participants including a patient recruiter, a physician, and patient recruits. The agent, who was aware of the illegal activity, provided information about ongoing law enforcement investigations to his co-conspirators and tried to disrupt those investigations. After a long-term investigation, a federal grand jury indicted the agent on several charges, including conspiracy to distribute oxycodone, conspiracy to commit witness tampering, multiple counts of witness tampering, and conspiracy to obstruct justice. Other participants pleaded guilty, and the agent proceeded to trial. In the United States District Court for the Southern District of Florida, the defendant was acquitted of conspiracy to distribute oxycodone but convicted of conspiracy to commit witness tampering, witness tampering, and conspiracy to obstruct justice. He was sentenced to 97 months in prison. During pretrial and trial proceedings, the district court denied the agent’s motions to suppress wiretap evidence as untimely, motions for mistrial, and request for a good-faith jury instruction. The court also limited recross-examination of a witness and admitted evidence of the agent’s prior workplace misconduct related to sale of personal protective equipment. On appeal to the United States Court of Appeals for the Eleventh Circuit, the agent challenged evidentiary rulings, the sufficiency of evidence for several counts, the denial of certain jury instructions, and the calculation of his sentence. The court held that the district court did not abuse its discretion or commit reversible error on any issue. The court found no cumulative error and concluded that the agent’s sentence was properly calculated based on the scope of his obstructive conduct. The Eleventh Circuit affirmed the convictions and sentence. View "USA v. Crespo" on Justia Law

Johnson v. Mayor, City of Jacksonville

2026-06-10T08:33:27-08:00

A Black resident of the Middle District of Florida, descended from enslaved individuals, brought suit against the Mayor of Jacksonville and the Governor of Florida in their official capacities. He alleged that the continued presence and maintenance of nearly fifty Confederate memorials, monuments, and naming tributes on public land, funded by city or state tax dollars, caused him to feel “deeply repulsed, disheartened, and intimidated.” He asserted that these symbols were governmental celebrations of White supremacy, and sought a declaratory judgment that their presence violated his rights under Title II of the Civil Rights Act, the Thirteenth Amendment, the Equal Protection and Due Process Clauses of the Fourteenth Amendment, and 42 U.S.C. § 1981. The United States District Court for the Middle District of Florida dismissed the complaint. The magistrate judge had recommended dismissal, finding that the plaintiff failed to allege facts showing a particularized injury, and thus lacked Article III standing. The magistrate also found that the plaintiff did not have taxpayer standing, as he failed to allege a direct injury or that taxpayer funds were specifically used to maintain the memorials. The district court adopted the recommendation, concluding that the plaintiff’s objections were not sufficiently specific, but nonetheless conducted a de novo review and agreed that standing was lacking. On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s dismissal. The court held that the plaintiff’s alleged psychological harm—feelings of repulsion and intimidation—did not constitute a concrete or particularized injury for Article III standing. It further found he did not demonstrate municipal taxpayer standing, as he failed to allege facts indicating that taxpayer funds were used for the memorials. The Eleventh Circuit concluded that the plaintiff lacked standing and affirmed the dismissal. View "Johnson v. Mayor, City of Jacksonville" on Justia Law

USA v. Lebarron

2026-06-08T08:01:57-08:00

A woman, identified as J.B., fatally overdosed on fentanyl and methamphetamine in the home of the defendant, who operated a drug distribution operation from that location. Security footage showed J.B. participating in drug sales, obtaining drugs from the defendant’s bedroom, and then injecting herself shortly before her death in the living room. After her overdose, the defendant and others attempted to revive her and later removed her body and drug paraphernalia from the home. An autopsy confirmed lethal levels of both drugs, each of which could have independently caused her death. The defendant was indicted in the United States District Court for the Middle District of Florida on multiple drug-related charges, including conspiracy to possess and distribute controlled substances and possession with intent to distribute, both carrying enhanced penalties because of J.B.'s death and his prior conviction. At trial, the defendant was allowed to argue that J.B. may have obtained the drugs elsewhere for some charges, but the court limited his ability to present a theory that J.B. stole the drugs as a defense to the charges that carried the enhanced penalty for causing death. The jury found that the defendant’s drugs were the but-for cause of J.B.’s death, resulting in two concurrent life sentences. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed whether the district court properly applied the penalty enhancement under 21 U.S.C. § 841(b)(1)(C) and the related jury instructions. The Eleventh Circuit held that the penalty enhancement applies to violations involving possession with intent to distribute, does not require a separate mens rea as to the resulting death, and does not permit a proximate or intervening cause defense. The court affirmed both the convictions and the sentences. View "USA v. Lebarron" on Justia Law

