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

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

USA v. Blair

2026-05-01T05:33:13-08:00

The case involves an individual who orchestrated a scheme in which he recruited travelers to take fully paid trips to Costa Rica, under the guise of participating in an insurance company’s security audit. In reality, these travelers were unknowingly used to smuggle cocaine into the United States inside canned goods labeled as fruits and vegetables. The individual coordinated travel arrangements, provided financial support for trip-related expenses, and ensured the travelers received the cans. The scheme was exposed when one traveler was caught with cocaine at customs and cooperated with authorities, leading to the organizer’s arrest. Further investigation revealed extensive communications and financial transactions related to the drug smuggling operation. After charges were initially dismissed, the same individual resumed similar activities, resulting in additional arrests and a multi-count indictment for cocaine importation, possession, and money laundering. Several co-conspirators, including the individual’s main contact, cooperated with the government. The main contact also paid for the defendant’s legal fees, raising concerns about conflicts of interest. The United States District Court for the Northern District of Georgia oversaw the trial, during which the defendant argued lack of knowledge regarding the cocaine, challenged evidentiary rulings, and objected to the government’s handling of cooperating witnesses. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed multiple claims, including alleged violations of the Sixth Amendment right to counsel, evidentiary errors, improper quashing of subpoenas, incorrect jury instructions, due process violations, and the reasonableness of the sentence imposed. The Eleventh Circuit held that none of the alleged errors warranted reversal. The court found no Sixth Amendment violations, upheld the admission of cell phone evidence, affirmed the quashing of subpoenas for lack of proper foundation, determined that the jury instructions were appropriate, and concluded that the sentence was both procedurally and substantively reasonable. The judgment of the district court was affirmed. View "USA v. Blair" on Justia Law

Moore v. Senate Majority PAC

2026-04-24T05:02:18-08:00

A political action committee (SMP) created and broadcast a television advertisement during a 2017 Alabama Senate special election. The ad referenced news reports about allegations of sexual misconduct by the Republican nominee. In particular, two key statements appeared in consecutive frames: one stated that the nominee was “banned from the Gadsden Mall . . . for soliciting sex from young girls”; the other noted that “one he approached was 14 and working as Santa’s helper.” The ad ran over 500 times. The nominee, who lost the election, contended that the juxtaposition of these statements created the false and defamatory implication that he had solicited sex from the 14-year-old referenced. In the United States District Court for the Northern District of Alabama, the nominee sued for defamation and false-light invasion of privacy, focusing on the implication created by these two statements together. The case proceeded to a jury trial. The jury found for the plaintiff on both claims and awarded $8.2 million in compensatory damages. The district court denied SMP’s renewed motion for judgment as a matter of law or for a new trial. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed whether there was clear and convincing evidence that SMP acted with “actual malice,” as required under New York Times v. Sullivan, for defamation against a public figure. The court held that, in cases of defamation by implication, the plaintiff must show both that the defendant knew of or recklessly disregarded the falsity of the implication and that the defendant intended to communicate, or recklessly disregarded, the defamatory implication. The court found the evidence insufficient to meet this standard and reversed the district court’s denial of judgment as a matter of law, remanding with instructions to enter judgment for SMP. View "Moore v. Senate Majority PAC" on Justia Law

McLean v. Delta Air Lines, Inc.

2026-04-22T21:07:12-08:00

Two former pilots for a major airline, who also served as reservists in the United States Air Force, brought suit against their employer. They claimed that the airline forced them out of their jobs because of their military service obligations, and that the company’s handling of their pension contributions and vacation accrual during military leave violated the Uniformed Services Employment and Reemployment Rights Act (USERRA). The pilots had been investigated by the airline for abusing military and sick leave policies, including instances where they claimed sick leave from the airline but performed military duties on those days, and for reporting false military obligations to avoid work. The United States District Court for the Northern District of Georgia granted summary judgment to the airline on all claims. The court found that, while the pilots established a prima facie case that their military service was a motivating factor in their resignations, the airline demonstrated legitimate, non-discriminatory reasons for its actions: the pilots’ abuse of sick-leave benefits. Regarding the pension-contribution claim, the district court determined that the pilots’ rates of compensation were not reasonably certain and that the airline’s method of calculating pension contributions during military leave exceeded statutory requirements. For the vacation-time claim, the court held there was no evidence showing that pilots on comparable non-military leave accrued vacation time, as required by USERRA. The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo and affirmed the district court’s grant of summary judgment on all counts. The appellate court held that the airline’s actions were justified by the pilots’ misuse of sick leave, the pension calculations met or exceeded legal obligations, and the vacation accrual policy did not violate USERRA because no comparable leave existed. View "McLean v. Delta Air Lines, Inc." on Justia Law

Chemaly v. Lampert

2026-04-22T08:34:06-08:00

A seaman who worked aboard a Cayman Islands-flagged yacht suffered a right shoulder injury while helping recover an underwater scooter at the direction of his captain. After the incident, the seaman alleged he was denied pain medication, reassigned to night shifts to hide his injury from guests, and eventually repatriated to his home country without his belongings. He sued the yacht’s beneficial owner, the captain, the vessel’s record owner, his nominal employer, the yacht’s manager, and the insurer, asserting various claims including negligence under the Jones Act, unseaworthiness, failure to provide maintenance and cure, failure to treat, negligence, conversion, and breach of insurance contract. The defendants (except the insurer) removed the case to the United States District Court for the Southern District of Florida under the New York Convention, citing an arbitration provision in the seaman’s employment agreement requiring disputes to be arbitrated in the Cayman Islands. The district court compelled arbitration as to the Jones Act, maintenance and cure, and failure to treat claims against the yacht owner, the beneficial owner, and the employer, but remanded the remaining claims to state court. The insurer later settled. On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision compelling arbitration for the Jones Act, maintenance and cure, and failure to treat claims against the nominal employer, and for the maintenance and cure and failure to treat claims against the yacht owner and beneficial owner. However, it reversed the order to the extent it compelled arbitration of the Jones Act claim against the yacht owner and beneficial owner, finding insufficient allegations of concerted misconduct to warrant estoppel. The court dismissed the cross-appeal for lack of jurisdiction as to the remanded claims. The main holding is that arbitration must be compelled for the relevant claims as to the nominal employer, and for maintenance and cure and failure to treat as to the yacht owner and beneficial owner, but not for the Jones Act claim against the latter two. View "Chemaly v. Lampert" on Justia Law

USA v. Alsenat

2026-04-21T21:07:45-08:00

The defendant was indicted for knowingly possessing machinegun conversion devices, which are considered machineguns under federal law. He moved to dismiss the indictment, arguing that the federal prohibition on possessing machineguns violates the Second Amendment when applied to adult citizens without felony convictions. After the district court denied his motion, he pleaded guilty, admitting that he knowingly sold three machinegun conversion devices to an undercover officer. He was sentenced to 24 months in prison and three years of supervised release. The United States District Court for the Southern District of Florida denied the defendant’s motion to dismiss the indictment. The court concluded that machineguns are not in common use, are dangerous and unusual, and thus not protected by the Second Amendment. Alternatively, it found that machinegun conversion devices not attached to a firearm are merely accessories and not “Arms” under the Second Amendment. Following the denial, the defendant pleaded guilty and was sentenced. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed whether the Second Amendment protects possession of machineguns in light of Supreme Court precedent. The Eleventh Circuit applied a de novo standard of review and held that machineguns are not protected by the Second Amendment because they are not weapons typically possessed by law-abiding citizens for lawful purposes and are considered dangerous and unusual. The court also noted the historical and widespread regulation and prohibition of machineguns. The Eleventh Circuit affirmed the defendant’s conviction, holding that the federal machinegun ban is constitutional, including as applied to law-abiding, non-felon adults. The disposition by the Eleventh Circuit was to affirm the conviction. View "USA v. Alsenat" on Justia Law

Friends of the Everglades, Inc. v. Secretary of the U.S. Department of Homeland Security

2026-04-21T21:07:45-08:00

State officials in Florida constructed an immigration detention facility at the Dade-Collier Training and Transition Airport, located in the Florida Everglades, using state funds and employees. The facility was built on state property and managed by state law enforcement, although federal Immigration and Customs Enforcement (ICE) officials inspected the site and occasionally coordinated the transport and detention of individuals there. The state planned to seek federal reimbursement but had not received any federal funding at the time of the events in question. Several state agencies operated under agreements with the federal government, pursuant to 8 U.S.C. § 1357(g), allowing them to assist with immigration enforcement, but Florida retained control over the facility’s management and construction. The Friends of the Everglades, the Center for Biological Diversity, and the Miccosukee Tribe of Indians of Florida filed suit in the United States District Court for the Southern District of Florida. They alleged violations of the Administrative Procedure Act (APA) and the National Environmental Policy Act (NEPA), claiming that officials failed to conduct a required environmental review before constructing and operating the facility. The district court issued a preliminary injunction halting further construction, requiring removal of certain structures, and prohibiting detention of additional individuals at the site. The court found that the plaintiffs were likely to succeed on the merits, concluding that the construction was a final agency action and a major federal action under NEPA, and that federal officials exercised substantial control over the project. On appeal, the United States Court of Appeals for the Eleventh Circuit held that the plaintiffs failed to demonstrate either a final agency action under the APA or substantial federal control necessary to trigger NEPA, given that Florida constructed and controlled the facility without federal funding or operational authority. The court also found that the district court’s injunction violated a statutory prohibition against enjoining immigration enforcement. The Eleventh Circuit vacated the preliminary injunction and remanded for further proceedings. View "Friends of the Everglades, Inc. v. Secretary of the U.S. Department of Homeland Security" on Justia Law

Lavina v. Florida Prepaid College Board

2026-04-21T10:34:34-08:00

Two individuals purchased Florida prepaid college tuition savings plans for their daughters in 2004 and 2006. The plans promised to cover tuition at Florida public colleges or transfer an equivalent amount to non-Florida colleges if the beneficiary chose to attend elsewhere. In 2007, the Florida Legislature authorized a new “tuition differential” fee, exempting holders of existing plans from paying that fee at Florida colleges. The Florida Prepaid College Board amended the plan contracts to specify that this new fee was not covered for out-of-state schools. Over a decade later, when both daughters chose to attend out-of-state colleges, the Board declined to transfer an amount equivalent to the tuition differential fee. The purchasers filed a putative class action in the United States District Court for the Southern District of Florida against members of the Board, alleging that the Board’s refusal violated the Contracts and Takings Clauses of the U.S. Constitution. They sought declaratory and injunctive relief to prevent the Board from applying the statutory exemption and contract amendments to beneficiaries attending non-Florida schools. The Board moved to dismiss, arguing it was protected by sovereign immunity. A magistrate judge recommended denying the motion, reasoning the relief sought was prospective. However, the district court disagreed, ruling that the relief requested was essentially a demand for a refund, thus barred by the Eleventh Amendment, and dismissed the complaint with prejudice. The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that the suit was barred by sovereign immunity because the relief sought would require specific performance of a contract with the state, which is not permitted under Ex parte Young and related Supreme Court precedent. However, the appellate court vacated the district court’s dismissal with prejudice and remanded with instructions to dismiss without prejudice, as the dismissal was for lack of subject-matter jurisdiction. View "Lavina v. Florida Prepaid College Board" on Justia Law

Associated Builders and Contractors Florida First Coast Chapter v. General Services Administration

