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

Rodolfo Maisonet was arrested for conspiring to distribute cocaine, a crime subject to a mandatory minimum sentence. He initially cooperated with the government, providing some information about the drug distribution scheme. However, he continued his criminal activities and was caught again. Before sentencing, Maisonet submitted an affidavit with additional information about the conspiracy, but the district court found that he had not fully disclosed all relevant information and imposed the mandatory minimum sentence.The United States District Court for the Northern District of Florida held that Maisonet's lies and ongoing criminal activity made him ineligible for the safety valve provision, which allows for sentencing without regard to mandatory minimums if certain conditions are met. The court also indicated that his affidavit did not provide all necessary information about the drug distribution scheme.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court disagreed with the district court's legal conclusion that Maisonet's continued criminal activity and lies automatically disqualified him from safety valve relief. The statute requires that a defendant provide all information by the time of sentencing, regardless of whether the government already knows the information or if the defendant's cooperation was prompted by a government investigation. However, the appellate court affirmed the district court's factual finding that Maisonet's affidavit did not fully disclose all relevant information about the drug distribution scheme. This factual determination was not clearly erroneous, and thus, the district court's imposition of the mandatory minimum sentence was upheld. View "USA v. Maisonet" on Justia Law

Thomas Swinford was shot and killed by Athens-Clarke County police officers after he refused to drop a gun and instead raised and pointed it at the officers. His widow, Jayne Swinford, filed a lawsuit in Georgia state court alleging claims under 42 U.S.C. § 1983 and Georgia’s wrongful death statute against seven officers, the police chief, and the county government. The case was removed to federal court.The defendants moved to dismiss the complaint on qualified and official immunity grounds, relying on body camera footage showing the events leading up to the shooting. The district court considered the footage and granted the motion to dismiss, finding that the officers acted reasonably and did not violate Thomas’s constitutional rights. The court also denied Mrs. Swinford’s motion to amend her complaint and her motion for reconsideration.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court determined that the district court properly considered the body camera footage under the incorporation-by-reference doctrine. The footage showed that the officers had probable cause to believe Thomas posed a serious threat when he raised his gun at them, justifying their use of deadly force. The court found that the officers did not use excessive force and were entitled to qualified immunity. Consequently, the supervisory liability claim against the police chief and the Monell claim against the county also failed.The Eleventh Circuit affirmed the district court’s orders, including the denial of Mrs. Swinford’s motion to amend her complaint and her motion for reconsideration. View "Swinford v. Santos" on Justia Law

Alfreida Hogan, an African-American woman, was employed by the Department of Veterans Affairs (VA) as a nurse practitioner from July 2012 until March 2019, when she was demoted to staff nurse and subsequently resigned. She alleged that her immediate supervisor harassed her and gave her false, negative performance reviews due to her race, leading to her demotion. In April 2019, Hogan contacted her agency counselor, claiming racial discrimination. On July 3, 2019, the counselor informed her that informal resolution efforts had ended and that she could file a formal administrative complaint. Hogan's counsel claimed to have emailed the complaint on July 19, 2019, but the VA never received it. Hogan's counsel did not follow up until April 2020, when he learned the VA had not received the complaint. The VA dismissed the complaint due to the missed 15-day filing deadline.The district court dismissed Hogan's Title VII claims for race discrimination and retaliation, citing the Eleventh Circuit's decision in Crawford v. Babbitt, which held that failure to exhaust administrative remedies was a jurisdictional bar. The district court concluded it lacked subject-matter jurisdiction due to Hogan's untimely filing of her administrative complaint.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court determined that the 15-day deadline to file a formal administrative complaint, set by EEOC regulation 29 C.F.R. § 1614.106(b), is a claims-processing rule subject to equitable tolling, not a jurisdictional requirement. The court noted that Crawford did not control this case because it involved a different issue. The court also referenced the Supreme Court's decision in Fort Bend County v. Davis, which held that Title VII's charge-filing requirement is not jurisdictional. Despite this, the court affirmed the district court's dismissal, concluding that Hogan did not demonstrate due diligence to warrant equitable tolling of the 15-day deadline. View "Hogan v. Secretary, U.S. Department of Veterans Affairs" on Justia Law

