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

John Labriola, a media aide for the Miami-Dade Board of County Commissioners, wrote an inflammatory opinion piece criticizing the Equality Act, using derogatory language towards the LGBT community. Following public backlash and internal complaints, the County suspended him without pay, mandated anti-discrimination training, and eventually terminated him for not completing the training.Labriola sued Miami-Dade County in the United States District Court for the Southern District of Florida, alleging retaliation for exercising his First Amendment rights, compelled speech, and that the County's anti-discrimination policy was unconstitutionally overbroad. The district court granted summary judgment in favor of the County on all counts, applying the Pickering-Connick test to Labriola's free speech and free exercise claims, and ruling that his free-press claim was invalid because he was not a journalist.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court affirmed the district court's decision, holding that Labriola's free speech and free exercise claims failed the Pickering-Connick balancing test, as his speech impeded the County's ability to perform its duties efficiently and disrupted workplace harmony. The court also rejected Labriola's free-press claim, noting that even though the district court erred in stating he couldn't bring the claim as a non-journalist, his claim failed on the merits. Additionally, the court found no evidence to support Labriola's compelled speech claim, as the required training did not compel him to express views he disagreed with. Lastly, the court dismissed Labriola's overbreadth challenge to the County's anti-discrimination policy, as he failed to demonstrate that the policy was substantially overbroad.The Eleventh Circuit affirmed the district court's grant of summary judgment to Miami-Dade County on all counts. View "Labriola v. Miami-Dade County" on Justia Law

Carmen Lamonaco sued Experian Information Solutions, Inc., alleging violations of the Fair Credit Reporting Act after a fraudulent auto loan appeared on her credit report. She claimed Experian failed to implement reasonable procedures to ensure credit report accuracy and did not conduct a proper reinvestigation. Experian moved to compel arbitration based on a clickwrap agreement that included an arbitration clause and a delegation clause. The District Court for the Middle District of Florida denied the motion, concluding that Experian did not prove the existence of an agreement and had waived arbitration by engaging in litigation.The District Court found that Experian's declaration, which was based on internal records and described the enrollment process, lacked probative value because it did not attach the internal records or provide sufficient detail. The court also held that Experian waived its right to arbitration by participating in litigation activities such as answering the complaint, participating in a case management conference, and serving Rule 26 disclosures.The United States Court of Appeals for the Eleventh Circuit reviewed the case and reversed the District Court's decision. The appellate court held that Experian provided competent and unrebutted evidence that Lamonaco agreed to the Terms of Use, which included the arbitration clause. The court also determined that the delegation clause in the agreement assigned the question of waiver to the arbitrator, not the court. Therefore, the District Court lacked the authority to decide the waiver issue. The Eleventh Circuit reversed and remanded the case with instructions to grant Experian's motion to compel arbitration. View "Lamonaco v. Experian Information Solutions, Inc." on Justia Law

Joff Stenn Wroy Philossaint pled guilty to conspiracy to commit wire fraud and conspiracy to commit money laundering. These charges stemmed from his involvement in a scheme to fraudulently obtain Paycheck Protection Plan (PPP) and Economic Injury Disaster Loan (EIDL) loans. He was sentenced to 50 months in prison, followed by supervised release, and ordered to pay $3.85 million in restitution. Additionally, a forfeiture judgment of $673,210 was entered against him. On appeal, Philossaint contested the forfeiture amount, arguing it was miscalculated.The United States District Court for the Southern District of Florida initially handled the case. Philossaint pled guilty to the wire fraud and money laundering conspiracy charges, and the court accepted a factual proffer detailing his role in the fraudulent loan scheme. The presentence investigation report (PSI) provided additional details, including the specific companies involved and the amounts of the fraudulent loans. The government moved for a preliminary order of forfeiture, but miscalculated the amount by assuming Philossaint received a 10% kickback on every loan funded, which was incorrect.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court found that the district court had committed a clear error in determining the forfeiture amount due to the government's miscalculation. The correct amount of forfeiture should have been $549,226.30, based on the accurate figures of the loan proceeds and kickbacks Philossaint received. The Eleventh Circuit vacated the forfeiture order and remanded the case for further proceedings, noting that the district court did not make any factual findings about whether Philossaint was a leader or mastermind of the scheme, which could affect the forfeiture amount under the Honeycutt v. United States hypothetical. View "USA v. Philossaint" on Justia Law