2026-04-21T08:35:04-08:00

Two builders’ associations, whose members are largely non-union construction contractors, challenged a federal procurement mandate issued by executive order in February 2022. The order, issued by the President, presumptively requires all contractors and subcontractors on federal construction projects valued at $35 million or more to enter into project labor agreements with unions. The order allows for three specific exceptions if a senior agency official provides a written explanation. The Federal Acquisition Regulatory Council issued regulations implementing the order, and the Office of Management and Budget provided guidance. The associations argued that the mandate unfairly deprived their members of contracting opportunities and brought a facial challenge under several statutory and constitutional grounds, seeking to enjoin the mandate’s enforcement. The United States District Court for the Middle District of Florida denied the associations’ motion for a preliminary injunction. It found that the associations were likely to succeed on their claim under the Competition in Contracting Act, since the government was not meaningfully applying the order’s exceptions, but concluded that the associations would not suffer irreparable harm because they could challenge individual procurements in the United States Court of Federal Claims. The district court did not consider irreparable harm as to the associations’ other claims. On interlocutory appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the denial of the preliminary injunction, although for different reasons. The Eleventh Circuit held that the associations were unlikely to succeed on the merits of their facial challenge under the Competition in Contracting Act, the Federal Property and Administrative Services Act, the First Amendment, the Administrative Procedure Act, the Office of Federal Procurement Policy Act, and the National Labor Relations Act. The court emphasized that the existence of written exceptions in the executive order precluded a facial invalidity finding, and that the government acted within its statutory and proprietary authority. The court affirmed the district court’s order. View "Associated Builders and Contractors Florida First Coast Chapter v. General Services Administration" on Justia Law

USA v. Defilippis

2026-04-20T11:02:19-08:00

A man was prosecuted after a person, J.R., died from a fentanyl overdose following the purchase of drugs from him. The central witness was J.R.’s girlfriend, who described the events leading up to J.R.’s death, including a meeting at a bank where J.R. met the defendant and returned with drugs packaged in foil. Video surveillance, financial records, and communications via Facebook Messenger corroborated the meeting and drug transaction. Law enforcement arrested the defendant during a sting operation using J.R.’s phone, and drugs found during the arrest matched the chemical profile of those found near J.R.’s body. The United States District Court for the Middle District of Florida conducted the trial. The defendant challenged the admissibility of Facebook messages as evidence of intent and prior bad acts, the use of photographs showing him in jail attire, and various aspects of the forensic evidence. The court admitted the challenged evidence, issued limiting instructions to the jury, and denied a motion to continue the trial. The jury convicted the defendant on counts of distributing fentanyl resulting in death and possession with intent to distribute. The court sentenced him to life imprisonment on the first count and ten years on the second. The district court also denied a motion for a new trial, rejecting claims of evidentiary errors and discovery violations. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed evidentiary rulings, sufficiency of the evidence, and the constitutionality of the mandatory life sentence. The appellate court held that the Facebook messages were properly admitted as probative of intent, that any error in admitting jail photographs was harmless, and that sufficient evidence supported the conviction. The court also found no reversible discovery or Brady violations, and no plain error in the imposition of a mandatory life sentence under 21 U.S.C. § 841(b)(1)(C). The convictions and sentence were affirmed. View "USA v. Defilippis" on Justia Law

Frida Kahlo Corporation v. Pinedo

2026-04-19T21:04:20-08:00

This case involves a dispute over the rights to the name, image, and trademarks associated with the late artist Frida Kahlo. Two Panamanian corporations with principal places of business in Florida, Frida Kahlo Corporation and Frida Kahlo Investments, manage and license numerous Frida Kahlo trademarks. Mara Cristina Teresa Romeo Pinedo, Frida Kahlo’s grandniece and a resident of Mexico, is an owner and former officer of Familia Kahlo S.A. de C.V., a Mexican company. The parties’ relationship became contentious, leading to litigation in several countries over the intellectual property rights. Plaintiffs alleged that, beginning in 2017 and specifically targeting Florida in 2021 and 2022, the defendants sent cease-and-desist letters to plaintiffs’ business partners in Florida, threatening legal action based on what plaintiffs contend were false claims to trademark ownership. Plaintiffs claimed these actions constituted tortious interference under Florida law and the Lanham Act. The United States District Court for the Southern District of Florida dismissed the lawsuit for lack of personal jurisdiction. The court found that Florida’s long-arm statute was satisfied for Familia Kahlo, but the corporate shield doctrine protected Pinedo because she was not acting in her personal capacity. The court further concluded that the minimum contacts required by due process were not established for either defendant, as sending cease-and-desist letters alone was insufficient. On appeal, the United States Court of Appeals for the Eleventh Circuit reversed the district court’s decision. The Eleventh Circuit held that the corporate shield doctrine did not apply to Pinedo because the cease-and-desist letters were sent on her behalf in her personal capacity. The court also held that due process permitted the exercise of personal jurisdiction over both defendants, as the “effects test” was satisfied and a tortious cease-and-desist letter can meet the minimum contacts requirement. The case was remanded for further proceedings. View "Frida Kahlo Corporation v. Pinedo" on Justia Law

Joyce v. Forest River, Inc.

2026-04-17T10:34:00-08:00

In June 2020, an individual purchased a recreational vehicle manufactured by two companies. The vehicle quickly developed problems, prompting the owner to seek repairs on multiple occasions and to notify the manufacturers of ongoing defects. Over the course of about two years, the vehicle underwent several repair attempts by both manufacturers and their authorized agents. After further repair offers were declined by the owner, statutory defect notices were sent, and additional repairs were made. The owner eventually sought relief under Florida’s Lemon Law, alleging that the manufacturers failed to adequately repair the defects. The dispute was submitted to arbitration pursuant to Florida Statute § 681.1095. The arbitration board concluded that the owner did not meet the burden of eligibility for a refund under the Lemon Law and only ordered limited repairs. The owner then appealed to the United States District Court for the Southern District of Florida. That court granted summary judgment for both manufacturers, holding that the owner failed to establish entitlement to relief because the statutory presumptions for repairs or days out-of-service were not met, and deemed as admitted the manufacturers’ statements of material facts due to procedural deficiencies in the owner’s filings. On appeal, the United States Court of Appeals for the Eleventh Circuit found that the district court erred by treating the statutory presumptions in Florida’s Lemon Law as mandatory requirements for relief. The court clarified that these presumptions are not prerequisites but rather examples of when a “reasonable number of attempts” has been made. Applying the correct standard, the appellate court affirmed summary judgment for one manufacturer because the owner failed to satisfy initial notice and repair requirements. However, as to the other manufacturer, it found genuine disputes of material fact regarding whether a reasonable number of attempts had been made and therefore reversed and remanded for further proceedings. View "Joyce v. Forest River, Inc." on Justia Law

USA v. Martinez

2026-04-16T09:07:43-08:00

Three individuals were detected by U.S. authorities aboard a “go-fast” vessel approximately 158 nautical miles southeast of Isla Beata, Dominican Republic. During the encounter, the men were seen discarding packages, later recovered as cocaine. The Coast Guard boarded the vessel, whose master claimed Colombian nationality, but Colombian authorities would not confirm or deny the vessel’s registration. As a result, U.S. authorities deemed the vessel “stateless” and seized approximately 375 kilograms of cocaine. The men were arrested and charged under the Maritime Drug Law Enforcement Act (MDLEA) with conspiracy to possess with intent to distribute cocaine while onboard a vessel subject to U.S. jurisdiction. The United States District Court for the Southern District of Florida denied the defendants’ joint motion to dismiss the indictment. The court relied on Eleventh Circuit precedent upholding the constitutionality of the MDLEA, specifically regarding Congress’s ability to assert jurisdiction over stateless vessels on the high seas under the protective principle of international law. After the motion was denied, all three defendants pleaded guilty. At sentencing, the district court imposed varying terms of imprisonment and supervised release, granting some downward variances but denying a minor-role reduction to one defendant, who raised the issue on appeal. The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court’s rulings. The appellate court held that binding circuit precedent forecloses constitutional challenges to the MDLEA, including claims based on the Felonies Clause, the lack of a nexus to the United States, and the statute’s definition of “stateless vessel.” The court also held that recent amendments to the Sentencing Guidelines regarding minor-role reductions were substantive and not retroactively applicable. The district court’s denial of a minor-role reduction and all other challenged rulings were affirmed. View "USA v. Martinez" on Justia Law

AE OPCO III, LLC v. AAR CORP.

2026-04-15T12:31:57-08:00

The case involves a business arrangement among AE OpCo, AAR, and Short Brothers, centered on a procurement contract. AAR’s subsidiary manufactured airline parts for Short Brothers, and AAR guaranteed its subsidiary’s performance. When AE OpCo acquired AAR’s business, it assumed the obligation to perform under the contract, while AAR guaranteed AE OpCo’s performance to Short Brothers. In turn, AE OpCo agreed to indemnify AAR if AE OpCo defaulted. Later, AE OpCo filed for bankruptcy and rejected the procurement contract, prompting both Short Brothers and AAR to file claims in the bankruptcy proceeding. The United States Bankruptcy Court for the Middle District of Florida considered three claims from AAR: an indemnification claim for potential liability to Short Brothers, a defense-costs claim for legal fees incurred in ongoing litigation with Short Brothers in Northern Ireland, and a bankruptcy-costs claim for attorneys’ fees incurred in the bankruptcy proceedings. The bankruptcy court disallowed the indemnification claim as contingent and barred by 11 U.S.C. § 502(e)(1)(B), allowed the defense-costs claim as a fixed, non-contingent claim, and disallowed the bankruptcy-costs claim as a post-petition unsecured claim. On direct appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the bankruptcy court’s disallowance of the indemnification claim, holding that under Delaware law, the settlement between AE OpCo and Short Brothers did not release AE OpCo’s liability, so AAR remained co-liable and the claim was properly disallowed under § 502(e)(1)(B). The appellate court also affirmed the allowance of the defense-costs claim, finding it was not contingent since all events giving rise to liability had occurred. However, the court reversed the disallowance of the bankruptcy-costs claim, holding that neither § 502(b) nor § 506(b) barred allowance of such a claim, and remanded for further proceedings. View "AE OPCO III, LLC v. AAR CORP." on Justia Law

Anderson v. City of Atlanta, Georgia

2026-04-15T10:31:43-08:00

A sign operator installed two advertising signs near Interstate 85 in Atlanta in 1993, after obtaining permits under the city’s 1982 sign code. These permits were renewed several times. In 2015, after the Supreme Court’s decision in Reed v. Town of Gilbert, the city amended its sign code, removing several content-based provisions but allowing lawful, nonconforming signs to remain. When the sign operator later sought to upgrade the signs, the city approved the changes, but private parties challenged the decision. The Superior Court of Fulton County found that the original permits were unlawful under the 1982 code, making the signs illegal. The city then ordered removal of the signs and issued citations when the order was not followed. The sign operator, joined by the property owner and its president, sued the City of Atlanta in the United States District Court for the Northern District of Georgia, seeking a declaration that the 1982 sign code was unconstitutional under the First Amendment and seeking to enjoin its enforcement. The district court initially dismissed some claims for lack of jurisdiction, then reconsidered and ruled in favor of the plaintiffs, concluding that the code was content-based and subject to strict scrutiny, which the city had not attempted to satisfy. On appeal, the United States Court of Appeals for the Eleventh Circuit held that the plaintiffs only had standing to challenge the provision of the 1982 code that applied to their signs—section 16-28.019(7)—rather than the entire code. The court further held that this provision, which distinguished between on-premises and off-premises signs, was content-neutral under the Supreme Court’s decision in City of Austin v. Reagan National Advertising of Austin, LLC. The Eleventh Circuit vacated the district court’s judgment and injunction and remanded for further proceedings to determine whether the provision meets the applicable intermediate scrutiny standard. View "Anderson v. City of Atlanta, Georgia" on Justia Law

The Lane Construction Corporation v. Skanska USA Civil Southeast, Inc.