The plaintiffs, co-personal representatives of the estate of Sara Schleider, filed a lawsuit in Florida state court against GVDB Operations, LLC, and JSMGV Management Company, LLC. They alleged that the defendants failed to prevent the spread of COVID-19 at their assisted living facility, resulting in Sara Schleider contracting the virus and subsequently dying. The plaintiffs asserted state-law claims for survival and wrongful death under Florida Statute § 429.28, alleging negligence and, alternatively, willful misconduct or gross negligence.The defendants removed the case to the United States District Court for the Southern District of Florida, claiming federal subject matter jurisdiction on three grounds: acting under a federal officer, complete preemption by the Public Readiness and Emergency Preparedness (PREP) Act, and an embedded federal question concerning the PREP Act. The district court concluded it lacked subject matter jurisdiction and remanded the case to state court, finding that the defendants' arguments did not establish federal jurisdiction.The United States Court of Appeals for the Eleventh Circuit reviewed the district court's decision. The appellate court affirmed the remand, holding that the defendants did not act under a federal officer, as their compliance with federal guidelines did not equate to acting under federal authority. The court also determined that the PREP Act did not completely preempt the plaintiffs' state-law claims, as the Act's willful misconduct provision did not wholly displace state-law causes of action for negligence. Lastly, the court found that the plaintiffs' claims did not raise a substantial federal question under the Grable doctrine, as the federal issues were not necessarily raised by the plaintiffs' well-pleaded complaint. Thus, the district court's remand to state court was affirmed. View "Howard Schleider v. GVDB Operations, LLC" on Justia Law

Jimmy Ray Lightsey was convicted by a jury of possessing a firearm as a felon, possessing with intent to distribute cocaine, cocaine base, and marijuana, and possessing a firearm in furtherance of a drug-trafficking crime. At sentencing, the district court determined that Lightsey was an armed career criminal under the Armed Career Criminal Act (ACCA) and enhanced his sentence accordingly. Lightsey appealed his 240-month sentence, arguing that the district court erred in finding that his prior convictions qualified as predicate offenses under ACCA.The United States District Court for the Middle District of Florida initially reviewed the case. Lightsey was found guilty on all counts by a jury. At sentencing, the district court applied the ACCA enhancement based on Lightsey's prior convictions, including a 1997 conviction for attempted armed robbery and two drug-related convictions from 2000 and 2009. Lightsey objected to the ACCA enhancement, arguing that his prior convictions should not qualify as predicate offenses. The district court overruled his objections, noting that existing case law foreclosed his arguments, and sentenced him to 240 months in prison.The United States Court of Appeals for the Eleventh Circuit reviewed the case. Lightsey contended that his prior drug convictions did not qualify as "serious drug offenses" under ACCA because the definition of cocaine under Florida law was broader than the federal definition at the time of his federal offense. He also argued that his 1997 conviction for attempted armed robbery did not qualify as a "violent felony" under ACCA. The Eleventh Circuit held that Lightsey's drug convictions were properly considered "serious drug offenses" under ACCA, as both state and federal laws criminalized the conduct at the time of his convictions. The court also held that his attempted armed robbery conviction qualified as a "violent felony" under ACCA, following its precedent in United States v. Joyner. Consequently, the Eleventh Circuit affirmed Lightsey's sentence. View "USA v. Lightsey" on Justia Law

VFS Leasing Co. ("VFS") leased trucks to Time Definite Leasing, LLC ("TDL"), which insured the trucks with Markel American Insurance Company ("Markel American"). Markel American issued joint checks to VFS and TDL for insurance claims, but TDL cashed the checks without VFS's endorsement and kept the proceeds. VFS sued Markel American for breach of contract, claiming it was owed the funds from the joint checks.The United States District Court for the Middle District of Florida granted summary judgment in favor of VFS, holding that Markel American breached the insurance contract by failing to ensure VFS received the funds. The court found that under Florida's Uniform Commercial Code (UCC), Markel American's obligation was not discharged because the checks were not properly endorsed by both co-payees.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed whether Markel American's obligation to VFS was discharged when the drawee bank improperly accepted the joint checks. The court concluded that under Florida Statute § 673.4141(3), a drawer's obligation is discharged when a bank accepts a jointly issued check, regardless of whether both co-payees endorsed it. The court noted that while VFS could pursue a conversion claim against the bank, Markel American's obligation was discharged upon the bank's acceptance of the checks.The Eleventh Circuit reversed the district court's summary judgment in favor of VFS and remanded the case for further proceedings consistent with its opinion. View "VFS Leasing Co. v. Markel Insurance Company" on Justia Law

Eric and Todd Romano, trustees of the Romano Law, PL 401(k) Plan, filed a class action against John Hancock Life Insurance Company. They claimed that John Hancock breached its fiduciary duties under the Employee Retirement Income Security Act of 1974 (ERISA) by not passing through the value of foreign tax credits received from mutual funds to the defined-contribution plans. The Romanos argued that John Hancock should have used these credits to reduce the administrative fees charged to the plans.The United States District Court for the Southern District of Florida granted summary judgment in favor of John Hancock, concluding that John Hancock was not an ERISA fiduciary regarding the foreign tax credits and did not breach any fiduciary duties. The court also ruled that the Romanos and the class lacked Article III standing because they failed to establish loss causation.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 John Hancock was not an ERISA fiduciary concerning the foreign tax credits because these credits were not plan assets. The court explained that the foreign tax credits were a result of John Hancock's ownership of mutual fund shares and were not held in trust for the benefit of the plans. Additionally, the court found that John Hancock did not have discretionary authority over the management or administration of the separate accounts that would make it a fiduciary under ERISA. Consequently, the Romanos' claims for breach of fiduciary duty and engaging in prohibited transactions failed as a matter of law. View "Romano v. John Hancock Life Insurance Company (USA)" on Justia Law

