Justia U.S. 11th Circuit Court of Appeals Opinion Summaries

A federal prisoner serving a sentence for drug-related offenses sought compassionate release, arguing that he was the only available caregiver for his incapacitated father living in Honduras. The prisoner’s father had become bedridden and previously relied on the care of the prisoner’s former partner, who could no longer provide assistance due to her own health problems. The prisoner asserted that none of his five children could serve as caregivers: one was deceased, one’s whereabouts were unknown, two resided in the United States and could not relocate, and the remaining son, Elmer, lived four hours away in Honduras but faced logistical and economic barriers to providing care.The United States District Court for the Northern District of Florida initially denied the compassionate release motion, finding that the prisoner had not demonstrated the unavailability of other family members as caregivers. After the prisoner renewed his motion with more details, the district court again denied relief, concluding that Elmer, despite living several hours away and having work and family obligations, was nonetheless an available caregiver. The court reasoned that the practical burdens cited were not sufficient to show unavailability.On appeal, the United States Court of Appeals for the Eleventh Circuit addressed the meaning of “only available caregiver” under U.S.S.G. § 1B1.13(b)(3)(C). The court held that an inmate must show that no other person is both qualified and free to provide the needed care, and outlined relevant factors for district courts to consider in making this determination. Applying this standard, the Eleventh Circuit found no clear error in the district court’s determination that Elmer was available to provide care, and affirmed the denial of compassionate release. View "United States v. Robelo-Galo" on Justia Law

The case involves a man who was convicted of first-degree murder in Broward County, Florida, after a fatal shooting during a domestic dispute with his girlfriend. The key evidence during trial was a confession obtained by police after the man initially invoked his right to counsel but later agreed to speak with detectives. This confession was not admitted as direct evidence at his second trial but was used extensively to impeach his testimony when he took the stand in his own defense. The prosecution also presented substantial physical and eyewitness evidence, including the testimony of two individuals present at the scene and expert forensic analysis.After his conviction, the defendant challenged the use of his statement in postconviction proceedings. The Florida trial court denied his motion for a new trial, and the Florida Fourth District Court of Appeal affirmed. The defendant later argued in a state postconviction proceeding that his trial counsel was ineffective for failing to challenge the statement on the grounds that it was coerced, in violation of the Due Process Clause. The state postconviction court, adopting the State’s response, found that the defendant was not prejudiced by any alleged error of his counsel, as the other evidence against him was overwhelming. The Fourth DCA affirmed without opinion.The United States Court of Appeals for the Eleventh Circuit reviewed the denial of federal habeas corpus relief. The court held that the state court had adjudicated the prejudice prong of the ineffective assistance claim on the merits, entitling its decision to deference under the Antiterrorism and Effective Death Penalty Act. The Eleventh Circuit found that the state court’s determination—that the outcome would not have been different even if the statement had been excluded—was neither contrary to nor an unreasonable application of federal law. Accordingly, the denial of habeas relief was affirmed. View "Calder v. Secretary, Florida Department of Corrections" on Justia Law

A franchisee brought several claims against a franchisor and related parties, including allegations of breach of contract, unjust enrichment, violations of Florida law, and Fair Labor Standards Act (“FLSA”) violations. The parties settled, with the franchisee receiving $50,000 and both sides signing a mutual release that broadly barred any future claims. The agreement was not approved by a court or the Department of Labor and contained a confidentiality provision. Subsequently, the franchisee initiated a separate action for fraudulent transfer and other non-FLSA claims, arguing these were not barred by the settlement’s release.After the settlement, the franchisee filed a supplemental complaint in the United States District Court for the Middle District of Florida, alleging fraudulent transfer and related non-FLSA claims. The franchisor responded with a motion for judgment on the pleadings, citing the settlement’s release. The franchisor also filed counterclaims, including breach of contract based on the franchisee’s new filings. The franchisee attempted to amend his complaint to add a claim for rescission, arguing fraudulent inducement, but the magistrate judge denied this motion, finding it was inadequately pleaded and untimely. The franchisee did not properly object to this denial before the district judge.The United States Court of Appeals for the Eleventh Circuit considered whether the unapproved settlement agreement barred the non-FLSA claims. The court held that, while FLSA claims cannot be waived or settled without court or Department of Labor approval, non-FLSA claims may be released according to state contract law. The court found the release enforceable under Florida law as to non-FLSA claims and affirmed the district court’s dismissal of the fraudulent transfer claims and grant of summary judgment to the franchisor on its counterclaims. The court also ruled the franchisee had waived his right to appeal the denial of his motion to amend. View "O'Neal v. American Shaman Franchise Systems, Inc." on Justia Law