2026-04-15T06:01:37-08:00

A group of three major construction firms formed a joint venture to undertake Florida’s largest infrastructure project: the reconstruction and expansion of a major interstate. The venture’s contractual and financial structure was complicated, involving a public-private partnership in which a concessionaire entity financed the project, hired the joint venture to perform the actual construction, and would gain long-term maintenance rights. One member of the joint venture, aware of mounting losses, proposed a strategy for the venture to attempt to exit the project or use the threat of termination as leverage in negotiations. This strategy relied on a contested interpretation of the contract and was opposed by the other members, who considered it dangerously speculative and likely to cause greater harm. As losses increased, the dissenting member stopped contributing required capital to the joint venture, accusing the managing partner of breaching its fiduciary duties by refusing to pursue the proposed termination strategy, and alleging a conflict of interest due to overlapping ownership between the managing partner and the concessionaire. The other members responded by contributing additional funds to keep the project solvent and countersued for breach of contract and indemnity. The United States District Court for the Middle District of Florida held a bench trial and found that the managing partner had not breached any fiduciary duty or acted with gross negligence. The court also found that the dissenting member had materially breached the joint venture agreement by refusing to pay its share of capital calls, and ordered it to reimburse the other members, including prejudgment interest and attorneys’ fees. On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed. The court held that the managing partner had acted in the best interest of the joint venture by not pursuing the proposed termination, and that there was no actionable conflict of interest under Florida partnership law. The court also concluded that the dissenting member’s failure to fund was a material breach, entitling the other members to indemnification and statutory prejudgment interest. View "The Lane Construction Corporation v. Skanska USA Civil Southeast, Inc." on Justia Law

McClinton v. Warden

2026-04-14T09:07:41-08:00

A prisoner at Phillips State Prison in Georgia stabbed a high-ranking member of the Bloods gang and, for his protection, was placed in protective custody and then transferred to Baldwin State Prison. The transfer request referenced the risk from the gang member he had assaulted. Upon arrival at Baldwin, the prisoner was placed in the general population rather than protective custody. There, after a brief period, he was stabbed to death by another inmate associated with the Bloods gang. The prisoner’s parents and estate brought claims against five Georgia Department of Corrections officials, alleging violations of the Eighth Amendment based on deliberate indifference to the risk the prisoner faced. The United States District Court for the Middle District of Georgia dismissed some claims as time-barred and, on summary judgment, found that all defendants were entitled to qualified immunity. The district court concluded that none of the officials had violated clearly established law or demonstrated the subjective awareness required for Eighth Amendment liability under claims of deliberate indifference. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed whether the district court correctly applied the standard for deliberate indifference, as clarified in Wade v. McDade and Farmer v. Brennan. The Eleventh Circuit held that, while the risk to the prisoner was objectively serious, none of the defendants possessed the necessary subjective knowledge that their own conduct placed the prisoner at substantial risk of serious harm. The court emphasized that deliberate indifference requires actual, specific knowledge of the risk and a disregard of that risk. As a result, the Eleventh Circuit affirmed the district court’s grant of qualified immunity to all defendants and upheld the dismissal of the claims. View "McClinton v. Warden" on Justia Law

Spirit Airlines, LLC v. Transportation Security Administration

2026-04-13T12:36:50-08:00

Spirit Airlines sold tickets to customers and collected a government-mandated security fee at the time of purchase. When customers canceled their tickets, Spirit deducted a cancellation fee and, if any value remained, issued a travel credit that expired after 60 days. If a customer did not use the credit before it expired, Spirit retained the full value—including the security fee—as revenue. Spirit either did not remit the security fee from these unused credits to the Transportation Security Administration (TSA), or, if the fee had already been remitted, offset it against future payments. The U.S. Customs and Border Protection audited Spirit and determined that it had “under-remitted” security fees by retaining those attributable to expired credits. TSA adopted these findings, concluding that Spirit owed nearly $2.8 million. Spirit sought administrative review, arguing that it was not required to remit fees for customers who did not travel, as such individuals were not “passengers” under the statute. Alternatively, Spirit asserted it had effectively refunded the fees through credits and offsets. TSA rejected these arguments, finding that the statutory scheme required remittance of all fees collected unless they were actually refunded to the customer, and that expired credits did not constitute refunds. The United States Court of Appeals for the Eleventh Circuit reviewed TSA’s decision, applying de novo review to questions of law and upholding factual findings if supported by substantial evidence. The court held that the statute required airlines to remit all security fees collected, regardless of whether the customer traveled, unless the fee was actually refunded. The court also found that TSA’s guidance gave Spirit fair notice of its obligations. The Eleventh Circuit denied Spirit’s petition for review, affirming TSA’s decision. View "Spirit Airlines, LLC v. Transportation Security Administration" on Justia Law

Dish Network L.L.C. v. Fraifer

2026-04-09T08:33:22-08:00

DISH Network L.L.C. held exclusive rights to broadcast certain Arabic-language television channels in the United States, secured through written agreements with foreign content producers. The defendants operated businesses that provided U.S. customers with unauthorized access to these channels through internet streaming devices and services, bypassing DISH’s authorization and payments. The defendants’ services relied on content delivery networks and encoders to capture, transcode, and transmit live broadcasts of the protected channels to their customers in the U.S. The United States District Court for the Middle District of Florida first considered cross-motions for summary judgment. It granted summary judgment for DISH regarding its ownership of valid copyrights but found factual disputes about infringement, leading to a bench trial. After trial, the district court ruled in favor of DISH, finding that the defendants' use of both content delivery networks and encoders constituted direct copyright infringement. The court awarded DISH a permanent injunction, $600,000 in statutory damages, attorney fees, and costs. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s legal conclusions de novo and factual findings for clear error. The appellate court rejected all arguments by the defendants, including challenges to DISH’s ownership, the validity and transfer of the copyrights, and several evidentiary rulings. The court specifically found that the audiovisual works at issue were “Collective Works” under UAE law, supporting MBC’s initial ownership, and that the transfer of rights to DISH was uncontested by the original owner. The Eleventh Circuit held that sufficient evidence showed the defendants directly infringed DISH’s exclusive rights by operating encoders, and affirmed the district court’s judgment in all respects. View "Dish Network L.L.C. v. Fraifer" on Justia Law

Faulk v. Dimerco Express USA Corp.

2026-04-07T11:01:48-08:00

The case centers on Kenny Faulk, a Black man, who was conditionally offered a sales position by Dimerco Express USA, a transportation company. The offer was rescinded after the company’s president learned of Faulk’s race, despite Faulk successfully passing a background check that revealed only a prior misdemeanor conviction. Internal communications and testimony showed that Dimerco’s leadership, particularly its president, maintained a policy of hiring only white individuals for sales positions and had rejected non-white applicants for this reason. Faulk later learned that a white applicant with a more significant criminal history was hired for a similar position, and after discovering the discriminatory policy, he filed suit against Dimerco for racial discrimination under 42 U.S.C. § 1981. The United States District Court for the Northern District of Georgia presided over the trial. At trial, Dimerco sought to introduce evidence of Faulk’s unrelated 2019 arrest to undermine his emotional distress claim, but the district court ultimately excluded this evidence, finding it minimally relevant and highly prejudicial. The jury returned a verdict for Faulk, awarding him $90,000 in lost wages, $300,000 in emotional distress damages, and $3 million in punitive damages. Dimerco moved for a new trial, arguing that misconduct by Faulk’s counsel and evidentiary errors required one, or alternatively, for remittitur of the damages as excessive. The district court denied these motions. On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s rulings. The court held that any misconduct by Faulk’s counsel was effectively cured by the district court’s instructions and did not deprive Dimerco of a fair trial. The evidentiary rulings were not erroneous or, if so, were harmless. The compensatory and punitive damages were supported by the evidence and not unconstitutionally excessive. The judgment in Faulk’s favor was affirmed in all respects. View "Faulk v. Dimerco Express USA Corp." on Justia Law

Georgia v. Heinze

2026-04-07T10:32:53-08:00

In 2016, law enforcement officers were tasked with apprehending an individual, Jamarion Robinson, who had several outstanding felony warrants. The officers, including two federal task force members, located Robinson at an apartment and conducted a raid that resulted in his death. Five years after the incident, a state grand jury in Georgia indicted these officers on charges including felony murder, aggravated assault, burglary, making a false statement, and violation of oath by a public officer. The officers removed the case to the United States District Court for the Northern District of Georgia, arguing they were entitled to a federal forum under 28 U.S.C. § 1442 as federal officers. After removal, the State of Georgia sought to have the case remanded to state court, but the district court denied the motion. Later, the State requested a “limited remand” to return to state court solely to seek a superseding indictment that would modify the charges. The district court denied this request, concluding it lacked statutory authority for such a remand and noting the State had alternative means for pursuing additional charges. The court also found the State’s request untimely and speculative regarding necessity. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed whether it had jurisdiction to consider the district court’s denial of the “limited remand.” The Eleventh Circuit held that it lacked appellate jurisdiction because the order was not final and did not qualify under the collateral order doctrine or as an appealable injunction under 28 U.S.C. § 1292(a)(1). The court reasoned that federal law did not prohibit the State from seeking a superseding indictment in state court, and the district court’s order did not prevent the State from doing so. The appeal was dismissed for lack of jurisdiction. View "Georgia v. Heinze" on Justia Law

Hayes v. Director, OWCP

2026-04-07T10:32:53-08:00

An employee worked for Cowin & Company for nearly three decades, performing construction in coal mines and regularly being exposed to coal dust. Years after his employment ended, he filed a claim for benefits under the Black Lung Benefits Act, alleging total disability due to pneumoconiosis (“black lung disease”) caused by his coal mine work. The claimant relied on a regulatory presumption that applies to miners who have a disabling breathing impairment and at least fifteen years of qualifying coal mine employment. A key dispute in the case involved how to calculate a “year” of coal mine employment under Department of Labor regulations. An administrative law judge initially granted benefits, finding the claimant had at least fifteen years of qualifying employment, thus triggering the presumption. Cowin & Company appealed to the Benefits Review Board, which vacated the benefits award in part and instructed the judge to recalculate the length of coal mine employment, questioning the method used to credit years of employment. On remand, the judge again found more than fifteen years, but the Board disagreed with the method, holding that a claimant must prove both a 365/366-day period of employment and at least 125 working days during that period. Ultimately, after further proceedings, the administrative law judge found only 13.76 years of qualifying employment, and the Board affirmed the denial of benefits. The United States Court of Appeals for the Eleventh Circuit reviewed the Board’s decision. The court held that, under the plain text of the relevant regulation, a claimant establishes a “year” of coal mine employment by showing at least 125 working days in or around coal mines during a calendar year or partial periods totaling one year. The court granted the petition for review, vacated the Board’s decision, and remanded for further proceedings. View "Hayes v. Director, OWCP" on Justia Law

