U.S. Court of Appeals for the Eleventh Circuit - Justia Case Law Summaries

Thomas v. City Schools of Decatur

2026-11-06T12:30:46-08:00

A mother reported to the City Schools of Decatur, Georgia, that her five-year-old Black daughter had been sexually assaulted by a male classmate in a kindergarten restroom. She was dissatisfied with the school district’s response to the report, alleging that school staff delayed action, failed to adequately investigate the incident, and made a child protective services referral that implicated her in neglect. The mother also claimed the district’s response was influenced by the race of her family, given that her daughter is Black and the alleged perpetrator was a Black boy adopted by White parents. After the report, the school principal and staff took several steps: contacting a school resource officer and social workers, informing district administrators, ensuring both children were supervised during restroom visits, and referring the matter to the Department of Family and Children Services (DFCS) for both the victim and alleged perpetrator. The mother took her daughter to the hospital for examination, and the girl was later moved to a different classroom and eventually transferred to another school at her mother’s request. DFCS investigated and closed the case against the mother as unsubstantiated. The Department of Education’s Office for Civil Rights later found the district’s Title IX response was inadequate under its regulations, though it found no retaliation. In the United States District Court for the Northern District of Georgia, summary judgment was granted for the school district on both the Title IX (sex discrimination) and Title VI (race discrimination) claims. The court found the district’s response did not amount to deliberate indifference, as required under Title IX, and that there was insufficient evidence of racial discrimination under Title VI. On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed. The court held that the district’s actions—including an immediate investigation, protective measures, and student transfers—were not clearly unreasonable and did not constitute deliberate indifference under Title IX. The court also held that the plaintiff failed to present sufficient evidence of intentional race discrimination under Title VI. View "Thomas v. City Schools of Decatur" on Justia Law

McClinton v. Warden

2026-11-06T08:00:43-08:00

A prison inmate was transferred from Phillips State Prison in Georgia, where he had stabbed a high-ranking member of the Bloods gang, to Baldwin State Prison after being placed in protective custody due to the imminent threat of retaliation. The transfer request cited his need for mental health services and mentioned the risk posed by his known enemy, but did not specify risks at Baldwin. Upon arriving at Baldwin, the inmate was placed in the general population, and after briefly requesting protective custody—which he later withdrew—he was stabbed to death by another inmate, allegedly a Bloods member. The parents and estate of the deceased sued five Georgia Department of Corrections officials, alleging that each was deliberately indifferent to the risk of harm under the Eighth Amendment. The United States District Court for the Middle District of Georgia initially dismissed certain wrongful death claims as time-barred, but allowed Eighth Amendment claims by the estate against all five defendants to proceed. The district court ultimately granted summary judgment in favor of the defendants, holding that each was entitled to qualified immunity because there was no violation of clearly established law and no evidence of subjective awareness by any defendant that their conduct caused a substantial risk of harm. The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s rulings de novo. The Eleventh Circuit affirmed the district court’s judgment, holding that none of the defendants possessed the requisite subjective knowledge that their actions or inactions placed the inmate at substantial risk of serious harm. Applying the deliberate indifference standard established in Wade v. McDade and Farmer v. Brennan, the court concluded that all defendants were protected by qualified immunity, as there was no constitutional violation. View "McClinton v. Warden" on Justia Law

Consul v. Progressive American Insurance Company

2026-11-05T13:33:43-08:00

The case concerns an automobile accident in which the insured, Consul, rear-ended another driver, Choisser, causing injuries and significant vehicle damage. Consul’s insurer, Progressive, provided coverage with $10,000 bodily injury and $10,000 property damage limits. After the accident, Progressive determined Consul was fully at fault. Progressive and Choisser’s attorney began settlement negotiations, during which Progressive sought a release of any loss of consortium claim from Choisser’s wife and required transfer of the vehicle title for what it deemed a total loss. Choisser’s attorney objected to these conditions, stating he did not represent the wife and disputing the total loss valuation. Negotiations stalled, and Choisser ultimately sued Consul. The property damage claim settled, but the bodily injury claim proceeded to trial, resulting in a judgment exceeding $1 million against Consul. Following the judgment, Consul sued Progressive in the United States District Court for the Middle District of Florida, alleging bad faith in Progressive’s settlement negotiations and communications. Progressive moved for summary judgment, arguing it had acted reasonably under the circumstances. The district court granted summary judgment in Progressive’s favor, concluding there was no evidence of bad faith and that Progressive’s actions were reasonable, including its handling of the consortium waiver and title transfer issues. On appeal, the United States Court of Appeals for the Eleventh Circuit held that summary judgment was improper. The appellate court found that genuine disputes of material fact existed regarding whether Progressive acted in bad faith, particularly concerning the reasonableness of requiring the consortium waiver, the handling of the vehicle title, and communication with Consul. The Eleventh Circuit vacated the district court’s judgment and remanded the case for further proceedings, holding that a reasonable jury could find Progressive failed to fulfill its duty of good faith under Florida law. View "Consul v. Progressive American Insurance Company" on Justia Law

USA v. Adams

2026-11-05T12:03:22-08:00

Police in Manatee County, Florida, began investigating an individual known as “Dre” following a tip that he was selling drugs and collecting payments through Cash App. Surveillance linked “Dre” to a residence in Bradenton, which was then associated with Andre Adams Jr. Officers observed frequent, brief visits to the home and witnessed Adams hand items to visitors. Trash recovered from the property contained evidence of drugs, and Cash App records revealed Adams received over $67,000 in small payments, with some transactions referencing drug slang. Adams had no reported employment during this period. A search warrant was obtained for the residence, where officers found substantial evidence of drug trafficking, including narcotics, cash, firearms, and paraphernalia. A subsequent search of a storage unit rented by Adams uncovered more drugs, cash, and firearms. A federal grand jury indicted Adams on charges of possessing drugs with intent to distribute, possessing a firearm in furtherance of a drug trafficking crime, and possessing a firearm as a convicted felon. Adams moved to suppress evidence, arguing the search warrant affidavit omitted material information, and sought a hearing under Franks v. Delaware. A magistrate judge recommended denying his motions, finding Adams failed to submit a sworn statement as required, and the district court adopted this recommendation. Adams’s evidentiary objections to the introduction of his financial records and employment history were also denied, as was his request for a specific jury instruction on “mere presence.” At trial, the jury convicted Adams on all counts. The United States Court of Appeals for the Eleventh Circuit reviewed and affirmed the district court’s decisions. The appellate court held that Adams was not entitled to a Franks hearing, the evidentiary rulings were proper or harmless, the jury instructions were adequate, the evidence was sufficient to support the convictions, and the 228-month sentence was substantively reasonable. View "USA v. Adams" on Justia Law

Chianne D. v. Secretary, Florida Agency for Health Care Administ

2026-11-04T14:02:46-08:00

Several Medicaid enrollees in Florida, whose benefits were terminated due to income-based eligibility determinations, challenged the adequacy of the notices they received from the state. These notices, generated by Florida’s Department of Children and Families (DCF), typically stated that Medicaid benefits would end because “household income is too high,” but did not include essential individualized information such as the household size used, the countable income figure, the income threshold applied, or the specific Medicaid eligibility category considered. In some cases, the notices also included contradictory or confusing information about which household members were affected. Many recipients later learned that their coverage had been terminated or restored in error, but the notices did not provide enough detail for them to understand or contest the agency’s decisions. The case was brought as a class action in the United States District Court for the Middle District of Florida, focusing on whether the notices met the requirements of due process. After a bench trial, the district court found that the written notices were confusing, lacked sufficient individualized detail to explain the state’s decisions, and failed to enable recipients to understand or meaningfully challenge their benefit terminations. The court also found that other sources of information available to recipients, such as call centers or online resources, did not cure these deficiencies. The district court issued a declaratory judgment and a permanent injunction, requiring Florida to provide clear and case-specific information in future notices before terminating Medicaid benefits for income ineligibility. On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s judgment. The court held that Florida’s notice system, considered as a whole, did not satisfy due process because it was not reasonably calculated to adequately inform recipients of the reasons for benefit termination or enable them to decide whether to contest the action. View "Chianne D. v. Secretary, Florida Agency for Health Care Administ" on Justia Law

USA v. Lemaine

2026-10-30T12:01:54-08:00

The defendant, previously convicted of serious felonies, was indicted for possessing a firearm as a felon after officers found a firearm in his vehicle during a traffic stop. He initially pleaded not guilty, but later changed his plea to guilty. While released on bond awaiting sentencing—subject to home detention and an ankle monitor—the defendant requested and received removal of the home detention condition. Shortly before sentencing, he was arrested for armed robbery. The incident involved two masked men robbing a victim at gunpoint, stealing cash, jewelry, and a cell phone. Circumstantial evidence, including location data from the defendant’s ankle monitor and a tracking device registered to him, placed him at the scene and linked him to the crime. The United States District Court for the Middle District of Florida held a bond revocation hearing, found probable cause the defendant violated his release conditions, revoked his bond, and later conducted a sentencing hearing. The presentence report initially recommended a reduction for acceptance of responsibility, but after the robbery charge, a revised report removed the reduction and increased the guideline range. The prosecution sought an upward variance based on the new criminal conduct. At sentencing, the district court considered testimony and evidence from both hearings, denied the reduction for acceptance of responsibility, and imposed a 96-month sentence, citing the defendant’s continued dangerous conduct. The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that the district court did not reversibly err in finding the defendant committed armed robbery by a preponderance of the evidence, did not plainly err in considering the robbery to deny the offense-level reduction for acceptance of responsibility, and did not impose an unreasonable sentence. The court affirmed the conviction and sentence. View "USA v. Lemaine" on Justia Law

O'Kelley v. Warden, Georgia Diagnostic Prison

2026-10-27T12:31:08-08:00

A Georgia inmate was sentenced to death after being convicted by a jury of two counts of malice murder, along with other crimes, based on evidence that he and an accomplice burglarized a residence, set fire to another nearby home, and killed two victims. The inmate confessed to the crimes and was linked by physical evidence. After exhausting his appeals in the Georgia Supreme Court and being denied certiorari by the United States Supreme Court, he filed a state habeas petition, which was denied, and the Georgia Supreme Court denied his application for a certificate of probable cause to appeal. Following these state proceedings, the inmate filed a federal habeas corpus petition in the United States District Court for the Southern District of Georgia, raising nine claims with approximately sixty subclaims. The Warden argued that most claims were procedurally defaulted, unexhausted, or insufficiently pleaded under Rule 2(c) of the Rules Governing Section 2254 Cases. The district court dismissed six subclaims as insufficiently pleaded, some on its own motion (sua sponte), and denied the petitioner’s motion for reconsideration and for leave to amend the petition, reasoning that the petitioner had long been aware of the pleading requirements and had delayed seeking leave to amend. On appeal, the United States Court of Appeals for the Eleventh Circuit addressed the narrow question of whether the Constitution required the district court to give the petitioner notice and an opportunity to amend before dismissing subclaims sua sponte for insufficient pleading. The Eleventh Circuit held that the petitioner had adequate notice of the pleading requirements and the possibility of dismissal under the applicable rules and case law, and that he had sufficient opportunity to be heard, including through his original petition and motion for reconsideration. The court therefore affirmed the district court’s denial of the habeas petition. View "O'Kelley v. Warden, Georgia Diagnostic Prison" on Justia Law

USA v. Rizo

2026-10-27T06:31:14-08:00

The defendant was convicted in 1997 of participating in a conspiracy to rob drug dealers at gunpoint, resulting in the theft of large amounts of money and drugs. He received a total sentence of 468 months, which included consecutive sentences for two convictions under 18 U.S.C. § 924(c) related to firearm use during crimes of violence and drug trafficking. At the time, sentencing law required a 20-year consecutive sentence for a “second or subsequent” § 924(c) conviction, even if both convictions arose from the same prosecution. Following a 2018 amendment to § 924(c), which eliminated the “stacking” requirement for first-time offenders with multiple convictions in a single prosecution, the defendant moved for a sentence reduction under 18 U.S.C. § 3582(c)(1)(A)(i) in the United States District Court for the Southern District of Florida. He argued that the change in law, though not retroactive, constituted an “extraordinary and compelling” reason for a reduction under a 2023 Sentencing Commission policy statement (U.S.S.G. § 1B1.13(b)(6)). The district court granted the motion, reduced the defendant’s second § 924(c) sentence from 20 to 5 years, and ordered his release. The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s decision. The appellate court held it had jurisdiction over the government’s appeal. On the merits, the court concluded that the district court erred because, under Rutherford v. United States, 608 U.S. 454 (2026), the 2018 non-retroactive amendment to § 924(c) cannot, as a matter of law, constitute an “extraordinary and compelling” reason for a sentence reduction under § 3582(c)(1)(A)(i). The Eleventh Circuit reversed the district court’s order and directed reinstatement of the original sentence. View "USA v. Rizo" on Justia Law

Cormier v. Florida Department of Corrections

2026-10-26T12:00:43-08:00

The petitioner was convicted in Florida state court in 2013 of two counts of first-degree grand theft and one count of second-degree grand theft for taking investments from three individuals and using the funds for personal expenses. He was sentenced to fifteen years in prison and ordered to pay $835,000 in restitution. His conviction and sentence were affirmed by the Florida Fourth District Court of Appeal, and his motion for rehearing was denied in January 2016, making his conviction final ninety days later. Shortly before his conviction became final, he filed a motion to reduce his imprisonment, which was denied in April 2016. He later mailed a separate motion, challenging only the restitution part of his sentence, but this motion was never docketed by the state court. In December 2017, he filed a state post-conviction motion, which was eventually denied and became final in December 2022. The United States District Court for the Southern District of Florida dismissed his federal habeas petition as untimely under the Antiterrorism and Effective Death Penalty Act (AEDPA), holding that the one-year limitations period was not tolled by his undocketed motion challenging restitution, because it did not challenge the custody-imposing portion of his sentence. The district court also found no basis for equitable tolling and held, in the alternative, that his ineffective-assistance-of-counsel and due process claims were not colorable. On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s dismissal. The Eleventh Circuit held that a motion challenging only restitution does not toll AEDPA’s statute of limitations, because restitution does not relate to the custody underlying habeas relief. Therefore, his federal habeas petition was untimely, and the court did not reach the merits of his constitutional claims. The district court’s order was affirmed. View "Cormier v. Florida Department of Corrections" on Justia Law

Safe Affordable Georgia, Inc. v. Chairman of the State Ethics Commission

2026-10-26T10:30:44-08:00

Several individuals sought the Republican nomination for Governor in Georgia’s 2026 primary election. Under state law, only certain officials—including the Lieutenant Governor—could create a special “leadership committee” that was permitted to raise and spend unlimited funds in direct coordination with their campaigns. Burt Jones, the Lieutenant Governor, formed such a committee to support his own campaign. Brad Raffensperger, Georgia’s Secretary of State, also ran in the primary, but his supporters—including Safe Affordable Georgia, a hybrid political action committee (PAC) chaired by Raffensperger—were subject to contribution and coordination restrictions and could not operate a leadership committee. Safe Affordable Georgia filed suit in the United States District Court for the Northern District of Georgia, challenging these campaign finance restrictions as violating the First Amendment. The group sought a preliminary injunction to prevent enforcement of the contribution and coordination limits against it, specifically so it could support Raffensperger’s campaign during the ongoing primary. The district court denied the motion for preliminary injunction. Safe Affordable Georgia appealed to the United States Court of Appeals for the Eleventh Circuit, seeking expedited review. By the time the Eleventh Circuit heard the appeal, the 2026 primary election was over and Raffensperger’s campaign had ended. The Eleventh Circuit concluded that the case was moot because the court could no longer provide meaningful relief relating to the completed election. The court also found that the “capable of repetition yet evading review” exception to mootness did not apply, as there was no reasonable expectation that the same dispute would recur involving the same parties. Consequently, the Eleventh Circuit dismissed the appeal and remanded the case with instructions to dismiss it as moot. View "Safe Affordable Georgia, Inc. v. Chairman of the State Ethics Commission" on Justia Law

USA v. McLaurin

2026-10-23T06:00:38-08:00

The case concerns a defendant who pleaded guilty to conspiracy to distribute, and possession with intent to distribute, methamphetamine, fentanyl, and cocaine. The defendant was part of a group engaged in distributing these drugs from multiple residences. Law enforcement conducted several search warrants at locations linked to the group, recovering significant quantities of the controlled substances and other evidence. The defendant admitted to being involved in the conspiracy, selling drugs at one of the residences, and participating in music videos promoting the drug operation. After the indictment, the defendant entered a guilty plea to both conspiracy and substantive drug charges without a plea agreement. The United States District Court for the Middle District of Florida accepted the plea. At sentencing, the court relied on the presentence investigation report, which attributed to the defendant all drugs seized in connection with the group’s activities at various residences. The court also applied a two-level enhancement for maintaining premises for drug distribution, based on co-conspirator conduct. The defendant objected, arguing he should be accountable only for drugs at the location where he sold, and that the enhancement should not apply based on co-conspirator actions. On appeal to the United States Court of Appeals for the Eleventh Circuit, the defendant contested the drug quantity attributed to him and the application of the sentencing enhancement. The Eleventh Circuit held that the district court did not clearly err in attributing the full drug quantity to the defendant because the relevant conduct included reasonably foreseeable acts of co-conspirators within the scope of the conspiracy. The court also held that the premises-maintaining enhancement could be based on co-conspirator conduct if it was reasonably foreseeable. The court affirmed the sentence. View "USA v. McLaurin" on Justia Law

Zurich American Insurance Co. v. First Solar Electric LLC

2026-10-22T09:00:50-08:00

First Solar Electric LLC was constructing a solar power plant in Georgia when five heavy rain events damaged the project. First Solar held a builders risk insurance policy with Zurich American Insurance Company, which covered both water and flood damage but applied different deductibles: $100,000 for water damage and $2.5 million for flood damage. Zurich initially determined the damage was water-related and issued three advance payments to First Solar, applying the lower deductible and not reserving rights to later change its determination. Subsequently, Zurich reversed its coverage decision, classified the events as floods, and asserted that the higher deductible applied, concluding First Solar’s losses did not exceed the deductible and closing the claim. The United States District Court for the Middle District of Georgia reviewed the dispute. It granted partial summary judgment to both parties, finding that, absent waiver, the flood deductible applied, but Zurich had waived its right to enforce the flood deductible for all events by its conduct. The court also ruled that the policy’s suit-against-the-company provision did not bar First Solar’s suit as untimely. The case proceeded to a jury trial solely on damages, after which the court denied Zurich’s motion to strike a damages witness and entered final judgment in favor of First Solar. On appeal, the United States Court of Appeals for the Eleventh Circuit held that: (1) Georgia law permits an insurer to waive a deductible provision that limits payment, but not coverage; (2) Zurich waived the flood deductible for the first three rain events by its unconditional payments and conduct, but a genuine factual dispute remains as to waiver for the last two events; (3) the suit-against-the-company provision is not a suit-limitation bar; (4) the district court did not abuse its discretion in denying sanctions; and (5) absent waiver, the flood deductible applies. The judgment was affirmed in part, vacated in part, and remanded for further proceedings. View "Zurich American Insurance Co. v. First Solar Electric LLC" on Justia Law

