Case Explained: ANDREW JOSEPH, JR. as natural father, next friend and personal representative of the Estate of Andrew Joseph III deceased v. HILLSBOROUGH COUNTY SHERIFF

Court: United States Court of Appeals for the Eleventh Circuit

Filed: 2026-07-10

Docket: 8:16-cv-00274-MSS-CPT

The Eleventh Circuit affirmed the district court’s denial of the plaintiff’s renewed motion for judgment as a matter of law and motion for a new trial regarding the Fourth Amendment claim, as well as the district court’s rulings on sovereign immunity, evidentiary admissibility, and jury instructions. The court held that the Hillsborough County Sheriff’s Office was not entitled to sovereign immunity because its failure to notify Andrew Joseph III’s parents or release him to a responsible adult constituted an operational decision rather than a discretionary planning decision under Florida law. Regarding the Fourth Amendment claim, the court applied the probable cause standard, determining that a reasonable jury could conclude Deputy Clark had probable cause to arrest Andrew for disorderly conduct based on evidence that Andrew ran through chaotic crowds while officers were managing other detainees. The court further held that C.T.’s testimony regarding an officer’s statements was not inadmissible hearsay because it was introduced to show the effect of those statements on the boys’ motivation to cross the interstate, and its probative value outweighed any risk of unfair prejudice under Federal Rule of Evidence 403. Finally, the court affirmed the jury instruction that statutory violations constituted prima facie evidence of negligence, finding that Florida statutes required officers to notify guardians and release minors to responsible adults, and the record supported a finding that these duties were breached. The practical consequence is that the jury’s verdict in favor of the plaintiff on the wrongful death claim stands, while the verdict for the defendant on the Fourth Amendment claim remains intact, leaving the Sheriff’s Office liable for damages under Florida tort law.

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