Senatus v. U.S. Attorney General

2026-06-08T05:31:36-08:00

A Haitian citizen who became a lawful permanent resident of the United States was convicted in Florida of aggravated assault with a firearm and sentenced to imprisonment and probation. Following this conviction, the Department of Homeland Security initiated removal proceedings, asserting that the conviction constituted an aggravated felony—a crime of violence—under the Immigration and Nationality Act. The individual, represented by counsel, conceded removability before an Immigration Judge and proceeded with applications for asylum and withholding of removal, which the judge denied. The Board of Immigration Appeals (BIA) affirmed the removal decision. After removal, the petitioner submitted pro se motions to the BIA: a motion to reopen proceedings and an emergency stay of removal. The motion to reopen argued that counsel was ineffective for failing to challenge removability, contending that the Florida statute permitted convictions based on recklessness, which did not meet the federal “crime of violence” standard requiring intent. The BIA denied the motion to reopen, finding the petitioner’s arguments unpersuasive and concluding he was not prejudiced by any alleged deficient performance by counsel. The United States Court of Appeals for the Eleventh Circuit reviewed the BIA’s denial for abuse of discretion and legal error. The court held that precedent interpreting both the Armed Career Criminal Act and the Immigration and Nationality Act establishes that Florida’s aggravated assault statute requires at least knowing conduct, not mere recklessness. Thus, a conviction under this statute categorically qualifies as a “crime of violence” for removal purposes, even for convictions predating clarification by the Florida Supreme Court. The Eleventh Circuit denied the petition for review, concluding that the BIA did not abuse its discretion. View "Senatus v. U.S. Attorney General" on Justia Law

USA v. Niksich

2026-06-04T12:01:06-08:00

The case involves an individual who, following advice from his accountant, opened and maintained several foreign bank accounts in Switzerland and Panama between 2006 and 2012. He did not timely file the required Reports of Foreign Bank and Financial Accounts (FBARs) disclosing these accounts to the United States government. The accounts were significant in value and were sometimes held under an alias. The individual self-prepared his tax returns during this period, and while he reported domestic investment income, he did not disclose his foreign accounts. In 2014, after learning of the FBAR requirements, he entered an IRS voluntary disclosure program, filed untimely FBARs, and attempted to resolve his liabilities with the IRS through a settlement, which was ultimately not honored by the IRS. The United States initiated a civil suit in the United States District Court for the Northern District of Georgia to collect penalties for the willful failure to file timely FBARs. The individual moved for summary judgment, asserting affirmative defenses of accord and satisfaction and equitable estoppel, based on his attempted settlement with the IRS. The United States also moved for summary judgment, seeking a finding of willfulness as a matter of law. The district court granted summary judgment to the United States, finding the failure to file was willful, rejecting the affirmative defenses, and holding that the Eighth Amendment's Excessive Fines Clause did not apply to FBAR penalties. The United States Court of Appeals for the Eleventh Circuit reviewed the case. It affirmed the district court’s rulings on willfulness and rejection of the affirmative defenses, holding that the failure to file FBARs was willful under an objective standard and that the IRS agents lacked authority to bind the government to a settlement. However, the Eleventh Circuit reversed the district court’s determination regarding the Excessive Fines Clause, holding that FBAR penalties are subject to the Eighth Amendment and remanding for factual development on whether the penalties were unconstitutionally excessive. View "USA v. Niksich" on Justia Law

Lil' Joe Records, Inc. v. Won

2026-06-02T08:31:45-08:00

Members of the rap group 2 Live Crew, including Mark Ross, created five albums between 1986 and 1989. Through a written agreement, the group assigned the sound recording copyrights to Luke Records, a company owned by one of the group’s members. In 1995, following Luke Records’ bankruptcy, these copyrights were sold to Lil’ Joe Records. In 2000, Mark Ross filed for Chapter 7 bankruptcy; his termination interests in these copyrights were never listed or addressed in his bankruptcy proceedings. Years later, within the statutory window, Ross, another group member, and heirs of a third served a notice attempting to terminate the copyright grants to Luke Records, as permitted by the Copyright Act. The United States District Court for the Southern District of Florida initially concluded that Ross’s termination interests did not enter his bankruptcy estate, interpreting the Copyright Act and Bankruptcy Code to exclude them. The court denied both parties’ motions for summary judgment on the effectiveness of the termination notice, and the case proceeded to trial. After the jury’s factual findings, the district court concluded the termination notice was valid. Lil’ Joe Records appealed the district court’s final judgment, the denial of its motion for summary judgment, and the denial of its motion for reconsideration. The United States Court of Appeals for the Eleventh Circuit held that Ross’s termination interests were property of his bankruptcy estate under the Bankruptcy Code, notwithstanding the Copyright Act’s inalienability restriction. Because these interests were never scheduled or administered by the bankruptcy court, they remained with the bankruptcy estate when Ross attempted to exercise them. As a result, Ross could not validly sign the termination notice, and the group did not have the required majority to terminate the copyright grants. The Eleventh Circuit reversed the district court’s judgment and remanded the case for further proceedings. View "Lil' Joe Records, Inc. v. Won" on Justia Law