Pen American Center, Inc. v. Adams

2026-10-19T11:01:21-08:00

A group of parents, authors, a free speech organization, and a book publisher brought a lawsuit against a county school board, challenging the removal of certain library books from public school libraries. The school board had adopted policies, as required by Florida law, mandating the removal of materials deemed pornographic or describing sexual conduct, and established procedures for reviewing objections to specific books. After objections were raised to various titles, review committees and the superintendent made recommendations, and the school board ultimately voted to remove several groups of books based on its existing policies and a directive aligned with state guidelines. Prior to this appeal, the United States District Court for the Northern District of Florida considered whether members of the school board could claim legislative privilege to avoid being deposed about their reasons for voting to remove the books. The district court ruled that legislative privilege did not apply in this context, finding that the board members’ votes to remove specific books constituted administrative acts—applying established policy to particular facts—rather than legislative acts involving the creation or amendment of policy. The district court denied the board members’ motion for a protective order and subsequent motions to quash deposition subpoenas. The United States Court of Appeals for the Eleventh Circuit reviewed whether legislative privilege shielded the school board members from testifying about their decisions to remove the books. The Eleventh Circuit affirmed the district court, holding that the board members’ votes to remove specific books, as applications of existing policy to individual cases, were administrative rather than legislative acts. Therefore, legislative privilege did not bar their depositions regarding those specific removal decisions. The court emphasized its holding was limited to the particular facts of this case and did not address whether other privileges or rules might limit such discovery. View "Pen American Center, Inc. v. Adams" on Justia Law

NetChoice v. Attorney General, State of Georgia

2026-10-15T04:30:22-08:00

A recently enacted Georgia law restricts minors’ ability to create accounts on social media platforms. The statute requires covered platforms to verify users’ ages, prohibits minors under sixteen from creating accounts without parental consent, and limits how personal data may be used for advertising to minors. The law defines “social media platform” broadly, but includes numerous exceptions for platforms with different primary functions. An internet trade association, representing major social media companies, challenged the law before its effective date, arguing that it violates the First Amendment, is unconstitutionally vague, and is preempted by Section 230 of the Communications Decency Act. The United States District Court for the Northern District of Georgia granted a preliminary injunction, preventing enforcement of the law. The court found that the association had associational and third-party standing, that the law was likely a content-based speech restriction failing strict scrutiny, was unconstitutionally vague, and was preempted by federal law. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed whether the association had standing and whether it demonstrated a likelihood of success on the merits. The circuit court held that the association had associational standing to challenge the law on behalf of its members. However, the court concluded that the association failed to meet the burden required for a facial First Amendment challenge under the standard set forth in Moody v. NetChoice, LLC, because it did not adequately address the full range of the law’s applications and did not demonstrate that unconstitutional applications substantially outweighed constitutional ones. The court also found that the vagueness and Section 230 preemption claims were unlikely to succeed. The Eleventh Circuit affirmed the standing determination, vacated the preliminary injunction, and remanded the case for further proceedings. View "NetChoice v. Attorney General, State of Georgia" on Justia Law

Computer & Communications Industry Association v. Attorney General, State of Florida

2026-10-14T10:00:27-08:00

Florida enacted a statute (HB3) restricting minors’ access to social media platforms that employ certain “addictive features,” such as infinite scrolling, push notifications, and auto-play. Platforms meeting defined criteria—including algorithmic content selection and significant minor usage—must prohibit account creation by those under 14 and require parental consent for those aged 14–15. The Computer & Communications Industry Association and NetChoice, representing affected platforms, challenged the law on First Amendment grounds, asserting both facial and as-applied claims. The United States District Court for the Northern District of Florida initially denied a preliminary injunction for lack of associational standing, but after the plaintiffs amended their complaint and renewed their motion, the court granted a preliminary injunction. The district court found that the trade groups had standing, abstention under Younger v. Harris was unwarranted, and that although HB3 was a content-neutral regulation, it was insufficiently tailored to survive intermediate scrutiny, thus likely unconstitutional. On appeal, the United States Court of Appeals for the Eleventh Circuit first held that the plaintiffs had associational standing to challenge HB3 on behalf of their members. The court also determined that the district court properly declined to abstain under Younger because substantial proceedings had already occurred in federal court before the state enforcement action was initiated. Addressing the merits, the Eleventh Circuit concluded that HB3 is a content-neutral regulation implicating the First Amendment, but it likely survives intermediate scrutiny due to its age-based tailoring and focus on addictive features. The court rejected the facial challenge, holding that the plaintiffs had not demonstrated, as required by Moody v. NetChoice, LLC, that HB3’s unconstitutional applications substantially outweighed its constitutional ones. The disposition affirmed in part, reversed in part, vacated in part, and remanded for further proceedings. View "Computer & Communications Industry Association v. Attorney General, State of Florida" on Justia Law

USA v. Johnson

2026-10-14T06:00:25-08:00

A defendant was indicted in federal court for knowingly possessing a firearm as a convicted felon, in violation of 18 U.S.C. § 922(g)(1). He pleaded guilty to the charge. At sentencing, his presentence investigation report calculated a higher base offense level under the U.S. Sentencing Guidelines because of a prior Florida conviction for attempted manslaughter, which was treated as a “crime of violence.” The defendant also received enhancements for involvement with a stolen firearm and drugs, and a reduction for acceptance of responsibility. The recommended Guidelines range was 84 to 105 months. The defendant objected, arguing that his prior conviction was not a “crime of violence” and requested his federal sentence run concurrently with an expected state court sentence. The United States District Court for the Southern District of Florida overruled his objections, found that attempted manslaughter was a crime of violence, and imposed an 84-month sentence, to run consecutively to any state sentence. The court stated that it would have imposed the same sentence even if it had ruled differently on the Guidelines issue. The defendant appealed, challenging the crime of violence finding, the consecutive sentence, and raising a new constitutional challenge to § 922(g)(1). The United States Court of Appeals for the Eleventh Circuit held that the district court erred in finding Florida attempted manslaughter to be a “crime of violence” under the Guidelines, and that its statement about imposing the same sentence did not render the error harmless due to procedural timing. The court affirmed that it was not an abuse of discretion to impose a consecutive sentence and rejected the constitutional challenge, finding it foreclosed by precedent. The sentence was vacated, and the case was remanded for resentencing. View "USA v. Johnson" on Justia Law

USA v. Louis

2026-10-13T07:00:22-08:00

The defendant, after serving a prison sentence for a Florida felony drug offense, was released into the state's conditional release program. Three days post-release, he signed a certificate agreeing to various conditions, including submission to searches by his release supervisor. Shortly before his conditional release was scheduled to end, he tested positive for cocaine. The supervisor recommended a warrant for his arrest, which was issued by the Florida Commission on Offender Review. When officers executed the warrant at his residence, the supervisor conducted a warrantless search, finding drugs and a firearm. This led to federal charges including possession of a firearm by a convicted felon and possession with intent to distribute a controlled substance. The United States District Court for the Southern District of Florida denied the defendant’s motion to suppress evidence from the warrantless search, concluding he was still on conditional release at the time and that reasonable suspicion justified the search. The defendant then pleaded guilty to the firearm possession charge. During sentencing, the presentence investigation report recommended a mandatory minimum sentence under the Armed Career Criminal Act (ACCA), listing several prior Florida convictions as possible predicate offenses. The defendant objected, arguing both legally and factually that the convictions did not qualify and that the government had not proven their existence by a preponderance of the evidence. The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s denial of the motion to suppress, holding that the defendant was still subject to conditional release and that the search was supported by reasonable suspicion. However, the appellate court vacated the sentence, finding the district court erred by imposing the ACCA enhancement without requiring the government to prove the necessary predicate convictions. The case was remanded for resentencing without the ACCA enhancement. View "USA v. Louis" on Justia Law

Bolton v. Inland Fresh Seafood Corporation of America, Inc.

2026-10-13T07:00:21-08:00

A group of former employees participated in an employee stock ownership plan (ESOP) established by a seafood company. In 2016, the plan used borrowed funds to purchase all outstanding shares from several company officers and directors. The employees alleged that the purchase price was grossly inflated due to false financial projections, resulting in significant financial harm to the plan and its participants. The plaintiffs, on behalf of themselves and a proposed class, brought statutory claims under the Employee Retirement Income Security Act (ERISA), asserting breaches of fiduciary duty by the company’s officers, directors, trustee, and committee members. The United States District Court for the Northern District of Georgia dismissed the plaintiffs’ complaint, relying on Eleventh Circuit precedent from Mason v. Continental Group, Inc. and its progeny, which required administrative exhaustion of statutory ERISA claims before filing suit. The district court also denied the plaintiffs’ request to stay the proceedings to pursue administrative remedies, reasoning that both it and the parties were bound by the Eleventh Circuit’s exhaustion requirement. A panel of the Eleventh Circuit affirmed the dismissal, citing the binding nature of Mason. The United States Court of Appeals for the Eleventh Circuit, sitting en banc, reviewed the case and overruled Mason and related decisions to the extent that they held ERISA itself requires exhaustion of statutory claims, including breach of fiduciary duty claims. The court determined that ERISA does not impose such an exhaustion requirement and found that the plan at issue did not mandate exhaustion either. Accordingly, the Eleventh Circuit reversed the district court’s dismissal and remanded the case to the panel for further proceedings. View "Bolton v. Inland Fresh Seafood Corporation of America, Inc." on Justia Law

Hernandez v. Florida Board of Bar Examiners

2026-10-09T08:30:35-08:00

Two attorneys, licensed in New Jersey and Michigan, sought admission to the Florida Bar and challenged a Florida rule requiring applicants admitted to another bar for more than twelve months to pay a higher application fee. They argued that this "experienced-applicant" rule violated the dormant Commerce Clause by burdening out-of-state applicants both on its face and in practical effect. One attorney paid the fee and then sued, seeking a refund and an injunction; the other attorney did not pay and joined the suit to seek prospective relief. The United States District Court for the Northern District of Florida initially dismissed most claims for lack of standing or based on Eleventh Amendment immunity, but allowed a limited practical-effect claim against the executive director of the Florida Board of Bar Examiners. After further amendments and discovery, the district court denied summary judgment to the plaintiffs and granted summary judgment to the executive director, finding that the rule did not discriminate against out-of-state applicants in practice. The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that the Board of Bar Examiners is an arm of the state and therefore immune from suit under the Eleventh Amendment. As to the claim against the executive director, the court found that the experienced-applicant rule did not facially discriminate against out-of-state applicants, as it was based solely on years of admission, not geographic origin. The court further concluded that undisputed evidence showed the rule imposed similar burdens on both in-state and out-of-state applicants and was adopted for legitimate, non-protectionist reasons. The Eleventh Circuit affirmed the district court’s dismissal and summary judgment, holding that neither facial nor practical-effect dormant Commerce Clause claims could succeed. View "Hernandez v. Florida Board of Bar Examiners" on Justia Law

USA v. Brown

2026-10-08T06:30:47-08:00

The defendant participated in two armed robberies of auto-parts stores in Tampa, Florida, along with a co-defendant. Both men entered the stores wearing masks and brandishing handguns, demanding money from employees and directing them to lie down in the back of the stores while they made their escape. Surveillance footage and subsequent police investigation linked the defendant to the crimes, resulting in his arrest after officers found incriminating evidence in his vehicle. He was charged with two counts of Hobbs Act robbery, one count of conspiracy, and two counts of brandishing a firearm during a crime of violence. The case was first heard in the United States District Court for the Middle District of Florida. The defendant pleaded guilty to all counts except one firearm charge, which was dropped pursuant to a plea agreement. The government agreed to recommend a within-guidelines sentence, but reserved the right to provide relevant information and respond to the defendant’s comments. A pre-sentence investigation report recommended several sentencing enhancements, including a two-level enhancement for physically restraining victims. The district court imposed a sentence of 204 months (17 years), consisting of 120 months for the Hobbs Act charges and a consecutive 84 months for the brandishing charge, after varying upward from the guidelines range based on the defendant’s criminal history. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed three issues: alleged breach of the plea agreement, the propriety of the two-level physical restraint enhancement, and substantive reasonableness of the sentence. The court held that the government did not breach the plea agreement. However, it found that the district court plainly erred in applying the two-level enhancement, due to a recent, retroactively applicable amendment to the Sentencing Guidelines. The court vacated the sentence and remanded for resentencing, while affirming the convictions. View "USA v. Brown" on Justia Law

USA v. Chirino-Lovera

2026-10-08T06:00:40-08:00

Three defendants were apprehended by the United States Coast Guard while operating a go-fast vessel approximately 128 miles off the coast of Colombia. When detected, they attempted to flee and discarded 19 bales containing 623 kilograms of cocaine into the sea before being stopped. They were subsequently charged under the Maritime Drug Law Enforcement Act (MDLEA) for conspiracy and possession with intent to distribute cocaine on the high seas. In the United States District Court for the Southern District of Florida, the defendants moved to dismiss the indictment, arguing that the Coast Guard failed to establish U.S. jurisdiction because officers allegedly did not properly confirm that the vessel was “without nationality.” The district court held an evidentiary hearing, where Coast Guard Officer Balboa testified that he individually asked each defendant if they claimed nationality for the vessel, and all declined. The court credited Balboa’s testimony on this point, despite finding he had lied about other details, and concluded U.S. jurisdiction was established. The court denied constitutional and sentencing challenges, then sentenced each defendant to 96 months’ imprisonment, applying a guidelines enhancement for recklessly endangering others during their flight. The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that (1) the government must establish MDLEA jurisdiction by a preponderance of the evidence, not beyond a reasonable doubt; (2) the district court did not clearly err in crediting Balboa’s testimony that no claim of nationality was made, thus supporting jurisdiction; (3) the MDLEA is constitutional as applied; and (4) the sentencing enhancement for recklessly creating a substantial risk of serious bodily injury was properly applied. The Eleventh Circuit affirmed the convictions and sentences. View "USA v. Chirino-Lovera" on Justia Law

Martin v. USA

2026-10-07T11:30:44-08:00

Federal agents executed a pre-dawn raid targeting a gang member in Atlanta, but mistakenly entered the plaintiffs’ residence, three houses away from the intended address and on a different street. The FBI SWAT team forcibly entered, detonated a flash-bang grenade, and detained the plaintiffs, including a minor, before realizing their error and departing. The raid’s leader, Agent Guerra, later attributed the mistake to his personal GPS device, which he discarded shortly after the incident. Plaintiffs disputed the adequacy of pre-raid preparations and alleged multiple torts and constitutional violations. The plaintiffs filed suit in the United States District Court for the Northern District of Georgia, asserting claims against the United States under the Federal Tort Claims Act (FTCA) for false arrest, assault and battery, trespass, emotional distress, and negligence, as well as a Bivens claim against Agent Guerra and others for Fourth Amendment violations. The district court granted summary judgment to the United States on most FTCA claims under the discretionary-function exception, and to Agent Guerra on the Bivens claim based on qualified immunity. After an intervening Eleventh Circuit decision, the district court granted judgment to the government on the remaining FTCA claims. On appeal, the United States Court of Appeals for the Eleventh Circuit was instructed by the Supreme Court (following Martin v. United States, 605 U.S. 395 (2025)) to re-examine whether the FTCA’s discretionary-function exception barred the plaintiffs’ claims. The Eleventh Circuit held that the discretionary-function exception shielded the United States from all FTCA claims arising from the raid and affirmed their dismissal. However, the court reversed the grant of qualified immunity to Agent Guerra, finding that, when viewing the evidence most favorably to the plaintiffs, his actions violated clearly established Fourth Amendment law. The case was remanded for further proceedings consistent with these holdings. View "Martin v. USA" on Justia Law

Tate v. Warden GDCP

2026-09-30T11:00:55-08:00

In December 2001, a 21-year-old man and his two younger brothers planned and carried out the murders of a woman, Chrissie Williams, and her three-year-old daughter, Katelyn, in Georgia. The crime involved home invasion, use of weapons, and acts of extreme violence and sexual assault. After fleeing the state and being apprehended, the brothers entered plea agreements: the two younger brothers received life sentences with parole eligibility, while the petitioner, after initially negotiating for a similar deal, ultimately rejected a plea offer and decided to plead guilty, influenced by religious beliefs that demanded confession and acceptance of the death penalty. The Superior Court of Paulding County accepted the petitioner’s guilty plea and, following a bench sentencing trial at his request, imposed the death penalty. The Georgia Supreme Court affirmed his convictions and sentences on direct appeal. After a failed “next friend” habeas attempt by a brother, the petitioner filed his own state habeas petition, arguing ineffective assistance of counsel and other constitutional violations. While the state habeas court initially granted relief on the sentencing, the Georgia Supreme Court reversed, reinstating the death sentence. The petitioner then pursued federal habeas relief in the United States District Court for the Northern District of Georgia, which denied relief but granted a certificate of appealability on selected claims. The United States Court of Appeals for the Eleventh Circuit reviewed the case and held that the Georgia Supreme Court’s denial of the petitioner’s claims was not an unreasonable application of clearly established federal law or an unreasonable determination of the facts. The court found that trial counsel’s recommendation to waive a jury for sentencing was reasonable, that no prejudice resulted from counsel’s alleged failure to investigate mitigating evidence due to the petitioner’s own instructions, and that the prosecution’s use of alternative theories in codefendants’ proceedings did not violate constitutional rights. The district court’s denial of habeas relief was affirmed. View "Tate v. Warden GDCP" on Justia Law

Edwards v. Randolph County Sheriff

2026-09-28T12:31:00-08:00

A woman was arrested in Randolph County, Alabama, under a system that required arrestees to pay a predetermined bail amount based on the charged offense for immediate release. Those unable to pay had to wait until an initial appearance, which could take up to three days, and frequently did not result in a release determination. Instead, release decisions were often deferred until a preliminary hearing up to four weeks later. The plaintiff, unable to afford bail, filed a class action alleging that the county’s bail practices discriminated against indigent individuals and violated their constitutional rights. The United States District Court for the Middle District of Alabama initially granted a temporary restraining order, releasing the plaintiff. While the case was pending, Randolph County adopted a new, more permissive bail policy. Defendants moved to dismiss the case as moot, arguing the new policy ended the challenged conduct. The district court certified a class of arrestees unable to pay secured bail, but after the Supreme Court denied certiorari in a similar case, Schultz v. Alabama, the district court dismissed most claims as moot, limiting plaintiffs to facial challenges against the new policy, and concluded those remaining claims failed to state a plausible claim for relief. The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s dismissal. The court held that the voluntary cessation doctrine precludes defendants from mooting the case simply by changing the bail policy during litigation. The class may proceed with facial and as-applied challenges to the prior bail practices, as well as as-applied challenges to the current bail practices. However, the court affirmed the district court’s dismissal of facial challenges to the current bail policy. The case was remanded for further proceedings consistent with these holdings. View "Edwards v. Randolph County Sheriff" on Justia Law

Callaway v. Adcock

2026-09-22T07:00:51-08:00

A man in his early thirties, who had recently undergone brain surgery for an aggressive form of cancer and was experiencing severe side effects, including irrational and violent behavior, began acting erratically at a rural Alabama home where he was living with family. On the day of the incident, he stopped taking his medications, engaged in increasingly disturbing behavior, damaged property, and physically threatened those around him. After he shattered the window of a sheriff’s vehicle and the windshield of an ambulance, law enforcement was summoned. A deputy attempted to subdue him with a taser, which failed, and was then pursued by the man. The man chased the deputy onto the property of a nearby police captain, who had been alerted to the disturbance and came outside to assist. The United States District Court for the Middle District of Alabama previously reviewed the case. The estate of the deceased sued the police captain under 42 U.S.C. § 1983, claiming excessive use of deadly force in violation of the Fourth Amendment. The district court granted summary judgment for the officer, finding he was entitled to qualified immunity because a reasonable officer could have believed the use of deadly force was necessary under the circumstances. The United States Court of Appeals for the Eleventh Circuit reviewed the case on appeal. The court examined the facts from the perspective of the officer on the scene, emphasizing the man’s violent, erratic conduct, the ineffectiveness of non-lethal force, and the officer’s reasonable perception of a serious physical threat. The Eleventh Circuit held that the use of deadly force did not violate the Fourth Amendment because a reasonable officer could have concluded such force was necessary to prevent serious physical harm or death. The court affirmed the district court’s judgment in favor of the officer. View "Callaway v. Adcock" on Justia Law

