Justia Civil Procedure Opinion Summaries

In this case, Amber Jackson filed a lawsuit against Atlanta police officers Cody Swanger and Jeremiah Brandt, alleging that they violated her constitutional rights by unlawfully seizing her without reasonable suspicion or probable cause and using excessive force. She also claimed that Brandt failed to intervene in Swanger's use of excessive force. The officers moved to dismiss the case, arguing that they were entitled to qualified immunity, but the district court denied their motion. The officers then appealed the decision.The United States Court of Appeals for the Eleventh Circuit found that it had jurisdiction to review the district court's denial of the officers' motion to dismiss Jackson's unlawful seizure claim. The court affirmed the district court's decision, agreeing that Jackson had plausibly alleged that the officers violated her clearly established right to be free from an unreasonable seizure.However, the court found that it did not have jurisdiction to review the district court's decision not to incorporate certain video footage into the pleadings. The court also declined to assert pendant appellate jurisdiction over that issue.As for Jackson's claim that Brandt failed to intervene in Swanger's use of excessive force, the court found that it had jurisdiction to review the district court's denial of Brandt's motion to dismiss this claim. However, the court vacated and remanded this part of the case, instructing the district court to dismiss the claim. The court reasoned that Brandt did not have a reasonable opportunity to intervene physically or verbally and stop Swanger's use of alleged excessive force against Jackson. Therefore, Brandt did not violate Jackson's Fourth Amendment rights. View "Jackson v. Swanger" on Justia Law

The case involves a claimant, Isaac Flowers, who applied for Social Security Disability benefits due to various health issues including back, neck, shoulder, and joint problems, obesity, vision loss in one eye, and depression and opioid dependence. The Administrative Law Judge (ALJ) initially denied his claim, deeming that he could perform "sedentary work". Later, Flowers applied for benefits again, and the ALJ denied his claim again, this time finding that he could perform "light work", a classification slightly more intensive than "sedentary work".Flowers appealed this decision, arguing that the ALJ's finding that he could perform "light work" wasn't supported by substantial evidence as there was no proof of his condition improving. He also suggested that the ALJ should have considered the previous finding of him only being able to perform "sedentary work".The United States Court of Appeals for the Eleventh Circuit rejected Flowers' argument. Firstly, the court found that Flowers hadn't raised this legal issue in the lower courts and they declined to consider it for the first time on appeal. Secondly, the court concluded that even if Flowers had raised the issue in the lower courts, any error would have been harmless because Flowers hadn't shown that he would be entitled to disability benefits even if he was limited to "sedentary work". Lastly, the court found that the ALJ's decision was supported by substantial evidence. Consequently, the court affirmed the ALJ's decision. View "Flowers v. Commissioner, Social Security Administration" on Justia Law

The case in question involves a receiver, Burton Wiand, appointed after the collapse of a $78 million Ponzi scheme operated by Oasis, who sued ATC Brokers Ltd. (where Oasis held accounts), David Manoukian (owner of ATC Brokers), and Spotex LLC (which provided software to Oasis). Wiand alleged common-law tort claims against the defendants and fraudulent-transfer claims against ATC Brokers only. The district court dismissed Wiand’s complaint with prejudice, ruling that Wiand lacked standing to sue ATC Brokers and Manoukian and that Spotex was immune under the Communications Decency Act.The United States Court of Appeals for the Eleventh Circuit found that the district court erred in dismissing the fraudulent-transfer claims for lack of standing. The court explained that a receiver for a Ponzi estate has standing to maintain fraudulent-transfer claims on behalf of the estate. However, the court agreed with the district court that Wiand lacked standing to maintain the tort claims, as the Oasis corporate entities were not separate and distinct from the Ponzi scheme, and Wiand couldn't allege an injury to sustain his tort claims.As a result, the court reversed the dismissal of the fraudulent-transfer claims and remanded for further proceedings, and vacated the dismissal with prejudice of the tort claims and remanded with instructions to dismiss without prejudice. View "Wiand v. ATC Brokers Ltd." on Justia Law