A man was charged with one count of conspiracy to commit money laundering and seven counts of money laundering after opening numerous bank accounts and using them to launder millions of dollars in fraud proceeds for a group operating romance and business email scams. He also recruited and supervised a co-conspirator, helping that person set up a similar laundering operation. The laundered funds were ultimately sent to Africa. Following his arrest, the defendant attempted to cooperate with the government but did not enter into a plea agreement. At his first change-of-plea hearing, he hesitated and the hearing was postponed. At the second hearing, with two lawyers present, he pleaded guilty to all charges, affirming he did so knowingly and voluntarily.Before sentencing, the defendant’s bond was revoked after he was arrested for assaulting his girlfriend. While in custody, he moved to withdraw his guilty plea, alleging one of his lawyers coerced him into pleading guilty and that he was not aware of a co-conspirator’s cooperation with the government. The United States District Court for the Northern District of Georgia held an evidentiary hearing, found the attorneys credible and the defendant not credible, and denied the motion to withdraw the plea.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the denial of the motion to withdraw the guilty plea, the calculation of the loss amount, several sentencing enhancements, the denial of a reduction for acceptance of responsibility, and the substantive reasonableness of the 120-month sentence. The court held that the district court did not abuse its discretion in denying the motion to withdraw the plea, did not err in its application of sentencing enhancements and guidelines, and that the sentence imposed was substantively reasonable. The court affirmed the judgment. View "USA v. Mullings" on Justia Law

In 2008, a federal grand jury indicted Michael Bowe on charges including conspiracy and attempt to commit Hobbs Act robbery, and for using, brandishing, or discharging a firearm during and in relation to a crime of violence, with the firearm offense predicated on the Hobbs Act offenses. Bowe pleaded guilty and admitted in court to shooting a security guard during the attempted robbery. He was sentenced in 2009 to 288 months’ imprisonment, including a mandatory 120-month consecutive sentence for the firearm offense. He did not file a direct appeal.Over the years, Bowe challenged his conviction and sentence through several motions under 28 U.S.C. § 2255, citing Supreme Court decisions such as Johnson v. United States, United States v. Davis, and United States v. Taylor, which altered the understanding of what qualifies as a “crime of violence” under § 924(c). His initial and successive motions were denied by the United States District Court and the United States Court of Appeals for the Eleventh Circuit, largely because, at the time, circuit precedent held that attempted Hobbs Act robbery remained a crime of violence. The Eleventh Circuit repeatedly denied his applications, relying on its decision in In re Baptiste, which interpreted statutory bars to successive claims as applicable to federal prisoners.Subsequently, the Supreme Court abrogated Baptiste, holding that 28 U.S.C. § 2244(b)(1)’s bar on “old claims” does not apply to federal prisoners seeking successive § 2255 motions. On remand, the United States Court of Appeals for the Eleventh Circuit held that Bowe made a prima facie showing under § 2255(h)(2) that his conviction for discharging a firearm during a crime of violence may no longer be valid in light of Davis and Taylor. The court granted his application for leave to file a second or successive § 2255 motion. View "In re: Bowe" on Justia Law

A young man, after displaying erratic behavior in his Florida apartment, was tied up by his family who feared for his safety. Family members called 911, expressing concern but clarifying he was not violent. When police officers arrived, they found the man tied up, wet, and partially undressed. The officers attempted to detain him under Florida’s Baker Act, which allows for involuntary mental health evaluations under specific criteria. A struggle ensued, during which officers used force, including repeated taser deployments, physical strikes, and dragging the man outside, resulting in injuries. The man was taken to the hospital but not criminally charged.In the United States District Court for the Southern District of Florida, the man sued the responding officers and the city under federal and state law, alleging false arrest, excessive force, and assault and battery, among other claims. The officers moved for summary judgment, arguing qualified immunity and state agent immunity. The district court granted summary judgment for some claims but allowed others—including false arrest and excessive force under 42 U.S.C. § 1983, and state-law claims of assault and battery—to proceed to trial against certain officers.The United States Court of Appeals for the Eleventh Circuit reviewed the appeal. The court reversed the district court’s denial of qualified immunity to two officers on the false arrest claim, finding they had arguable probable cause to detain the man under the Baker Act. However, the court affirmed the denial of qualified immunity to two other officers on excessive force claims, concluding that a reasonable jury could find their use of force grossly disproportionate and in violation of clearly established law. The court also affirmed denial of state agent immunity on the assault and battery claims. The case was remanded for further proceedings. View "Castro-Reyes v. Bosque" on Justia Law

A Black man worked as a truck salesman at a Florida business where he was the only nonwhite employee. He observed that his supervisors and colleagues frequently made derogatory, racially charged comments about nonwhite customers, including the use of slurs for various ethnic groups and stereotypes about Black customers. These comments occurred nearly every time a nonwhite customer entered the business, which happened often. The employee was also the subject of racial slurs behind his back and was sometimes called “boy” in a heated workplace dispute. He reported these incidents to his supervisor, but no corrective action was taken. Over time, his managers began documenting performance and attendance issues, and he was ultimately terminated and replaced by a white employee.The United States District Court for the Northern District of Florida granted summary judgment to the employer on all claims, finding the employee did not provide sufficient evidence of discriminatory or retaliatory termination or a racially hostile work environment.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the case de novo. The court affirmed summary judgment in favor of the employer on the claims of discriminatory and retaliatory termination. It held the employee failed to present substantial evidence that his termination was motivated by racial animus or retaliation for protected complaints, and the employer articulated legitimate, nondiscriminatory reasons for its actions.However, the Eleventh Circuit vacated the summary judgment on the hostile work environment claim and remanded for further proceedings. The court held that the employee presented substantial evidence that he was subjected to a racially hostile work environment, including pervasive use of racial slurs and discriminatory conduct towards nonwhite individuals, sufficient for a reasonable jury to find in his favor on that claim. View "Melton v. I-10 Truck Center, Inc." on Justia Law