USA v. Gibbs

2026-09-17T08:31:01-08:00

A software company managing cloud storage accounts detected that a user had uploaded material suspected to be child sexual abuse content. As required by federal law, the company reported this to the National Center for Missing and Exploited Children (NCMEC), which in turn forwarded a CyberTip containing the information, including the suspect’s phone number, to law enforcement. A detective from the Tallahassee Police Department reviewed the CyberTip and submitted an affidavit to a Florida state court judge to obtain a warrant to search the suspect’s cloud account. The affidavit referenced the reliability of NCMEC’s processes and the detective’s experience, but did not describe the alleged illicit images. The warrant was granted, and the subsequent search uncovered child sexual abuse images. Further investigation led to the identification of a victim and the arrest of the suspect, who was later charged federally. The defendant moved in the United States District Court for the Northern District of Florida to suppress the evidence, arguing that the search warrant affidavit lacked probable cause and that the good faith exception to the exclusionary rule did not apply. The district court agreed, finding that the affidavit was too vague and conclusory, lacking sufficient details to support probable cause or reasonable reliance. As a result, the court suppressed all evidence obtained from the searches. On appeal, the United States Court of Appeals for the Eleventh Circuit considered whether the good faith exception to the exclusionary rule applied, assuming without deciding that the affidavit was deficient in establishing probable cause. The court held that the affidavit contained enough indicia of probable cause, particularly due to the general trustworthiness of NCMEC’s CyberTip program and the detective’s reasonable reliance on established procedures. Therefore, the court reversed the district court’s suppression order and remanded for further proceedings. View "USA v. Gibbs" on Justia Law

Mueller v. Walmart Corporation

2026-09-16T05:30:47-08:00

Todd Mueller was shopping at a Walmart in Duluth, Georgia, when store employee Brandon Burston suspected him of shoplifting and surveilled him. After Mueller checked out, Burston and another associate approached him, resulting in a disputed encounter that led Mueller to exit through a rear entrance. Police pursued and arrested Mueller for obstruction of justice, and Burston later applied for a shoplifting warrant. Mueller also filed assault claims with police, but an additional warrant was issued against him for filing a false report. Ultimately, Mueller faced charges for obstruction, shoplifting, and filing a false police report. The district attorney declined to prosecute the false-report charge, negotiated a plea for obstruction resulting in probation, and dropped the shoplifting charge, with the parties disputing whether the latter was connected to the plea deal. Mueller initially sued Walmart and Burston in the United States District Court for the Northern District of Georgia, asserting federal civil-rights claims under 42 U.S.C. §§ 1981 and 1982, as well as various state-law claims including false arrest, false imprisonment, malicious prosecution, assault, and battery. Mueller abandoned the federal claims, which the district court dismissed. The court exercised supplemental jurisdiction over the false-arrest, false-imprisonment, and malicious-prosecution claims, granting summary judgment in favor of the defendants, but declined jurisdiction over the assault and battery claims, dismissing them. The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that district courts have broad discretion under 28 U.S.C. § 1367(c) to exercise supplemental jurisdiction over some, but not all, state-law claims after federal claims are dismissed. The court affirmed the district court’s jurisdictional decisions but reversed the summary judgment on Mueller’s malicious-prosecution claim, concluding that a reasonable jury could find in Mueller’s favor regarding favorable termination of the shoplifting charge. The case was remanded for further proceedings. View "Mueller v. Walmart Corporation" on Justia Law

Martin v. Commissioner, Alabama Department of Corrections

2026-09-14T08:01:16-08:00

A former Alabama State Trooper was accused of murdering his wife, allegedly staging a car accident to collect life insurance proceeds. The prosecution's case was circumstantial, relying heavily on witness testimony and evidence suggesting financial motive. After initially failing to indict, the Alabama Attorney General’s Office pursued the case, resulting in the trooper’s conviction and a sentence of death. However, a lengthy series of postconviction proceedings revealed that the prosecution had committed several Brady violations, including withholding exculpatory evidence that implicated alternative suspects and supported the defense’s theory. This led to the trial court granting a new trial and later dismissing the indictment with prejudice due to willful prosecutorial misconduct, a decision eventually reversed by the Supreme Court of Alabama, which ordered a second trial. During the second trial, the new trial judge issued a preclusion order barring mention of prior prosecutorial misconduct or the procedural history. The defendant argued this order violated his constitutional rights, specifically the Confrontation Clause and his right to present a complete defense. He was again convicted of capital murder for pecuniary gain and sentenced to life without parole. The Alabama Court of Criminal Appeals affirmed, and the Supreme Court of Alabama denied certiorari. The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s denial of habeas relief. The court held that, although Alabama’s misconduct was egregious, the limitations imposed by the Antiterrorism and Effective Death Penalty Act (AEDPA) prevented granting habeas relief. The Eleventh Circuit found no procedural default, but ruled that neither the preclusion order nor the sufficiency of the evidence claim warranted relief under AEDPA’s standards. The district court’s judgment denying habeas relief was affirmed. View "Martin v. Commissioner, Alabama Department of Corrections" on Justia Law

USA v. Olson

2026-09-09T10:31:10-08:00

Police officers in Miami-Dade surveilled a house known for prior drug activity and a recent drive-by shooting. They observed Olson Joseph getting a haircut on the front lawn and later noticed he was carrying a concealed handgun in his sweatshirt pocket. The officers detained Joseph at gunpoint, removed the firearm, and conducted records checks, revealing Joseph was a felon without a concealed-carry permit. About twenty minutes after the stop, Joseph was transported to the station. He was subsequently charged in federal court with possession of a firearm and ammunition by a felon in violation of 18 U.S.C. § 922(g)(1). The United States District Court for the Southern District of Florida denied Joseph’s motion to dismiss the indictment, rejecting his argument that § 922(g)(1) violated the Second Amendment. The court also denied his motion to suppress the gun, finding the encounter was a Terry stop and that the officers had reasonable suspicion based on Joseph’s gun possession, his presence in a high-crime area, and proximity to a house associated with a recent homicide and drug activity. Joseph entered a conditional guilty plea, preserving his right to appeal the suppression ruling. The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that, under circuit precedent, § 922(g)(1) does not violate the Second Amendment and affirmed denial of the motion to dismiss. However, the court found that the officers lacked reasonable suspicion for the stop, since Florida’s 2015 concealed-carry statute amendment made carrying a concealed weapon presumptively lawful, and Joseph’s conduct did not indicate criminal activity. The court vacated Joseph’s conviction, reversed the partial denial of the suppression motion, and remanded for further proceedings. View "USA v. Olson" on Justia Law

USA v. Brown

2026-09-09T08:30:45-08:00

Rodney Brown was charged with Hobbs Act robbery and brandishing a firearm during a crime of violence after he robbed a convenience store, threatening a cashier and her son, and stealing money and personal items. The robber left a soda bottle at the scene, which, along with a mask found nearby, was tested for DNA. Law enforcement obtained Brown’s DNA and had it analyzed by a private lab. At trial, a DNA analyst from the lab testified that Brown’s DNA matched the evidence, but the analyst had not personally performed the hands-on lab work generating the DNA profiles. In the United States District Court for the Southern District of Florida, a jury found Brown guilty on both counts. At sentencing, the court classified Brown as a career offender under the United States Sentencing Guidelines, using the 2023 version of the Guidelines, which treated Hobbs Act robbery as a crime of violence. This resulted in an increased sentencing range, and Brown was sentenced to 324 months in prison. On appeal to the United States Court of Appeals for the Eleventh Circuit, Brown argued for the first time that his Confrontation Clause rights were violated by the DNA analyst’s testimony, and that the Ex Post Facto Clause was violated when the district court used a later version of the Guidelines Manual. The Eleventh Circuit held that the district court did not plainly err in permitting the DNA analyst’s testimony, since the analyst independently reviewed and analyzed the DNA profiles and did not merely act as a surrogate for other lab personnel. However, the court found plain error in sentencing Brown under the 2023 Guidelines Manual, as the offense occurred before the relevant amendment. The court affirmed Brown’s convictions, vacated his sentence, and remanded for resentencing under the correct Guidelines version. View "USA v. Brown" on Justia Law

Williams v. Board of Regents of the University System of Georgia

2026-09-04T04:31:00-08:00

Dr. Lesley Williams, a second-year anesthesiology resident at Augusta University, experienced a traumatic assault and was subsequently diagnosed with PTSD. She requested modified duties and accommodations, but the residency program placed her in observer roles and required fitness-for-duty evaluations. Williams filed complaints regarding denial of academic credit and alleged discrimination based on sex and disability. Faculty raised concerns about her professionalism, clinical judgment, and exam conduct. Williams was suspended and ultimately terminated from the residency program after loss of clinical privileges, but an ad hoc committee initially recommended reinstatement with zero tolerance for further unprofessional behavior. Following further faculty concerns, Williams was again suspended and terminated. Williams appealed her termination through Augusta University’s internal procedures. The ad hoc committee found her clinical evaluations were generally adequate, but noted serious concerns about exam misconduct. Dean Hess ordered her reinstatement with strict conditions, but after additional negative evaluations and faculty meetings, Williams was suspended and terminated for patient safety reasons. She appealed to the University President and the Board of Regents of the University System of Georgia, both of whom upheld her termination. The United States Court of Appeals for the Eleventh Circuit reviewed the district court's grant of summary judgment in favor of the Board of Regents on Williams’s claims, which included sex discrimination, retaliation, disability discrimination, whistleblower retaliation, denial of procedural due process, and breach of contract. The Eleventh Circuit held that Williams failed to establish the required elements for each claim, including the lack of similarly situated comparators, absence of evidence supporting discriminatory or retaliatory intent, and insufficient support for procedural or contractual violations. The court affirmed the district court’s grant of summary judgment on all claims. View "Williams v. Board of Regents of the University System of Georgia" on Justia Law

Russo v. Secretary, U.S. Department of Commerce

2026-09-03T06:01:02-08:00

Two commercial fishermen and their family business challenged federal regulations that reduced catch limits for gag grouper in the Gulf of Mexico, a fish central to their livelihood. The fishermen argued that the Gulf of Mexico Fishery Management Council, which played a key role in proposing the catch limits and regulatory framework, was unconstitutionally composed and shielded from removal, violating the Appointments Clause and other constitutional provisions. Their complaint alleged significant financial harm resulting from the reduced catch limits. The United States District Court for the Southern District of Alabama found that certain powers granted to the Council—specifically, three statutory “veto” provisions that allow the Council to block actions by the Secretary of Commerce—rendered Councilmembers “officers” wielding significant federal authority. It determined their appointments violated the Appointments Clause because they were not properly appointed as principal officers. However, instead of vacating the catch limit rule, the district court severed the unconstitutional veto provisions from the governing statute and entered judgment for the plaintiffs. On appeal, the United States Court of Appeals for the Eleventh Circuit largely agreed that the Council’s veto powers confer significant authority, so Councilmembers’ appointments as currently structured are constitutionally deficient. However, the Eleventh Circuit held that the remedy should be limited to invalidating actions taken with those veto powers. Because the gag grouper rule was not promulgated using the Council’s unconstitutional veto authority but rather through an advisory process ratified by the Secretary, the rule itself was not tainted. The court vacated the district court’s judgment for the plaintiffs and remanded for entry of judgment in favor of the government, concluding that vacatur of the challenged rule was unwarranted. View "Russo v. Secretary, U.S. Department of Commerce" on Justia Law

Filipowski v. Commissioner of Internal Revenue

2026-09-02T06:31:20-08:00

Andrew Filipowski, a software entrepreneur, accumulated significant tax liability after selling his company for $3.5 billion in 1999 and claiming $110 million in losses through a partnership later deemed a sham by the U.S. Tax Court. The IRS assessed Filipowski’s individual tax liability, including taxes, penalties, and interest totaling approximately $140 million. Filipowski did not challenge the notice of deficiency or the amount owed, nor did he make substantive payments toward the liability, aside from applying a minor tax credit. When the IRS initiated collection proceedings, Filipowski sought a Collection Due Process hearing, indicating his inability to pay and offering an installment agreement or an offer-in-compromise (OIC). After receiving Filipowski’s OIC proposing to settle his tax debt for $1.5 million, the IRS’s collections department investigated his finances. The investigation raised concerns about Filipowski’s connections to the DePasquale Trust, delayed tax filings, and alleged undisclosed assets. The IRS calculated his reasonable collection potential as $5.9 million, which was less than the owed amount but still higher than the OIC. The IRS ultimately rejected the OIC on public policy grounds, reasoning that acceptance would undermine voluntary compliance. Filipowski challenged this decision in the U.S. Tax Court, arguing that disputed facts remained and that summary judgment was inappropriate. The Tax Court granted summary judgment in favor of the IRS, concluding that the rejection was supported by Filipowski’s tax history and the magnitude of his liability. The United States Court of Appeals for the Eleventh Circuit reviewed the Tax Court’s grant of summary judgment de novo. It held that the IRS did not abuse its discretion in rejecting Filipowski’s OIC on public policy grounds and affirmed the Tax Court’s decision, finding no genuine disputes of material fact that would preclude summary judgment. View "Filipowski v. Commissioner of Internal Revenue" on Justia Law

Zafirov v. Florida Medical Associates, LLC

2026-09-01T12:00:58-08:00

A physician brought a lawsuit on behalf of the United States under the False Claims Act (FCA), alleging that her employer and associated healthcare entities knowingly submitted false diagnosis codes to Medicare in order to obtain inflated payments. The case proceeded for several years. In February 2024, the defendants sought judgment on the pleadings or dismissal, arguing that the FCA’s qui tam provisions—which allow private individuals (relators) to sue on behalf of the government—violated the Constitution’s Appointments Clause, Take Care Clause, and Vesting Clause. The United States District Court for the Middle District of Florida granted the defendants’ motion, concluding that the qui tam provisions violated the Appointments Clause. The district court reasoned that relators are “officers of the United States” because they exercise significant federal authority and occupy a continuing position established by law, but are not appointed by the President as required by Article II. The court dismissed the case, finding the relator lacked authority to proceed on behalf of the United States, and did not address the other constitutional arguments. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s constitutional analysis de novo. The Eleventh Circuit disagreed with the lower court’s conclusion, holding that relators under the FCA are not officers of the United States because they do not occupy a continuing position established by law. The court explained that relators’ roles are temporary, personal, and lack a continuing emolument or transferable duties. Therefore, the FCA’s qui tam provisions do not violate the Appointments Clause. The Eleventh Circuit vacated the district court’s dismissal and remanded the case for consideration of the remaining constitutional arguments. View "Zafirov v. Florida Medical Associates, LLC" on Justia Law

Guthrie v. Coal Bed Services Inc.

2026-09-01T11:31:00-08:00

Two Black employees, Hall and Hughes, worked as laborer-operators for Coal Bed Services, Inc., a subsidiary of Pate Holdings, Inc. They complained to their supervisor about alleged racially discriminatory conduct by another supervisor. About a month later, Hall and Hughes were fired after refusing a drug test on a jobsite. A White coworker, Ramsey, also refused the same test and was initially terminated, but was later allowed to return to work under conditions not imposed on Hall and Hughes. The company paid Ramsey for a full shift but only paid Hall and Hughes for the hours worked. Subsequent hires for their positions were White employees, including one previously fired for failing a drug test. Hall and Hughes alleged these events were motivated by racial discrimination and retaliation. The United States District Court for the Northern District of Alabama granted summary judgment in favor of the defendants, Coal Bed Services and Pate Holdings, on all claims. Hall and Hughes had brought four claims: two under Title VII (race discrimination and retaliation) against Coal Bed Services, and two under 42 U.S.C. § 1981 (race discrimination and retaliation) against both companies. The district court found, among other things, that the White coworker was not a valid comparator under the McDonnell Douglas framework and concluded that Hall and Hughes could not establish causation for their retaliation claims. The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo. It determined that there was a genuine issue of material fact regarding whether the companies discriminated and retaliated against Hall and Hughes. The court held that circumstantial evidence, viewed in the light most favorable to the plaintiffs, was sufficient for a reasonable jury to infer intentional discrimination and retaliation under both Title VII and § 1981. The Eleventh Circuit reversed the district court’s summary judgment and remanded for further proceedings. View "Guthrie v. Coal Bed Services Inc." on Justia Law

USA v. Smith

2026-08-28T10:00:54-08:00

Reginald Smith, previously convicted of multiple cocaine-related felonies in Florida state court, was arrested in December 2019 after officers investigating illegal hunting found him holding a loaded shotgun. During a search, officers discovered additional ammunition, a hunting knife, and MDMA pills. An agent determined that Smith’s shotgun had traveled in interstate commerce, having been manufactured outside Florida. Smith, as a result, was indicted for possession of a firearm as a felon under 18 U.S.C. § 922(g)(1) and possession of MDMA under 21 U.S.C. § 844(a). He pleaded guilty to both counts. The United States District Court for the Middle District of Florida reviewed Smith’s prior convictions to determine whether they triggered the mandatory minimum sentence under the Armed Career Criminal Act (ACCA), 18 U.S.C. § 924(e). The court considered evolving precedent—including United States v. Conage and United States v. Jackson—regarding whether certain Florida drug crimes qualified as “serious drug offenses” under ACCA. After law developments clarified that Smith’s two 1993 convictions for selling cocaine and his 2001 conviction for trafficking cocaine were ACCA predicates under Eleventh Circuit precedent, the court applied the ACCA enhancement. Smith was sentenced to 180 months’ imprisonment for the firearm count and 12 months for MDMA possession, to run concurrently. Smith objected to the ACCA enhancement but acknowledged its applicability under current circuit law. The United States Court of Appeals for the Eleventh Circuit affirmed Smith’s conviction and sentence. The court held that § 922(g)(1) did not violate the Second Amendment or Commerce Clause, Smith invited any error regarding ACCA classification of his convictions, the district court’s error under Erlinger v. United States did not affect Smith’s substantial rights, and any error in calculating his base offense level under the Sentencing Guidelines was harmless. View "USA v. Smith" on Justia Law

Acevedo v. de la Portilla

2026-08-26T09:31:03-08:00

A city’s Chief of Police was recruited for his reformist reputation and soon after his arrival, he observed and reported that several City Commissioners were improperly interfering in police investigations and using police resources to pursue personal vendettas. The Chief communicated his concerns to the Mayor and City Manager, and, believing himself unable to investigate the Commissioners due to a prior City resolution, he sent a whistleblowing memorandum detailing abuses of power to the Mayor, City Manager, the State Attorney’s Office, and the FBI. The memo was subsequently leaked to the media. Following this, the Chief faced public criticism from the Commissioners, had his job responsibilities undermined, was suspended with pay by the City Manager pending a termination hearing, and was ultimately terminated by the City Commission. The Chief filed suit in the United States District Court for the Southern District of Florida against three Commissioners and the City Manager, alleging retaliation for protected First Amendment activity under 42 U.S.C. § 1983. The individual defendants moved to dismiss, asserting legislative and qualified immunity. The district court denied their motions, finding that neither defense shielded the Commissioners or the City Manager at that stage. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s denial of immunity de novo. The Eleventh Circuit held that the Commissioners were not entitled to legislative immunity because terminating an employee is administrative, not legislative, action. The court further held that the Commissioners were not entitled to qualified immunity at the pleading stage because, accepting the complaint’s allegations as true, the Chief’s whistleblower memo was constitutionally protected speech, and binding precedent clearly established that retaliating against such speech is unlawful. However, the court held that the City Manager was entitled to qualified immunity, as it was not clearly established that suspending the Chief with pay, pending further proceedings, constituted an adverse employment action. The panel affirmed the denial of immunity for the Commissioners, reversed as to the City Manager, and remanded for further proceedings. View "Acevedo v. de la Portilla" on Justia Law

