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

The case involves a dispute between two federally recognized Indian tribes, the Muscogee (Creek) Nation and the Poarch Band of Creek Indians, over the excavation and development of a burial site known as Hickory Ground in Wetumpka, Alabama. The Muscogee Nation claims that the site is sacred and historically significant, containing graves and ceremonial grounds. The Poarch Band, which purchased the site in 1980 and later had it held in trust by the United States, excavated the site with Auburn University and announced plans to develop a hotel and casino on it. The Muscogee Nation sued to stop the development and restore the site.The United States District Court for the Middle District of Alabama dismissed the Muscogee Nation's complaint, ruling that the Poarch Band and its officials enjoyed sovereign immunity. The court also found that the Poarch officials were immune under an exception to Ex parte Young for claims that are the functional equivalent of a quiet title action and implicate special sovereignty interests. The district court did not analyze the claims individually but dismissed them collectively, leading to the current appeal.The United States Court of Appeals for the Eleventh Circuit reviewed the case and found that the district court erred by not analyzing the Poarch officials' sovereign immunity on a claim-by-claim basis. The appellate court emphasized that each claim must be considered separately to determine whether it is the functional equivalent of a quiet title action and whether it implicates special sovereignty interests. The Eleventh Circuit vacated the district court's order and remanded the case for further proceedings, instructing the lower court to allow the Muscogee Nation to amend its complaint and to analyze the claims individually. The appellate court also rejected the argument that the Supreme Court had abrogated the Coeur d’Alene exception to Ex parte Young, affirming that it remains a narrow but valid exception. View "Muscogee (Creek) Nation v. Rollin" on Justia Law

In this labor dispute, several employees sued their employer, a steel manufacturer, alleging violations of the Fair Labor Standards Act (FLSA) and Alabama common law. They claimed the company failed to pay wages for all hours worked, improperly calculated overtime, and delayed overtime payments. The plaintiffs sought relief for themselves and similarly situated employees.The United States District Court for the Southern District of Alabama ordered the defendant to produce key time and pay records multiple times over two years. The defendant repeatedly failed to comply, offering various excuses and blaming its third-party payroll processor, ADP. The court eventually issued a default judgment against the defendant due to its continuous noncompliance and misrepresentations.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court affirmed the district court's decision to issue a default judgment, finding that the defendant's conduct warranted such a severe sanction. The appellate court also upheld the district court's denial of the defendant's motion to reconsider the sanctions, noting that the district court had the discretion to revisit its interlocutory orders but did not abuse that discretion in this case.The appellate court also affirmed the district court's determination that the plaintiffs' claims regarding workweek calculations and bonus payments were well-pleaded. However, the appellate court vacated and remanded the district court's calculation of damages, instructing the lower court to provide a more thorough explanation of its reasoning regarding the statute of limitations defense. View "Hornady v. Outokumpu Stainless USA, LLC" on Justia Law

Joseph and Jo-Lynn Jenkins Parrott filed for Chapter 13 bankruptcy in 2018, committing to a payment plan. After several amendments to their plan, the bankruptcy trustee moved to dismiss the case due to missed payments. The bankruptcy court ordered the Parrotts to catch up on payments or face dismissal. Despite extensions, the Parrotts failed to comply, leading to a dismissal order on January 29, 2020, effective February 13, 2020. The Parrotts filed a pro se notice of appeal on February 5, 2020, which was struck for lacking their attorney’s signature. They filed a second notice on February 18, 2020, after their attorney withdrew.The United States District Court for the Middle District of Florida dismissed the Parrotts' appeal, ruling it untimely and citing their failure to comply with procedural rules. The court noted the Parrotts' noncompliance with local rules and their inadequate response to an order to show cause regarding jurisdiction. The district court concluded it lacked jurisdiction and, alternatively, dismissed the case as a sanction for procedural noncompliance.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that the Parrotts' initial notice of appeal, though defective, was timely and that the second notice cured the defect, thus conferring jurisdiction on the district court. The appellate court also found that the district court abused its discretion by dismissing the case as a sanction, noting that dismissal is a last resort and should only be used in extreme circumstances, which were not present here. The Eleventh Circuit vacated the district court's dismissal and remanded the case for consideration on the merits. View "Parrott v. Neway" on Justia Law