Smith v. Slott

2026-06-01T13:01:45-08:00

Donald Smith owned and operated a company called No Rust Rebar, along with four other related entities. All these entities were controlled by Smith, shared business locations, and had overlapping operations and assets. No Rust Rebar filed for Chapter 11 bankruptcy, which was later converted to Chapter 7 liquidation after a creditor's motion. During the bankruptcy proceedings, the court found that Smith routinely commingled the assets of No Rust Rebar with those of the other entities, failed to observe corporate formalities, and treated the businesses as a single operation subject to his personal discretion. Following these findings, the bankruptcy court appointed a trustee, who moved to substantively consolidate the assets and liabilities of the four non-debtor entities with No Rust Rebar’s bankruptcy estate. All entities received notice of this motion and objected, arguing that substantive consolidation required a separate adversary proceeding and an additional evidentiary hearing. However, they did not challenge the merits of consolidation or the findings that led to it, focusing solely on procedural issues. The United States District Court for the Southern District of Florida affirmed the bankruptcy court’s consolidation order after the non-debtor entities appealed, again raising only procedural arguments. The United States Court of Appeals for the Eleventh Circuit reviewed the bankruptcy court’s decision de novo for legal conclusions and for clear error as to factual findings. The Eleventh Circuit held that the bankruptcy court had the authority to order substantive consolidation based on its findings that the entities were alter egos with a substantial identity. The court also concluded that any procedural errors related to the style or process of the motion were harmless, as all parties had notice and an opportunity to be heard. The substantive consolidation order was affirmed. View "Smith v. Slott" on Justia Law

Light v. LVNV Funding, LLC

2026-06-01T06:01:12-08:00

A Florida attorney was retained by a consumer who was sued in small claims court for an alleged debt. The attorney attempted to resolve the case with the debt collector’s counsel before a scheduled pretrial conference and was told a settlement would be communicated to the court. Relying on this, he did not attend the conference. The court entered a default against the consumer for failure to appear. Despite assurances from opposing counsel that the default would be set aside, and after a settlement agreement was executed, the debt collector moved for a default judgment and the court entered a default final judgment against the consumer. The attorney spent significant time and effort remedying the situation, ultimately securing vacatur of the default judgment. He then brought suit in federal court in his own name, alleging violations of the Fair Debt Collection Practices Act and Florida law, claiming personal injuries such as distress, embarrassment, and lost time. The United States District Court for the Southern District of Florida dismissed the case, finding the attorney lacked statutory standing under both federal and state law because the alleged debt collection activities targeted his client, not him. The district court did not reach the merits of the state law claim because it found no standing. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s dismissal. The appellate court held that the attorney had not alleged a concrete injury in fact sufficient to establish Article III standing. The court explained that any harm he experienced was derivative of his client’s injury and did not amount to a cognizable injury for standing purposes. The Eleventh Circuit therefore dismissed the appeal for lack of jurisdiction, without reaching the merits of the statutory claims. View "Light v. LVNV Funding, LLC" on Justia Law

Florida East Coast Holdings Corporation v. Lexington Insurance Company

2026-05-29T11:01:13-08:00

A company operating a railroad in Florida took precautionary measures in anticipation of Hurricane Irma in 2017 by removing and later reinstalling crossing gates at approximately 600 locations to prevent storm-related damage. These actions caused operational delays and additional expenses, but ultimately prevented significant physical damage. The company submitted a claim for these expenses, totaling over $5.6 million, under its property insurance policy covering direct physical loss, time element losses, and certain preventative measures. The insurers denied the claim, contending the deductible applicable to hurricane-related events exceeded the claimed amount. The United States District Court for the Middle District of Florida reviewed the insurance policy and determined that only the provisions related to “Protection and Preservation of Property” applied, not broader coverage provisions. The court concluded that the “Named Windstorm” deductible of 5% of the property value at all affected locations applied, resulting in a deductible of over $10.9 million, which surpassed the company’s losses. Consequently, the district court granted summary judgment to the insurers. On appeal, the United States Court of Appeals for the Eleventh Circuit held that the relevant coverage provisions were indeed those for “Protection and Preservation of Property,” but determined that the correct deductible was $750,000, not the higher amount calculated by the district court. The Court of Appeals found that since there was no actual physical damage to the properties, the policy did not require the 5% calculation, and the minimum deductible applied. The appellate court affirmed the district court’s identification of the applicable coverage, vacated the summary judgment based on the deductible calculation, and remanded the case for further proceedings to determine the amount recoverable after the $750,000 deductible. View "Florida East Coast Holdings Corporation v. Lexington Insurance Company" on Justia Law