United States v. Florida

2026-03-31T12:31:50-08:00

The United States brought a lawsuit against Florida alleging that the state was discriminating against children with medically complex conditions by failing to provide care in the most integrated setting as required under Title II of the Americans with Disabilities Act (ADA). The federal government claimed that Florida’s inadequate provision of at-home and group-home care forced some children into institutionalization and placed others at serious risk of institutionalization. Additionally, it argued that once children were institutionalized, Florida’s poor care coordination and deficient transition planning made it difficult for families to bring their children home. This litigation proceeded over many years, culminating in a bench trial in the United States District Court for the Southern District of Florida. Previously, the United States Court of Appeals for the Eleventh Circuit had determined that the United States had statutory authority to sue Florida under the ADA. After trial, the district court found that Florida’s Medicaid program failed to provide adequate private duty nursing (PDN) services and effective care coordination, resulting in unnecessary institutionalization of children or placing them at risk. The district court concluded that these failures constituted violations of the ADA as interpreted by Olmstead v. L.C. ex rel Zimring, and issued a permanent injunction requiring Florida to improve its services, with specific mandates regarding PDN, care coordination, transition planning, data collection, and appointment of a monitor. On appeal to the United States Court of Appeals for the Eleventh Circuit, Florida challenged the findings and scope of the injunction. The Eleventh Circuit held that the United States may seek injunctive relief for systemic ADA violations affecting a group of children, not just those who individually filed complaints. The court affirmed the district court’s findings that the United States established the elements required under Olmstead, that the violations were widespread, and that system-wide injunctive relief was warranted. The Eleventh Circuit affirmed the district court’s liability determinations and most provisions of the injunction, but vacated or modified some portions as overbroad. View "United States v. Florida" on Justia Law

C.B. v. Naseeb Investments, Inc.

2026-03-30T11:31:57-08:00

Two minor plaintiffs, A.G. and G.W., were sex trafficked as teenagers by traffickers who repeatedly brought them to United Inn, a hotel in Decatur, Georgia, owned and operated by Northbrook Industries, Inc. Their traffickers spent time each day at the hotel interacting with staff, and on two occasions, hotel employees allowed the minors back into their room at the trafficker’s request even though they had no identification and were not on the reservation. The hotel was in a high-crime area with frequent prostitution arrests, and it failed to post required anti-trafficking notices. Another plaintiff, C.B., a minor, was sex trafficked at The Hilltop Inn, owned by Naseeb Investments, Inc., by a registered sex offender who was a long-term guest. The hotel placed this offender in an area with other sex offenders, rented him a second room, and complied with his request not to clean it. Employees testified to a pattern of sex trafficking and prostitution at the hotel. In the United States District Court for the Northern District of Georgia, all three plaintiffs brought civil beneficiary claims under the Trafficking Victims Protection Reauthorization Act (TVPRA) against the hotel operators, alleging the hotels knowingly benefited from and participated in trafficking ventures. A.G. and G.W. also asserted state law negligence claims. The district court granted summary judgment to the defendants, finding insufficient evidence of participation in a trafficking venture or knowledge, and concluded A.G. and G.W. were not invitees for their negligence claims. On appeal, the United States Court of Appeals for the Eleventh Circuit held that the TVPRA’s “participation in a venture” element requires more than an arms-length transaction but does not require knowledge of a specific victim. The court found sufficient evidence for a jury to infer the hotels provided personal support to the traffickers, satisfying both the participation and knowledge elements. The court also found disputes of fact regarding invitee status under Georgia law. The Eleventh Circuit vacated the grants of summary judgment and remanded the cases for further proceedings. View "C.B. v. Naseeb Investments, Inc." on Justia Law

Joyner v. City of Atlanta

2026-03-25T10:08:44-08:00

A White police officer employed by the Atlanta Police Department alleged that he was denied a promotion to Captain in December 2014 and was later removed from a flexible work schedule after he reported alleged misconduct by superiors. The officer had previously reported in 2008 that Black supervisors were allegedly treating White officers less favorably, which resulted in tension but was not shown to have been communicated to the ultimate decisionmaker for promotions. In 2015, after reporting possible ticket-fixing by his superiors to internal and federal authorities, the officer was required to work a fixed schedule, which impacted his ability to work a second job and fulfill childcare obligations. The United States District Court for the Northern District of Georgia dismissed or granted summary judgment on most of the officer’s claims, including those under Title VII for racial discrimination and retaliation, and under the Georgia Whistleblower Act. The court found no evidence that the Police Chief, who was the sole decisionmaker for promotions, was aware of the officer’s 2008 discrimination complaint, and further held that the officer had not experienced an adverse employment action as required by the statutes. At trial, the jury found for the City on the Title VII discrimination claim, concluding the officer had not been denied a promotion. On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed most of the district court’s rulings, including summary judgment for the City on the Title VII and Whistleblower Act claims and the jury verdict on the discrimination claim. However, the Eleventh Circuit reversed the grant of summary judgment for the Chief and another supervisor on the First Amendment retaliation claim, holding that revoking the officer’s flexible schedule constituted a material adverse action sufficient to support such a claim. The case was remanded for further proceedings on this First Amendment issue. View "Joyner v. City of Atlanta" on Justia Law

United States v. Alexander

2026-03-24T11:03:33-08:00

An orthopedic surgeon partnered with a medical supply businessman to form a durable medical equipment company. The company was formally listed under the surgeon’s mother’s name, even though she had no actual ownership or management role. The surgeon provided his mother’s personal information to his partner, who submitted Medicare enrollment forms on the company’s behalf. In January 2019, the company submitted a Medicare form notifying a change in business hours, but it falsely listed the mother as the sole owner and manager. The company ceased operations after Medicare began to suspect fraud. A federal grand jury in the Southern District of Florida indicted the surgeon on charges of conspiracy to defraud the United States and pay health care kickbacks, and making a false statement relating to health care matters. The jury acquitted him of conspiracy but convicted him of making a false statement. The United States District Court for the Southern District of Florida sentenced him to thirty-three months in prison, imposed three years of supervised release, and ordered him to pay $315,704.52 in restitution and to forfeit $125,000. The defendant challenged several aspects of his conviction and sentence, including venue, the sufficiency of the indictment, the sufficiency of the evidence, jury instructions, forfeiture, and restitution. The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s rulings on all grounds except restitution. The court held that the evidence was sufficient to support the false statement conviction and found no error in the jury instructions or the forfeiture order. However, the court determined that the government had not shown by a preponderance of the evidence that the false statement actually caused the losses for which restitution was ordered. The restitution order was vacated and the case remanded for further proceedings on that issue. View "United States v. Alexander" on Justia Law

Upside Foods Inc v. Commissioner, Florida Department of Agriculture

2026-03-23T10:08:07-08:00

A California-based company that produces lab-grown chicken sought to distribute and sell its product in Florida. After the company received federal approval from the USDA and FDA to market its lab-grown chicken, Florida enacted SB 1084, a law banning the manufacture, sale, and distribution of all lab-grown meat within the state. The company had previously held tasting events and developed business relationships in Florida but had no plans to manufacture its product there. Following the enactment of SB 1084, the company filed suit in the U.S. District Court for the Northern District of Florida against state officials, seeking declaratory and injunctive relief. The company argued that the federal Poultry Products Inspection Act (PPIA) preempted Florida’s ban, claiming the state’s law imposed “additional or different” ingredient or facilities requirements in violation of the PPIA. The district court denied the company’s motion for a preliminary injunction, finding the company unlikely to succeed on its preemption claims because SB 1084 did not regulate the company’s ingredients, premises, facilities, or operations. The court also addressed standing and procedural questions, ultimately dismissing the preemption claims after the company amended its complaint. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed whether the filing of an amended complaint or the district court’s dismissal order rendered the appeal moot and whether the company could challenge the Florida law as preempted. The Eleventh Circuit held the appeal was not moot and that the company could bring a preemption action in equity. However, the court concluded the company was unlikely to succeed on the merits. The court held that Florida’s ban did not impose ingredient or facilities requirements preempted by the PPIA, as it simply banned the product’s sale and manufacture. Therefore, the district court’s denial of a preliminary injunction was affirmed. View "Upside Foods Inc v. Commissioner, Florida Department of Agriculture" on Justia Law

Nance v. Commissioner, Georgia Department of Corrections

2026-03-19T08:34:29-08:00

Michael Nance, a Georgia prisoner sentenced to death, brought a civil rights action under 42 U.S.C. § 1983 against state prison officials. He alleged that execution by lethal injection posed a substantial likelihood of severe pain due to his compromised veins, which he claimed would make it difficult or impossible for the execution team to establish intravenous access. Nance argued that extravasation of pentobarbital could cause intense, prolonged pain and asserted that execution by firing squad was a feasible, less painful alternative. The United States District Court for the Northern District of Georgia held a bench trial. Prior to trial, the court permitted the prison officials’ medical expert to examine Nance’s veins and allowed members of the execution team to testify anonymously and remotely, consistent with Georgia’s Secrecy Act. The parties submitted medical records and declarations, which showed that Nance had successfully undergone several recent medical procedures requiring intravenous access without noted complications. After trial, the district court found that Nance failed to prove a substantial likelihood of severe pain from lethal injection, based largely on his medical records, and entered judgment for the defendants. Nance later moved to alter or amend the judgment, but the district court denied the motion. The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s factual findings for clear error and its evidentiary rulings for abuse of discretion. The appellate court held that the district court did not err in its factual findings or evidentiary rulings, and concluded that Nance failed to prove the planned execution method posed a substantial risk of serious harm. The Eleventh Circuit affirmed the judgment in favor of the prison officials. View "Nance v. Commissioner, Georgia Department of Corrections" on Justia Law

Foster v. King

2026-03-18T07:33:08-08:00

Dr. Lana Foster, a lifelong resident of Echols County, Georgia, was among the first Black students and later one of the first Black educators in the county’s school district. Over the years, she experienced various forms of racial discrimination, including being reassigned to a less desirable teaching position and being stripped of leadership duties, which led her to sue the school district. That lawsuit was settled in 2011, with the district agreeing to reinstate her role and pay damages. However, Foster alleged continued racial hostility, culminating in her termination in 2018. Subsequent investigations found no probable cause for her firing based on the cited ethical violations. Foster then filed complaints with state and federal agencies, resulting in another settlement in 2020 that required the district to revise its hiring practices and take additional steps to remedy discrimination. Foster later discovered, through an open records request, that the school district had not complied with the settlement's terms. She filed suit in the United States District Court for the Middle District of Georgia against the district, the school board, and several school officials, alleging violations of her rights under federal and state law, including claims under 42 U.S.C. § 1981 and § 1983 for denial of her right to make and enforce contracts based on her race. The district court dismissed some claims but allowed others to proceed, including her § 1981 claim against the individual officials, and denied their motion to dismiss based on qualified immunity. The United States Court of Appeals for the Eleventh Circuit reviewed the denial of qualified immunity. It held that the law was clearly established that government officials may not interfere with contractual rights because of race. The court concluded that uncertainty about possible personal liability under § 1981 does not entitle officials to qualified immunity. The Eleventh Circuit affirmed the district court’s decision denying qualified immunity. View "Foster v. King" on Justia Law