In 2010, four individuals sued the Revolutionary Armed Forces of Colombia (FARC) under the Anti-Terrorism Act, resulting in a default judgment of $318 million against FARC. Unable to collect from FARC, the plaintiffs sought to garnish assets of Samark José López Bello and his companies, alleging they were agents or instrumentalities of FARC. The district court initially ruled in favor of the plaintiffs, but the Eleventh Circuit reversed, mandating a jury trial to determine the agency status of López and his companies.On remand, the district court scheduled a jury trial and allowed discovery. The plaintiffs sought to depose López and requested documents. López and his companies filed motions for protective orders to avoid discovery, which the district court denied, warning of sanctions for non-compliance. López failed to appear for his deposition and did not comply with document requests. Consequently, the district court entered default judgments against López and his companies, citing willful disobedience and the inability to compel compliance due to López's fugitive status.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court affirmed the district court's entry of default judgments, finding no abuse of discretion. The Eleventh Circuit held that the district court correctly interpreted its scheduling order to allow discovery and found that López's failure to comply with discovery orders was willful. The court also determined that less severe sanctions would not ensure compliance, given López's fugitive status. The Eleventh Circuit dismissed the argument that the district court lacked jurisdiction due to an appeal of the protective order denials, as those orders were not final or immediately appealable. View "Stansell v. Lopez Bello" on Justia Law

In this case, Jimmy Davis, Jr., an Alabama prisoner sentenced to death for the 1993 murder of Johnny Hazle during a gas station robbery, appealed the district court’s denial of his 28 U.S.C. § 2254 federal habeas petition. Davis argued that his trial counsel was ineffective during the penalty phase of his trial for failing to investigate and present mitigating evidence of childhood abuse and the circumstances of his prior conviction for third-degree robbery.The Alabama Court of Criminal Appeals affirmed Davis’s conviction and sentence on direct appeal. Davis then filed a state postconviction petition, which was denied after an evidentiary hearing. The state court found that Davis’s trial counsel did not perform deficiently and that Davis was not prejudiced by the alleged deficiencies. The Alabama Court of Criminal Appeals affirmed the denial of the postconviction petition, concluding that the investigation conducted by Davis’s attorneys was reasonable and that Davis failed to show prejudice.The United States District Court for the Northern District of Alabama denied Davis’s § 2254 petition, concluding that the state court’s decision was not an unreasonable application of Supreme Court precedent or based on an unreasonable determination of the facts. The Eleventh Circuit Court of Appeals reviewed the case and affirmed the district court’s denial of the habeas petition.The Eleventh Circuit held that the state court’s conclusion that Davis was not prejudiced by his counsel’s alleged deficiencies was not contrary to or an unreasonable application of clearly established federal law. The court noted that the additional mitigating evidence presented during the postconviction proceedings, including evidence of childhood abuse and the non-violent nature of the prior robbery, did not create a reasonable probability of a different outcome. The court emphasized that the state court’s decision was not so obviously wrong that it lay beyond any possibility for fairminded disagreement. View "Davis v. Commissioner, Alabama Department of Corrections" on Justia Law

Hector Diaz-Arellano, a Mexican national, entered the U.S. illegally in 1989. In 2017, the Department of Homeland Security charged him as a removable alien. Diaz-Arellano conceded removability but sought cancellation of removal, claiming it would cause "exceptional and extremely unusual hardship" to his U.S.-citizen daughter, who was under 21 at the time. However, by the time of his final removal hearing, his daughter had turned 21, making her ineligible as a qualifying relative under the statute.The Immigration Judge (IJ) initially warned Diaz-Arellano that his daughter's upcoming 21st birthday could affect his eligibility for cancellation of removal. Despite this, Diaz-Arellano delayed filing his application and did not object to a hearing date set after his daughter's birthday. At the final hearing, the IJ denied his application, noting that his daughter no longer qualified as a "child" under the statute. The Board of Immigration Appeals (BIA) affirmed this decision, citing Matter of Isidro-Zamorano, which holds that a child must be under 21 at the time of the final adjudication.The United States Court of Appeals for the Eleventh Circuit reviewed the BIA's decision. The court held that the statute unambiguously requires a qualifying relative to be under 21 at the time of the final decision on cancellation of removal. The court rejected Diaz-Arellano's argument that the BIA's interpretation was incorrect and found no undue or unfair delay in his proceedings that would warrant an exception. Consequently, the court denied Diaz-Arellano's petition for review, affirming that he was ineligible for cancellation of removal because his daughter was no longer a qualifying child. View "Diaz-Arellano v. U.S. Attorney General" on Justia Law