Citadel Securities LLC v. Securities and Exchange Commission

2026-05-29T10:01:14-08:00

This case involves a challenge to the approval by the U.S. Securities and Exchange Commission (“SEC”) of a new options trading exchange, IEX Options, proposed by Investors Exchange LLC (“IEX”). The dispute centers on IEX’s plan to introduce a 350-microsecond “speedbump” delay and a software mechanism called the Options Quote Indicator and Options Risk Parameter (“ORP”), designed to detect and mitigate “latency arbitrage.” Latency arbitrage occurs when high-frequency traders exploit tiny delays in the updating of quotes across exchanges, resulting in significant profits for these traders and increased costs for market makers and investors. IEX’s system aims to limit this practice by slowing the entry of incoming orders and repricing or canceling stale quotes when rapid price changes are detected, a model previously approved for equities trading. After IEX submitted its proposal, the SEC solicited public comment and received input from market makers, institutional investors, and competitors. The SEC approved the proposal, finding that it was consistent with the Securities Exchange Act and did not unfairly discriminate or impose undue burdens on competition. The SEC also determined that quotes subject to IEX’s ORP qualified as “protected” quotations under the Options Order Protection and Locked/Crossed Market Plan. Citadel Securities LLC (“Citadel”), a major market maker and high-frequency trader, petitioned the U.S. Court of Appeals for the Eleventh Circuit for review, arguing that the SEC’s approval was arbitrary and capricious and that the IEX system did not meet legal requirements. The United States Court of Appeals for the Eleventh Circuit reviewed the SEC’s approval under the Administrative Procedure Act’s arbitrary-and-capricious standard. The court held that substantial evidence supported the SEC’s findings about the existence and harm of latency arbitrage in the options market and the effectiveness of IEX’s ORP. The court also concluded that IEX’s quotes were legally “protected,” the SEC’s approval was neither unfairly discriminatory nor unduly burdensome on competition, and denied Citadel’s petition. View "Citadel Securities LLC v. Securities and Exchange Commission" on Justia Law

Khatabi v. Car Auto Holdings LLC

2026-05-28T07:04:33-08:00

An employee at a Miami car dealership filed suit against her employer and its manager, alleging sexual harassment and discrimination. During her four months of employment, she experienced persistent verbal and physical harassment by the manager and other colleagues, which included inappropriate comments, unwanted touching, and suggestions that she use her appearance to sell cars. Unable to endure the harassment, she resigned and brought claims under both Title VII of the Civil Rights Act and the Florida Civil Rights Act. The United States District Court for the Southern District of Florida presided over the trial. The jury found in favor of the plaintiff, awarding her $81,028 in compensatory damages and $750,000 in punitive damages. The defendants moved to reduce the damages, arguing that Title VII capped damages at $50,000 for employers with fewer than 101 employees, and the Florida statute capped punitive damages at $100,000. The court ultimately awarded the plaintiff $181,028—her full compensatory damages plus $100,000 in punitive damages under the Florida statute—reasoning that she was entitled to the larger of the two statutory caps. The United States Court of Appeals for the Eleventh Circuit reviewed the case. The appellate court held that when a jury awards damages for claims under both Title VII and a parallel state law, and the verdict does not allocate damages between the statutes, the plaintiff’s recovery may be up to the sum of the statutory maximums under each law. The court further held that the Title VII $50,000 employee-headcount cap is an affirmative defense, and, because the dealership failed to timely assert it, the defense was waived. The court reversed the district court’s judgment and remanded with instructions to enter judgment for $481,028. View "Khatabi v. Car Auto Holdings LLC" on Justia Law

Declan Flight, Inc. v. Textron eAviation, Inc.

2026-05-26T10:04:34-08:00

Two American companies, Declan Flight, Inc. and Right Rudder Aviation, LLC (RRA), developed successful sales and distribution relationships with Pipistrel, a Slovenian aircraft manufacturer, through contracts signed in 2020 and 2021. Their contracts contained forum-selection clauses specifying Slovenia as the forum for disputes. In 2022, Textron, Inc., a large U.S. aerospace company, acquired Pipistrel through its subsidiary Textron eAviation, Inc. Shortly after the acquisition, Textron and eAviation orchestrated the termination of Declan’s and RRA’s contracts. RRA also lost a separate sales contract with Mesa Airlines after Textron and eAviation allegedly interfered with that business relationship. Declan and RRA sued Textron and eAviation in the United States District Court for the Middle District of Florida, alleging tortious interference with the Pipistrel contracts and with the Mesa Airlines contract. The district court dismissed the claims related to the Pipistrel contracts (Counts I and II) for forum non conveniens, holding that the forum-selection clauses could be enforced by Textron and eAviation—nonsignatories—under the federal doctrine of equitable estoppel, thus requiring litigation to proceed in Slovenia. The district court also found that personal jurisdiction existed for the Mesa Airlines claim (Count III), but dismissed it for failure to state a claim. On appeal, the United States Court of Appeals for the Eleventh Circuit reversed the dismissal of Counts I and II. The court held that the applicability of the forum-selection clauses is governed by Slovenian law, not federal common law, and that Slovenian law does not permit nonsignatories to invoke these clauses. Thus, the district court erred in applying the modified forum non conveniens rule from Atlantic Marine. The Eleventh Circuit also reversed the finding of personal jurisdiction over Textron and eAviation as to Count III, remanding all claims for further proceedings. View "Declan Flight, Inc. v. Textron eAviation, Inc." on Justia Law

Drummond v. Southern Company Services, Inc.