All Does v. Conrad & Scherer, LLP

2026-08-26T07:30:58-08:00

A group of Colombian plaintiffs retained two attorneys under a contingency fee agreement to sue a multinational corporation for allegedly funding a paramilitary group that murdered their relatives. The agreement specified that the attorneys would receive one-third of any monetary award obtained before trial. A conflict soon arose between the attorneys after one joined a law firm, leading to disputes over representation and eventual court intervention. The case was consolidated into multidistrict litigation in the United States District Court for the Southern District of Florida, and over time, one attorney was discharged, with the court instructing the discharged attorney’s firm to file a charging lien to preserve its claim for fees and costs. After a settlement was reached that allocated $12.8 million to the plaintiffs and their counsel, the discharged firm moved to enforce its charging lien against the attorney’s share of the recovery. The district court referred the motion to a magistrate judge, who recommended nearly full payment to the firm. The district court adopted this recommendation, ordered the disputed funds to be held in the court registry pending appeal, and required that the funds not be disbursed until appellate review was exhausted. The United States Court of Appeals for the Eleventh Circuit reviewed whether it had jurisdiction to hear an interlocutory appeal of the district court’s order enforcing the charging lien. The Eleventh Circuit held that such orders do not fall within the collateral-order doctrine because they do not resolve important issues separate from the merits and are not effectively unreviewable after final judgment. The court explained that attorneys’ contractual or equitable rights to payment do not implicate substantial public interests or values of a high order and can be adequately reviewed after final judgment. Accordingly, the Eleventh Circuit dismissed the appeal for lack of appellate jurisdiction. View "All Does v. Conrad & Scherer, LLP" on Justia Law

Doe v. Carnival Corporation

2026-08-25T12:01:05-08:00

A passenger aboard a cruise ship alleged that, after becoming inebriated, she was separated from her friends and ended up in a maintenance closet with a crewmember. She stated that she was held against her will and sexually assaulted. Both she and the crewmember gave differing accounts of the incident to FBI agents: she could not recall if she consented to sexual conduct, while the crewmember claimed it was consensual and that he did not know she was intoxicated. The FBI investigator ultimately concluded the encounter was consensual, and prosecutors declined to bring criminal charges. The passenger brought suit in the United States District Court for the Southern District of Florida asserting claims including false imprisonment and sexual assault. In pretrial proceedings, the district court granted her motion for partial summary judgment on the issue of false imprisonment liability, finding that the cruise line had not produced admissible evidence to create a dispute of material fact. The district court excluded the FBI reports as hearsay. At trial, the district court instructed the jury that the cruise line was already liable for false imprisonment and limited the ability of the defendant to challenge the factual basis for that claim. The jury found the cruise line liable for sexual assault but rejected the negligence and intentional infliction of emotional distress claims, awarding over $10 million in damages. On appeal, the United States Court of Appeals for the Eleventh Circuit held that the district court erred in granting partial summary judgment on false imprisonment and in excluding the FBI investigator’s conclusions, which were admissible under the public records exception to the hearsay rule. The appellate court reversed the partial summary judgment on the false imprisonment claim, vacated the judgment as to the false imprisonment and sexual assault claims, and remanded for a new trial on those claims. The negligence and intentional infliction of emotional distress claims remain resolved in favor of the cruise line. View "Doe v. Carnival Corporation" on Justia Law

Ellis v. Sheriff, Hillsborough County Florida

2026-08-25T09:01:03-08:00

After his termination from the Hillsborough County Sheriff’s Office, Jeremy Ellis, who had worked there since 2007 and as a detention deputy since 2010, filed suit against the Sheriff in his official capacity. Ellis claimed he was fired in retaliation for filing charges of discrimination with both the EEOC and the Florida Commission on Human Relations, which alleged disability and religious discrimination. The Sheriff's Office conducted an internal investigation after Ellis's EEOC filing, focusing on alleged falsehoods and disparagement found in his charge, and asserted his termination was based on these false statements, along with a procedural infraction regarding address notification. Evidence at trial showed that Ellis’s drinking and his statements during the investigation were also considered, but the termination notice expressly cited the EEOC charge as the basis for dismissal. The United States District Court for the Middle District of Florida heard the case. At trial, both sides presented evidence regarding the motivations for Ellis's termination. The jury found in Ellis’s favor on both his retaliation claims under Title VII and Florida law, awarding him significant damages. After the verdict, the Sheriff moved for judgment as a matter of law, arguing insufficient evidence of causation, and separately for a new trial, contending the jury was improperly instructed that an employer cannot fire an employee for statements in an EEOC charge, even if false. The district court denied both motions. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s jury instruction and its denial of judgment as a matter of law. The appellate court held that, under binding precedent, an employer may not terminate an employee for statements made in an EEOC charge, even if believed false, and found sufficient evidence supported the jury’s finding of retaliatory motive. Accordingly, the Eleventh Circuit affirmed the district court’s rulings. View "Ellis v. Sheriff, Hillsborough County Florida" on Justia Law

Burton v. Espino

2026-08-25T05:30:52-08:00

A Florida state inmate alleged that he was severely beaten by prison guards on two occasions and subsequently experienced seizures and ongoing pain in his head, hand, and ribs. After the assaults, he sought medical care and was treated for his head wound by staff, but further injuries were not assessed. When he was later evaluated by a prison doctor, he claimed the doctor refused to provide meaningful treatment for his injuries and dismissed his complaints, allegedly in retaliation for grievances the inmate had filed against him. Over the following months, the inmate’s hand injury worsened, and a later orthopedic evaluation confirmed a deformity that required physical therapy. Despite this recommendation, the doctor again refused treatment, allegedly referencing the inmate’s previous grievances as the reason. The United States District Court for the Middle District of Florida granted summary judgment in favor of the doctor, finding that he was not deliberately indifferent to the inmate’s medical needs and had not retaliated against him for filing grievances. The district court concluded that the doctor neither acted with subjective recklessness nor denied medical care for retaliatory reasons. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed whether genuine disputes of material fact precluded summary judgment. The appellate court found that, crediting the inmate’s verified complaint, there was sufficient evidence for a reasonable jury to find that the doctor was deliberately indifferent to serious medical needs regarding both the head and hand injuries, and that he acted with retaliatory motive in denying care after grievances were filed. The Eleventh Circuit reversed the district court’s summary judgment decision and remanded the case for further proceedings, holding that the inmate’s claims should proceed to a jury. View "Burton v. Espino" on Justia Law

USA v. Thompson

2026-08-24T12:30:56-08:00

A former stadium control room engineer for the Jacksonville Jaguars, who had previously been convicted of child sexual abuse, was suspected of interfering with the stadium’s videoboards after his contract was terminated. Investigators traced unauthorized access to the videoboard computer network to him, and a subsequent FBI search uncovered large volumes of child pornography as well as evidence that he had produced exploitive material involving children. When he learned of the investigation, he fled abroad but was eventually returned to the United States. He faced a ten-count indictment including charges related to child pornography, enticement of minors, computer intrusion, sex offender registration violations, and firearm possession as a felon. The case was first reviewed by the United States District Court for the Middle District of Florida. The defendant chose to represent himself at trial after a Faretta hearing in which he was informed of the risks of self-representation; standby counsel was appointed. Over the course of the proceedings, he challenged the validity of the search warrant, sought to suppress evidence, and requested certain discovery and a trial continuance, all of which were denied. He also objected to a child victim testifying by closed-circuit television, but the court allowed it after making the necessary findings. The jury convicted him on all counts, and he received a sentence of 2,640 months in prison followed by supervised release. The United States Court of Appeals for the Eleventh Circuit reviewed the appeal. It held that the defendant’s waiver of counsel remained valid after new charges were added, that the district court did not err in allowing the child witness to testify remotely, and that the denial of the defendant’s motions for discovery, continuance, and suppression of evidence was proper. The court also upheld the validity of the search warrant and the denial of subpoenas for a Franks hearing. The Eleventh Circuit affirmed the convictions and sentence. View "USA v. Thompson" on Justia Law

USA v. Miller

2026-08-24T11:00:52-08:00

Over a two-week period, the defendant entered four financial institutions in Florida, presenting notes to tellers demanding money. The notes did not explicitly threaten violence and were sometimes phrased politely. In two instances, the defendant succeeded in obtaining cash; in the other two, he left without money. The tellers’ responses varied: some felt intimidated, while others initially perceived the acts as non-threatening but later reconsidered after the defendant’s actions, such as staring and insisting on the return of his note. Law enforcement arrested the defendant the same day as the last incident. The United States District Court for the Southern District of Florida indicted the defendant on two counts of attempted credit-union robbery, one count of credit-union robbery, and one count of bank robbery, all under 18 U.S.C. § 2113(a). At trial, the defendant moved for judgment of acquittal under Rule 29, arguing that the government failed to prove intimidation, a required element of the offenses. The district court denied the motion, referencing persuasive authority that a demand for money alone can constitute intimidation, and found sufficient evidence based on trial testimony. The jury convicted the defendant on all counts, and he timely appealed. The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo. The court held that, in the context of a suspected bank robbery, a demand for cash from a teller—whether verbal or written, threatening or polite—provides sufficient evidentiary grounds to affirm a jury’s finding of intimidation under 18 U.S.C. § 2113(a). The court concluded that the defendant’s actions satisfied the intimidation requirement for both completed and attempted offenses. Accordingly, the Eleventh Circuit affirmed the convictions. View "USA v. Miller" on Justia Law

Ramdial v. U.S. Attorney General

2026-08-21T11:03:34-08:00

A lawful permanent resident originally from Trinidad and Tobago was convicted in a Florida state court of robbery by sudden snatching, along with several drug offenses. The Department of Homeland Security initiated removal proceedings, charging him as removable for committing an aggravated felony, specifically a theft offense for which the term of imprisonment was at least one year. The individual sought cancellation of removal but was found removable by an Immigration Judge (IJ) based on his convictions. The IJ also held that his robbery by sudden snatching conviction qualified as an aggravated felony theft offense, rendering him ineligible for cancellation of removal. The individual appealed to the Board of Immigration Appeals (BIA), arguing that the Florida statute was broader than the generic federal definition of theft because it permitted conviction for temporary takings and for depriving a non-owner victim, and did not require proof of nonconsent. The BIA dismissed his appeal, agreeing with the IJ that the Florida offense matched the generic definition of theft under federal law. He then petitioned the United States Court of Appeals for the Eleventh Circuit for review, raising new arguments about the breadth of the Florida statute. After the case was initially remanded to the BIA for further consideration, the BIA reaffirmed its decision and again dismissed the appeal. The United States Court of Appeals for the Eleventh Circuit reviewed the BIA’s decision de novo and held that Florida robbery by sudden snatching is not broader than the generic definition of theft for aggravated felony purposes under the Immigration and Nationality Act. The court concluded that the statute’s intent and consent elements, as interpreted by Florida courts and reflected in jury instructions, were consistent with generic theft, and that the statute did not criminalize a broader range of conduct. The court denied the petition for review. View "Ramdial v. U.S. Attorney General" on Justia Law

Wilson v. Secretary, Florida Department of Corrections

2026-08-21T07:02:22-08:00

An incarcerated individual in Florida filed a civil rights lawsuit under 42 U.S.C. § 1983, alleging that prison officials failed to protect him from a cellmate with mental illness who subsequently assaulted him, causing serious injury. At the time he filed suit, the plaintiff requested to proceed in forma pauperis because he could not afford the filing fees. However, he had previously filed at least three federal actions that were dismissed as frivolous or for failure to state a claim, triggering the “three-strikes” provision of the Prison Litigation Reform Act (PLRA), which generally bars further filings without prepayment unless the plaintiff demonstrates imminent danger of serious physical injury. A magistrate judge in the United States District Court for the Northern District of Florida screened the initial complaint, determined the plaintiff did not sufficiently allege imminent danger, and recommended dismissal under the PLRA’s three-strikes rule. The plaintiff objected, adding new factual allegations about ongoing threats and the continued presence and violence of his assailant, and formally requested leave to amend his complaint. The district judge adopted the magistrate judge’s recommendation, dismissing the complaint without prejudice and refusing to consider the new allegations or grant leave to amend. The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that the district court abused its discretion by failing to either treat the plaintiff’s objections and supplemental allegations as an amendment to the complaint, which he was entitled to file as a matter of course under Federal Rule of Civil Procedure 15(a), or as a motion to amend. The appellate court vacated the district court’s order of dismissal and remanded for further proceedings. View "Wilson v. Secretary, Florida Department of Corrections" on Justia Law

Brown v. Commissioner, Alabama Department of Corrections

2026-08-21T06:02:10-08:00

The case concerns a man who was convicted by an Alabama jury of murdering his girlfriend and her mother. The key facts established at trial showed that after the murders occurred in the victims’ home, the defendant left the state with the children, the victims’ car, and their checks, traveling to Cleveland, Ohio. Witness testimony placed him at the scene around the time of the murders, and his fingerprints were found on duct tape used to bind one of the victims. Additional evidence included his efforts to obtain cash using the victims’ checks, his lies about needing money for a child’s medical care, and his subsequent standoff with police in Cleveland. Family members of the defendant, including his aunt and uncle, were involved in alerting police to possible trouble at the victims’ home before the bodies were discovered. The Alabama Court of Criminal Appeals, reviewing the conviction and death sentence, agreed that the trial court erred in admitting testimony from a police investigator about a statement the defendant allegedly made to his aunt (“I hurt them girls”) without proper impeachment procedure. However, the appellate court held that this error was harmless beyond a reasonable doubt, given the overwhelming evidence of guilt. After unsuccessful state postconviction proceedings, the defendant sought federal habeas relief in the United States District Court for the Northern District of Alabama, arguing that admission of his alleged statement violated his federal due process rights. The district court denied relief, ruling that any error was not prejudicial in light of the full record. On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed, holding that admission of the statement did not violate due process because it was not a crucial or highly significant factor in the conviction, and any error was harmless under both state and federal standards. View "Brown v. Commissioner, Alabama Department of Corrections" on Justia Law

Kingsolver v. U.S. Attorney General

2026-08-20T12:02:51-08:00

An employee of the Bureau of Alcohol, Tobacco, and Firearms suffered from depression and cardiac arrhythmia. After being promoted to a more demanding position, she reported that the increased stress from her job was worsening her health conditions. She requested several accommodations, including unpaid leave, a lateral transfer to a comparable position, or other unspecified assistance. Her supervisors denied unpaid leave, offering instead flexible use of her accrued paid leave and eventually a demotion to a less stressful position. After ongoing health issues and no suitable positions becoming available, the employee accepted the demotion, which subsequently improved her symptoms. The employee filed a complaint with the Equal Employment Opportunity office, alleging that her demotion constituted disability discrimination and that her supervisors failed to provide reasonable accommodation. An initial administrative judge found the agency had failed to accommodate her, but this was reversed by the Office of Federal Operations upon appeal. She then brought suit in the United States District Court for the Southern District of Georgia. The district court granted summary judgment for the government, holding that the employee had not been coerced into her demotion and that her accommodation requests, except for the demotion, were either not reasonable or would have required the creation of a new position. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s grant of summary judgment de novo. The court held that the government did not have a duty to provide the other requested accommodations because they were either not specific or not reasonable. The court further held that no reasonable jury could find that the employee was coerced into accepting the demotion, and thus, her demotion did not constitute disability discrimination. The judgment of the district court was affirmed. View "Kingsolver v. U.S. Attorney General" on Justia Law

Delta Air Lines, Inc. v. U.S. Department of Transportation

2026-08-20T11:32:29-08:00

Delta Air Lines, Inc. and Aerovias de México, S.A. de C.V. sought approval from the U.S. Department of Transportation (DOT) for a joint venture to provide integrated airline services between the United States and Mexico. DOT approved the joint venture in 2016, granting both approval and antitrust immunity after finding that it would increase competition and public benefits in the U.S.–Mexico aviation market. As part of the approval, DOT required the petitioners to divest certain take-off and landing slots at Mexico City’s airport and imposed a five-year limit on antitrust immunity, citing concerns about slot allocation practices at that airport. After the initial approval, the petitioners operated under these conditions and, in 2022, sought renewal of the joint venture’s approval and immunity. However, DOT issued show-cause orders in 2024, and subsequently a final order in 2025, terminating both the approval and antitrust immunity. The DOT’s decision was based primarily on changes to slot allocation and restrictions on all-cargo carriers by the Mexican government at Mexico City’s airport, which DOT concluded had undermined competition and the public interest. The petitioners challenged this final order in the United States Court of Appeals for the Eleventh Circuit, arguing that DOT’s decision was arbitrary and capricious. The Eleventh Circuit agreed with the petitioners. It found that DOT had departed from its uniform practice of conducting comprehensive market analyses, instead focusing narrowly on a single airport without adequate explanation. The court also determined that DOT had imposed a requirement for open skies agreement implementation on the petitioners that it had not imposed in similar cases involving other countries. The court held that DOT’s final order was arbitrary and capricious, and vacated the order. View "Delta Air Lines, Inc. v. U.S. Department of Transportation" on Justia Law

Peden v. Stephens

2026-08-19T08:32:43-08:00

A deputy sheriff in Gwinnett County, Georgia, was terminated from his position following allegations that he engaged in extramarital affairs during work hours and while using county resources. An anonymous letter triggered an internal investigation, which included a polygraph examination. After being confronted with the charges, the deputy was issued a pre-termination notice and ultimately fired. He appealed his termination but later entered into a settlement in which the Sheriff's Office agreed to treat his departure as a resignation. Subsequently, a local news outlet obtained and reported on his personnel file, and the deputy learned the identity of the person behind the anonymous letter. The former deputy and his wife filed a lawsuit in the United States District Court for the Northern District of Georgia, asserting claims for procedural due process and equal protection violations under the Fourteenth Amendment, as well as state law defamation. The district court granted summary judgment to the Gwinnett County officials on all claims, finding insufficient evidence to proceed. On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s grant of summary judgment on the procedural due process and defamation claims. The court held that the plaintiff could not maintain a procedural due process claim because he failed to exhaust available state remedies before pursuing federal relief. The defamation claim failed due to a lack of evidence connecting the defendants to the alleged leak. However, the court vacated the summary judgment on the equal protection claim and remanded with instructions to dismiss that claim for lack of standing, because private citizens generally have no judicially cognizable interest in whether another individual is prosecuted. The officials’ cross-appeal was dismissed as moot. View "Peden v. Stephens" on Justia Law

USA v. Mininger

2026-08-18T09:32:44-08:00

Kenneth Mininger, during a visit to his ex-wife’s home over Thanksgiving 2021, placed hidden video cameras in shared areas, specifically his ex-wife’s daughter’s bedroom and a shared bathroom. The daughter, then seventeen, discovered the cameras, removed the SD cards from them, and reviewed footage that included images of herself and a friend, as well as recordings of herself undressing from earlier years. After confronting Mininger and asking him to leave, the daughter and her mother turned the SD cards over to police, who searched them without a warrant. The footage led to a broader investigation, during which law enforcement obtained and executed warrants for Mininger’s residence and devices, discovering extensive child sexual abuse material. In the United States District Court for the Northern District of Alabama, Mininger moved to suppress the evidence obtained from the SD cards and the subsequent searches, arguing a Fourth Amendment violation due to the warrantless search and alleging the warrants for his devices were overbroad. The district court denied the motion, finding Mininger had a reasonable expectation of privacy in the SD cards but that the homeowner had authority to consent to the search. Mininger entered a conditional guilty plea, preserving his right to appeal the suppression ruling, and was sentenced to 600 months in prison. The United States Court of Appeals for the Eleventh Circuit reviewed the denial of the suppression motion, applying a mixed standard of review. The court held that Mininger had no reasonable expectation of privacy in the SD cards because he had placed them, unsecured and without consent, in shared spaces for illicit purposes. The court also held that the warrants for Mininger’s devices were not overbroad, as they were reasonably limited to evidence of child pornography and sexual exploitation. The Eleventh Circuit affirmed Mininger’s convictions. View "USA v. Mininger" on Justia Law