In this case, plaintiffs Lee Anne and John Savoia-McHugh sued defendant Michael Glass, alleging misconduct related to real estate investment transactions. Despite being served with the complaint, Glass did not respond to the complaint, the amended complaint, written discovery requests, a motion to compel, or a subpoena over a period of 15 months. Consequently, the plaintiffs requested and were granted an entry of default. Glass later engaged counsel and moved to set aside the default, arguing that his delayed appearance was not willful, that he had established meritorious defenses, and that setting aside the default would not prejudice the plaintiffs. However, the district court denied his motion and entered a default judgment against him.The United States Court of Appeals for the Eleventh Circuit affirmed the district court's decision, holding that Glass willfully defaulted. The court noted that despite Glass's contention that he was not served with the complaint or the amended complaint, he acknowledged receipt of several other legal documents related to the case. Furthermore, Glass's excuse that he was confused and did not understand the need to act until the magistrate judge’s order was deemed inadequate. As a result, the court concluded that Glass displayed an intentional or reckless disregard for the judicial proceedings, which negated a finding of good cause to set aside the default. View "Savoia-McHugh v. Glass" on Justia Law

In this lawsuit, Keith Sylvester alleged that Detective James Barnett violated his Fourth Amendment rights by causing his arrest and detention without probable cause. Sylvester's parents were murdered and their house set on fire. Detective Barnett led the investigation and suspected Sylvester was the culprit, ultimately obtaining an arrest warrant for him. Sylvester spent over a year in jail until the charges were dropped. Sylvester claimed that Barnett lacked probable cause when he applied for the arrest warrant, arguing that key exonerating evidence was omitted from the affidavit.The district court granted Detective Barnett summary judgment, stating that the record did not establish that Barnett knew about the exonerating information when he wrote the warrant affidavit. The court concluded that, based on the totality of circumstances known to Barnett at the time of the arrest, his suspicion of Sylvester was reasonable.On appeal, the United States Court of Appeals for the Eleventh Circuit reversed the lower court's decision. The appellate court found that there were material facts omitted from the warrant affidavit. When those omissions were corrected, the affidavit failed to establish even arguable probable cause for Sylvester's arrest. The court further held that a reasonable jury could find that Barnett intentionally or recklessly left out information that exonerated Sylvester. If a jury finds such misconduct, qualified immunity would not shield Barnett from liability. Therefore, the case was remanded for further proceedings. View "Sylvester v. Barnett" on Justia Law

The case involves Dr. Robert H. Wainberg, a tenured biology professor at Piedmont University, who filed a lawsuit against several officers and trustees of the university. He alleged that they conspired to retaliate against him for filing a prior lawsuit and to deter witnesses from participating in that lawsuit, and negligently refused to prevent that conspiracy. The district court dismissed Wainberg’s claims as time-barred, concluding that the statute of limitations ran from the first overt act Wainberg alleged as part of the conspiracy.On appeal, the United States Court of Appeals for the Eleventh Circuit held that under its precedent, each overt act triggers its own statute of limitations. Therefore, Wainberg’s claims arising out of some overt acts were timely. The court vacated the district court’s dismissal and remanded for further proceedings. The court also held that the continuing-violation doctrine, which allows a plaintiff to sue on an otherwise time-barred claim when additional violations of the law occur within the statutory period, did not apply in this case because the alleged violations were not ongoing but were discrete acts, each triggering its own statute of limitations. View "Wainberg v. Mellichamp" on Justia Law

In this case, three individuals and the Firearms Policy Coalition (FPC), an advocacy group, challenged a Georgia law that prohibits individuals under the age of 21 from obtaining licenses to carry firearms. They sued three county probate judges, who issue carry licenses, and Georgia’s Commissioner of Public Safety, who designs the carry license application form. The district court dismissed the case, concluding that the plaintiffs lacked standing to sue any of the defendants and that the case was both moot and unripe. On appeal, the United States Court of Appeals for the Eleventh Circuit held that the plaintiffs have standing to sue the probate judges, but not the Commissioner of Public Safety. The court found that the plaintiffs' alleged injury - the inability to carry firearms due to their age - is traceable to the actions of the probate judges who issue the licenses, and could be redressed by a court order directed at them. However, the court held that the plaintiffs' injuries are not fairly traceable to, nor redressable by a court order against, the Commissioner of Public Safety, who merely designs the application form and lacks enforcement authority. The court also held that the case was neither moot nor unripe with respect to the probate judges, reversing the district court's dismissal of the case in part and remanding the case to the district court for further proceedings. View "Baughcum v. Jackson" on Justia Law