2026-05-26T08:02:58-08:00

Two former employees of a large utility holding company, participants in the company’s defined-benefit pension plan, challenged the way their monthly retirement benefits were calculated. Both men, after vesting in the plan, selected joint-and-survivor annuities that would provide payments to their spouses if they died first. The plaintiffs argued that the plan used outdated and unreasonable actuarial assumptions—some based on mortality tables from 1951 or earlier—to determine both the conversion of their accrued single-life annuity benefit to a joint-and-survivor annuity and to calculate charges for mandatory preretirement survivor annuity coverage. They alleged these practices resulted in significantly lower monthly benefits than they would have received if reasonable, current actuarial assumptions had been used. The plaintiffs filed suit in the United States District Court for the Northern District of Georgia, asserting violations of the Employee Retirement Income Security Act of 1974 (ERISA). They claimed the plan failed to provide “actuarial equivalence” between single-life and joint-and-survivor annuities as required by ERISA, and that excessive reductions for preretirement survivor benefits amounted to unlawful forfeiture of accrued benefits. The district court dismissed the complaint for failure to state a claim. On appeal, the United States Court of Appeals for the Eleventh Circuit held that ERISA’s “actuarial equivalence” provision requires plans to use actuarial assumptions that a reasonable actuary would use at the time of benefit determination—not arbitrary or outdated assumptions. The court further held that employers cannot impose preretirement survivor benefit charges that exceed the actual, reasonably calculated cost of providing those benefits. Because the plaintiffs plausibly alleged violations of these standards, the Eleventh Circuit reversed the district court’s dismissal and remanded the case for further proceedings. View "Drummond v. Southern Company Services, Inc." on Justia Law

USA v. Irons

2026-05-26T05:32:37-08:00

A police officer in Fort Myers, Florida, observed Jddarrian Irons carrying a distinctive fanny pack and later found a handgun in it after stopping the car he was riding in. Irons, who had a prior felony conviction for attempted carjacking, was indicted for being a felon in possession of a firearm under federal law. He pleaded guilty to the charge. A probation officer prepared a presentence report recommending a base offense level of 20 under §2K2.1(a)(4)(A) of the Sentencing Guidelines, based on Irons’s prior conviction for a crime of violence, and a three-level reduction for acceptance of responsibility. The government, agreeing with most of the report, argued for a four-level enhancement under §2K2.1(b)(6)(B), contending Irons possessed the firearm in connection with the felony offense of carrying a concealed firearm under Florida law. The United States District Court for the Middle District of Florida adopted these recommendations, calculating a total offense level of 21 and imposing a sentence of 46 months in prison and three years of supervised release. The court also imposed special conditions of supervised release, including requirements to obtain a GED and submit to computer searches. The United States Court of Appeals for the Eleventh Circuit reviewed the case. The appellate court affirmed the district court’s calculation of the base offense level, holding that attempted carjacking qualifies as a crime of violence under the relevant Sentencing Guidelines, and that a four-level enhancement was appropriate because the firearm facilitated Irons’s concealed-carry offense. However, the appellate court vacated the conditions of supervised release requiring Irons to obtain his GED and to submit his computer to searches, ruling that these conditions were not properly pronounced at sentencing. The case was remanded for resentencing on those conditions. View "USA v. Irons" on Justia Law

Northfield Insurance Co. v. North Brook Industries, Inc.

2026-05-22T12:33:33-08:00

A hotel owner in Georgia faced a lawsuit brought by J.G., who alleged that she suffered injuries from being sex trafficked by third parties at the hotel between 2018 and 2019. The owner was insured under a commercial policy with an insurer, which included both general liability and personal and advertising injury coverage. The policy also contained two relevant endorsements: one excluded coverage for injuries arising from “abuse or molestation,” and the other limited or excluded coverage for injuries resulting from assault or battery offenses. After J.G. filed her lawsuit, the insurer provided the hotel with a defense, subject to a reservation of rights. Subsequently, the insurer initiated a declaratory judgment action in the United States District Court for the Northern District of Georgia, seeking a ruling that it did not owe coverage for J.G.'s claims under the policy. The hotel moved to dismiss the insurer’s complaint, arguing that the duty to indemnify was not ripe because liability had not yet been determined in the underlying action, and that the duty to defend existed because the allegations potentially fell within the policy’s coverage. The District Court evaluated the complaint and concluded that the insurer had a duty to defend the hotel in the underlying action, as the allegations in J.G.’s complaint potentially triggered coverage and the endorsements did not unambiguously bar or limit coverage. However, the court found the request for a declaration regarding the duty to indemnify was not ripe and retained jurisdiction over that issue. The insurer appealed, arguing the district court’s order was immediately appealable as an injunction. The United States Court of Appeals for the Eleventh Circuit held that the order was not final nor did it have the practical effect of an injunction, and therefore dismissed the appeal for lack of jurisdiction. View "Northfield Insurance Co. v. North Brook Industries, Inc." on Justia Law