USA v. Chun

2026-08-18T07:02:11-08:00

A physician specializing in pain medicine and a pharmaceutical sales representative were indicted in the Middle District of Florida for their roles in a scheme involving a fentanyl-based drug. The pharmaceutical company launched a speaker program to boost sales of its medication by paying physicians large honoraria for supposedly educational presentations that were, in fact, shams. The physician received significant payments as a speaker, and the sales representative arranged many of these events. Evidence showed that the supposed educational events were poorly attended or attended by inappropriate guests, and that payments were tied to prescription volume, not genuine educational services. After a grand jury indictment, the case proceeded to trial before the United States District Court for the Middle District of Florida. The jury found the physician guilty on conspiracy and substantive anti-kickback counts, while the sales representative was convicted on conspiracy, anti-kickback violations, and identity fraud counts. Both defendants moved for judgments of acquittal, arguing insufficient evidence and other legal grounds, but the District Court denied these motions. Both were sentenced to prison and appealed their convictions and sentences. The appeal also challenged the District Court’s responses to jury questions and the calculation of loss in sentencing. The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the District Court’s judgments. The Eleventh Circuit held that ample evidence supported the convictions for conspiracy and anti-kickback violations, including the physician’s knowledge of the sham nature of the speaker programs and the sales representative’s knowing participation. The Court also held that the District Court did not abuse its discretion in responding to jury questions and that any potential error in calculating the sentencing range was harmless, as the District Court would have imposed the same sentences in any event. The convictions and sentences were therefore upheld. View "USA v. Chun" on Justia Law

Warner v. Hillsborough County Clerk of Courts

2026-08-17T11:32:09-08:00

After being involved in an eviction proceeding in Hillsborough County, Florida, an individual deposited funds into the court registry, as required by state law. Over time, he changed addresses and updated his contact information in the state’s e-filing system, but did not always update his address with the county court. The county clerk attempted to notify him of unclaimed funds by mailing letters to an outdated address (despite repeated returned mailings) and by publishing notice in a local Spanish-language newspaper with very limited circulation in the county. The funds were eventually declared abandoned and forfeited to the county under a Florida statute. The United States District Court for the Middle District of Florida granted summary judgment in favor of the county clerk. The district court found that publication in the local newspaper constituted constitutionally sufficient notice and that the forfeiture did not amount to an unconstitutional taking because statutory schemes for escheatment of abandoned property are generally permissible. The United States Court of Appeals for the Eleventh Circuit reviewed the case. The appellate court held that the statute’s notice procedure is not facially unconstitutional because there are situations where publication alone may suffice—for instance, when the property owner is unknown. However, the court found the clerk’s application of the statute to this individual was unconstitutional. The clerk had access to alternative means of contact (including email and a valid mailing address in the state’s e-file system) but failed to use them, relying instead on methods not reasonably calculated to provide notice. The court also determined that the individual had not abandoned the funds, since he never received constitutionally adequate notice, and thus the county’s appropriation of the funds constituted an unconstitutional taking. The Eleventh Circuit affirmed in part, reversed in part, and remanded for further proceedings. View "Warner v. Hillsborough County Clerk of Courts" on Justia Law

Johnson v. Russell Investments Trust Company

2026-08-17T10:02:04-08:00

An employee of Royal Caribbean participated in the company’s retirement plan and invested in a series of target date funds managed by Russell. She, on behalf of a class, alleged that Royal Caribbean, as plan sponsor and fiduciary under ERISA, breached its duty of prudence by selecting and retaining the Russell Target Date Funds (TDFs) instead of alternatives like those from Vanguard or American Funds. The complaint highlighted that the Russell TDFs underperformed their peers and benchmarks, charged higher fees, and had features—such as a particular glidepath and asset allocation—that allegedly made them a poor fit for plan participants. Internal communications from Russell and Royal Caribbean raised concerns about the performance and cost of the Russell TDFs. The United States District Court for the Southern District of Florida granted summary judgment to Royal Caribbean. It reasoned that, in order to prove the investment was objectively imprudent, the plaintiff was required to present “apples-to-apples” comparator evidence—showing the Russell TDFs were worse than another fund with the same investment strategy and risk profile. The district court found that the plaintiff’s comparators, such as the Vanguard and American Funds TDFs, were not proper because they differed in strategy and structure from the Russell funds. The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that an ERISA plaintiff is not always required to provide an “apples-to-apples” comparator to establish that an investment was objectively imprudent. The court explained that evidence of objective imprudence can be qualitative or quantitative, and the inquiry is context-specific, depending on all relevant facts and circumstances. The Eleventh Circuit reversed the district court’s grant of summary judgment and remanded the case for further proceedings. View "Johnson v. Russell Investments Trust Company" on Justia Law

Finley v. Albritton

2026-08-17T08:32:54-08:00

Two high-ranking officers in a city police department—one the chief and the other the deputy chief of operations—were subject to an internal firearms proficiency assessment. Department policy mandated regular qualifications, and there was confusion over which of two overlapping policies governed discipline for failures. After the deputy chief failed the assessment, she received an extra attempt to qualify, which she passed, and the chief subsequently allowed all failing officers a third attempt. A lieutenant, believing the chief had abused his authority to benefit the deputy chief, filed a complaint with the state ethics commission, prompting an investigation by commission officials. During the investigation, the commission’s special agent and general counsel relied on the allegedly superseded policy, policy 2.311, to argue that the deputy chief faced possible financial penalties and thus had a financial interest in the outcome. There was confusion among department officials and investigators regarding which policy was in effect, and both policies were referenced in departmental communications and disciplinary records. The commission found probable cause of ethics violations by both officers and referred the matter to the state attorney general. However, the attorney general found that the commission officials had relied on false evidence and misrepresentations. An internal review by the commission cleared its officials of wrongdoing. The officers sued the commission’s executive director, special agent, and general counsel in the United States District Court for the Middle District of Alabama under 42 U.S.C. § 1983, alleging due process violations based on fabricated evidence, among other claims. The district court granted summary judgment to the defendants on the federal claims and declined to exercise supplemental jurisdiction over the state-law claims. The United States Court of Appeals for the Eleventh Circuit reviewed the grant of summary judgment de novo. It held that the officials were entitled to qualified immunity, finding no substantial evidence that they fabricated evidence or acted in bad faith. The court affirmed the district court’s grant of summary judgment for the defendants. View "Finley v. Albritton" on Justia Law

USA v. Sheely

2026-08-13T13:02:41-08:00

A man was arrested after police responded to reports of gunshots and found him in the area matching a witness description. He was charged with possession of a firearm and ammunition as a convicted felon, with prior felony convictions including felony battery, attempted robbery, and manslaughter in Florida. The defendant entered a plea agreement, admitting to the facts underlying the charge and his criminal history. The United States District Court for the Southern District of Florida initially calculated his guideline sentence using several prior convictions as “crimes of violence” under the Sentencing Guidelines. The defendant objected, arguing that some of his prior convictions, including felony battery, did not qualify as “crimes of violence” after the Supreme Court’s decision in Borden v. United States. The district court overruled his objections and imposed a sentence, but the United States Court of Appeals for the Eleventh Circuit later vacated the sentence, holding that attempted robbery and manslaughter were not “crimes of violence,” and remanded for resentencing to address whether felony battery still qualified. On remand, the district court recalculated the guideline range using only the felony battery conviction as a predicate “crime of violence” and imposed a new sentence. The defendant again appealed, arguing that Borden abrogated Eleventh Circuit precedent holding Florida felony battery is a “crime of violence.” The United States Court of Appeals for the Eleventh Circuit held that its precedent from United States v. Vail-Bailon, which found Florida felony battery to be a “crime of violence,” remained binding and was not abrogated by Borden. The court affirmed the sentence, holding that a conviction for Florida felony battery still qualifies as a “crime of violence” under the Sentencing Guidelines. View "USA v. Sheely" on Justia Law

Center for Biological Diversity v. U.S. Environmental Protection Agency

2026-08-12T10:02:22-08:00

A nonprofit organization challenged a decision by the U.S. Environmental Protection Agency (EPA), which approved a request by a fertilizer company to use phosphogypsum—a radioactive byproduct of fertilizer production—in the construction of a pilot road on the company’s private property in Florida. Phosphogypsum is typically stored in stacks due to its emission of radon gas, a known carcinogen. Federal regulations issued under the Clean Air Act generally prohibit its use outside of certain exceptions but allow the EPA to approve other uses if public health is protected as much as it would be by storage in stacks or mines. The EPA, after a multi-year review, found that the company's proposal included all necessary information and that the risks to workers, nearby residents, and the environment were below the applicable health thresholds. The EPA concluded that the road’s use of phosphogypsum posed no greater risk than storage and imposed ongoing monitoring requirements. The nonprofit submitted public comments opposing the approval, arguing that EPA’s action violated regulations and was arbitrary and capricious. After considering these comments, the EPA finalized its approval. The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court first determined that it had jurisdiction because the petitioner had associational standing and the case was not moot. On the merits, the court held that the EPA did not violate its regulations, as the relevant rules unambiguously permit case-by-case approval of “other uses” of phosphogypsum, including road construction, provided health protections are adequate. The court also found that the EPA’s technical review and risk assessment were reasonable and well-supported, and any alleged procedural errors were harmless. The court denied the petition. View "Center for Biological Diversity v. U.S. Environmental Protection Agency" on Justia Law

Renfroe v. USAA

2026-08-11T12:03:08-08:00

A father and daughter jointly owned a house in Alabama but had a contentious relationship, with both warning their insurer, USAA General Indemnity Co., that the other might intentionally set fire to the property. Despite these warnings, USAA issued a $500,000 policy covering both as insureds. The policy included an exclusion that denied coverage to all insureds if any one of them intentionally caused a loss, except in certain cases of domestic abuse. Shortly after the policy was issued, the house was destroyed by fire. The father, Martin D. Renfroe, filed a claim, but USAA denied coverage, suspecting arson by either Renfroe or his daughter. The United States District Court for the Northern District of Alabama considered Renfroe’s claims for breach of contract and bad faith. The court ruled that the innocent-insured exclusion was void as against Alabama public policy, allowing Renfroe’s breach of contract claim to proceed to trial, but granted summary judgment for USAA on the bad faith claim due to evidence suggesting Renfroe might have committed arson. At trial, the jury found in favor of Renfroe, awarding him damages, which the court later reduced. The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that Alabama law does not prohibit innocent-insured exclusions in insurance policies unless specifically barred by statute, and found no such bar here. The appellate court concluded the exclusion was enforceable, vacated the district court’s judgment on the breach of contract claim, and remanded for a new trial. The Eleventh Circuit affirmed the district court’s summary judgment for USAA on the bad faith claim, holding that USAA had at least an arguable basis for denying coverage due to evidence implicating Renfroe in arson. View "Renfroe v. USAA" on Justia Law

Florida East Coast Railway LLC v. Federal Railroad Administration

2026-08-11T11:02:31-08:00

Several railroads and industry groups challenged a federal regulation requiring most freight trains to operate with at least two crewmembers unless the use of a one-person crew is shown to be equally safe. The regulation, issued by the Federal Railroad Administration (FRA) in 2024, responded to safety concerns about the reduction of train crew sizes as technology advanced, citing specific accidents and research on the importance of crew redundancy for safety. The rule provides exemptions for smaller railroads with established one-person operations and offers a special approval process for others, especially those transporting hazardous materials. Previously, the FRA had declined to regulate crew size, withdrawing a proposed rule in 2019 based on insufficient evidence that one-person crews were less safe. However, the U.S. Court of Appeals for the Ninth Circuit vacated this withdrawal, criticizing the agency's reasoning and its attempt to preempt state crew-size laws. Following a new rulemaking process, the FRA finalized the 2024 regulation after considering thousands of public comments, a public hearing, and new safety data. The United States Court of Appeals for the Eleventh Circuit reviewed consolidated petitions from several railroads and associations. The petitioners argued, among other points, that the FRA exceeded its authority, acted arbitrarily and capriciously, failed to adequately consider costs, and violated statutory deadlines. The Eleventh Circuit held that the FRA acted within its broad statutory authority to regulate railroad safety, provided reasonable explanations for its policy changes and regulatory choices, adequately considered evidence and public input, and did not violate the law by taking more than twelve months to finalize the rule. The court denied all petitions for review, upholding the Crew Size Rule. View "Florida East Coast Railway LLC v. Federal Railroad Administration" on Justia Law

USA v. Hollington

2026-08-11T08:32:35-08:00

A physician who operated an addiction clinic was indicted on multiple counts of unlawfully prescribing controlled substances to five undercover law enforcement officers and four actual patients, as well as several counts of obstruction of justice for altering patient records after being indicted. At trial, four former patients testified that the physician prescribed drugs to them following minimal or inadequate medical evaluation, with several testifying to sexual misconduct or exploitation by the physician in connection with their prescriptions. Five undercover officers also testified to receiving prescriptions with little or no medical assessment, and video evidence corroborated their accounts. The prosecution further showed that after his indictment, the physician added false or misleading entries to the medical records of the undercover officers to make it appear that he had conducted more thorough evaluations than he actually had. The United States District Court for the Middle District of Florida granted the physician’s motion for acquittal only as to the conspiracy count but let the case proceed on the remaining charges. A jury convicted the defendant on all remaining counts. At sentencing, the district court adopted a guidelines range of 30 to 37 months but imposed a sentence of 144 months, an upward variance, citing the physician’s sexual misconduct against patients as a significant aggravating factor. The district court explained that the guidelines did not adequately capture the seriousness of the sexual abuse committed in connection with the unlawful prescriptions. The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that sufficient evidence supported all convictions for unlawful prescription and obstruction of justice. The court also found that the upward variance in sentencing was reasonable, given the aggravating circumstances, and that the district court did not commit procedural or substantive error. The Eleventh Circuit affirmed the defendant’s convictions and sentence. View "USA v. Hollington" on Justia Law

Mt. Hawley Insurance Company v. H&M Builders, LLC

2026-08-11T06:01:58-08:00

An individual was fatally electrocuted while installing rebar at a construction site where H&M Builders, LLC served as a subcontractor. H&M was insured by Mt. Hawley Insurance Company, which had issued a commercial general liability policy valid on the date of the incident. The decedent’s estate, represented by Gloria Escalante, filed a wrongful death lawsuit in Florida state court against H&M and others, alleging their negligence led to the fatality. Mt. Hawley undertook H&M’s legal defense in the state proceeding, but did so under a reservation of rights, disputing its obligation to defend or indemnify H&M. Subsequently, Mt. Hawley initiated a federal action in the United States District Court for the Southern District of Florida, seeking a declaratory judgment that it owed no duty to defend or indemnify H&M in the underlying state litigation. The district court granted summary judgment in favor of H&M and Escalante on the duty-to-defend issue, while reserving judgment on the duty to indemnify until the state case concluded. Mt. Hawley appealed this summary judgment order before the district court entered a final judgment. While the federal appeal was pending, the parties settled the state wrongful death case, which was then dismissed. The district court then dismissed the indemnification claim as moot and entered final judgment. The United States Court of Appeals for the Eleventh Circuit held that it lacked jurisdiction over Mt. Hawley’s appeal for three separate reasons: the underlying state-court action had been settled and dismissed, eliminating any live controversy; the summary judgment order appealed from did not possess injunctive qualities necessary for interlocutory appellate jurisdiction under 28 U.S.C. § 1292(a)(1); and, finally, the district court had entered a final judgment, so any appeal should be from that judgment rather than an interlocutory order. The appeal was therefore dismissed for lack of jurisdiction. View "Mt. Hawley Insurance Company v. H&M Builders, LLC" on Justia Law

Owoc v. The Liquidating Trustee on Behalf of the Liquidating Trust

2026-08-10T11:02:19-08:00

The case concerns the founder and sole shareholder of a corporation (VPX), who elected to treat the company as a Subchapter S Corporation for federal tax purposes. After VPX and affiliated entities filed for Chapter 11 bankruptcy, a reconstituted board removed the founder from his executive and board positions, though he remained the sole shareholder. The company’s assets were later sold, and its remaining interests were vested in a trust under the reorganization plan. The founder then sought confirmation that the bankruptcy automatic stay did not prohibit him from revoking the corporation’s Subchapter S status or, alternatively, for relief from the stay to do so. The United States Bankruptcy Court for the Southern District of Florida denied his motions, holding that the Subchapter S election constituted property of the bankruptcy estate and was therefore protected by the automatic stay. The founder appealed this decision to the United States District Court for the Southern District of Florida, which denied the trustee’s motion to dismiss the appeal as moot, consolidated the appeals, and certified a direct appeal to the United States Court of Appeals for the Eleventh Circuit. The United States Court of Appeals for the Eleventh Circuit addressed several issues, including mootness, the law of the case, and whether Subchapter S status is property of the bankruptcy estate. The court held that a corporate debtor’s Subchapter S election is not property of the bankruptcy estate because the election belongs to the shareholder, not the corporation. The court found the appeal neither constitutionally nor equitably moot, determined that procedural hurdles were met, and reversed the bankruptcy court’s denial of the founder’s motions. The case was remanded for further proceedings consistent with the Eleventh Circuit’s opinion. View "Owoc v. The Liquidating Trustee on Behalf of the Liquidating Trust" on Justia Law

Waller v. Board of Regents of the University System of Georgia

2026-08-10T08:02:51-08:00

A student enrolled in a respiratory therapy program at a public university in Georgia was disciplined following an incident during his clinical externship, where he was found responsible for endangering the health or safety of a patient. As a result, the university assigned him a failing grade in his clinical class. The student, who has attention deficit disorder, anxiety, and depression, alleged that university personnel were aware of his conditions. He claimed that prior to the disciplinary hearing, he was denied access to evidence and that the hearing procedures did not comply with the university’s written policies. After exhausting internal university appeals, the student filed a lawsuit in Georgia state court against the Board of Regents and several employees, asserting breach of contract and disability discrimination under the Americans with Disabilities Act and the Rehabilitation Act, among other claims. The case was removed to the United States District Court for the Middle District of Georgia. The district court dismissed the breach of contract claim on the basis of state sovereign immunity, finding no enforceable written contract that would waive immunity. The court also dismissed the disability discrimination claims for failure to state a claim, holding that the complaint did not plausibly allege adverse action taken because of the student’s disability. The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that neither the admission letter nor the student handbook, alone or together, constituted a written contract sufficient to waive Georgia’s sovereign immunity, as neither document set forth all essential terms, especially as to consideration. The court further held that the student’s complaint failed to plausibly allege that the university’s actions were taken because of his disabilities. Accordingly, the Eleventh Circuit affirmed the district court’s dismissal of the student’s breach of contract and disability discrimination claims. View "Waller v. Board of Regents of the University System of Georgia" on Justia Law

USA v. Ponce

2026-08-07T12:02:17-08:00

The case centers on a drug-related shootout in Orlando, Florida, in which Cristian Ponce, a convicted felon, was involved. On November 2, 2022, Ponce was a passenger in a vehicle with his co-conspirator, Savier Hernandez, when two rival drug dealers approached. A gunfight ensued, resulting in the deaths of Hernandez and one of the rivals, Eminem Esquilin. Evidence, including drugs and firearms, linked Ponce to ongoing drug distribution. After the incident, additional searches recovered more drugs, firearms, and communications indicating Ponce’s involvement in drug sales and awareness of rival territories. A grand jury indicted Ponce on four counts related to drug distribution and firearms offenses, but not murder. He pleaded guilty to all counts. The United States District Court for the Middle District of Florida, during sentencing, applied the murder cross-reference under U.S.S.G. § 2D1.1(d)(1), which increased Ponce’s offense level by referencing the guideline for second-degree murder. The court found that the shooting, as part of a drug conspiracy, was reasonably foreseeable and that Ponce had negligently placed himself in a situation requiring criminal conduct. Ponce objected, arguing the shooting was in self-defense and that he was not the aggressor. The district court overruled his objections and sentenced him to 240 months in prison. The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that the murder cross-reference was properly applied because Ponce was accountable for the actions of his co-conspirator under the relevant conduct guidelines. The court also concluded that Ponce could not claim self-defense, as he negligently placed himself in a dangerous situation by bringing firearms to sell drugs on a rival’s turf, thereby failing to meet the requirements for a justification defense. View "USA v. Ponce" on Justia Law

Key v. Dynamic Security, Inc.