Beazer v. Richmond County Constructors, LLC

2026-03-10T10:33:43-08:00

A former employee brought a Title VII action against his previous employer, alleging that he suffered race-based harassment, retaliation, and wrongful termination. After being fired in May 2022, he filed a charge of discrimination with the EEOC. The EEOC issued a right-to-sue notice on June 2, 2023, which required him to file a lawsuit within ninety days, by August 31, 2023. The plaintiff attempted to retain an attorney, paying consultation fees twice, but the attorney was unresponsive for several weeks. Only a few days before the filing deadline, the attorney declined representation and advised the plaintiff to file pro se. The plaintiff quickly prepared his complaint and, with two days remaining, paid for guaranteed overnight delivery via the U.S. Postal Service. Due to delays caused in part by Hurricane Idalia, the complaint arrived at the district court after the ninety-day deadline. The United States District Court for the Southern District of Georgia dismissed the lawsuit as untimely, finding that the plaintiff had not met his burden to show timely filing within the statutory period. The court considered, but rejected, the plaintiff’s explanation for the late filing. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s dismissal de novo. The appellate court held that the plaintiff was entitled to equitable tolling because he pursued his rights diligently and extraordinary circumstances—specifically, the attorney’s delay and the effects of Hurricane Idalia—prevented timely filing. The court found no prejudice to the defendant from the brief delay. The Eleventh Circuit vacated the district court’s dismissal and remanded for further proceedings, holding that the complaint should be deemed timely under the doctrine of equitable tolling. View "Beazer v. Richmond County Constructors, LLC" on Justia Law

United States v. Hamilton

2026-03-09T11:03:03-08:00

Two men wearing masks and armed with guns entered a Miami convenience store and exchanged gunfire with the store clerk during a failed robbery attempt. The suspects fled the scene, and shortly afterwards, a Ford Explorer registered to Rodrick Maurice Hamilton crashed nearby. Blood and a cellphone belonging to Hamilton were found in the vehicle. Hamilton’s girlfriend testified that he directed her to falsely report the vehicle stolen, and he later told her he was leaving for Georgia. Investigators also discovered evidence linking Hamilton and co-conspirator Untarius Alexander to the robbery, including phone records, location data, and clothing matches from surveillance footage. Both men were indicted and prosecuted in federal court. The United States District Court for the Southern District of Florida conducted a jury trial, resulting in Hamilton’s conviction for conspiracy and attempt to commit Hobbs Act robbery. The district court sentenced Hamilton to 170 months in prison, which included a twenty-month upward departure from the Sentencing Guidelines range. The government’s motion to dismiss a firearm charge was granted in light of United States v. Taylor, 596 U.S. 845 (2022). Hamilton appealed his convictions and sentence, raising several challenges, including the propriety of a jury flight instruction, alleged prosecutorial misconduct, the handling of a juror’s post-verdict statement, and the sentencing process. The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court’s judgment. The court held that the flight instruction was proper, the prosecutor’s comments during closing arguments did not violate Hamilton’s Fifth Amendment rights, and the district court acted within its discretion by denying a new trial and declining to investigate the juror’s post-verdict remarks under Rule 606(b). In addition, the appellate court found no procedural or substantive error in the upward departure at sentencing, as proper notice was given and the sentence was justified by Hamilton’s criminal history and the need for deterrence. View "United States v. Hamilton" on Justia Law

United States v. Ragland

2026-03-05T13:02:40-08:00

Between December 2007 and February 2008, the defendant and accomplices robbed seven Florida convenience stores and attempted to rob two others, occasionally stealing cash and cigarettes. In April 2009, a federal grand jury indicted him on twenty-two counts related to conspiracy, robbery, attempted robbery, and using or brandishing a firearm during crimes of violence. A jury convicted him on eighteen counts, and the United States District Court for the Southern District of Florida sentenced him to 196 years in prison, primarily due to consecutive mandatory minimum sentences under 18 U.S.C. § 924(c). After the Supreme Court’s decisions in Johnson v. United States, United States v. Davis, and United States v. Taylor clarified the definition of “crime of violence” under § 924(c), the defendant filed petitions under 28 U.S.C. § 2255. The Eleventh Circuit permitted a limited successive motion challenging only his § 924(c) conviction predicated on attempted Hobbs Act robbery (Count Sixteen). The district court vacated that count and held a de novo resentencing, ultimately imposing a new 173-year sentence. The defendant argued for application of the more lenient sentencing provisions of the First Step Act of 2018 (“FSA”) and sought to challenge his other § 924(c) convictions, but the district court declined both requests. On appeal, the Eleventh Circuit originally affirmed. After the Supreme Court decided Hewitt v. United States, which held that defendants resentenced after the FSA’s enactment are eligible for its revised penalties, the Eleventh Circuit granted rehearing. The United States Court of Appeals for the Eleventh Circuit held that the FSA applies retroactively to the defendant’s resentencing and vacated his sentence, remanding for resentencing under the FSA. The court affirmed that the district court lacked jurisdiction to consider new challenges to other counts not authorized by the appellate court. View "United States v. Ragland" on Justia Law

USA v. Brice

2026-02-27T07:03:00-08:00

Three individuals were involved in a conspiracy to rob a marijuana dealer at his home on the Big Cypress Seminole Indian Reservation. During the attempted robbery, a bystander was shot and killed, and the perpetrators fled without obtaining money or drugs. One of the defendants later discussed the crime with a third party, who reported the information to law enforcement and recorded a conversation, further implicating the participants. Additional evidence, including surveillance footage, cell site records, and ballistics, corroborated the involvement of the defendants. The United States District Court for the Middle District of Florida heard the case. One defendant moved to dismiss the indictment, arguing that because both he and the victim were enrolled members of Indian tribes and the offense occurred in Indian country, and since the charged crimes were not listed in the Major Crimes Act, the court lacked jurisdiction. The district court disagreed and denied the motion, allowing the prosecution to proceed. During trial, another defendant objected to the admission of prior convictions without an explicit balancing of probative value and prejudicial effect. The court admitted the evidence without making such a finding. The jury ultimately found the defendants guilty on various counts, and the defendants appealed. The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that federal courts possess jurisdiction over generally applicable federal crimes, such as Hobbs Act robbery, even when committed by an Indian against another Indian in Indian country. The court also found that the district court erred by not conducting an on-the-record balancing before admitting evidence of prior convictions, but deemed this error harmless given the strength of the government’s case. The convictions of all three defendants were affirmed. View "USA v. Brice" on Justia Law

United States v. Estadella

2026-02-20T11:09:33-08:00

The defendant was charged with possessing two firearms as a convicted felon and with possession of methamphetamine with intent to distribute, following a shooting and possible abduction at a motel in Hialeah, Florida. Surveillance footage and subsequent police investigation linked the defendant to the incident via a work van registered to his business, J&M Electric, and to a residential property where evidence was found. The defendant, his girlfriend, and his stepfather Soriano were associated with the property. After a violent altercation, Soriano temporarily relocated but retained access and possessions at the residence. Police obtained Soriano’s consent to search the property, and later, a search warrant; they found firearms, ammunition, and a large quantity of methamphetamine, along with items indicating drug trafficking. The United States District Court for the Southern District of Florida conducted a jury trial, during which the government presented evidence, including surveillance videos, forensic analyses, and a YouTube video filmed at the defendant’s residence. The jury convicted the defendant on two counts: felon in possession of a firearm and possession with intent to distribute methamphetamine, but acquitted him of possession of a firearm in furtherance of a drug trafficking crime. The district court dismissed one firearm count to avoid double jeopardy and sentenced the defendant to concurrent 96-month terms. The United States Court of Appeals for the Eleventh Circuit reviewed the case. It affirmed the district court’s denial of the defendant’s motion to suppress evidence, finding Soriano had actual authority to consent to the search. The appellate court also upheld evidentiary rulings, denial of the Rule 29 motion for acquittal, rejection of the prosecutorial misconduct claim, and the application of the sentencing guidelines. The court held there was no cumulative error and affirmed both convictions and the sentence. View "United States v. Estadella" on Justia Law

C.B. v. Henry County School District

2026-02-19T12:33:04-08:00

A student with Down syndrome, C.B., attends school in the Henry County School District in Georgia. Under the Individuals with Disabilities Education Act (IDEA), the school district was required to develop an individualized education program (IEP) for C.B. After reviewing C.B.’s progress in fourth grade, the school district’s IEP team decided to move C.B. from an interrelated resource (IRR) class to a mild intellectual disability (MID) class for language arts and math. C.B.’s parents disagreed with this new placement, believing the IRR class was less restrictive and more appropriate. They also objected to the school district’s decision to place C.B. on an alternative assessment track, rather than the regular statewide assessment. Following the school district’s decision, C.B.’s parents requested a due process hearing before the Georgia Office of State Administrative Hearings. The administrative law judge conducted a five-day hearing and found that the school district had complied with IDEA in making the placement decision and that the Georgia Alternate Assessment was appropriate for C.B. The United States District Court for the Northern District of Georgia affirmed the administrative law judge’s findings regarding the placement, concluding that the least restrictive environment requirement under IDEA did not apply to the choice between different types of special education classes. The district court also found C.B.’s claim regarding the alternative assessment moot, since C.B. was no longer required to take the alternative assessment. On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision regarding the placement in the MID class, holding that the least restrictive environment requirement under IDEA does not apply to placement decisions among special education classes. However, the court reversed the district court’s mootness determination on the assessment claim and remanded the case for further proceedings on that issue. View "C.B. v. Henry County School District" on Justia Law

Barrie v. Attorney General

2026-02-19T11:09:35-08:00

The petitioner, a citizen of Sierra Leone and lawful permanent resident, was convicted in the District of Columbia in 2014 of attempted first-degree sexual abuse and kidnapping. The factual basis for his conviction included both forceful digital penetration and forceful penile penetration. After serving his prison sentence, the Department of Homeland Security initiated removal proceedings, alleging that his conviction qualified as an aggravated felony under the Immigration and Nationality Act, specifically as “rape” or “an attempt to commit an aggravated felony,” and also as a crime of violence. In removal proceedings before the Immigration Judge, the petitioner admitted the factual allegations but disputed that his conviction was an aggravated felony, arguing that the D.C. statute criminalized digital penetration, which he claimed was not covered by the generic federal definition of rape. The Immigration Judge ordered removal, finding the conviction constituted attempted rape. The Board of Immigration Appeals affirmed, relying on its precedent that the generic definition of rape included digital penetration, and dismissed other removability grounds as unnecessary. The Board also denied the petitioner’s requests for a waiver of inadmissibility, but remanded for further consideration of his claim under the Convention Against Torture, directing the Immigration Judge to consider aggregate risks of torture. After additional hearings, the Immigration Judge again denied relief, and the Board affirmed, declining to revisit removability. The United States Court of Appeals for the Eleventh Circuit reviewed only the Board’s removability determination. It held that the generic federal definition of “rape” under 8 U.S.C. § 1101(a)(43)(A) does not include digital penetration, joining other circuits. Consequently, the Board erred in concluding the petitioner’s conviction categorically matched the federal definition of rape. The court vacated the Board’s decision and remanded for further proceedings on other removability grounds. View "Barrie v. Attorney General" on Justia Law