Marbut v. Phillips

2026-05-22T05:32:07-08:00

A woman became unconscious after riding home with her mother, who suspected a drug overdose and called 911. When police officers and emergency medical personnel arrived, the woman regained consciousness but refused medical assistance, adamantly stating she wished to go inside to use the restroom. As she attempted to pass one of the officers, a physical altercation ensued involving four officers. During the struggle, she sustained a fractured arm, resulting in lasting injury. She later sued the officers, alleging unlawful detention and excessive force in violation of her Fourth Amendment rights. The United States District Court for the Northern District of Georgia granted summary judgment for the officers, finding they were entitled to qualified immunity. The court determined that the officers had probable cause to execute a mental-health seizure and that their use of force was objectively reasonable under the circumstances. It also concluded that there was no duty for the other officers to intervene because no excessive force had occurred. The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo. It held that the officers did not violate the woman’s clearly established Fourth Amendment rights. The court found two independent grounds for affirming qualified immunity: first, the officers had an objectively reasonable basis to seize her under the emergency-aid doctrine, as clarified by Case v. Montana, which requires only objective reasonableness and not probable cause in emergency situations; second, they had probable cause to believe she had committed a crime due to suspected GHB possession. The court also held that the force used was not excessive, as it was proportionate and fell within established standards for physical restraint, even though injury resulted. Finally, since no excessive force occurred, the other officers had no obligation to intervene. The Eleventh Circuit affirmed the summary judgment in favor of the officers. View "Marbut v. Phillips" on Justia Law

Bolton v. Sheriff of Coweta County

2026-05-21T13:03:19-08:00

A man was sitting in the backseat of his vehicle in a shopping center parking lot when sheriff’s deputies approached and asked for identification, suspecting loitering. The man repeatedly questioned the request, moved to the driver’s seat without complying, and started the vehicle. He drove away after deputies drew their weapons and commanded him to stop, nearly striking one deputy. The deputies pursued him, during which he drove through stop signs and on the wrong side of the road. A pursuit intervention technique caused his vehicle to spin and become pinned between police cars. Despite being boxed in, the man continued to press the accelerator, causing his tires to squeal and the car to push against a deputy’s vehicle. At this point, a deputy fired one shot, hitting the man in the eye. The man was then removed from the vehicle, handcuffed on the ground, and a deputy briefly placed a knee on his back. The United States District Court for the Northern District of Georgia granted summary judgment to the sheriff and deputies. It found that the shooting was a reasonable use of force in response to the perceived threat and that no clearly established law made the force unconstitutional. It held that the force used to arrest the man after the shooting was de minimis and not excessive. The court also determined the sheriff was entitled to sovereign immunity and the deputies to official immunity on state law claims because there was no showing of malice. The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s judgment. It held that the deputies did not violate the man’s constitutional rights or act with malice, and that the sheriff was immune from suit. The court found the shooting objectively reasonable under the circumstances, the force used during the arrest minimal, and no duty for a deputy to intervene. It also affirmed immunity for state law claims. View "Bolton v. Sheriff of Coweta County" on Justia Law

T-Mobile South, LLC v. City of Roswell, Georgia

2026-05-21T09:08:51-08:00

T-Mobile South, a wireless service provider, applied for a permit to construct a 108-foot cell phone tower on vacant residential property in Roswell, Georgia. The City of Roswell denied the application based on its zoning ordinance, which required permits for new wireless facilities and allowed decision-makers to consider several factors. T-Mobile then sued, claiming the denial both prevented it from filling a service coverage gap and discriminated among service providers. The company sought an injunction compelling Roswell to issue the permit. Proceedings in the United States District Court for the Northern District of Georgia resulted in an initial grant of summary judgment for T-Mobile, which was reversed by the United States Court of Appeals for the Eleventh Circuit. The Supreme Court also reviewed the case and remanded it. On remand, the district court ultimately ruled in favor of T-Mobile after a bench trial, applying the “significant gap” test: it found T-Mobile had a significant gap in service that only the proposed tower would remedy and ordered Roswell to approve the necessary permits. The United States Court of Appeals for the Eleventh Circuit reviewed whether the “effective prohibition” provision of the Telecommunications Act of 1996 applies to a single permit denial. The court held that the statutory prohibition on local “regulation” that “prohibits or has the effect of prohibiting” wireless service applies to general rules or regulations, not to individual zoning decisions or permit denials. The Eleventh Circuit vacated the district court’s judgment and remanded the case for further proceedings under the correct legal standard, concluding that T-Mobile must challenge the city’s rules themselves, not individual permit denials, to invoke the effective prohibition clause. View "T-Mobile South, LLC v. City of Roswell, Georgia" on Justia Law

Great Lakes Insurance SE v. Crabtree

2026-05-19T06:32:31-08:00

After a boat owned by Bryan and Bethea Crabtree was severely damaged by fire while in storage in Florida, the Crabtrees sought coverage under their insurance policy with Great Lakes Insurance. Great Lakes denied their claim, alleging noncompliance with policy conditions, and subsequently filed a declaratory judgment action against the Crabtrees in the United States District Court for the District of Montana, based on the policy’s forum-selection clause and the Crabtrees’ Montana address. The parties agreed that Great Lakes would voluntarily dismiss the Montana case and refile in the United States District Court for the Southern District of Florida (SDFL), with the understanding that the Crabtrees would not contest jurisdiction or venue. Great Lakes dismissed the Montana action and refiled in SDFL. In response, the Crabtrees initiated a state court action and moved to stay or dismiss the SDFL federal suit. Instead of opposing the motion, Great Lakes voluntarily dismissed the SDFL suit as well. That same day, Great Lakes refiled a third action in Montana, which was later transferred back to SDFL at the Crabtrees’ request and with Great Lakes’s consent. Upon return to SDFL, the United States District Court for the Southern District of Florida considered whether, under Federal Rule of Civil Procedure 41(a)(1)(B), Great Lakes’s second voluntary dismissal barred further litigation of the same claim. The court granted summary judgment for the Crabtrees, holding that Rule 41(a)(1)(B) means what it says: a second voluntary dismissal acts as an adjudication on the merits, i.e., a dismissal with prejudice, even if the first dismissal was by agreement. The United States Court of Appeals for the Eleventh Circuit affirmed, concluding that Great Lakes was precluded from relitigating its claim in SDFL. View "Great Lakes Insurance SE v. Crabtree" on Justia Law

