Justia Civil Procedure Opinion Summaries

Katie Wood, a transgender woman teaching at a public high school in Florida, challenged the enforcement of Fla. Stat. § 1000.071(3), which prohibits her from using the honorific “Ms.” and the gendered pronouns “she,” “her,” and “hers” in exchanges with students during class time. Wood argued that this statute violated her First Amendment right to free speech and sought a preliminary injunction to prevent its enforcement.The United States District Court for the Northern District of Florida granted Wood a preliminary injunction, finding that she had shown a substantial likelihood of success on the merits of her First Amendment claim. The district court reasoned that Wood’s use of her preferred honorific and pronouns constituted speech as a private citizen on a matter of public concern, and that her interest in expressing her gender identity outweighed the state’s interest in promoting workplace efficiency.The United States Court of Appeals for the Eleventh Circuit reviewed the case and disagreed with the district court’s findings. The appellate court held that Wood had not demonstrated a substantial likelihood that Fla. Stat. § 1000.071(3) infringed her free speech rights. The court concluded that when Wood used her preferred honorific and pronouns in the classroom, she was speaking as a government employee, not as a private citizen. Consequently, her speech was not protected under the First Amendment in this context. The Eleventh Circuit vacated the preliminary injunction and remanded the case to the district court for further proceedings consistent with its opinion. View "Wood v. Florida Department of Education" on Justia Law

In the early hours of August 22, 1972, military officers at the Almirante Zar Naval Base in Trelew, Argentina, removed nineteen unarmed political prisoners from their cells and shot them, resulting in what became known as the Trelew Massacre. The plaintiffs in this case are the surviving family members of four of those prisoners. They filed a lawsuit against Roberto Guillermo Bravo, one of the officers involved in the massacre, seeking compensatory and punitive damages under the Torture Victim Protection Act (TVPA) for the extrajudicial killing and torture of their relatives.The United States District Court for the Southern District of Florida heard the case. A jury found Mr. Bravo liable for the deaths and awarded the plaintiffs over $24 million. Mr. Bravo appealed, arguing that the district court erred by equitably tolling the TVPA statute of limitations on the plaintiffs’ claims until October 15, 2012. The district court had concluded that extraordinary circumstances, including the plaintiffs’ fear of reprisal, inability to locate Mr. Bravo, and inability to discover crucial evidence, justified tolling the statute of limitations.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court vacated the district court’s judgment, finding that the district court failed to make sufficient findings of fact to support its ruling on equitable tolling. The appellate court remanded the case for additional findings on whether the plaintiffs were entitled to equitable tolling beyond March 2008. The court also instructed the district court to reconsider whether the plaintiffs acted with due diligence in filing their claims, particularly in the case of Eduardo Cappello, who was found not to have acted diligently by the district court. The appellate court upheld the district court’s exclusion of evidence regarding the victims' alleged ties to communism and Cuba, finding no abuse of discretion. View "Camps v. Bravo" on Justia Law

Jekyll Island State Park Authority, a Georgia entity, operates the Summer Waves Water Park and owns the federally registered trademark for SUMMER WAVES. In 2021, Jekyll Island discovered that Polygroup Macau Limited, an intellectual property holding company registered in the British Virgin Islands, had registered nearly identical SUMMER WAVES marks. Polygroup Macau’s general counsel had also asked to buy Jekyll Island’s domain name, summerwaves.com. Jekyll Island sued Polygroup Macau for trademark infringement and to cancel Polygroup Macau’s marks. Polygroup Macau moved to dismiss for lack of personal jurisdiction, arguing it did not sell products in the United States using its trademarks.The United States District Court for the Southern District of Georgia granted Polygroup Macau’s motion to dismiss, concluding that Polygroup Macau did not have sufficient contacts with the United States to support personal jurisdiction. The court noted that Polygroup Macau did not sell products in the United States using its trademarks and only permitted other entities to do so, making the connection between Polygroup Macau’s activities and Jekyll Island’s claims too attenuated.The United States Court of Appeals for the Eleventh Circuit reviewed the case and disagreed with the district court’s conclusion. The Eleventh Circuit found that Polygroup Macau had purposefully availed itself of the benefits of United States law by registering and maintaining trademarks with the USPTO, allowing its sister companies to use those trademarks to sell products in the United States, and marketing specifically to U.S. consumers. The court held that the connection between Jekyll Island’s claims and Polygroup Macau’s activities in the United States was close enough to support specific jurisdiction. The Eleventh Circuit reversed the district court’s dismissal and remanded the case for consideration on the merits. View "Jekyll Island-State Park Authority v. Polygroup Macau Limited" on Justia Law