USA v. Hernandez

2026-02-19T08:33:43-08:00

Javier Hernandez was a participant in a transnational criminal operation that smuggled Cuban migrants into Mexico for eventual entry into the United States. His primary role involved stealing boats from Southwest Florida, which he delivered to co-conspirators in Mexico. These vessels were used to transport migrants from Cuba or were sold to support the smuggling enterprise, including bribing law enforcement. Hernandez also transported stolen vehicles to Mexico for similar purposes. He was compensated for each delivery and admitted to earning substantial profits from these activities. Federal authorities identified Hernandez through investigative techniques including cell-site location tracking and the recovery of his cell phone, which had been seized by Mexican authorities. The government obtained and executed a warrant to search his phone, extracting relevant data. After initial technical difficulties, a second extraction was performed after the warrant’s nominal expiration date but while the phone was still in government custody. Hernandez was indicted in the United States District Court for the Southern District of Florida on five counts, including conspiracy to encourage unlawful entry, transportation of stolen vessels, trafficking in vehicles with altered VINs, and money laundering. He moved to suppress the evidence from the second extraction, but the district court denied the motion, applied several sentencing enhancements, and imposed a sentence of ninety-five months. On appeal, the United States Court of Appeals for the Eleventh Circuit held that the second extraction did not violate Federal Rule of Criminal Procedure 41 or the Fourth Amendment, as Rule 41(e)(2)(B) allows for off-site copying and review of electronic information after the warrant period. The court also found that even if there were a procedural violation, suppression would not be warranted due to the agents’ good faith and lack of prejudice. The court determined that the evidence was sufficient to sustain all convictions and found no reversible error in the sentencing calculations or guideline enhancements. The Eleventh Circuit affirmed the district court’s judgment. View "USA v. Hernandez" on Justia Law

United States v. Robelo-Galo

2026-02-17T11:34:05-08:00

A federal prisoner serving a sentence for drug-related offenses sought compassionate release, arguing that he was the only available caregiver for his incapacitated father living in Honduras. The prisoner’s father had become bedridden and previously relied on the care of the prisoner’s former partner, who could no longer provide assistance due to her own health problems. The prisoner asserted that none of his five children could serve as caregivers: one was deceased, one’s whereabouts were unknown, two resided in the United States and could not relocate, and the remaining son, Elmer, lived four hours away in Honduras but faced logistical and economic barriers to providing care. The United States District Court for the Northern District of Florida initially denied the compassionate release motion, finding that the prisoner had not demonstrated the unavailability of other family members as caregivers. After the prisoner renewed his motion with more details, the district court again denied relief, concluding that Elmer, despite living several hours away and having work and family obligations, was nonetheless an available caregiver. The court reasoned that the practical burdens cited were not sufficient to show unavailability. On appeal, the United States Court of Appeals for the Eleventh Circuit addressed the meaning of “only available caregiver” under U.S.S.G. § 1B1.13(b)(3)(C). The court held that an inmate must show that no other person is both qualified and free to provide the needed care, and outlined relevant factors for district courts to consider in making this determination. Applying this standard, the Eleventh Circuit found no clear error in the district court’s determination that Elmer was available to provide care, and affirmed the denial of compassionate release. View "United States v. Robelo-Galo" on Justia Law

Calder v. Secretary, Florida Department of Corrections

2026-02-13T09:04:00-08:00

The case involves a man who was convicted of first-degree murder in Broward County, Florida, after a fatal shooting during a domestic dispute with his girlfriend. The key evidence during trial was a confession obtained by police after the man initially invoked his right to counsel but later agreed to speak with detectives. This confession was not admitted as direct evidence at his second trial but was used extensively to impeach his testimony when he took the stand in his own defense. The prosecution also presented substantial physical and eyewitness evidence, including the testimony of two individuals present at the scene and expert forensic analysis. After his conviction, the defendant challenged the use of his statement in postconviction proceedings. The Florida trial court denied his motion for a new trial, and the Florida Fourth District Court of Appeal affirmed. The defendant later argued in a state postconviction proceeding that his trial counsel was ineffective for failing to challenge the statement on the grounds that it was coerced, in violation of the Due Process Clause. The state postconviction court, adopting the State’s response, found that the defendant was not prejudiced by any alleged error of his counsel, as the other evidence against him was overwhelming. The Fourth DCA affirmed without opinion. The United States Court of Appeals for the Eleventh Circuit reviewed the denial of federal habeas corpus relief. The court held that the state court had adjudicated the prejudice prong of the ineffective assistance claim on the merits, entitling its decision to deference under the Antiterrorism and Effective Death Penalty Act. The Eleventh Circuit found that the state court’s determination—that the outcome would not have been different even if the statement had been excluded—was neither contrary to nor an unreasonable application of federal law. Accordingly, the denial of habeas relief was affirmed. View "Calder v. Secretary, Florida Department of Corrections" on Justia Law

O'Neal v. American Shaman Franchise Systems, Inc.

2026-02-11T09:33:48-08:00

A franchisee brought several claims against a franchisor and related parties, including allegations of breach of contract, unjust enrichment, violations of Florida law, and Fair Labor Standards Act (“FLSA”) violations. The parties settled, with the franchisee receiving $50,000 and both sides signing a mutual release that broadly barred any future claims. The agreement was not approved by a court or the Department of Labor and contained a confidentiality provision. Subsequently, the franchisee initiated a separate action for fraudulent transfer and other non-FLSA claims, arguing these were not barred by the settlement’s release. After the settlement, the franchisee filed a supplemental complaint in the United States District Court for the Middle District of Florida, alleging fraudulent transfer and related non-FLSA claims. The franchisor responded with a motion for judgment on the pleadings, citing the settlement’s release. The franchisor also filed counterclaims, including breach of contract based on the franchisee’s new filings. The franchisee attempted to amend his complaint to add a claim for rescission, arguing fraudulent inducement, but the magistrate judge denied this motion, finding it was inadequately pleaded and untimely. The franchisee did not properly object to this denial before the district judge. The United States Court of Appeals for the Eleventh Circuit considered whether the unapproved settlement agreement barred the non-FLSA claims. The court held that, while FLSA claims cannot be waived or settled without court or Department of Labor approval, non-FLSA claims may be released according to state contract law. The court found the release enforceable under Florida law as to non-FLSA claims and affirmed the district court’s dismissal of the fraudulent transfer claims and grant of summary judgment to the franchisor on its counterclaims. The court also ruled the franchisee had waived his right to appeal the denial of his motion to amend. View "O'Neal v. American Shaman Franchise Systems, Inc." on Justia Law

USA v. Mullings

2026-02-10T08:34:45-08:00

A man was charged with one count of conspiracy to commit money laundering and seven counts of money laundering after opening numerous bank accounts and using them to launder millions of dollars in fraud proceeds for a group operating romance and business email scams. He also recruited and supervised a co-conspirator, helping that person set up a similar laundering operation. The laundered funds were ultimately sent to Africa. Following his arrest, the defendant attempted to cooperate with the government but did not enter into a plea agreement. At his first change-of-plea hearing, he hesitated and the hearing was postponed. At the second hearing, with two lawyers present, he pleaded guilty to all charges, affirming he did so knowingly and voluntarily. Before sentencing, the defendant’s bond was revoked after he was arrested for assaulting his girlfriend. While in custody, he moved to withdraw his guilty plea, alleging one of his lawyers coerced him into pleading guilty and that he was not aware of a co-conspirator’s cooperation with the government. The United States District Court for the Northern District of Georgia held an evidentiary hearing, found the attorneys credible and the defendant not credible, and denied the motion to withdraw the plea. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the denial of the motion to withdraw the guilty plea, the calculation of the loss amount, several sentencing enhancements, the denial of a reduction for acceptance of responsibility, and the substantive reasonableness of the 120-month sentence. The court held that the district court did not abuse its discretion in denying the motion to withdraw the plea, did not err in its application of sentencing enhancements and guidelines, and that the sentence imposed was substantively reasonable. The court affirmed the judgment. View "USA v. Mullings" on Justia Law

In re: Bowe

2026-02-09T07:03:23-08:00

In 2008, a federal grand jury indicted Michael Bowe on charges including conspiracy and attempt to commit Hobbs Act robbery, and for using, brandishing, or discharging a firearm during and in relation to a crime of violence, with the firearm offense predicated on the Hobbs Act offenses. Bowe pleaded guilty and admitted in court to shooting a security guard during the attempted robbery. He was sentenced in 2009 to 288 months’ imprisonment, including a mandatory 120-month consecutive sentence for the firearm offense. He did not file a direct appeal. Over the years, Bowe challenged his conviction and sentence through several motions under 28 U.S.C. § 2255, citing Supreme Court decisions such as Johnson v. United States, United States v. Davis, and United States v. Taylor, which altered the understanding of what qualifies as a “crime of violence” under § 924(c). His initial and successive motions were denied by the United States District Court and the United States Court of Appeals for the Eleventh Circuit, largely because, at the time, circuit precedent held that attempted Hobbs Act robbery remained a crime of violence. The Eleventh Circuit repeatedly denied his applications, relying on its decision in In re Baptiste, which interpreted statutory bars to successive claims as applicable to federal prisoners. Subsequently, the Supreme Court abrogated Baptiste, holding that 28 U.S.C. § 2244(b)(1)’s bar on “old claims” does not apply to federal prisoners seeking successive § 2255 motions. On remand, the United States Court of Appeals for the Eleventh Circuit held that Bowe made a prima facie showing under § 2255(h)(2) that his conviction for discharging a firearm during a crime of violence may no longer be valid in light of Davis and Taylor. The court granted his application for leave to file a second or successive § 2255 motion. View "In re: Bowe" on Justia Law

Castro-Reyes v. Bosque

2026-02-06T09:08:34-08:00

A young man, after displaying erratic behavior in his Florida apartment, was tied up by his family who feared for his safety. Family members called 911, expressing concern but clarifying he was not violent. When police officers arrived, they found the man tied up, wet, and partially undressed. The officers attempted to detain him under Florida’s Baker Act, which allows for involuntary mental health evaluations under specific criteria. A struggle ensued, during which officers used force, including repeated taser deployments, physical strikes, and dragging the man outside, resulting in injuries. The man was taken to the hospital but not criminally charged. In the United States District Court for the Southern District of Florida, the man sued the responding officers and the city under federal and state law, alleging false arrest, excessive force, and assault and battery, among other claims. The officers moved for summary judgment, arguing qualified immunity and state agent immunity. The district court granted summary judgment for some claims but allowed others—including false arrest and excessive force under 42 U.S.C. § 1983, and state-law claims of assault and battery—to proceed to trial against certain officers. The United States Court of Appeals for the Eleventh Circuit reviewed the appeal. The court reversed the district court’s denial of qualified immunity to two officers on the false arrest claim, finding they had arguable probable cause to detain the man under the Baker Act. However, the court affirmed the denial of qualified immunity to two other officers on excessive force claims, concluding that a reasonable jury could find their use of force grossly disproportionate and in violation of clearly established law. The court also affirmed denial of state agent immunity on the assault and battery claims. The case was remanded for further proceedings. View "Castro-Reyes v. Bosque" on Justia Law

Melton v. I-10 Truck Center, Inc.