Katie Wood, a transgender woman teaching at a public high school in Florida, challenged the enforcement of Fla. Stat. § 1000.071(3), which prohibits her from using the honorific “Ms.” and the gendered pronouns “she,” “her,” and “hers” in exchanges with students during class time. Wood argued that this statute violated her First Amendment right to free speech and sought a preliminary injunction to prevent its enforcement.The United States District Court for the Northern District of Florida granted Wood a preliminary injunction, finding that she had shown a substantial likelihood of success on the merits of her First Amendment claim. The district court reasoned that Wood’s use of her preferred honorific and pronouns constituted speech as a private citizen on a matter of public concern, and that her interest in expressing her gender identity outweighed the state’s interest in promoting workplace efficiency.The United States Court of Appeals for the Eleventh Circuit reviewed the case and disagreed with the district court’s findings. The appellate court held that Wood had not demonstrated a substantial likelihood that Fla. Stat. § 1000.071(3) infringed her free speech rights. The court concluded that when Wood used her preferred honorific and pronouns in the classroom, she was speaking as a government employee, not as a private citizen. Consequently, her speech was not protected under the First Amendment in this context. The Eleventh Circuit vacated the preliminary injunction and remanded the case to the district court for further proceedings consistent with its opinion. View "Wood v. Florida Department of Education" on Justia Law

In March 1988, Isaiah Harris, a sheriff in Montgomery County, Alabama, was killed. His wife, Louise, was having an affair and conspired with her lover, Lorenzo McCarter, to have Harris killed for insurance money. McCarter recruited Michael Sockwell and Alex Hood to carry out the murder. Sockwell was later convicted of capital murder for pecuniary gain and sentenced to death.Sockwell appealed his conviction, arguing that the prosecution used peremptory strikes to exclude Black jurors in a discriminatory manner, violating Batson v. Kentucky. The Alabama Court of Criminal Appeals (ACCA) affirmed his conviction, finding no clear error in the trial court’s denial of the Batson challenge. The Alabama Supreme Court also affirmed, stating that the prosecutor’s identification of a juror’s race was merely descriptive and not a race-based reason for the strike.Sockwell then filed a habeas corpus petition in the United States District Court for the Middle District of Alabama, which was denied. The district court found the strike of a Black juror, Eric Davis, problematic but concluded that the Alabama Supreme Court did not unreasonably apply Batson. The district court granted a certificate of appealability on the Batson issue, and Sockwell appealed to the United States Court of Appeals for the Eleventh Circuit.The Eleventh Circuit held that the Alabama Supreme Court unreasonably applied federal law by not properly considering all relevant circumstances under Batson’s third step. The court found that the prosecutor’s history of Batson violations, statistical evidence of disproportionate strikes against Black jurors, and the comparison of Davis to similarly situated white jurors indicated purposeful discrimination. The Eleventh Circuit reversed the district court’s ruling and directed it to issue a writ of habeas corpus, allowing Alabama the right to retry Sockwell. View "Sockwell v. Commissioner, Alabama Department of Corrections" on Justia Law

Shadon Edwards was suspected of being a high-level organizer in a drug-trafficking organization in South Florida. After obtaining an arrest warrant, law enforcement officials observed Edwards driving, followed him, and arrested him. A search incident to his arrest revealed a loaded Glock 43 nine-millimeter semi-automatic pistol. Edwards was indicted for knowingly possessing a firearm and ammunition as a convicted felon, in violation of 18 U.S.C. § 922(g)(1). He filed a motion to suppress the gun and ammunition, which the district court denied. Edwards then pleaded guilty without expressly preserving or waiving his right to appeal.The district court for the Southern District of Florida accepted Edwards's guilty plea and sentenced him to 180 months in prison, applying an enhancement under the Armed Career Criminal Act (ACCA) based on three prior convictions. Edwards did not object to the ACCA enhancement at sentencing. He later sought to appeal the denial of his suppression motion and the ACCA enhancement.The United States Court of Appeals for the Eleventh Circuit reviewed the case. Edwards argued that his guilty plea was not knowing and voluntary because he was not informed that he would waive his right to appeal the suppression motion. The court found no plain error, noting that there was no indication during the plea hearing that Edwards misunderstood the consequences of his plea. Edwards also contended that the ACCA enhancement was improper because the government did not prove beyond a reasonable doubt that his prior offenses occurred on different occasions, as required by Erlinger v. United States. The court held that Edwards failed to show a reasonable probability that a jury would have found the offenses occurred on the same occasion, thus not meeting the plain-error standard.Lastly, Edwards challenged the constitutionality of § 922(g) under the Commerce Clause. The court reaffirmed its precedent that § 922(g) is constitutional both facially and as applied, given the firearm and ammunition had moved in interstate commerce. The Eleventh Circuit affirmed the district court's judgment. View "United States v. Edwards" on Justia Law