John P. Middleton filed a defamation lawsuit against Roy Lee, The Hollywood Reporter LLC, and Gary Baum in the Southern District of Florida. The case stemmed from a professional and personal fallout between Middleton and Lee, which began and ended in California. Middleton had sued Lee in California for millions of dollars, and during the ongoing legal battle, Middleton relocated to Florida. In June 2020, The Hollywood Reporter published an article by Baum that detailed the feud and contained allegedly false statements about Middleton. Middleton claimed these statements were defamatory and filed the lawsuit in June 2022.The district court dismissed Middleton's action, applying California's one-year statute of limitations for defamation claims, which rendered the claims time-barred. The court concluded that Florida's borrowing statute and choice-of-law rules required the application of California law due to the significant relationship factors. The court also denied Middleton's motion to amend the complaint, deeming it futile as the proposed amendments did not alter the determination that California's statute of limitations applied.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that California had the most significant relationship to the defamation claims, considering factors such as the place where the injury and conduct causing the injury occurred, the domicile and residence of the parties, and where the relationship between the parties was centered. Consequently, California's one-year statute of limitations applied, and Middleton's claims were time-barred. The court upheld the dismissal of the action and the denial of the motion to amend the complaint. View "Middleton v. The Hollywood Reporter LLC" on Justia Law

A couple, the Marons, alleged that Florida's Disposition of Unclaimed Property Act violated the Takings Clause of the Fifth Amendment. They claimed that the Act allowed the state to take their unclaimed property without compensating them for the earnings accrued while the property was in the state's custody. The Act requires holders of unclaimed property to deliver it to the state's Department of Financial Services, which then uses the property for public purposes, including investing it. The Marons argued that they were entitled to these earnings.The United States District Court for the Northern District of Florida dismissed the Marons' suit. The court reasoned that the state could constitutionally escheat the property altogether, so it could also keep the property in its custody without compensating for the earnings. The court also addressed jurisdictional issues, concluding that the Marons had standing and that their claim was not fully barred by sovereign immunity, but ultimately found that the Marons failed to state a claim.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court concluded that the district court had jurisdiction over the Marons' takings claim, as the Marons had standing, the claim was ripe, and it was not barred by sovereign immunity. However, the appellate court disagreed with the district court's analysis on the merits. The appellate court held that the Act did not transfer title of the unclaimed property to the state, but merely placed it in the state's custody. The court vacated the district court's judgment and remanded the case for further proceedings to determine whether the Marons' property was directly appropriated by the state and whether the Act provided just compensation. View "Maron v. Chief Financial Officer of Florida" on Justia Law

A former president of Panama, while residing in the United States, was extradited to Panama under a bilateral treaty. Panama initially charged him with specific crimes, but after his extradition, he was prosecuted for additional money laundering crimes not included in the original extradition request. He claimed these prosecutions violated the treaty's rule of specialty, which restricts prosecution to the crimes listed in the extradition request unless the extradited individual has had the opportunity to return to the extraditing country.The United States District Court for the Southern District of Florida dismissed his lawsuit for lack of standing. The court concluded that he failed to show that his injury was traceable to the defendants' actions or that a favorable ruling would redress his injuries. The court also determined that he lacked standing under the treaty's rule of specialty provision because the United States had waived its right to object to the additional prosecutions, and his rights under the treaty were derivative of the United States' rights.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's dismissal. The appellate court held that the plaintiff failed to establish Article III standing because his injury was not fairly traceable to the defendants' actions, as the decision to prosecute him was made independently by Panamanian officials. Additionally, the court found that a favorable declaratory judgment would not redress his injury, as it would not bind the Panamanian officials to drop the prosecutions. The court also concluded that the plaintiff lacked standing under the rule of specialty because the United States had consented to the prosecutions, extinguishing his derivative rights under the treaty. View "Berrocal v. Attorney General of the United States" on Justia Law

Bruce Henry, who pled guilty to possessing child pornography in 2013, challenged Alabama Code § 15-20A-11(d)(4), which prohibits adult sex offenders convicted of a sex offense involving a child from residing or conducting overnight visits with a minor, including their own child. Henry, who has completed his prison term, married, and fathered a son, argued that the statute violated his First Amendment right of intimate association and the Fourteenth Amendment’s guarantees of equal protection and due process.The United States District Court for the Middle District of Alabama denied Henry’s motion for a preliminary injunction but later partially granted his motion for summary judgment, finding the statute facially unconstitutional. The district court concluded that the statute was not narrowly tailored to further Alabama’s compelling interest in protecting children and issued an injunction against its enforcement.The United States Court of Appeals for the Eleventh Circuit reviewed the case and agreed that the statute violated Henry’s fundamental right to live with his child. The court held that the statute was overinclusive, underinclusive, and not narrowly tailored to achieve its goal. However, the court also concluded that the district court abused its discretion in facially enjoining the statute, as Henry had not shown that it was unconstitutional in all its applications. The court vacated the district court’s injunction and remanded the case for further proceedings consistent with its opinion. View "Henry v. Sheriff of Tuscaloosa County" on Justia Law