2026-02-06T09:08:33-08:00

A Black man worked as a truck salesman at a Florida business where he was the only nonwhite employee. He observed that his supervisors and colleagues frequently made derogatory, racially charged comments about nonwhite customers, including the use of slurs for various ethnic groups and stereotypes about Black customers. These comments occurred nearly every time a nonwhite customer entered the business, which happened often. The employee was also the subject of racial slurs behind his back and was sometimes called “boy” in a heated workplace dispute. He reported these incidents to his supervisor, but no corrective action was taken. Over time, his managers began documenting performance and attendance issues, and he was ultimately terminated and replaced by a white employee. The United States District Court for the Northern District of Florida granted summary judgment to the employer on all claims, finding the employee did not provide sufficient evidence of discriminatory or retaliatory termination or a racially hostile work environment. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the case de novo. The court affirmed summary judgment in favor of the employer on the claims of discriminatory and retaliatory termination. It held the employee failed to present substantial evidence that his termination was motivated by racial animus or retaliation for protected complaints, and the employer articulated legitimate, nondiscriminatory reasons for its actions. However, the Eleventh Circuit vacated the summary judgment on the hostile work environment claim and remanded for further proceedings. The court held that the employee presented substantial evidence that he was subjected to a racially hostile work environment, including pervasive use of racial slurs and discriminatory conduct towards nonwhite individuals, sufficient for a reasonable jury to find in his favor on that claim. View "Melton v. I-10 Truck Center, Inc." on Justia Law

John Doe, 1 v. USA

2026-02-04T06:58:54-08:00

Three children attending a government-owned daycare center at Robins Air Force Base in Georgia suffered physical and emotional abuse at the hands of two childcare workers. The children’s parents, who had entrusted them to the Center and paid for their care, alleged that the government had provided assurances of safety and had adopted formal criteria to prevent and respond to child abuse. The parents claimed that the Center’s director failed to report the abuse to authorities and that the government breached its duty to protect the children. The parents brought suit against the United States under the Federal Tort Claims Act (FTCA) in the United States District Court for the Middle District of Georgia, alleging negligence in failing to protect the children. The government moved to dismiss, arguing that the claims were barred by the FTCA’s intentional tort exception, which preserves sovereign immunity for claims arising out of certain intentional torts, including assault and battery. The district court agreed, finding that the parents’ claims were dependent on the employment status of the abusers and thus fell within the exception. The court dismissed the complaint for lack of subject matter jurisdiction and denied the parents’ motion to amend, reasoning that amendment would be futile. On appeal, the United States Court of Appeals for the Eleventh Circuit held that the FTCA’s intentional tort exception did not apply because the government’s duty to care for and protect the children was independent of the employment status of the abusers. The court vacated the district court’s dismissal and denial of leave to amend, and remanded for further proceedings, instructing the district court to consider whether the parents had stated a claim for relief. View "John Doe, 1 v. USA" on Justia Law

USA v. Holley

2026-02-04T06:58:53-08:00

Charlie Holley lived in a Florida City townhouse and was involved in a violent incident on June 21, 2021. Armed with a scoped assault rifle, Holley threatened neighbors and a visiting relative, then pointed the rifle at Charlotte Wicker, a United States Postal Service mail carrier, and fired at her vehicle. The situation led to multiple 911 calls, a large police response, and Holley’s eventual arrest after he barricaded himself inside his home. Subsequent searches found weapons and ammunition, and ballistics confirmed the rifle had been fired. A federal grand jury in the Southern District of Florida indicted Holley on five counts, including attempted murder and assault of a federal employee, brandishing and discharging a firearm in furtherance of a crime of violence, and possession of a firearm and ammunition as a felon. Holley underwent several psychiatric evaluations and was found incompetent to stand trial twice, but after further treatment, he was ultimately deemed competent. At trial in the United States District Court for the Southern District of Florida, Holley objected to the introduction of several body-worn camera clips and a 911 call, arguing these violated evidentiary rules and the Confrontation Clause. The district court admitted the evidence, finding it relevant to the police response and not unfairly prejudicial, and gave limiting instructions to the jury. After the jury convicted Holley on all but the attempted murder count, the district court sentenced him to 192 months’ imprisonment, considering both his criminal history and mental health issues. The United States Court of Appeals for the Eleventh Circuit reviewed Holley’s challenges to the admissibility of the evidence and his sentence. The court held that the evidentiary rulings were within the district court’s discretion and that the sentence was reasonable and adequately considered Holley’s mental health. The Eleventh Circuit affirmed both the convictions and sentence. View "USA v. Holley" on Justia Law

USA v. Rodgers

2026-01-30T11:33:36-08:00

Myelicia Rodgers, a clerk at a United States post office in Crestview, Florida, was accused of tampering with and stealing mail while working alone during early morning shifts. After suspicions arose due to complaints about opened mail, the Office of Inspector General conducted an investigation. Rodgers was observed via video and in person engaging in suspicious activities, including taking greeting cards into restricted areas, opening packages, and removing mail. Test letters with cash and gift cards were used in the investigation, some of which went missing, and Rodgers was caught taking and hiding one such letter. Upon being confronted, Rodgers admitted to opening some letters but denied stealing their contents. A grand jury indicted Rodgers on counts of mail tampering and theft by a postal employee. She waived her right to a jury and opted for a bench trial in the United States District Court for the Northern District of Florida. At trial, the government presented multiple witnesses and video evidence. Rodgers did not testify or call any witnesses in her defense. After the prosecution rested, Rodgers moved for a judgment of acquittal, which the district court denied. The district court explicitly informed Rodgers of her right not to testify and assured her that her silence would not be considered in determining guilt. Rodgers’s counsel argued that her silence should not be taken as evidence against her, and the court reiterated that it would base its decision solely on the evidence presented. The United States Court of Appeals for the Eleventh Circuit reviewed whether the district court drew an adverse inference from Rodgers's decision not to testify. The court held that the district court did not consider Rodgers’s silence as evidence of guilt and properly respected her Fifth Amendment rights. Therefore, the Eleventh Circuit affirmed Rodgers’s conviction. View "USA v. Rodgers" on Justia Law

Hughes v. Locure

2026-01-29T09:04:10-08:00

A Macon County sheriff’s deputy in Alabama, while off duty but using a police vehicle after caring for his police dog, became intoxicated and drove his police truck at an excessive speed without headlights or emergency lights at night. The deputy struck another vehicle, causing it to overturn and resulting in the death of a passenger, Edwin Moss. After the collision, the deputy fled the scene. He was later indicted for felony reckless manslaughter. The administrator of Moss’s estate filed a lawsuit, bringing state law claims for wrongful death and a federal claim under 42 U.S.C. § 1983, alleging the deputy violated Moss’s substantive due process right to life under the Fourteenth Amendment by acting with deliberate indifference. The case was removed to the United States District Court for the Middle District of Alabama, where the defendant sought dismissal of the federal claim on grounds of qualified immunity and argued he was not acting under color of law. The district court denied the motion, finding that the complaint plausibly alleged the deputy acted under color of law and was not entitled to qualified immunity. Following the deputy’s death, his estate was substituted as appellant and appealed the denial of qualified immunity. The United States Court of Appeals for the Eleventh Circuit reviewed only the denial of qualified immunity, holding that it lacked jurisdiction to review the color of law determination on interlocutory appeal. The appellate court assumed for purposes of appeal that the deputy acted under color of law and within his discretionary authority. It concluded, however, that existing circuit precedent did not clearly establish that the deputy’s conduct constituted a constitutional violation for purposes of § 1983. Therefore, the Eleventh Circuit reversed the district court’s denial of qualified immunity and remanded the case for further proceedings. View "Hughes v. Locure" on Justia Law

USA v. Ott

2026-01-29T08:03:07-08:00

In this case, the defendant was convicted of bank robbery in Florida in 2024. His criminal history included a 2010 conviction in New York for attempted second-degree robbery, which involved forcibly stealing property from an elderly woman and causing her injury. After robbing the Florida bank, the defendant fled the state, led police on a high-speed chase in Virginia, and was eventually apprehended. The United States District Court for the Southern District of Florida accepted the defendant’s guilty plea for the bank robbery charge. During sentencing, the court calculated his sentence using the U.S. Sentencing Guidelines and applied a career offender enhancement based on two prior felony convictions for crimes of violence, one of which was his New York attempted robbery conviction. The defendant objected, arguing that attempted New York robbery did not qualify as a crime of violence under the Guidelines. The district court disagreed, relying on a recent amendment to the Guidelines that expressly included attempts to commit crimes of violence. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s interpretation of the Sentencing Guidelines de novo. The Eleventh Circuit held that, following a 2023 amendment to the Guidelines, any attempt to commit a qualifying crime of violence is itself a crime of violence. The court confirmed that New York second-degree robbery qualifies as a crime of violence under the Guidelines’ elements clause. Therefore, the defendant’s attempt to commit that crime also qualifies. The Eleventh Circuit rejected the defendant’s arguments to the contrary and affirmed the sentence imposed by the district court. View "USA v. Ott" on Justia Law

Lewis v. Sheriff, Fulton County Georgia

2026-01-28T13:32:59-08:00

Kevin Lewis, who is legally blind, was arrested in Georgia on an outstanding warrant and detained for less than 48 hours in the Chatham County jail and for about 16 days in the Fulton County jail. During both periods of incarceration, Lewis alleges he was denied assistance with reading documents, navigating the facilities, accessing the grievance process, and obtaining requested medications. He also reports that, despite his requests, he was not provided accommodations for using jail telephones and kiosks. After his release and the dismissal of criminal charges against him, Lewis filed suit in the United States District Court for the Northern District of Georgia against Sheriffs John Wilcher and Patrick Labat in their official capacities, seeking damages and injunctive relief under Title II of the Americans with Disabilities Act and § 504 of the Rehabilitation Act. The district court granted summary judgment in favor of the sheriffs. The court found that Lewis had not produced sufficient evidence to show he was denied benefits or discriminated against “by reason of” his disability, and had not shown that the sheriffs engaged in intentional discrimination. Regarding his claims for injunctive relief, the court determined they were moot because Lewis was no longer incarcerated. On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The appellate court held that Lewis failed to present evidence of intentional discrimination by the sheriffs, as required for damages under both statutes. It also held that his claims for injunctive relief were moot, as there was no reasonable expectation he would be subject to the challenged conditions again. The district court’s grant of summary judgment was thus affirmed. View "Lewis v. Sheriff, Fulton County Georgia" on Justia Law

Finney v. Metropolitan Life Insurance Company

2026-01-26T12:02:17-08:00

Selina Anderson, a federal employee with a history of severe lung disease, broke her leg in a parking lot accident and subsequently died less than a week later following complications from surgery. Her official cause of death was a pulmonary embolism, but her autopsy noted that her longstanding interstitial lung disease contributed to her death. Anderson’s daughter, Brittany Finney, was the beneficiary of Anderson’s life insurance policy under the Federal Employees’ Group Life Insurance Act (FEGLI), which included both standard and accidental death benefits. After Anderson’s death, Finney submitted claims for both types of benefits to Metropolitan Life Insurance Company (MetLife), the insurer. MetLife paid the standard life insurance benefit but denied the additional accidental death benefit. The denial was based on two grounds: that Anderson’s death was not “accidental” within the policy’s meaning, and that her death was “contributed to by” her pre-existing physical illness, thus falling under an exclusion in the policy. Finney filed suit in the United States District Court for the Northern District of Alabama, arguing that the denial breached the insurance contract. Both parties moved for judgment as a matter of law. The district court ruled in favor of MetLife, finding that the denial was reasonable under the policy’s physical illness exclusion. On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s judgment. The Eleventh Circuit held that MetLife’s decision to deny accidental death benefits was not arbitrary or capricious, as the policy clearly excluded coverage when a physical illness contributed to the insured’s death. The court concluded that Anderson’s pre-existing lung disease contributed to her death and that MetLife’s denial was reasonable under the terms of the insurance contract. View "Finney v. Metropolitan Life Insurance Company" on Justia Law