L.W. v. Commissioner of the Georgia Department of Community Health

2026-05-18T10:03:08-08:00

A three-year-old child, L.W., who has a rare metabolic condition that can cause life-threatening hypoglycemia, moved from Virginia to Georgia. In Virginia, he had received 96 hours per week of care through Medicaid, including private nursing and support provided by his mother. After his family relocated to Georgia, L.W.'s mother applied for comparable nursing services under the Georgia Pediatric Program (GAPP), but the state approved only 21 hours per week. Requests for increased hours were denied by the state’s contractor, Alliant Health Solutions, which relied on a policy requiring evidence of a change in medical condition to justify increasing hours. L.W.’s family and physician argued that the approved hours were insufficient and unsustainable, risking L.W.’s health and placing heavy burdens on his parents. The United States District Court for the Northern District of Georgia reviewed the case after L.W.’s mother filed suit under 42 U.S.C. § 1983, alleging that Georgia’s Medicaid program was failing to provide services required by federal law. The court found that 21 hours of nursing care per week was insufficient to meet L.W.'s medical needs, based on evidence from his mother and physician. It granted a preliminary injunction requiring Georgia to provide at least 100 hours of private nursing care per week and to evaluate future requests under the correct legal standard, without requiring a bond from the plaintiffs. The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s order. It held that, regardless of the reasonableness of the state’s general policy, Georgia Medicaid must provide care sufficient to correct or ameliorate an individual patient’s medical condition as required by federal law. The Eleventh Circuit concluded that the district court did not clearly err in its factual findings, and that the injunction was proper under the applicable legal standards. View "L.W. v. Commissioner of the Georgia Department of Community Health" on Justia Law

Mobile Baykeeper, Inc. v. Alabama Power Company

2026-05-18T08:35:04-08:00

A local environmental organization brought a citizen suit against an electric utility company, alleging that the company’s plan to close a large coal ash storage impoundment at one of its plants violated federal Environmental Protection Agency (EPA) regulations. The organization asserted that the plan would leave significant amounts of coal ash in contact with groundwater, causing toxins to leach into the Mobile River and surrounding waterways, which harmed the recreational and aesthetic interests of its members. The plant’s closure plan, already underway, was a cap-in-place strategy rather than removal, and the organization claimed this approach did not satisfy the federal performance standards meant to prevent further pollution. The case was first reviewed by the United States District Court for the Southern District of Alabama. After briefing and a hearing, the district court dismissed the complaint, holding that the organization lacked standing for failing to establish causation and redressability, and that the claims were not ripe for review because the closure plan would not be completed for several years and its final form was uncertain. The court reasoned that the alleged harms predated the closure plan and that a judicial order would not provide immediate relief. On appeal, the United States Court of Appeals for the Eleventh Circuit disagreed with the district court’s findings. The appellate court concluded that the organization adequately pleaded standing by alleging concrete injuries caused by the utility’s ongoing implementation of a closure plan that did not comply with EPA regulations, and that a compliant plan would likely alleviate those harms. The court also found the claims ripe for review, as the legal issues were fit for decision and delaying consideration would further harm the organization’s members. The Eleventh Circuit reversed the district court’s dismissal and remanded the case for further proceedings. View "Mobile Baykeeper, Inc. v. Alabama Power Company" on Justia Law

Quinn v. Secretary of State, State of Georgia

2026-05-11T06:02:38-08:00

Two Georgia voters, William T. Quinn and David Cross, independently analyzed Georgia’s voter registration list by comparing it with the United States Postal Service’s National Change of Address database. Believing they had found evidence that the Secretary of State was not properly maintaining the voter rolls as required by the National Voter Registration Act of 1993 (NVRA) and state law, they notified the Secretary, requesting that potentially ineligible voters be flagged and notified. When the Secretary did not respond, the plaintiffs filed suit, asserting that this alleged failure undermined their confidence in the election process and risked diluting their votes. The United States District Court for the Northern District of Georgia dismissed the case for lack of Article III standing. The district court found that the plaintiffs’ claimed injuries—undermined confidence in elections and risk of vote dilution—were generalized grievances common to all Georgia voters, not injuries particularized to the plaintiffs themselves. The court reasoned that any voter could express similar concerns based on the state’s alleged noncompliance with the NVRA, and that such concerns were too speculative to confer standing. On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s dismissal. The Eleventh Circuit held that the plaintiffs’ alleged injuries were not particularized, as the supposed harm—loss of confidence in the electoral process—equally affected all Georgia voters. The court concluded that merely discovering or believing in government error, even after personal investigation, does not transform a generalized grievance into a particularized injury sufficient for federal court standing. Thus, the plaintiffs lacked standing, and the dismissal was affirmed. View "Quinn v. Secretary of State, State of Georgia" on Justia Law

