U.S. Court of Appeals for the Eleventh Circuit
Margherita Cunningham v. Centurion of Florida LLC
September 9, 2026
Summary
The Eleventh Circuit affirmed the district court’s dismissal of the estate’s second amended §1983 complaint. The court held that the estate forfeited the issue of failure to state a deliberate‑indifference claim, that the claim was time‑barred under Florida’s four‑year limitations period, that the amendment could not relate back because it presented a factually distinct claim, and that the complaint failed to plead a Monell policy‑or‑custom theory.