2026-08-05T12:01:58-08:00

A woman applied for a mailroom position with a security company that provided services at an automobile manufacturing plant. The company had a grooming policy prohibiting certain hairstyles, including locs. During her interview, concerns about her hairstyle were raised, but she was hired after showing a picture of her hair styled in an "updo." She began work with her locs, but was sent home because of her hair. After subsequent discussions and expressing concerns about discrimination, she was ultimately not allowed to return to work. She filed complaints with the Equal Employment Opportunity Commission (EEOC), naming individuals involved, and later received a right-to-sue letter for one of her charges, but maintains she never received the letter for the other. She filed suit in the United States District Court for the Middle District of Alabama, alleging race and pregnancy discrimination and retaliation under Title VII and 42 U.S.C. § 1981 against several defendants. The district court dismissed disparate-impact claims and all Title VII claims against one defendant, then granted summary judgment on all claims against two defendants, and on all but one retaliation claim against the security company. That retaliation claim went to a jury, which awarded substantial damages. The district court denied the security company’s motion to strike her jury demand, finding no knowing and intentional waiver of her right to a jury trial. The United States Court of Appeals for the Eleventh Circuit affirmed dismissals and summary judgment for two defendants and on the race discrimination claim against the security company. However, it held that the district court erred by presuming timely receipt of the right-to-sue letter at summary judgment and by failing to properly instruct the jury on the protected activity element of retaliation. The court vacated the judgment against the security company and remanded for a new trial on the remaining claims. View "Key v. Dynamic Security, Inc." on Justia Law

USA v. Romain

2026-08-05T08:32:13-08:00

Several individuals affiliated with an organization headquartered in Florida, which advocates for the rights of African people worldwide, developed a close relationship with a Russian citizen who directed a Russian government-backed group. Over the course of several years, this Russian contact funded trips to Russia for organization leaders, sponsored events, and directed them to produce and disseminate pro-Russian statements and media. These individuals participated in activities at the direction of the Russian contact, including authoring petitions, organizing demonstrations, publishing statements, recording videos, and protesting at the request of their Russian counterpart. None of them notified the U.S. Attorney General as required by law for acting as agents of a foreign government. A federal grand jury indicted three organization members and one former member for acting as unregistered agents of a foreign government under 18 U.S.C. § 951(a), and for conspiracy to do so under 18 U.S.C. § 371. After a jury trial in the United States District Court for the Middle District of Florida, the defendants were found guilty of conspiracy but not of the substantive offense. The district court sentenced the former member to 60 months’ probation and the other three to 36 months’ probation. The defendants raised several arguments on appeal, including claims that the statute was unconstitutional as applied, that the evidence was insufficient, that evidentiary and jury instruction errors occurred, and that there was prosecutorial misconduct. The United States Court of Appeals for the Eleventh Circuit held that 18 U.S.C. §§ 951 and 371 are constitutional as applied, as they are content-neutral and survive intermediate scrutiny. The Court found sufficient evidence to support the conspiracy convictions, ruled that the district court did not abuse its discretion regarding jury instructions or evidentiary rulings, and found no prosecutorial misconduct. The convictions were affirmed. View "USA v. Romain" on Justia Law

L.E. v. Superintendent of Cobb County School District

2026-08-05T07:02:36-08:00

Four students with disabilities, who attended public schools in Cobb County, Georgia, challenged the school district’s COVID-19 masking policy. Initially, the district required masks, but later implemented a policy prohibiting mask mandates, allowing voluntary mask-wearing only. The students’ disabilities made them particularly vulnerable to respiratory viruses. When the district declined their requests for stricter COVID accommodations, including mandatory masks, all four switched to virtual learning; eventually, two left for private schools due to the district’s refusal. The students alleged that the district’s blanket ban prevented individualized consideration of their health needs, causing them to lose access to in-person education. The students filed suit in the United States District Court for the Northern District of Georgia under Title II of the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act (RA), seeking damages and a preliminary injunction to require the district to consider their masking requests. The district court dismissed two students (A.Z. and C.S.) for lack of standing after they unenrolled, and denied injunctive relief for the remaining two (B.B. and L.E.), finding they were unlikely to succeed on the merits because the district had already provided reasonable accommodations. On a prior appeal, the United States Court of Appeals for the Eleventh Circuit remanded for reconsideration, emphasizing the need to focus on access to in-person schooling. On appeal again, the United States Court of Appeals for the Eleventh Circuit held that all four students had standing, including those who had switched to private schools, because standing is determined at the time of filing and claims for past damages remain viable. The court affirmed denial of the preliminary injunction for B.B. and L.E., concluding the district’s accommodations had been effective and mandatory masking was not necessary for equal access. The court reversed the dismissal of A.Z. and C.S. for lack of standing and remanded for the district court to address the merits of their claims. View "L.E. v. Superintendent of Cobb County School District" on Justia Law

USA v. Alli

2026-08-05T05:31:55-08:00

During the COVID-19 pandemic, Congress established a program to provide emergency loans and grants to small businesses impacted by the crisis. Almar Sales and Services, Inc.—with Alexander Alli as its principal owner—submitted a loan application to the Small Business Administration (SBA) under this program, falsely stating it was based in Minnesota, had two employees, and claimed $250,000 in gross revenues. The SBA approved the application, granting $2,000 and later issuing an $80,500 loan. Alli signed the loan documents and received the funds, which he used in part to purchase two trucks, but only made one payment before the loan was charged off. Subsequent investigation revealed numerous false representations in the application, including business location, revenue, and citizenship status. The United States District Court for the Middle District of Florida reviewed the case after a grand jury indicted Alli on one count of conspiracy to commit wire fraud and two counts of wire fraud. Before trial, the prosecution sought to exclude certain portions of Alli’s interviews with a Homeland Security agent. The district court ruled that most of Alli’s requested excerpts were inadmissible hearsay, though it allowed some additional context where needed. The court also instructed the jury on Pinkerton liability and deliberate ignorance over Alli’s objections. After trial, the jury convicted Alli on all counts, and he was sentenced to 13 months’ imprisonment and ordered to pay restitution. The United States Court of Appeals for the Eleventh Circuit reviewed the evidentiary rulings, sufficiency of evidence, and jury instructions. The court held that the district court did not err in its application of the rule of completeness regarding Alli’s interviews, found sufficient evidence supported the conspiracy conviction, and upheld the jury instructions on Pinkerton liability and deliberate ignorance. The Eleventh Circuit affirmed Alli’s convictions. View "USA v. Alli" on Justia Law

USA v. Lambert

2026-08-04T12:32:19-08:00

At a daycare facility located on a military base in Georgia, two teachers in a toddler classroom abused children over several months. The director of the facility, who had access to video monitors of all classrooms and regularly used them to monitor staff, received multiple reports from workers about inappropriate conduct by the teachers, including cursing at children and playing profane music. One worker specifically expressed discomfort, reported the behavior to the director, and refused to work in the classroom further out of concern for the children’s safety. The director did not make a report of suspected child abuse until prompted by a later conversation with another employee, by which time the abuse had been ongoing and captured on video. After the abuse came to light, the United States District Court for the Middle District of Georgia presided over the criminal case. The two teachers pled guilty to cruelty to children. The director was indicted for failure to report suspected child abuse, among other charges. A jury acquitted her of being an accessory after the fact and making false statements, but convicted her of failing to report, and the district court imposed a sentence of probation. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed whether the evidence was sufficient to support the director’s conviction under 18 U.S.C. § 2258. The Eleventh Circuit held that a reasonable jury could infer the director had reason to suspect children suffered mental injury, given the reports she received and her access to video evidence. The court concluded the evidence was sufficient and affirmed the conviction. View "USA v. Lambert" on Justia Law

Curry v. Warden

2026-08-04T12:02:41-08:00

The case involves a fatal car crash in Escambia County, Alabama, in which Estella Curry, while driving at a high speed and under the influence of multiple medications, collided with Richard Walker’s vehicle. The crash caused Walker’s death, and Curry was indicted for reckless murder. Prior to trial, Curry expressed dissatisfaction with her appointed counsel and made several pro se motions seeking his removal and requesting to represent herself. The trial court denied these motions, finding her requests equivocal and ultimately deciding she had not made a clear, unequivocal demand for self-representation. Curry was tried in the Circuit Court of Escambia County, Alabama, where the jury found her guilty of reckless murder, based on evidence including her excessive speed and impairment due to drugs. The trial court denied Curry’s motions for judgment of acquittal. On appeal to the Alabama Court of Criminal Appeals, Curry challenged her conviction, arguing errors in the denial of self-representation, competency rulings, and sufficiency of the evidence. The appellate court affirmed the conviction. Curry then pursued post-conviction relief under Rule 32 of the Alabama Rules of Criminal Procedure, which was dismissed, and that dismissal was affirmed by the appellate courts, with the Alabama Supreme Court denying certiorari. The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s denial of Curry’s federal habeas corpus petition. The Eleventh Circuit affirmed the district court’s judgment, holding that Curry did not qualify for the Martinez v. Ryan exception for procedurally defaulted ineffective-assistance-of-counsel claims, that she did not make a clear and unequivocal request for self-representation, and that the evidence supporting her conviction was not based on an unreasonable determination of the facts or law. The district court’s denial of habeas relief was affirmed. View "Curry v. Warden" on Justia Law

Phillips v. City of Hanceville

2026-08-04T12:02:40-08:00

Joshua Phillips visited a police station in Hanceville, Alabama, intending to file a complaint against an officer. During his visit, he had an argument with Officers Kyle Duncan and Josh Howell, leading to his arrest. Phillips alleged that excessive force was used during his arrest and that Deputy Chief Adam Hadder assaulted him later while Phillips was in jail. The events were largely captured on body-worn and closed-circuit cameras, with some details based on Phillips’s account where no video existed. Phillips was initially charged with disorderly conduct and resisting arrest, but the charges were later dropped. The United States District Court for the Northern District of Alabama reviewed Phillips’s claims under 42 U.S.C. § 1983, which included false arrest, retaliatory arrest, and excessive force under the Constitution. The district court granted summary judgment in favor of the officers and the City of Hanceville, finding that the officers had probable cause for the arrest and only used de minimis force. The district court also found no basis for municipal liability because it concluded there was no underlying constitutional violation. Reviewing the appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s summary judgment. The appellate court held that the officers were entitled to qualified immunity because they had probable cause to arrest Phillips for disorderly conduct and trespass, and any force used was de minimis and reasonable under the circumstances. The court also concluded that Phillips’s retaliatory arrest claim failed due to the existence of probable cause, and there was no evidence of excessive force by any officer. Because there was no constitutional violation, the City could not be held liable. The court therefore affirmed the judgment for the officers and the City. View "Phillips v. City of Hanceville" on Justia Law

Pasqual-Andres v. U.S. Attorney General

2026-08-04T11:31:57-08:00

A Guatemalan citizen entered the United States as a minor and was subsequently charged with removability for being present in the country without authorization. Represented by counsel, he conceded his inadmissibility and applied for asylum, withholding of removal, and relief under the Convention Against Torture. After a merits hearing, the immigration judge denied all forms of relief, finding the applicant not credible and concluding that he had not sufficiently alleged persecution or established membership in a cognizable social group. The judge also found he was ineligible for withholding of removal and CAT relief. The applicant appealed to the Board of Immigration Appeals (BIA), submitting a brief that was labeled pro se but had been prepared by his former counsel. The brief inadequately challenged the judge’s findings and contained errors. The BIA dismissed the appeal, agreeing with the immigration judge’s reasoning and noting the applicant failed to contest several key findings. Subsequently, new counsel filed a motion to reopen based on ineffective assistance of prior counsel, arguing that the prior brief was so deficient as to be functionally no representation at all. The applicant documented that he had filed a complaint with the Executive Office for Immigration Review (EOIR) Disciplinary Counsel regarding his former counsel’s conduct. The BIA denied the motion, holding that he failed to comply with the third Lozada requirement because he did not file a complaint with the state bar. The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that reporting prior counsel to the EOIR Disciplinary Counsel satisfies the requirement in Matter of Lozada to file a complaint with “appropriate disciplinary authorities.” The court concluded that the BIA abused its discretion in requiring a state bar complaint as the only means of compliance. The Eleventh Circuit vacated the BIA’s decision and granted the petition for review. View "Pasqual-Andres v. U.S. Attorney General" on Justia Law

Deltona Transformer Corporation v. The Noco Company

2026-08-04T09:03:07-08:00

A manufacturer of battery chargers, which owns the registered trademarks “Battery Tender” and “Deltran Battery Tender,” discovered that a competitor began advertising its own similar chargers using those terms. The competitor used the marks in multiple ways: purchasing them as keywords to trigger ads on Amazon, including the marks in the text of its Amazon ads and product descriptions, and referring to its own products as “battery tenders” in communications with marketing firms and consumers. The trademark owner sent several cease-and-desist letters, but the conduct continued. The company then sued the competitor for trademark infringement, unfair competition, false designation of origin, and related state law claims. In the United States District Court for the Middle District of Florida, a jury found in favor of the trademark owner on all counts, including trademark infringement and false advertising, and awarded damages. The district court denied the competitor’s motions for judgment as a matter of law and for a new trial, and later ordered disgorgement of profits and issued a permanent injunction prohibiting the competitor from using the marks, as well as the term “tender,” in connection with its products. The competitor appealed, challenging the jury’s findings, the district court’s legal rulings, and the scope of the injunction and damages. The United States Court of Appeals for the Eleventh Circuit held that the “Battery Tender” marks were not generic, but at least descriptive with secondary meaning, and affirmed the finding of trademark infringement for visible uses of the marks. However, the court held that purchasing the marks as keywords alone does not constitute infringement, reversed the jury’s verdict on false advertising, and vacated the damages award for a new trial, as the amount could not be separated from improper theories. The court affirmed the injunction and disgorgement order. View "Deltona Transformer Corporation v. The Noco Company" on Justia Law

HM Florida-ORL, LLC v. Secretary of the Florida Department of Business

2026-08-04T07:32:22-08:00

A restaurant in Florida that hosts drag performances challenged the constitutionality of a state law known as the Protection of Children Act. The Act makes it a misdemeanor to knowingly admit a child to an “adult live performance,” defined as shows depicting nudity, sexual conduct, or lewd conduct, and meeting additional criteria based on prurient appeal, offensiveness to community standards for the age of the child present, and lack of serious value for that age. The restaurant argued that the Act’s use of the word “lewd” and its age-variable standards rendered the law unconstitutionally vague and overbroad, alleging harm to its business and chilling of its performances. The United States District Court for the Middle District of Florida granted a preliminary injunction, finding the Act unlikely to survive strict scrutiny and to be unconstitutionally vague and overbroad. The injunction barred the Secretary of the Florida Department of Business and Professional Regulation from enforcing the Act against anyone in the state. This decision was affirmed by a divided panel of the United States Court of Appeals for the Eleventh Circuit, but the full court granted rehearing en banc, stayed the injunction as to nonparties, and requested briefing on the scope and merits of the case. The United States Court of Appeals for the Eleventh Circuit, on en banc review, vacated the preliminary injunction in its entirety. The court held that the district court lacked authority to issue a universal injunction barring enforcement of the Act statewide, as such relief exceeds a federal court’s equitable power. Furthermore, the court found the Act’s language, as construed by Florida precedent, did not render it unconstitutionally vague or overbroad, and Hamburger Mary’s was not substantially likely to succeed on the merits. The matter was remanded for further proceedings consistent with this opinion. View "HM Florida-ORL, LLC v. Secretary of the Florida Department of Business" on Justia Law

City of Brunswick v. Honeywell International, Inc.

2026-08-03T11:31:54-08:00

A city in Georgia experienced ongoing pollution of its property from hazardous substances, including mercury and PCBs, allegedly released as a result of historical industrial operations at a nearby plant site. Georgia Power initially owned the site and later sold it to a Honeywell predecessor, with both companies involved in activities that contributed to the contamination. Over decades, these pollutants migrated into the city’s property and surrounding waterways. In the 1990s, the Environmental Protection Agency (EPA) intervened and required the companies to investigate and remediate the site’s contamination under its oversight, culminating in a consent decree that obligated the companies to implement EPA’s official remediation plan. The city filed suit in Georgia’s Superior Court of Glynn County, asserting state-law claims for continuing nuisance and trespass, seeking damages and remediation costs. The defendants removed the case to the United States District Court for the Southern District of Georgia, arguing several grounds for federal jurisdiction, including federal officer removal under 28 U.S.C. § 1442(a)(1). The district court rejected all removal grounds and remanded the case to state court, finding that the defendants were not “acting under” a federal officer. The defendants appealed the remand order while litigation continued in state court. The United States Court of Appeals for the Eleventh Circuit held that it had jurisdiction to review the remand order, finding that the defendants’ notice of appeal triggered an automatic stay of the district court’s remand, rendering subsequent state court proceedings void for these purposes. On the merits, the court held that federal officer removal was proper because the defendants’ remediation obligations arose from and were controlled by the EPA under a consent decree. The court reversed the district court’s remand order, allowing the case to proceed in federal court. View "City of Brunswick v. Honeywell International, Inc." on Justia Law

USA v. Pineda-Torres

2026-08-03T11:01:47-08:00

Coast Guardsmen intercepted two stateless vessels in international waters, each carrying large quantities of cocaine traveling from Colombia to Mexico. Alonso Pineda-Torres, a Colombian citizen and resident, was involved in planning and preparing these smuggling operations, including paying crewmembers and assisting with a launch from Colombia. After his extradition to the United States, he was indicted under the Maritime Drug Law Enforcement Act for conspiracy to distribute and possess cocaine on a vessel subject to U.S. jurisdiction. In the United States District Court for the Middle District of Florida, Pineda-Torres initially pleaded not guilty, but later entered a plea agreement, admitting involvement in the operation. He moved to dismiss the indictment, arguing the court lacked jurisdiction because his conduct occurred abroad and he was not captured in international waters. The district court denied his motion, and he subsequently pleaded guilty. The United States Court of Appeals for the Eleventh Circuit reviewed the constitutionality of the statute as applied to Pineda-Torres. He argued the statute was invalid because his acts lacked a nexus to the United States and occurred solely in Colombia. The Eleventh Circuit rejected these arguments, relying on its precedent that the Act’s extraterritorial reach is supported by universal and protective principles, and that no nexus to the United States is required. The court held that, even if the Felonies Clause alone did not provide authority, the Necessary and Proper Clause empowered Congress to criminalize conspiracies to commit drug trafficking on the high seas, including land-based conduct like Pineda-Torres’s. Accordingly, the Eleventh Circuit affirmed the conviction, holding Congress had constitutional authority to punish this kind of conspiracy involving drug trafficking in international waters. View "USA v. Pineda-Torres" on Justia Law

USA v. Hernandez

2026-07-31T11:32:31-08:00

A nurse practitioner was accused of orchestrating a large-scale Medicare fraud scheme beginning in 2018. The evidence showed that she signed prescriptions for durable medical equipment and genetic testing that were medically unnecessary, often without examining patients or verifying their needs. She worked with telemarketers who cold-called Medicare beneficiaries, fabricated records, and sold prescriptions to medical providers who then billed Medicare. The practitioner received significant kickbacks for her participation and later recruited others to help. When government investigations targeted similar schemes, she attempted to cover her tracks but continued fraudulent conduct by billing for nonexistent telemedicine appointments, at times claiming over twenty-four hours of appointments in a single day. Ultimately, she received more than $1.66 million from these activities, and law enforcement discovered a written confession during a search of her residence. A grand jury indicted her on conspiracy, health care fraud, and false statement charges. Pretrial, the United States District Court for the Southern District of Florida denied her motion to exclude her written statement, finding the attorney-client privilege was waived. During jury selection, her request to strike a potentially biased juror for cause was denied, forcing her to use a peremptory challenge. At trial, disputes arose over the introduction of her inculpatory statement, and the court allocated more time for the government’s closing argument than for her defense. The jury found her guilty, and she was sentenced based on intended loss, not just actual billed amounts, despite her objections. The United States Court of Appeals for the Eleventh Circuit reviewed her claims, including the unequal allocation of closing argument time, a misstatement in oral jury instructions, jury selection issues, the handling of her statement, and sentencing calculations. The court held that although the district court abused its discretion by giving the government more closing argument time based solely on its burden of proof, this error was harmless due to overwhelming evidence of guilt. The court found no reversible error on the other grounds and affirmed her conviction. View "USA v. Hernandez" on Justia Law