The case involves Constantine Varazo II, who was convicted by a jury for possession with intent to distribute methamphetamine and heroin, and possession of a firearm in furtherance of a drug-trafficking crime. The key facts include a high-speed chase initiated by Deputy Chandler Buchanan after Varazo's vehicle refused to stop. During the chase, items were thrown from the car, which were later identified as drugs. A book bag containing drugs, a firearm, and a cell phone was found by an employee of Miller Supply and eventually handed over to law enforcement.In the lower court, the United States District Court for the Middle District of Georgia admitted Deputy Buchanan’s testimony about statements made by Russell Chapman, a state probation officer, and admitted the book bag over Varazo’s chain-of-custody objection. Varazo did not object at the time to hearsay statements by James Eidson and Cliff Miller regarding the discovery of the bag. The district court denied Varazo’s motion for a new trial and sentenced him to 228 months’ imprisonment.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that any error in admitting Chapman’s out-of-court statements was harmless because Chapman later testified and was subject to cross-examination. The court also held that challenges to the chain of custody go to the weight rather than the admissibility of evidence, and sufficient circumstantial evidence connected the bag to Varazo. Lastly, the court found that any hearsay error regarding the discovery of the bag did not affect Varazo’s substantial rights, as other evidence sufficiently supported the verdict. The Eleventh Circuit affirmed Varazo’s convictions. View "USA v. Varazo" on Justia Law

A group called Moms for Liberty, along with several individual members, filed a lawsuit against Brevard Public Schools and members of the Brevard County School Board. The plaintiffs claimed that their speech was unconstitutionally restricted at school board meetings. They argued that the Board's policies prohibiting "abusive," "personally directed," and "obscene" speech were unconstitutional. The plaintiffs sought declaratory and injunctive relief, as well as nominal damages.The United States District Court for the Middle District of Florida granted summary judgment in favor of the Board. The district court concluded that the plaintiffs lacked standing because they could not show an actual or imminent injury. It also held that the Board's policies did not objectively chill the plaintiffs' protected speech. Despite finding no standing, the district court went on to rule that the Board's policies were constitutional.The United States Court of Appeals for the Eleventh Circuit reviewed the case and reversed the district court's decision. The Eleventh Circuit found that the plaintiffs had standing to seek both retrospective and prospective relief. The court held that the Board's policy on "abusive" speech was unconstitutional because it was viewpoint-based and prohibited offensive speech. The policy on "personally directed" speech was also found to be unreasonable and inconsistently enforced, making it unconstitutional. Lastly, the court ruled that the prohibition on "obscene" speech was unreasonably applied to restrict protected speech, particularly when it involved reading from books available in school libraries. The case was remanded for further proceedings consistent with the Eleventh Circuit's opinion. View "Moms for Liberty v. Brevard Public Schools" on Justia Law

A former railroad employee, Demetris Hill, was convicted of theft of government property and making a false claim to the Railroad Retirement Board (RRB). Hill had been receiving monthly disability benefits from the RRB since 2012, based on his claim that he was unable to perform substantial gainful activity. As a condition of receiving these benefits, Hill was required to report any changes in his employment status, including any ownership in a family business. Despite this, Hill helped his ex-wife start a janitorial business, SparClean Premier Cleaning Solutions, and failed to report his involvement to the RRB.Hill was initially charged in a 60-count indictment for theft of government money or property. A superseding indictment later charged him with one count of theft of government property, one count of making false claims to the government, and one count of wire fraud. After a jury trial, Hill was found guilty of theft of government property and making false claims but was acquitted of wire fraud. The district court denied Hill’s motion for judgment of acquittal and sentenced him to 33 months for each conviction, to be served concurrently, followed by supervised release. Hill appealed his convictions.The United States Court of Appeals for the Eleventh Circuit reviewed Hill’s appeal. The court found sufficient evidence that Hill was not entitled to the disability payments because he engaged in substantial gainful activity and failed to report his involvement with SparClean. The court also found that Hill knowingly deprived the government of its property by continuing to receive the payments without reporting his employment status. Additionally, the court held that receiving direct deposits while failing to disclose his employment constituted making a false claim to the government. Hill’s arguments regarding the sufficiency of evidence, the jury instruction, and the constitutionality of the False Claims Act were rejected. The Eleventh Circuit affirmed Hill’s convictions. View "USA v. Hill" on Justia Law

Willie Hayden pleaded guilty to distribution of heroin and possession with intent to distribute heroin. After serving a prior term of imprisonment for drug trafficking, Hayden was released and began supervised release. Within a year, he was found selling heroin, leading to his arrest and the discovery of 29 bags of heroin in his home. The probation office's presentence investigation report calculated a guideline range of 151 to 188 months of imprisonment, considering Hayden's career offender status and criminal history. The report also detailed Hayden's mental health challenges, learning disabilities, and substance abuse history.The United States District Court for the Middle District of Florida sentenced Hayden to 170 months of imprisonment and imposed a three-year term of supervised release with standard conditions. The district court did not orally describe each standard condition but included them in the written judgment. Hayden's counsel objected to the career-offender guideline application and the sentence's length but did not object to the standard conditions' oral pronouncement.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that Hayden's sentence was substantively reasonable, as the district court considered all relevant factors, including Hayden's neurological issues, and imposed a sentence within the guideline range. The court also held that the district court did not err in imposing the standard conditions of supervised release without orally describing each one, as Hayden had notice and an opportunity to object. The court affirmed Hayden's sentence. View "USA v. Hayden" on Justia Law