Alvarez v. Warden, Federal Detention Center Miami

2026-05-06T13:02:34-08:00

Two individuals, both Mexican nationals who entered the United States without inspection and had resided in the country for several years with U.S. citizen children, were arrested by immigration authorities following traffic stops in Florida. After their arrests, they were placed in removal proceedings and detained without the possibility of a bond hearing under 8 U.S.C. § 1225(b)(2)(A), which the Department of Homeland Security argued required mandatory detention of unadmitted aliens found in the interior of the United States. Each petitioner filed a habeas corpus petition in the United States District Court for the Southern District of Florida, challenging their detention without bond and arguing that they were eligible for bond under § 1226(a) of the Immigration and Nationality Act. The district court concluded that § 1226, not § 1225(b)(2)(A), governed their detention, finding that the petitioners were not “seeking admission” at the time of their arrest, and therefore were entitled to bond hearings. The court did not address their other claims. Following this ruling, both individuals received bond hearings and were released from custody. The government appealed, maintaining that all unadmitted aliens present in the United States are subject to mandatory detention under § 1225(b)(2)(A). The United States Court of Appeals for the Eleventh Circuit held that § 1225(b)(2)(A) does not apply to unadmitted aliens merely present in the country’s interior unless they are actively seeking lawful entry after inspection by an immigration officer. Instead, § 1226 governs the detention of such individuals, making them generally eligible for bond. The court affirmed the district court’s grant of habeas relief, finding no basis in the text, structure, or history of the INA to support the government’s broader reading of § 1225(b)(2)(A). View "Alvarez v. Warden, Federal Detention Center Miami" on Justia Law

Great Bowery Inc. v. Consequence Sound LLC

2026-05-05T10:04:13-08:00

A renowned photographer entered into a 2014 agreement with a licensing agency, granting it the exclusive worldwide right to license, market, and promote certain of her images. However, she reserved for herself the right to collaborate with or deliver these images to specific individuals or entities for special projects or other endeavors she deemed of interest. In subsequent years, the photographer took photographs for a magazine under agreements that reserved rights to her studio. The agency discovered that some of these photographs appeared on websites operated by the defendants and sued them for copyright infringement, supplying an authorization letter from the photographer permitting it to act on her behalf in matters relating to copyright infringement. In the United States District Court for the Southern District of Florida, the defendants argued that the agency lacked statutory standing under the Copyright Act because it was not the legal or beneficial owner of an exclusive right under the copyright. The district court agreed, finding that the photographer’s retention of certain rights in the agreement meant the agency did not have an exclusive license, and therefore lacked standing. The court granted summary judgment to the defendants. It also denied the agency’s late motion to amend the complaint to add the photographer as a co-plaintiff. The United States Court of Appeals for the Eleventh Circuit reviewed the case and held that the district court’s analysis was mistaken: the reservation of certain rights by the photographer did not automatically eliminate the agency’s ability to hold other exclusive rights. The appellate court vacated the summary judgment, affirmed the denial of the motion to amend, and remanded for further proceedings, instructing the district court to reconsider the standing issue and the effect of the authorization letter in light of its opinion. View "Great Bowery Inc. v. Consequence Sound LLC" on Justia Law

Tejon v. Zeus Networks, LLC

2026-05-01T13:03:29-08:00

Roger Tejon subscribed to a video streaming service operated by Zeus Networks, LLC, through its online platform using an Apple device. To register, Tejon chose between an annual or monthly plan by clicking one of two large, red buttons on a “Choose your plan” page. Below these buttons, in small, gray text was a hyperlinked “Terms of Service,” which included a mandatory arbitration clause, but there was no requirement that Tejon click on this link to complete his subscription. Tejon later alleged that Zeus shared his viewing history and personally identifiable information with a social media company without his consent and sued Zeus for violating the Video Privacy Protection Act. Zeus moved to compel arbitration, arguing that Tejon had consented to the arbitration clause by signing up for an account. The United States District Court for the Southern District of Florida denied this motion. The district court found that the terms of service hyperlink was not conspicuous enough to put a reasonably prudent user on inquiry notice of the arbitration provision. The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s denial de novo. The Eleventh Circuit held that the design of Zeus’s subscription page did not provide sufficient inquiry notice of the arbitration agreement to bind Tejon. The court explained that the hyperlink to the terms was small, in gray font, and located beneath prominent action buttons, making it easy to overlook. The court further noted that the page did not explicitly state that clicking the subscription button would bind the user to arbitration. The Eleventh Circuit affirmed the district court’s order denying the motion to compel arbitration. View "Tejon v. Zeus Networks, LLC" on Justia Law