Jones v. USA

2026-07-30T09:02:36-08:00

Two individuals were bowfishing on Lake Guntersville in Alabama when their boat collided with an unmarked, partially submerged duck blind, resulting in severe injuries. The duck blind, built by unknown persons prior to 2007, was affixed to land owned by the Tennessee Valley Authority (TVA), a federally owned corporation. The United States Coast Guard, the U.S. Army Corps of Engineers, and the TVA all have regulatory responsibilities over the lake, which is a navigable waterway. The plaintiffs alleged negligence and wantonness, claiming that the United States and the TVA failed to mark, remove, or warn about the hazard. The plaintiffs filed suit in the United States District Court for the Northern District of Alabama under two statutes: the Suits in Admiralty Act (SAA) and the TVA Act. Defendants moved to dismiss, arguing that the discretionary-function exception from the Federal Tort Claims Act (FTCA) shielded them from liability. The district court granted the motion, finding that the SAA's waiver of sovereign immunity was subject to the FTCA’s discretionary-function exception and that the conduct at issue was discretionary. On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s dismissal of all claims against the United States, holding that binding circuit precedent recognizes a discretionary-function exception under the SAA, which bars such claims. However, the Eleventh Circuit reversed the dismissal of the claims against the TVA under the TVA Act. The court held that the TVA’s sue-and-be-sued clause is not subject to the discretionary-function exception, allowing the plaintiffs’ claims against the TVA to proceed. The case was remanded for further proceedings against the TVA only. View "Jones v. USA" on Justia Law

The Town of Pine Hill, Alabama v. 3M Company

2026-07-29T07:31:42-08:00

A municipality in Alabama brought a lawsuit against a chemical manufacturer, alleging that the company’s products containing per- and poly-fluoroalkyl substances (PFAS) contaminated the Alabama River. The contamination allegedly originated from PFAS-containing wastewater discharged by paper mills, which used the manufacturer’s products. The municipality relies on water from the river for its drinking supply, and PFAS are difficult to remove with its current filtration system, necessitating expensive upgrades. After being sued in Alabama state court for negligence, nuisance, and trespass, the manufacturer removed the case to the United States District Court for the Southern District of Alabama, asserting jurisdiction under the federal officer removal statute. The municipality expressly disclaimed any claims related to PFAS contamination from aqueous film forming foam (AFFF), a firefighting product produced by the manufacturer for the military. The district court found that the heart of the claims was the supply of PFAS products to paper mills, not federal conduct, and remanded the case to state court. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court's decision de novo. The appellate court held that the manufacturer sufficiently alleged facts supporting federal officer removal jurisdiction. It concluded that the manufacturer plausibly acted under a federal officer when producing AFFF and that the complaint’s gravamen encompassed PFAS contamination generally, not just from paper mills. The court found the municipality’s disclaimers to be mere artful pleading that did not sever the causal connection required for removal. The manufacturer also plausibly asserted a colorable federal government contractor defense. Accordingly, the Eleventh Circuit vacated the district court’s remand order and remanded the case for further proceedings. View "The Town of Pine Hill, Alabama v. 3M Company" on Justia Law

African People's Education and Defense Fund, Inc. v. Pinellas County

2026-07-29T05:01:41-08:00

A nonprofit organization in Florida, serving the Black community in St. Petersburg, applied twice for COVID-19 relief grants from funds distributed by Pinellas County. The group’s first grant application was initially approved, but after a newly seated Board member raised concerns about the group’s association with the “Uhuru Movement” and its perceived ties to Black empowerment and alleged antisemitic organizations, the Board revoked the grant. The group’s second application, for a backup generator, was later denied despite being highly ranked by an independent review foundation. The nonprofit alleged that similar grants were awarded to other organizations serving predominantly white communities for comparable purposes. After the denial, the nonprofit sued Pinellas County in the United States District Court for the Middle District of Florida, alleging violations of the First Amendment (retaliation for expressive association), the Equal Protection Clause (racial discrimination), and the Due Process Clause (lack of notice and opportunity to be heard). The district court dismissed all claims with prejudice, concluding there was no actionable First Amendment or equal protection violation and that the nonprofit did not have a property interest protected by due process. The United States Court of Appeals for the Eleventh Circuit reviewed the appeal. It held that the nonprofit plausibly alleged First Amendment retaliation, as the facts showed the county may have revoked and denied grants based on the group’s expressive association, and that the organization was entitled to full First Amendment protection as a grant applicant. The court also held that the nonprofit stated a plausible claim for intentional racial discrimination under the Equal Protection Clause. However, the panel affirmed dismissal of the due process claim, finding the nonprofit lacked a constitutionally protected property interest in the grants. The case was affirmed in part, reversed in part, and remanded for further proceedings. View "African People's Education and Defense Fund, Inc. v. Pinellas County" on Justia Law

Davis v. Lockheed Martin Corp.

2026-07-28T11:32:05-08:00

The key facts concern allegations that Lockheed Martin improperly handled volatile organic compounds at its Orlando facility, resulting in environmental contamination that plaintiffs claim caused neurological illnesses, including multiple sclerosis and Parkinson’s disease, among workers and nearby residents. Plaintiffs relied on expert testimony to show that exposure to specific chemicals could cause the diseases in question. In the United States District Court for the Middle District of Florida, the plaintiffs presented two general causation experts who used epidemiological and other scientific methodologies to link the chemicals to the illnesses. Lockheed Martin challenged the admissibility of these experts’ opinions, arguing they were unreliable. The district court agreed, finding that the first expert failed to adequately explain or reliably apply his “weight of the evidence” methodology and did not sufficiently analyze the Bradford Hill factors. The second expert’s opinions were largely based on the first expert’s report and a statistical analysis that did not properly assess background risk. As a result, the district court excluded both experts’ testimony and granted summary judgment for Lockheed Martin, concluding that plaintiffs lacked admissible general causation evidence. In the related DeMilt case, the summary judgment was partial, but the district court certified it for immediate appeal under Rule 54(b). The United States Court of Appeals for the Eleventh Circuit reviewed whether the district court abused its discretion in excluding the experts and granting summary judgment. The appellate court held that the district court acted within its discretion, as the experts did not adequately explain or reliably apply their methodologies, and their testimony was thus properly excluded. Without this expert evidence, plaintiffs could not establish general causation. The Eleventh Circuit affirmed the district court’s orders excluding the experts and granting summary judgment in favor of Lockheed Martin. View "Davis v. Lockheed Martin Corp." on Justia Law

Bay United Holdings, LLC. v. INXS VII, LLC

2026-07-24T09:33:04-08:00

A company filed for Chapter 11 bankruptcy, which was later converted to Chapter 7. The trustee identified multiple parcels of real property that had been transferred to affiliated entities for no consideration, claiming these transfers were fraudulent. The parties settled, and it was agreed that the properties would be treated as assets of the bankruptcy estate and sold free and clear of liens, claims, and interests. The Bankruptcy Court approved the settlement and sale, ordering that any claims against the sale proceeds must be filed within thirty days. Cloud 9 Properties, LLC filed three claims related to the properties, attaching mortgage documents but initially lacking promissory notes. After an objection was raised due to insufficient evidence of debt owed to Cloud 9, Cloud 9 submitted the notes, but they showed the debts were actually owed to other entities at the relevant time. The United States Bankruptcy Court for the Middle District of Florida granted summary judgment for the objector, INXS VII, LLC, disallowing all of Cloud 9’s claims because Cloud 9 did not own the notes at the time the claims were filed. The District Court for the Middle District of Florida affirmed this decision, holding that only a party with an enforceable right to payment at the time of filing could assert a valid claim in bankruptcy. Bay United Holdings, LLC, which had been assigned Cloud 9’s claims, appealed, arguing that the existence of the mortgages justified the claims and that strict foreclosure standards should not apply in bankruptcy. The United States Court of Appeals for the Eleventh Circuit affirmed the District Court’s ruling. The court held that in bankruptcy, a creditor must demonstrate it has the right to enforce its claim at the time of filing. If a claimant cannot establish its entitlement to payment when the claim is filed, the claim is properly disallowed. The court rejected arguments for equitable relief and clarified that the validity of a claim in bankruptcy depends on enforceability under applicable state law. View "Bay United Holdings, LLC. v. INXS VII, LLC" on Justia Law

Carrin v. Smiledge

2026-07-23T11:32:32-08:00

Raymond Carrin was a federal detainee diagnosed with Hepatitis C who sought medical treatment while in custody at the Federal Detention Center in Tallahassee, Florida. Despite Carrin’s repeated requests and visible deterioration over more than a year—including emergency hospitalizations and symptoms consistent with advanced liver disease—medical staff did not provide him with the direct-acting antiviral treatment prescribed for his condition. The facility’s staff indicated that treatment would only begin once Carrin was transferred to his designated institution, a transfer that was delayed for various reasons. Carrin eventually died from hepatic cirrhosis without receiving the necessary medication. He did not file a formal grievance or seek relief under the prison’s Administrative Remedy Program (ARP) before his death. Carrin’s estate brought suit in the United States District Court for the Northern District of Florida against two federal prison officials, alleging violations of Carrin’s Fifth and Eighth Amendment rights and seeking damages under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 (1971). The district court initially denied the defendants’ motions to dismiss and for summary judgment. However, after the Eleventh Circuit’s decision in Johnson v. Terry, 119 F.4th 840 (11th Cir. 2024), the court granted judgment on the pleadings for the defendants, holding that the presence of the ARP constituted a special factor counseling against extending Bivens to these claims, and that Carrin’s case differed meaningfully from prior Supreme Court Bivens precedents. On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s dismissal. The court held that both the Eighth and Fifth Amendment claims arose in a new context distinct from Carlson v. Green, 446 U.S. 14 (1980), and that the existence of the ARP—regardless of its adequacy or accessibility to the estate—was a special factor precluding the extension of Bivens remedies. View "Carrin v. Smiledge" on Justia Law

Rodriguez v. Imperial Brands, PLC.

2026-07-23T05:01:45-08:00

Several U.S. nationals, descendants of Ramón Rodriguez Gutiérrez, alleged that their family’s property in Cuba was confiscated by the Cuban government in 1961. They claimed ownership of a significant interest in a Havana cigarette factory and an adjacent mixed-use building, both seized as part of the nationalization of the tobacco industry. The plaintiffs sued multiple corporations, including two British companies, asserting that these entities had trafficked in the confiscated property in violation of the Helms-Burton Act by marketing and publicizing Cuban tobacco products made at the seized factory, including activities on U.S.-based social media platforms. The United States District Court for the Southern District of Florida reviewed the case after the plaintiffs filed a second amended complaint. Following jurisdictional discovery, a magistrate judge recommended dismissal for improper venue for some defendants, and for lack of personal jurisdiction for others, specifically Imperial Brands and WPP. The district court adopted the recommendation to dismiss the claims against these British corporations, finding that the plaintiffs had failed to establish personal jurisdiction under Federal Rule of Civil Procedure 4(k)(2), as their alleged U.S.-related activities were insufficient to confer jurisdiction. The United States Court of Appeals for the Eleventh Circuit examined whether federal courts could exercise personal jurisdiction over Imperial Brands and WPP in light of the Supreme Court’s decision in Fuld v. Palestine Liberation Organization. The Eleventh Circuit held that the Fifth Amendment imposes a “reasonableness” standard for personal jurisdiction over foreign defendants. Applying this standard, the court found that neither Imperial Brands nor WPP had sufficient notice, meaningful U.S. connections, or presence to justify jurisdiction. The court concluded that subjecting these companies to U.S. jurisdiction would be unreasonable and affirmed the district court’s dismissal for lack of personal jurisdiction. View "Rodriguez v. Imperial Brands, PLC." on Justia Law

USA v. Rivera

2026-07-22T12:31:45-08:00

A man became involved with a woman who had a minor daughter. After the woman and her daughter moved in with him, the man’s relationship with the daughter deteriorated, especially after he assaulted her mother. Despite the girl’s reluctance to engage with him, he persistently attempted to discuss her personal and sexual life and offered her gifts. Unbeknownst to her, these gifts—a Bluetooth speaker, a USB charger, and a digital picture frame—each contained hidden recording devices, which he installed in her bedroom. The girl’s mother discovered the hidden cameras after breaking up with the man and notified authorities. Investigators found evidence on the man’s phones linking him to the purchase and use of the devices, as well as sexually explicit images and videos of the girl changing clothes, which were recovered from his devices. The United States District Court for the Middle District of Florida presided over the trial. The government provided notice of its intent to introduce evidence of prior similar acts, specifically testimony from another woman who alleged that the defendant had sexually abused her as a minor. During trial, this witness’s testimony included a statement that went beyond what was disclosed in the government’s pretrial notice. The defense objected, moved for a mistrial, and requested that all of the witness’s testimony be stricken, arguing it was unreliable and unduly prejudicial. The district court struck only the unexpected portion, issued curative instructions to the jury, and denied the motions for mistrial and to strike all testimony. The jury convicted the defendant on all counts, and he was sentenced to 262 months’ imprisonment. On appeal, the United States Court of Appeals for the Eleventh Circuit held that the district court did not abuse its discretion in admitting the prior-act evidence, denying a mistrial, or refusing to strike all of the witness’s testimony. The court also held that the evidence was sufficient to support the convictions under 18 U.S.C. § 2251. The convictions were affirmed. View "USA v. Rivera" on Justia Law

Savannah Shoals, LLC v. Commissioner of Internal Revenue

2026-07-16T12:02:07-08:00

A developer purchased approximately 430 acres in Georgia and later sold a 103-acre tract to an investment company. This company, Savannah Shoals, LLC, planned to donate a conservation easement over the 103-acre tract. Expert testing determined that the property contained materials suitable for use as crushed rock aggregate, and an expert report valued the potential of an aggregate quarry on the property at $23.1 million. Savannah Shoals then completed a series of transactions to acquire and transfer membership interests in the property, after which it granted the conservation easement and claimed a $23 million tax deduction for its donation. The Internal Revenue Service (IRS) disallowed the deduction, arguing that Savannah Shoals had grossly overstated the value of the easement. The IRS issued a Final Partnership Administrative Adjustment, finding the deduction unsupported and imposing a 40% penalty for gross valuation misstatement. Savannah Shoals challenged these findings in the United States Tax Court. After a four-day trial with expert testimony, the Tax Court concluded that the property’s highest and best use was not as an aggregate quarry, but rather for low-density residential and recreational purposes. Relying on comparable sales and the actual transaction value, the Tax Court determined the easement’s value to be $480,000 and upheld the 40% penalty. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the Tax Court’s decision. The Eleventh Circuit held that the Tax Court was not required to apply a specific four-factor test for highest and best use and that its focus on market demand and feasibility was appropriate under the law and regulations. The appellate court also found no abuse of discretion in the admission of expert testimony and concluded that the Tax Court’s factual findings were not clearly erroneous. The judgment of the Tax Court was affirmed. View "Savannah Shoals, LLC v. Commissioner of Internal Revenue" on Justia Law

Estate of Caviness v. Atlas Air, Inc.

2026-07-10T05:31:52-08:00

A group of employees in the commercial aviation sector challenged their employers’ COVID-19 policies, which required vaccination unless a religious or medical exemption was obtained. Those with exemptions had to comply with periodic testing and mask-wearing. The plaintiffs objected to the requirements on religious and personal grounds, alleging that the accommodations for religious objectors were inadequate and burdensome. While the complaint did not claim anyone was terminated, it did allege some employees were assigned to less desirable flights due to these policies. The United States District Court for the Southern District of Florida dismissed all claims against Flight Services International and certain claims against Atlas Air for lack of personal jurisdiction. The court also dismissed the remaining claims against Atlas Air for failure to state a claim. The plaintiffs then appealed to the United States Court of Appeals for the Eleventh Circuit. The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The appellate court held that there was no personal jurisdiction over Flight Services International because it was neither incorporated nor headquartered in Florida, and the alleged contacts with Florida were insufficient for either general or specific jurisdiction. Regarding Atlas Air, the court found that the plaintiffs failed to state a plausible claim under Title VII, as there were no facts suggesting religious discrimination or hostile intent. The court held that the plaintiffs could not bring claims under the Federal Food, Drug, and Cosmetic Act, as enforcement is limited to the federal government. Constitutional claims under § 1983 and Bivens failed because Atlas Air is a private entity. Additionally, the state law tort claims for invasion of privacy, negligent disclosure, and intentional infliction of emotional distress were found insufficiently pleaded or unsupported by the alleged facts. The judgment of dismissal was affirmed. View "Estate of Caviness v. Atlas Air, Inc." on Justia Law

USA v. Brillhart

2026-07-09T12:02:08-08:00

A man was investigated after Google and Yahoo flagged several of his email accounts for sending and storing what appeared to be child pornography. Both companies identified the user through information like a shared recovery phone number, birthdate, and selfies associated with the accounts. Yahoo manually reviewed and confirmed the images as child pornography before reporting them to the National Center for Missing and Exploited Children (NCMEC). Google used both human review and a hash-value matching protocol, whereby a file’s unique digital fingerprint was compared against a database of previously identified illegal images. One of the files in the defendant’s account matched the hash of a known child pornography image. Law enforcement, after receiving tips from NCMEC, conducted warrantless searches and confirmed the illicit nature of the files, leading to search warrants for the defendant’s residence and devices, which yielded more incriminating evidence. The United States District Court for the Middle District of Florida denied the defendant’s motions to suppress the evidence (arguing a Fourth Amendment violation), to dismiss one of the charges on double jeopardy grounds, and to exclude certain evidence. The court also rejected his arguments concerning the admissibility of defense evidence, the sufficiency of the evidence, and the jury instructions. The defendant was convicted by a jury on both distribution and possession charges and given an enhanced sentence based on a finding of a pattern of activity involving abuse or exploitation. His subsequent motions for psychological evaluation and sentencing continuance were also denied. On appeal, the United States Court of Appeals for the Eleventh Circuit held that Google’s use of hash-value matching constituted a valid private search under the Fourth Amendment, so the government’s warrantless review did not violate the defendant’s rights. The court also held that possession and distribution of child pornography are separate offenses for double jeopardy purposes. The appellate court affirmed all district court decisions except for the application of a pattern-of-activity sentencing enhancement, which it found improper; it vacated the sentence and remanded for resentencing. View "USA v. Brillhart" on Justia Law

Clayton v. Essentia Insurance Company

2026-07-08T06:01:59-08:00

The case concerns an Alabama resident who was injured by an uninsured motorist while riding his motorcycle. At the time, he held two separate insurance policies: a standard auto insurance policy from GEICO covering his motorcycle, and a specialty policy from Essentia Insurance Company covering his antique truck. The GEICO policy provided uninsured motorist coverage as required by Alabama law, and the insured collected $25,000 under it. Essentia’s policy, which covered only the antique vehicle, excluded uninsured motorist coverage for accidents involving vehicles other than the covered antique truck. The policy also required the insured to maintain a separate insurance policy that satisfied Alabama’s minimum coverage requirements. After Essentia denied his claim for uninsured motorist coverage, the insured brought suit in the United States District Court for the Middle District of Alabama. Essentia moved for summary judgment, arguing that its specialty policy’s coverage exclusion was valid because the insured had other coverage meeting Alabama’s requirements. The district court denied Essentia’s motion in part, holding Essentia liable for uninsured motorist benefits, but limited the liability to the statutory minimum of $25,000, and entered judgment accordingly. Essentia appealed. The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s summary judgment de novo and reversed. The Eleventh Circuit held that Alabama law permits insurers to fulfill mandatory coverage requirements through multiple policies, and that Essentia’s exclusion is enforceable so long as the insured has other coverage meeting statutory requirements. The court remanded the case for further proceedings consistent with its opinion. View "Clayton v. Essentia Insurance Company" on Justia Law