Matthew A. Zayas was indicted on three counts of money laundering and one count of causing or attempting to cause a domestic financial institution to fail to file a currency transaction report under 31 U.S.C. § 5324(a)(1). After a jury trial, Zayas was acquitted of the money laundering counts but convicted of violating 31 U.S.C. § 5324(a)(1). The case involved Zayas making three cash withdrawals from his Wells Fargo account, each below the $10,000 reporting threshold, within a short period, which the government argued was an attempt to evade the bank's reporting requirements.The United States District Court for the Southern District of Florida denied Zayas's motions for a mistrial and judgment of acquittal. Zayas argued that the government constructively amended the indictment by presenting evidence and arguments related to structuring under § 5324(a)(3) instead of the charged § 5324(a)(1). The district court also provided jury instructions that included a definition of "structuring," which Zayas contended was inappropriate for the charge under § 5324(a)(1).The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the conviction. The court held that the government's evidence was consistent with a violation of § 5324(a)(1), as it demonstrated that Zayas made multiple withdrawals exceeding $10,000 in one business day, triggering the bank's duty to file a currency transaction report. The court found that the district court's jury instructions, while including a definition of "structuring," correctly conveyed the elements of § 5324(a)(1). The court also determined that the district court did not abuse its discretion in responding to a jury question during deliberations by referring the jury back to the original instructions, which accurately stated the law. View "USA v. Zayas" on Justia Law

In the early hours of August 22, 1972, military officers at the Almirante Zar Naval Base in Trelew, Argentina, removed nineteen unarmed political prisoners from their cells and shot them, resulting in what became known as the Trelew Massacre. The plaintiffs in this case are the surviving family members of four of those prisoners. They filed a lawsuit against Roberto Guillermo Bravo, one of the officers involved in the massacre, seeking compensatory and punitive damages under the Torture Victim Protection Act (TVPA) for the extrajudicial killing and torture of their relatives.The United States District Court for the Southern District of Florida heard the case. A jury found Mr. Bravo liable for the deaths and awarded the plaintiffs over $24 million. Mr. Bravo appealed, arguing that the district court erred by equitably tolling the TVPA statute of limitations on the plaintiffs’ claims until October 15, 2012. The district court had concluded that extraordinary circumstances, including the plaintiffs’ fear of reprisal, inability to locate Mr. Bravo, and inability to discover crucial evidence, justified tolling the statute of limitations.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court vacated the district court’s judgment, finding that the district court failed to make sufficient findings of fact to support its ruling on equitable tolling. The appellate court remanded the case for additional findings on whether the plaintiffs were entitled to equitable tolling beyond March 2008. The court also instructed the district court to reconsider whether the plaintiffs acted with due diligence in filing their claims, particularly in the case of Eduardo Cappello, who was found not to have acted diligently by the district court. The appellate court upheld the district court’s exclusion of evidence regarding the victims' alleged ties to communism and Cuba, finding no abuse of discretion. View "Camps v. Bravo" on Justia Law

Maria Fatima Mejia Ponce sought review of a Board of Immigration Appeals (BIA) decision denying her application for asylum, withholding of removal, and relief under the Convention Against Torture. Ponce claimed she faced persecution in Honduras due to her membership in a particular social group, specifically Honduran business owners perceived as wealthy and targeted by criminal gangs.The Immigration Judge (IJ) initially denied Ponce's application, finding that her proposed social group was not sufficiently particular or socially distinct. The BIA affirmed the IJ's decision, agreeing that Ponce's proposed group did not meet the criteria for a particular social group under U.S. asylum law.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court noted that to qualify for asylum, an applicant must demonstrate persecution based on membership in a particular social group, which must be defined by common, immutable characteristics, and be socially distinct within the society in question. The court referenced its prior decision in Perez-Zenteno v. U.S. Attorney General, which held that a particular social group must be narrowly defined and not overly broad.The Eleventh Circuit found that Ponce's proposed social group of Honduran business owners perceived as wealthy was too broad and lacked the necessary immutability, identity, visibility, homogeneity, and cohesiveness. The court concluded that Ponce's proposed group did not qualify as a particular social group for asylum purposes. Consequently, the court denied Ponce's petition for review, upholding the BIA's decision. View "Ponce v. U.S. Attorney General" on Justia Law

In July 2020, Jamie Cunningham burglarized a car dealership in Cobb County, Georgia, and fled the scene. Cobb County police officers pursued him, and during the arrest, they used physical force to handcuff him. Cunningham later filed a lawsuit under 42 U.S.C. § 1983 against certain police officers and Cobb County, alleging excessive force in violation of the Fourth Amendment and Georgia law. He also claimed that Cobb County was liable under the Monell doctrine for the officers' actions.The United States District Court for the Northern District of Georgia granted summary judgment in favor of the defendants. The court held that the officers were entitled to qualified immunity on the Fourth Amendment claim because their use of force was objectively reasonable and did not violate clearly established law. The court also found that the officers were entitled to official immunity on the state-law claim because Cunningham failed to show that the officers acted with actual malice. Additionally, the court granted summary judgment for Cobb County on the Monell claim, concluding that there was no underlying constitutional violation by the officers and no evidence of a defective custom or policy by Cobb County.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 officers' actions were objectively reasonable under the circumstances, as Cunningham had resisted arrest and the officers had a reasonable belief that he might be armed. The court also agreed that the officers did not act with actual malice, and thus were entitled to official immunity. Finally, the court affirmed the summary judgment for Cobb County, as there was no underlying constitutional violation to support the Monell claim. View "Cunningham v. Cobb County, Georgia" on Justia Law