United States v. Zappey

2026-01-21T10:05:41-08:00

A former elementary school teacher employed by the U.S. Department of Defense at an American school in Germany was charged with multiple counts of aggravated sexual abuse and abusive sexual contact with children under twelve. The allegations concerned incidents occurring between 2006 and 2010, when the teacher allegedly molested four students during class and private reading sessions. The accusations surfaced years later, as the now-adult women recalled the abuse after encountering triggers such as documentaries or educational programs about sexual abuse. Several witnesses, including additional former students, teachers, and a dental assistant, testified to observations of the teacher’s inappropriate physical interactions with students. A federal grand jury in the Northern District of Georgia indicted the defendant on several counts. Before trial, prosecutors sought to limit the scope of expert testimony proposed by the defense regarding the reliability of childhood memories. The district court allowed the defense expert to testify on general issues about memory and child abuse but excluded or limited testimony specifically addressing the credibility of the victims or the reliability of their memories in this case. A second defense expert’s testimony was excluded entirely as cumulative. After a jury trial, the defendant was convicted and sentenced to life imprisonment. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed whether the district court erred in restricting and excluding defense expert testimony. The Eleventh Circuit held that the district court did not abuse its discretion. The court ruled that expert testimony on the reliability of eyewitnesses is generally inadmissible if it invades the jury’s role in assessing credibility, and that the excluded testimony was either cumulative or not helpful to the jury. The court affirmed the convictions. View "United States v. Zappey" on Justia Law

The Renco Group Inc. v. Napoli Shkolnik PLLC

2026-01-21T07:30:48-08:00

The case involves a dispute over discovery between two companies engaged in mining operations in Peru and a group of law firms representing Peruvian plaintiffs who allege injuries from toxic exposure. The companies, seeking to defend themselves against these claims and pursuing a related criminal complaint in Peru alleging document falsification and other misconduct by a former attorney, Victor Careaga, filed an ex parte application under 28 U.S.C. § 1782 in the Southern District of Florida. They sought discovery from Careaga, who had worked for the law firms and played a key role in recruiting plaintiffs. The law firms intervened, seeking protective orders to prevent disclosure of certain documents, asserting attorney-client privilege and work product protection. Previously, the United States District Court for the Eastern District of Missouri, where the underlying personal injury cases (Reid and Collins) were pending, had denied the companies' discovery requests as to the active plaintiffs. When the companies sought discovery in Florida, the Southern District of Florida granted the application, which led to the disputed subpoena. The law firms then moved for protective orders, but the magistrate judge and the district judge found that the privilege claims were insufficiently supported—citing vague, bundled privilege logs, lack of individualized document identification, and inadequate supporting affidavits. The district court denied the motions for protective orders. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed only the Halpern law firm's appeal after the other intervenors voluntarily dismissed their appeals. The Eleventh Circuit affirmed, holding that the district court did not abuse its discretion in denying the protective order because Halpern failed to substantiate its privilege and work product claims with adequate evidence and document-specific explanations. The court also found that Halpern was not entitled to further process, such as in camera review or amendment of the privilege log, given these deficiencies. View "The Renco Group Inc. v. Napoli Shkolnik PLLC" on Justia Law

Securities and Exchange Commission v. Spartan Securities Group, LTD

2026-01-16T14:01:21-08:00

Several individuals orchestrated microcap securities fraud schemes by creating nineteen shell companies with no genuine business operations or assets, selling their securities at inflated prices once publicly tradable. Two firms, operated by Carl Dilley and Micah Eldred—Spartan Securities Group, Ltd. (a broker-dealer) and Island Capital Management (a transfer agent)—facilitated this process. Spartan submitted Form 211 applications to FINRA for each shell company, enabling public trading, while Island managed applications for Depository Trust Company (DTC) eligibility. The U.S. Securities and Exchange Commission (SEC) brought an enforcement action against Dilley, Eldred, Spartan, and Island, alleging, among other claims, that they made false statements to obtain FINRA clearance and DTC eligibility, violating Section 10(b) of the Securities Exchange Act of 1934 and SEC Rule 10b-5(b). The United States District Court for the Middle District of Florida denied the defendants’ pretrial motions to exclude the SEC’s expert witness and for special jury interrogatories, and allowed the case to proceed to trial. The jury found all defendants liable on the count concerning false statements or omissions under Section 10(b) and Rule 10b-5(b. The district court subsequently denied the defendants’ motions for judgment as a matter of law, and imposed remedies including injunctions against future violations, penny stock bars, civil penalties, and ordered Island to disgorge profits to the U.S. Treasury. On appeal to the United States Court of Appeals for the Eleventh Circuit, the defendants challenged the admission of expert testimony, denial of judgment as a matter of law, and the remedies imposed. The Eleventh Circuit affirmed the district court’s rulings, holding that sufficient evidence supported the jury’s finding of material misrepresentations made in connection with the purchase or sale of securities. The court further held that the SEC was authorized to seek disgorgement to the Treasury and that the remedies, including civil penalties, were timely and equitable. View "Securities and Exchange Commission v. Spartan Securities Group, LTD" on Justia Law

Baker v. City of Atlanta

2026-01-09T13:01:27-08:00

Several individuals who reside in DeKalb County, Georgia, outside the city limits of Atlanta, opposed the construction of a new public safety training facility on city-owned land and wished to collect signatures for a referendum petition to repeal the city ordinance authorizing the lease for the facility. Atlanta’s municipal code required that signature gatherers for such petitions be residents of the City of Atlanta. Because they did not meet this residency requirement, the plaintiffs filed suit against the City, arguing that the restriction violated their First Amendment rights. They sought a preliminary injunction to prevent enforcement of the residency requirement, as well as other relief connected to the signature collection process. The United States District Court for the Northern District of Georgia granted the preliminary injunction, enjoining Atlanta from enforcing the residency requirement for signature gatherers. The court also ordered the City to issue new petitions without the residency restriction and restarted the 60-day signature collection period, while counting previously collected signatures. The City appealed the injunction and obtained a stay from the United States Court of Appeals for the Eleventh Circuit. On appeal, the United States Court of Appeals for the Eleventh Circuit held that the plaintiffs failed to demonstrate irreparable harm sufficient for injunctive relief. The court specified that, under Kemp v. City of Claxton, 496 S.E.2d 712 (Ga. 1998), Georgia law does not allow the use of a referendum petition to challenge or repeal a city ordinance unless it amends the city charter. Because the plaintiffs could not lawfully utilize the referendum process for their intended purpose, they lacked a right to the process and consequently could not show irreparable injury. The Eleventh Circuit vacated the preliminary injunction and remanded the case to the district court for further proceedings. View "Baker v. City of Atlanta" on Justia Law

Athos Overseas Limited Corp. v. YouTube, Inc.

2026-01-07T12:01:38-08:00

Athos Overseas Limited owns copyrights to numerous classic Mexican and Latin American films. The company discovered that its copyrighted films were posted on YouTube without authorization. Athos sent multiple takedown notices to YouTube, which removed the specific videos identified in those notices. However, Athos argued that YouTube’s technology—particularly its video-hashing and content management tools—gave it actual or “red flag” knowledge of additional infringing material beyond what was specifically identified, and thus YouTube should have removed all such matches automatically. The United States District Court for the Southern District of Florida reviewed cross-motions for summary judgment. The district court adopted the magistrate judge’s recommendation, denied Athos’s motion for partial summary judgment, and granted summary judgment in favor of YouTube. The court found that YouTube qualified for safe-harbor protection under 17 U.S.C. § 512(c) of the Digital Millennium Copyright Act (DMCA), as it expeditiously removed infringing material identified by valid takedown notices and did not have actual or red flag knowledge of other specific infringements. On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The Eleventh Circuit held that YouTube’s copyright management technologies do not, in themselves, give YouTube actual or red flag knowledge of specific infringing material unless a valid DMCA notice is received. The court also found that YouTube’s moderation and curation features did not constitute the right and ability to control infringing activity for purposes of the DMCA safe harbor. Therefore, YouTube was entitled to safe-harbor protection under § 512(c), and summary judgment in its favor was proper. View "Athos Overseas Limited Corp. v. YouTube, Inc." on Justia Law

USA v. Barry

2026-01-07T08:31:26-08:00

A group of individuals, including the appellant, participated in a scheme involving the use of stolen credit cards and fraudulent memberships at a warehouse store to purchase large quantities of cigarettes. The appellant served as the primary account holder for two business membership accounts and was a secondary member on two others. The scheme resulted in over $2 million in cigarette purchases. Following an 85-count indictment, the appellant was charged with conspiracy to commit credit card fraud, several counts of credit card fraud, and aggravated identity theft. After his codefendants pleaded guilty, the appellant proceeded to trial. During the trial, the government presented testimony from victims whose credit cards were used without authorization. The district court granted the appellant’s motion for acquittal on certain counts due to insufficient evidence, and the jury acquitted him on others, but found him guilty of the remaining charges. The United States District Court for the Northern District of Georgia sentenced the appellant, holding him accountable for the total loss amount charged by all members of the conspiracy using the shared credit cards. This figure was calculated in the presentence report and included losses attributable to the codefendants, except for those counts where the appellant was acquitted. The appellant objected, arguing that he should only be held responsible for transactions he personally conducted, but the district court overruled his objection and imposed restitution matching the total loss amount. On appeal, the United States Court of Appeals for the Eleventh Circuit concluded that the district court committed legal error by failing to make individualized findings regarding the scope of criminal activity undertaken by the appellant, as required under the Sentencing Guidelines. The appellate court vacated the appellant’s sentence and restitution order, remanding for resentencing with instructions to determine the loss amount based on the appellant’s own conduct and correct a clerical error in the judgment. View "USA v. Barry" on Justia Law

A. B. v. Barrow

2026-01-07T05:31:00-08:00

A.B., a minor, was sexually exploited by her mother and David Barrow when she was ten years old. In February 2018, A.B. filed a lawsuit against Barrow in Alabama state court for invasion of privacy. After a bench trial in April 2022, the court found in favor of A.B., awarding her $4 million in compensatory damages and $6 million in punitive damages. During related litigation, A.B.’s attorney learned that Barrow was likely insured by Nationwide Mutual Insurance Company, and in November 2018, served a subpoena on Nationwide, which produced Barrow’s umbrella liability insurance policy covering invasion of privacy claims. Nationwide removed the subsequent coverage action filed by A.B. under Alabama’s Direct Action Statute to the United States District Court for the Northern District of Alabama. The district court granted summary judgment for Nationwide, holding that neither Barrow nor A.B. notified Nationwide of the potential duty to indemnify “as soon as reasonably possible,” as required by the policy. The district court emphasized the 58-month delay between Barrow’s conduct and Nationwide receiving notice, and found that no reasonable excuse for the delay was offered by Barrow. The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The appellate court held that, under Alabama law and the terms of the policy, notice may be provided by the insured or someone on the insured’s behalf, including the injured party. However, the timeliness of notice is judged from the insured’s perspective. Because Barrow did not give notice to Nationwide within a reasonable time and offered no excuse for the delay, coverage was barred. The court rejected arguments that notice by A.B. could reset the timing requirement and concluded that summary judgment for Nationwide was proper. View "A. B. v. Barrow" on Justia Law