Joseph Lusk was convicted in Florida state court in 2018 for traveling to meet a minor after soliciting a guardian. Less than a month after his release from prison in 2021, Lusk engaged in sexually explicit conversations with an undercover investigator posing as a 15-year-old girl. He was subsequently arrested and charged with attempted enticement of a minor and committing a felony involving a minor while required to register as a sex offender.The United States District Court for the Southern District of Florida denied Lusk's motion to dismiss Count 2, which argued that his conduct did not involve an actual minor. Lusk pled guilty to both charges but contested the application of a sentencing enhancement for being a "repeat and dangerous sex offender against minors" based on his prior Florida conviction. The district court applied the enhancement and sentenced Lusk to 355 months' imprisonment followed by a lifetime of supervised release.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that the district court erred in applying the "repeat and dangerous sex offender against minors" enhancement because the Florida statute under which Lusk was previously convicted is broader than the federal statute, thus not qualifying as a predicate offense. The court vacated Lusk's sentence and remanded for resentencing without the enhancement. However, the court affirmed Lusk's conviction under 18 U.S.C. § 2260A, citing binding precedent that a conviction under this statute does not require the involvement of an actual minor. View "USA v. Lusk" on Justia Law

Loren Read was indicted for attempting to entice a minor to engage in sexual activity after he exchanged online messages with an undercover federal agent posing as the father of young girls. Read expressed his desire to perform sexual acts on the girls and agreed to meet the undercover agent. Upon arrival, he was arrested with three condoms in his pocket. Read pled guilty in exchange for the government not charging him with other offenses and recommending a downward adjustment to his offense level. As part of his plea agreement, Read waived his right to appeal his sentence with three exceptions, including if the sentence exceeded the statutory maximum.The United States District Court for the Middle District of Florida sentenced Read to 180 months of imprisonment followed by five years of supervised release. The court imposed seven special conditions of supervised release and referenced the standard conditions adopted by the Middle District of Florida without detailing them. Read did not object at the time. The written judgment included 13 standard conditions that matched the district's standard conditions.The United States Court of Appeals for the Eleventh Circuit reviewed the case. Read argued that the district court violated his due process rights by not detailing the standard conditions during the oral pronouncement of his sentence. The government moved to dismiss the appeal based on Read's appeal waiver. The Eleventh Circuit granted the government's motion, holding that Read's appeal was barred by his waiver. The court determined that Read's challenge to the oral pronouncement of his sentence constituted an appeal of his sentence, which he had waived. The court also found that the exception for sentences exceeding the statutory maximum did not apply, as Read did not argue that the conditions violated statutory requirements. View "U.S. v. Read" on Justia Law

The case involves Bradley Rodriguez, who applied for disability benefits and supplemental security income, claiming a disability due to a traumatic brain injury, bipolar disorder, and depression. His application was denied by an Administrative Law Judge (ALJ) with the Social Security Administration (SSA). The Appeals Council also denied his request for review. Rodriguez then filed a federal lawsuit challenging the denial of benefits, raising several constitutional issues regarding the appointment of SSA ALJs, Appeals Council members, and the Commissioner of the SSA. He also argued that the ALJ’s decision was not supported by substantial evidence.The United States District Court for the Southern District of Florida granted summary judgment in favor of the Commissioner of the SSA. The court found that the ALJ was properly appointed, the Appeals Council members were not principal officers requiring presidential appointment and Senate confirmation, and the for-cause removal provision for the Commissioner was unconstitutional but severable. The court also held that Rodriguez was not entitled to a new hearing because he did not show that the unconstitutional removal provision caused him any harm. Additionally, the court determined that the ALJ’s decision was supported by substantial evidence.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court’s decision. The court held that the Commissioner had the statutory authority to appoint SSA ALJs and properly exercised that authority through ratification in July 2018. The Appeals Council members were deemed inferior officers, not principal officers, and thus did not require presidential appointment and Senate confirmation. The court also agreed that the for-cause removal provision for the Commissioner was unconstitutional but severable, and Rodriguez did not demonstrate entitlement to retrospective relief. Finally, the court found that the ALJ’s decision was supported by substantial evidence, including medical records and vocational expert testimony. View "Rodriguez v. Social Security Administration" on Justia Law