Three children attending a government-owned daycare center at Robins Air Force Base in Georgia suffered physical and emotional abuse at the hands of two childcare workers. The children’s parents, who had entrusted them to the Center and paid for their care, alleged that the government had provided assurances of safety and had adopted formal criteria to prevent and respond to child abuse. The parents claimed that the Center’s director failed to report the abuse to authorities and that the government breached its duty to protect the children.The parents brought suit against the United States under the Federal Tort Claims Act (FTCA) in the United States District Court for the Middle District of Georgia, alleging negligence in failing to protect the children. The government moved to dismiss, arguing that the claims were barred by the FTCA’s intentional tort exception, which preserves sovereign immunity for claims arising out of certain intentional torts, including assault and battery. The district court agreed, finding that the parents’ claims were dependent on the employment status of the abusers and thus fell within the exception. The court dismissed the complaint for lack of subject matter jurisdiction and denied the parents’ motion to amend, reasoning that amendment would be futile.On appeal, the United States Court of Appeals for the Eleventh Circuit held that the FTCA’s intentional tort exception did not apply because the government’s duty to care for and protect the children was independent of the employment status of the abusers. The court vacated the district court’s dismissal and denial of leave to amend, and remanded for further proceedings, instructing the district court to consider whether the parents had stated a claim for relief. View "John Doe, 1 v. USA" on Justia Law

Charlie Holley lived in a Florida City townhouse and was involved in a violent incident on June 21, 2021. Armed with a scoped assault rifle, Holley threatened neighbors and a visiting relative, then pointed the rifle at Charlotte Wicker, a United States Postal Service mail carrier, and fired at her vehicle. The situation led to multiple 911 calls, a large police response, and Holley’s eventual arrest after he barricaded himself inside his home. Subsequent searches found weapons and ammunition, and ballistics confirmed the rifle had been fired.A federal grand jury in the Southern District of Florida indicted Holley on five counts, including attempted murder and assault of a federal employee, brandishing and discharging a firearm in furtherance of a crime of violence, and possession of a firearm and ammunition as a felon. Holley underwent several psychiatric evaluations and was found incompetent to stand trial twice, but after further treatment, he was ultimately deemed competent. At trial in the United States District Court for the Southern District of Florida, Holley objected to the introduction of several body-worn camera clips and a 911 call, arguing these violated evidentiary rules and the Confrontation Clause. The district court admitted the evidence, finding it relevant to the police response and not unfairly prejudicial, and gave limiting instructions to the jury.After the jury convicted Holley on all but the attempted murder count, the district court sentenced him to 192 months’ imprisonment, considering both his criminal history and mental health issues. The United States Court of Appeals for the Eleventh Circuit reviewed Holley’s challenges to the admissibility of the evidence and his sentence. The court held that the evidentiary rulings were within the district court’s discretion and that the sentence was reasonable and adequately considered Holley’s mental health. The Eleventh Circuit affirmed both the convictions and sentence. View "USA v. Holley" on Justia Law

Myelicia Rodgers, a clerk at a United States post office in Crestview, Florida, was accused of tampering with and stealing mail while working alone during early morning shifts. After suspicions arose due to complaints about opened mail, the Office of Inspector General conducted an investigation. Rodgers was observed via video and in person engaging in suspicious activities, including taking greeting cards into restricted areas, opening packages, and removing mail. Test letters with cash and gift cards were used in the investigation, some of which went missing, and Rodgers was caught taking and hiding one such letter. Upon being confronted, Rodgers admitted to opening some letters but denied stealing their contents.A grand jury indicted Rodgers on counts of mail tampering and theft by a postal employee. She waived her right to a jury and opted for a bench trial in the United States District Court for the Northern District of Florida. At trial, the government presented multiple witnesses and video evidence. Rodgers did not testify or call any witnesses in her defense. After the prosecution rested, Rodgers moved for a judgment of acquittal, which the district court denied. The district court explicitly informed Rodgers of her right not to testify and assured her that her silence would not be considered in determining guilt. Rodgers’s counsel argued that her silence should not be taken as evidence against her, and the court reiterated that it would base its decision solely on the evidence presented.The United States Court of Appeals for the Eleventh Circuit reviewed whether the district court drew an adverse inference from Rodgers's decision not to testify. The court held that the district court did not consider Rodgers’s silence as evidence of guilt and properly respected her Fifth Amendment rights. Therefore, the Eleventh Circuit affirmed Rodgers’s conviction. View "USA v. Rodgers" on Justia Law