Eversheds Sutherland 11th Circuit Business Blog
content top

FEDERAL COMMON LAW APPLIES STATE PRECLUSION RULES TO JUDGMENTS IN DIVERSITY CASES

The Eleventh Circuit cleaned up some conflicting precedent this week and confirmed that state-law rules determine the preclusive effect of judgments rendered by federal courts in diversity cases. In deciding that question in CSX Transportation, Inc. v. General Mills, Inc., 2017 WL 393704 (11th Cir. Jan. 30, 2017), the court reversed the district court’s judgment and held that this...

Common-Law Agency Principles, Not DOL Regulations, Dictate Whether Company Is a Joint “Employer”

The Eleventh Circuit considered the meaning of “employer” in the context of the H-2A visa program and declined to apply Chevron deference to a then-prevailing Department of Labor interpretation.  The court instead applied common-law agency principles.  Garcia-Celestino v. Consolidated Citrus Limited Partnership, 2016 WL 7240150 (Dec. 15, 2016), involved claims brought by a group of...

“Binding” External Benefit Determinations Might Not Bind Courts Under ERISA

Does ERISA preempt rules that give “binding” effect to benefit determinations made by a plan’s external review panel? Not as long as those determinations don’t actually bind courts, the Eleventh Circuit held in Alexandra H. v. Oxford Health Insurance Inc. Freedom Access Plan, 2016 WL 4361936 (11th Cir. Aug. 16, 2016). The plaintiff in the case was challenging an adverse...