Marbury v. Warden

2026-07-07T11:02:05-08:00

An inmate at St. Clair Correctional Facility in Alabama brought suit under 42 U.S.C. § 1983 after he was assaulted by another prisoner in 2018. Previously, he had been attacked in 2016 and had requested transfer to segregation due to safety concerns but was denied by prison officials. Upon his return to St. Clair in 2017, he again sought protective housing, citing ongoing threats and hazardous conditions, including frequent violence, unauthorized inmate movement, and periods of absent supervision. Despite these requests, he remained in the general population and was ultimately assaulted, resulting in serious injuries. The United States District Court for the Northern District of Alabama first dismissed most of his claims, allowing only the Eighth Amendment deliberate-indifference claim based on a generalized risk of violence to proceed. After discovery, the district court granted summary judgment to the prison officials, finding that the plaintiff had failed to establish a genuine dispute of material fact as to whether he faced a substantial risk of serious harm. In an earlier appeal, the United States Court of Appeals for the Eleventh Circuit vacated the summary judgment due to improper denial of discovery, remanding for further proceedings. On remand, the district court again granted summary judgment, reasoning that the plaintiff had not sufficiently contextualized the violence statistics or provided adequate support for his allegations. Upon review, the United States Court of Appeals for the Eleventh Circuit held that the plaintiff had provided sufficient evidence—including statistical data on inmate assaults, contextual information about prison conditions, and sworn allegations of specific dangerous features—to create a genuine dispute of material fact regarding exposure to a substantial risk of serious harm. The court vacated the district court’s grant of summary judgment and remanded for further proceedings. View "Marbury v. Warden" on Justia Law

Pernell v. Commissioner of the FL State Board of Education

2026-07-07T06:31:44-08:00

Florida enacted a law prohibiting public university professors from endorsing or promoting certain ideas related to race, color, sex, and national origin in classroom instruction. The law, known as the Individual Freedom Act, identifies eight specific concepts that professors are barred from espousing, such as claims of moral superiority based on race or sex, inherent racism or oppression, and the idea that virtues like merit or colorblindness are themselves racist or sexist. The law allows professors to discuss these concepts in a neutral way, but not to advocate for them, and imposes severe penalties on both individual professors and universities for violations, including the loss of significant funding and potential termination of employment. Groups of professors and students from several Florida public universities filed lawsuits in the United States District Court for the Northern District of Florida, arguing that the Act violated their First Amendment rights by restricting viewpoint-based expression and was unconstitutionally vague. The district court granted preliminary injunctions in both cases, enjoining enforcement of the Act’s classroom restrictions against the plaintiffs, finding that at least one plaintiff had standing to challenge each prohibited concept. The court concluded the Act was likely unconstitutional as applied to public university professors. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s grant of a preliminary injunction. The Eleventh Circuit affirmed, holding that the Act’s restrictions amount to unconstitutional viewpoint discrimination in violation of the First Amendment. The court distinguished between permissible curricular control by universities and the broad, legislative ban imposed by the state’s political branches. It concluded that neither public-employee speech doctrine nor government speech doctrine justified the law’s suppression of disfavored ideas in the university classroom, and that the Act impermissibly infringed on academic freedom and open inquiry. The preliminary injunction was affirmed. View "Pernell v. Commissioner of the FL State Board of Education" on Justia Law

State of Florida v. Secretary, US Department of Education

2026-07-06T09:32:09-08:00

The dispute centers on whether the U.S. Department of Education may constitutionally rely on private educational accreditors in disbursing federal education funds. Under the Higher Education Act, colleges and universities must be accredited by a recognized accreditor for their students to be eligible for federal financial aid. Accreditors are private, voluntary organizations funded by the schools they accredit. Florida challenged this arrangement, alleging that it unconstitutionally delegates government power to private accreditors and violates both the Appointments Clause and the Spending Clause, claiming the accreditation requirement is an unascertainable condition for federal funds. The United States District Court for the Southern District of Florida reviewed the suit after Florida brought four claims: a private nondelegation doctrine challenge, an Appointments Clause challenge, a Spending Clause challenge, and a now-abandoned Administrative Procedure Act challenge. The federal government moved to dismiss, and the district court granted the motion. The district court found no unlawful delegation of government power, noted that Title IV funds are directed to students and not institutions, determined the accreditation requirement is unambiguous, and dismissed the Appointments Clause claim because accreditors do not determine eligibility for federal funds. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s dismissal de novo. The Court held that private accreditors do not exercise government authority that could violate the Vesting Clauses or the Appointments Clause. The Court also determined that the accreditation requirement is an ascertainable condition for federal funds, as it is a well-understood, longstanding practice and does not amount to an ambiguous or novel restriction. The Eleventh Circuit affirmed the district court’s dismissal of Florida’s suit. View "State of Florida v. Secretary, US Department of Education" on Justia Law

Henry v. Sheriff of Tuscaloosa County, Alabama

2026-07-06T07:32:30-08:00

A man who was convicted of possessing child pornography in 2013 served his sentence and later married and had a son. Despite completing sex offender treatment and complying with supervised release conditions, he remained subject to Alabama’s Sex Offender Registration and Community Notification Act (“the Act”). This law prohibits him, for life, from residing with or conducting overnight visits with any minor—including his own child—because his conviction involved a child-related offense. The Act contains no mechanism for relief or individualized assessment, even for parents who have shown rehabilitation. After the birth of his son, the man sued the Sheriff and District Attorney of Tuscaloosa County and the Alabama Attorney General under 42 U.S.C. § 1983, seeking to enjoin enforcement of the Act’s prohibition against living with his child. The United States District Court for the Middle District of Alabama granted summary judgment in his favor, declaring the Act’s prohibition facially unconstitutional and issuing a universal injunction. On appeal, a panel of the United States Court of Appeals for the Eleventh Circuit affirmed in part, reversed in part, and vacated and remanded in part, finding the Act unconstitutional as applied to the plaintiff but vacating the universal injunction. The panel’s opinion was then vacated, and the case was reheard en banc. The United States Court of Appeals for the Eleventh Circuit held that all parents—including those with past convictions or “misconduct”—enjoy a fundamental right to live with their children under the Fourteenth Amendment. The court rejected Alabama’s argument that certain classes of parents lack this right due to prior offenses. The court remanded the case to the panel for further proceedings under strict scrutiny, requiring Alabama to show its law is narrowly tailored to serve a compelling state interest. The court affirmed in part and remanded in part. View "Henry v. Sheriff of Tuscaloosa County, Alabama" on Justia Law

USA v. Carter

2026-07-06T05:02:05-08:00

The case concerns a defendant who pleaded guilty to possessing a firearm as a convicted felon, in violation of federal law. The defendant had four prior convictions under Georgia law for drug offenses involving cocaine, all committed on separate occasions. These prior convictions were used to classify him as an “armed career criminal,” triggering a mandatory minimum sentence of 15 years under the Armed Career Criminal Act (ACCA). The defendant did not dispute the existence of these convictions or that they occurred on different occasions. However, he argued that Georgia’s definition of cocaine is broader than the federal definition, contending that this difference should prevent his prior convictions from qualifying as ACCA predicate offenses. The United States District Court for the Middle District of Georgia overruled the defendant’s objection to the ACCA enhancement. The court concluded that the Georgia convictions counted as “serious drug offenses” under the ACCA and sentenced him to 210 months in prison. During sentencing, the court rejected arguments based on an expert’s declaration claiming a definitional mismatch between state and federal cocaine laws. Upon review, the United States Court of Appeals for the Eleventh Circuit considered whether Georgia law, by defining cocaine more broadly than federal law, rendered the prior convictions ineligible for ACCA enhancement. The appellate court held that for a substance to be a controlled substance under Georgia law, it must be listed on both Georgia and federal drug schedules. Thus, even if Georgia’s statutory language is broader, a conviction could not be based on conduct outside the federal definition. The court also rejected an argument based on changes to the federal schedules concerning “ioflupane.” The Eleventh Circuit affirmed the district court’s application of the ACCA enhancement. View "USA v. Carter" on Justia Law

Edwards v. Grubbs

2026-06-30T10:02:15-08:00

A 65-year-old homeless man was encountered by two Atlanta police officers near a highway on-ramp after he was observed receiving money from a driver. When approached, he fled on foot, and one officer pursued him across traffic. The man, unarmed and non-threatening, crossed a guardrail and began descending a steep embankment toward a highway. Without giving a verbal warning, the officer fired his taser in dart mode, striking the man in the back, causing him to fall down the embankment and suffer catastrophic injuries, including traumatic brain injury and quadriplegia. The man’s guardian filed suit in the United States District Court for the Northern District of Georgia against the officer and the City under 42 U.S.C. § 1983, alleging excessive force, as well as related state-law claims. The district court granted partial summary judgment on certain state claims and dismissed others by stipulation. At trial, the jury found in favor of the plaintiff, awarding $60 million against the City and $40 million against the officer (split between compensatory and punitive damages). The district court later set aside the verdict against the City, holding there was insufficient evidence of municipal liability, and reduced the punitive damages against the officer to $1 million. The United States Court of Appeals for the Eleventh Circuit reviewed these outcomes. It held that the officer was not entitled to qualified immunity, because tasing an unarmed, non-dangerous suspect fleeing on foot in a highly dangerous location, without warning, constituted excessive force under clearly established law. The appellate court affirmed setting aside the verdict against the City, finding insufficient evidence that any City policy or failure to enforce the body camera policy was the moving force behind the violation. The reduction of punitive damages to $1 million was upheld as constitutional. The court also affirmed the district court’s rulings on medical expenses and attorney’s fees. View "Edwards v. Grubbs" on Justia Law

Scott v. City of Daytona Beach

2026-06-25T12:31:58-08:00

Four individuals who regularly engage in panhandling in Daytona Beach, Florida, challenged the city’s 2019 ordinance that imposed wide-ranging restrictions on panhandling. They argued that the law, which defined panhandling as in-person requests for immediate donations, and which banned or restricted this conduct in various locations and circumstances, violated their First Amendment rights. Each plaintiff relied on panhandling for basic needs and had faced threats, arrests, or other enforcement actions as a result of the ordinance. The United States District Court for the Middle District of Florida reviewed the case and granted summary judgment in favor of the plaintiffs. The court found that the ordinance’s challenged provisions were content-based, failed strict scrutiny, and thus violated the First Amendment. It issued a declaratory judgment, a universal injunction against enforcement of the challenged provisions, and awarded damages as agreed by the parties. The City of Daytona Beach appealed these decisions. On appeal, the United States Court of Appeals for the Eleventh Circuit held that the ordinance imposed content-based restrictions on speech by targeting only in-person requests for immediate donations, distinguishing them from other types of solicitation. The court found that several provisions could not withstand strict scrutiny, as the city had less speech-restrictive means to achieve its public health and safety goals. However, the Eleventh Circuit determined that the plaintiffs had standing to challenge only some, not all, of the ordinance’s provisions and that the district court’s remedy was overbroad. The appellate court affirmed the district court’s ruling as to the provisions where at least one plaintiff had standing, vacated it in other respects, and remanded for further proceedings consistent with its opinion. The damages award was affirmed because at least one provision was found unconstitutional. View "Scott v. City of Daytona Beach" on Justia Law

U.S. All Star Federation, Inc. v. Open Cheer & Dance Championship Series, LLC

2026-06-24T10:32:51-08:00

Two organizations involved in competitive cheerleading became embroiled in a dispute over the use of two marks: “THE CHEERLEADING WORLDS,” which is registered on the Supplemental Register with the U.S. Patent and Trademark Office, and “WORLDS,” which is claimed as an unregistered common law mark. The plaintiff, a governing body for competitive cheerleading, has held an annual event under these marks since 2004. The defendants, including a group of former members of the plaintiff organization, began hosting a similarly named event in the same region, allegedly causing confusion among participants and the public. The United States District Court for the Middle District of Florida granted summary judgment for the defendants, concluding that both marks were generic as a matter of law and thus not entitled to trademark protection. The court found that the terms described the basic nature of the plaintiff’s services and discounted evidence showing non-generic use, reasoning that the plaintiff’s event had long been the only one of its kind. The court also rejected the plaintiff’s argument that the defendants were barred from contesting the marks’ distinctiveness due to an earlier dismissal of an affirmative defense with prejudice. On appeal, the United States Court of Appeals for the Eleventh Circuit reversed. The appellate court held that the issue of distinctiveness was properly before the district court, as distinctiveness is an element of the plaintiff’s claim and not an affirmative defense. The Eleventh Circuit found that there were genuine disputes of material fact as to whether the marks were descriptive or had acquired secondary meaning, based on evidence of public association with the plaintiff’s event. The court remanded the case for trial, holding that summary judgment was inappropriate because a reasonable jury could find the marks protectable. The court also declined to decide issues of likelihood of confusion and individual liability without factual findings. View "U.S. All Star Federation, Inc. v. Open Cheer & Dance Championship Series, LLC" on Justia Law

Braggs v. Commissioner, Alabama Department of Corrections

2026-06-24T10:32:51-08:00

A group of inmates incarcerated within Alabama’s state prison system filed a class action challenging the adequacy of mental health care provided by the Alabama Department of Corrections (ADOC). The plaintiffs, who suffer from serious mental illnesses, alleged that overcrowding, understaffing, and a series of systemic failures resulted in constitutionally deficient mental health services, contributing to a suicide rate far above the national average. Key alleged deficiencies included improper identification and classification of mental health needs, inadequate treatment plans, insufficient psychotherapy, lack of proper suicide risk management, improper use of segregation for mentally ill inmates, and the imposition of disciplinary sanctions for manifestations of mental illness. The United States District Court for the Middle District of Alabama managed the litigation in multiple phases. After a seven-week bench trial, the court found the ADOC liable under the Eighth Amendment for deliberate indifference to inmates’ serious mental health needs. The court then held extensive remedial proceedings, including further hearings and negotiations, and entered a comprehensive, system-wide remedial injunction. The court made detailed factual findings and, to comply with the Prison Litigation Reform Act (PLRA), issued particularized findings that the relief ordered was necessary, narrowly drawn, and the least intrusive means to remedy the constitutional violations. The court also adopted a monitoring plan to ensure compliance, involving external experts and a transition to internal oversight. On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s liability findings and most aspects of the remedial and monitoring orders, holding that system-wide relief was appropriate given the systemic nature of the violations. However, the appellate court reversed certain remedial provisions where it found the relief exceeded what was necessary to correct the constitutional violations, particularly with respect to suicide-proofing cells and some staffing requirements, and as applied to a women’s facility where violations were not established. The case was remanded for modification in those limited respects. View "Braggs v. Commissioner, Alabama Department of Corrections" on Justia Law

Hayles v. U.S. Attorney General

2026-06-22T08:31:56-08:00

A Jamaican citizen entered the United States unlawfully, claiming fear of political persecution in his home country. While in the United States, he was convicted of voluntary manslaughter and battery, resulting in a 20-year prison sentence. After completing his sentence, the Department of Homeland Security (DHS) detained him for administrative removal proceedings based on his aggravated felony convictions. The individual expressed fear of torture if returned to Jamaica, prompting referral to withholding-only proceedings to determine eligibility for deferral of removal under the Convention Against Torture (CAT). The immigration judge denied CAT relief, and the Board of Immigration Appeals affirmed that decision. DHS issued a final administrative removal order separately. The petitioner, acting pro se, filed for judicial review in the United States Court of Appeals for the Eleventh Circuit, challenging only the denial of CAT relief and not the underlying removal order. He acknowledged the petition was untimely and cited procedural issues, such as not receiving necessary legal resources. Subsequently, appointed counsel raised additional due process claims and contested the adverse CAT determination. The Eleventh Circuit ordered supplemental briefing to address jurisdiction. The United States Court of Appeals for the Eleventh Circuit held that it lacked jurisdiction to review the denial of CAT relief unless the petition for review also challenged a final order of removal. The court reasoned that under the relevant statutes, including the Illegal Immigration Reform and Immigrant Responsibility Act, the Foreign Affairs Reform and Restructuring Act, and the REAL ID Act, judicial review of CAT claims is only available as part of a review of a final removal order. Because the petition did not challenge the removal order, the court dismissed it for lack of jurisdiction. View "Hayles v. U.S. Attorney General" on Justia Law

Akel v. USA

2026-06-18T12:31:55-08:00

The petitioner was convicted after a jury trial of conspiracy to distribute and possess MDMA, marijuana, and cocaine; possession with intent to distribute marijuana; and possession of a firearm by a convicted felon. He was sentenced to concurrent terms of 480 months’ imprisonment for each count, with enhancements including one under the Armed Career Criminal Act. The original judgment erroneously included a cocaine charge for Count Two, although the jury only found marijuana involvement. The district court’s judgment reflected this mistake. On direct appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the convictions and sentences. Later, the petitioner filed an initial motion to vacate his sentence under 28 U.S.C. § 2255, challenging the ACCA enhancement. The district court denied the motion, and the Eleventh Circuit denied a certificate of appealability. The Supreme Court subsequently vacated that denial and remanded in light of Mathis v. United States. On remand, the district court found the ACCA enhancement was improper and that the sentence for Count Two exceeded the statutory maximum, so it resentenced the petitioner and entered an Amended Judgment with reduced sentences for Counts Two and Seven and corrected the charge for Count Two. After exhausting direct appeal of the Amended Judgment, the petitioner filed a new § 2255 motion raising claims relating both to the original trial and the resentencing. The district court for the Northern District of Florida dismissed eight claims as unauthorized “second or successive” claims. The petitioner appealed. The United States Court of Appeals for the Eleventh Circuit held that the new § 2255 motion was not “second or successive” because it challenged a new, intervening Amended Judgment. The court vacated the district court’s dismissal and remanded for further proceedings. View "Akel v. USA" on Justia Law

USA v. Spearman

2026-06-18T06:01:35-08:00

The case concerns a man who served as lead administrator for a large, international child pornography network operating via a dark web site, “Website A.” The website used the Tor network to mask users’ IP addresses and facilitate the sharing of child pornography through links and chat rooms, with elaborate systems to reward participation. The defendant rose from a regular user to the main administrator, supervising other staff and overseeing the website’s operations. In 2022, after a separate investigation and arrest of another high-ranking website member, the FBI received tips from a foreign law enforcement agency (FLEA) identifying an IP address associated with the website’s management, which was traced to the defendant’s address in Alabama. The FBI obtained a warrant, searched the home, found extensive evidence, and obtained incriminating admissions from the defendant. Following his arrest and arraignment in the United States District Court for the Southern District of Florida, the defendant moved to suppress the evidence, arguing that the FBI’s collaboration with the FLEA amounted to a “joint venture,” meaning the foreign search should be subject to Fourth Amendment scrutiny. He claimed he was entitled to an evidentiary hearing on this issue. The district court denied the motion without a hearing, finding the allegations speculative and not sufficiently detailed to require one. The defendant subsequently pled guilty and was sentenced to life imprisonment, despite presenting mitigating evidence including significant military service and mental health history. On appeal, the United States Court of Appeals for the Eleventh Circuit held that the district court did not abuse its discretion in denying an evidentiary hearing or in refusing to suppress the evidence. The court found the defendant’s allegations did not establish the necessary FBI involvement in the foreign search to trigger Fourth Amendment protections. The court also held that the life sentence was substantively reasonable, given the nature of the offense and the district court’s consideration of mitigating factors. The conviction and sentence were affirmed. View "USA v. Spearman" on Justia Law