In a personal injury lawsuit, Carelyn Fylling sued Royal Caribbean Cruises for negligence after she tripped, fell, and hit her head while entering a deck on one of their cruise ships. The case was tried before a jury in the United States District Court for the Southern District of Florida. During the trial, the court became aware that one of the jurors had a niece who worked for Royal Caribbean. Despite this potential conflict of interest, the court did not remove or question this juror about any potential bias, and allowed her to participate in deliberations. The jury found Royal Caribbean negligent, but also found Fylling comparative-negligent, reducing her recovery by ninety percent. Fylling appealed to the United States Court of Appeals for the Eleventh Circuit, arguing that the lower court abused its discretion by not investigating the potential bias of the juror related to an employee of the defendant.The Eleventh Circuit agreed with Fylling. The court held that the district court abused its discretion by not investigating whether the juror could impartially discharge her responsibilities once it became aware of her potential bias. The court explained that when a district court becomes aware of potential juror bias, it is required to develop the factual circumstances sufficiently to make an informed judgment as to whether bias exists. A district court's obligation to protect the right to an impartial jury does not end when the jury is impaneled and sworn. The Eleventh Circuit therefore reversed the judgment and remanded the case for a new trial. View "Fylling v. Royal Carribean Cruises, Ltd." on Justia Law

In this case heard by the United States Court of Appeals for the Eleventh Circuit, the appellant, Kai Hansjurgens, contested the revival of a bankruptcy judgment against him in favor of Donald Bailey. More than a decade earlier, Bailey had obtained a bankruptcy judgment against Hansjurgens for tortious interference with a contract, which Hansjurgens had not paid. To prevent the judgment from expiring under Georgia law, Bailey filed a motion to revive the judgment, which was granted by the bankruptcy court. Hansjurgens argued that the revival proceedings violated his due process rights and did not strictly comply with Georgia's scire facias procedures, which are used to revive dormant judgments.The court found that the Federal Rules of Civil Procedure, specifically Rule 69(a), only require the revival proceedings to "accord with" or substantially comply with state procedures, rather than strictly comply. The court further noted that the purpose of scire facias, providing notice to the party and an opportunity to present objections, had been served through mailed notices to Hansjurgens at several addresses. The court also observed that Georgia's scire facias procedures did not fit squarely within the federal court system, and requiring strict compliance would be impractical.Therefore, the court held that the bankruptcy court had properly revived the judgment and that the proceedings did not violate due process. It affirmed the district court's revival order. View "Hansjurgens v. Bailey" on Justia Law

The United States Court of Appeals for the Eleventh Circuit considered two petitions for review brought by Hunt Refining Company against decisions made by the U.S. Environmental Protection Agency (EPA). The EPA had denied Hunt's petitions for hardship exemptions under the Renewable Fuel Standard (RFS) program, part of the Clean Air Act that mandates most oil refineries in the U.S. to blend a certain quantity of renewable fuels into their transportation fuels each year. Small refineries can petition for exemption from these requirements if compliance would cause them "disproportionate economic hardship." The EPA's denial of Hunt's petitions was based on a new interpretation of the statutory provision and a new economic theory applicable to all small refineries, regardless of their location or market.The Eleventh Circuit held that Hunt's petitions for review should have been filed in the United States Court of Appeals for the District of Columbia because the EPA actions challenged were "nationally applicable." In other words, they applied a consistent statutory interpretation and economic analysis to small refineries across the country. The court dismissed Hunt's petitions, given that Hunt had already filed protective petitions for review of the same EPA decisions in the D.C. Circuit, which were currently being briefed on the merits. View "Hunt Refining Company v. U.S. Environmental Protection Agency" on Justia Law