Jaime Vargas and Francis R. Alvarez, former employees of medical supplier Lincare, Inc., and its subsidiary Optigen, Inc., filed a qui tam complaint under the False Claims Act (FCA). They alleged that Optigen engaged in fraudulent practices, including systematic upcoding of durable medical equipment, improper kickback arrangements, waiver of co-pays, and shipment of unordered supplies. The relators claimed that Optigen billed CPAP batteries and accessories under codes designated for ventilator accessories, waived patient co-pays without assessing financial hardship, shipped CPAP supplies automatically without patient requests, and paid kickbacks to healthcare providers for referrals.The case was initially filed in the Eastern District of Virginia and later transferred to the Middle District of Florida. The United States declined to intervene, and the District Court unsealed the complaint. The relators filed multiple amended complaints, each of which was dismissed by the District Court for failing to meet the heightened pleading standard of Federal Rule of Civil Procedure 9(b). The District Court dismissed the fourth amended complaint, holding that it still failed to plead sufficient facts with the requisite specificity.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court affirmed the District Court's dismissal of the relators' claims regarding improper kickback arrangements, waiver of co-pays, and automatic shipment of supplies, finding that these allegations lacked the necessary specificity and failed to identify any actual false claims submitted to the government. However, the court reversed the dismissal of the upcoding claim, holding that the relators had pleaded sufficient facts with particularity to withstand a motion to dismiss. The court remanded the case for further proceedings limited to the upcoding issue. View "Vargas v. Lincare, Inc." on Justia Law

Several college volleyball players accused their coach of physical, verbal, psychological, and sexual abuse. The players alleged that the coach engaged in a pattern of sexual harassment and abuse, including inappropriate touching and forcing players to engage in uncomfortable physical interactions. They also claimed that the coach's misconduct was reported to various university administrators and assistant coaches, who either witnessed or were informed of the abuse.The United States District Court for the Southern District of Alabama dismissed the players' Title IX and § 1983 claims with prejudice for failure to state a claim. The court found that the players had abandoned their breach-of-contract claims and dismissed those with prejudice. The court also declined to exercise supplemental jurisdiction over the remaining state-law claims, dismissing them without prejudice.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's dismissal. The court held that the players failed to state a Title IX claim because only certain university administrators were "appropriate persons" to receive notice of the misconduct, and the players did not provide sufficient actual notice of sexual harassment to those individuals. The court also found that the university did not act with deliberate indifference upon receiving the notice.Regarding the § 1983 claims, the court held that the players did not show that the university employees' conduct violated clearly established substantive-due-process principles. The court concluded that the employees were entitled to qualified immunity because the players did not provide case law with indistinguishable facts, a broad statement of principle, or conduct so egregious that it clearly violated constitutional rights.The Eleventh Circuit affirmed the district court's order dismissing the players' Title IX and § 1983 claims. View "DeMarcus v. University of South Alabama" on Justia Law

Ronald Rubin filed a lawsuit naming Kimberly Grippa as part of a criminal enterprise. His lawyer sent allegedly defamatory letters to state officials, asking them to investigate the alleged criminal enterprise and included copies of the complaint. Grippa sued Rubin for defamation, claiming the letters harmed her reputation and professional standing. Rubin moved for summary judgment, arguing the letters were protected by Florida’s absolute and qualified litigation privileges and that he could not be held vicariously liable for his lawyer’s actions.The United States District Court for the Northern District of Florida denied Rubin’s motion for summary judgment on all grounds. The court found that the letters were not protected by the absolute litigation privilege because they were sent outside the litigation process and included additional statements beyond those in the complaint. The court also determined that there was a genuine dispute of material fact regarding whether the statements were made with express malice, precluding the qualified litigation privilege. Lastly, the court rejected Rubin’s vicarious liability argument, suggesting that Rubin directed his lawyer’s actions.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that the denial of Florida’s absolute litigation privilege is immediately appealable under the collateral order doctrine but lacked jurisdiction to consider the denial of the qualified litigation privilege or the vicarious liability issue. The court affirmed the district court’s denial of the absolute litigation privilege, concluding that the letters were sent outside the judicial process and included additional defamatory statements. The court dismissed the appeal regarding the qualified litigation privilege and vicarious liability for lack of jurisdiction. View "Grippa v. Rubin" on Justia Law