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

In September 2019, Sweet Additions Ingredient Processors, LLC (Sweet Additions) and Meelunie America, Inc. (Meelunie) entered into a fixed-price sales contract for the supply of organic tapioca starch for the 2020 calendar year. Due to the COVID-19 pandemic, Meelunie faced supply chain disruptions and failed to deliver the full quantity of tapioca starch. Meelunie suggested that Sweet Additions cover higher shipping costs, which Sweet Additions declined. Sweet Additions then contracted with another supplier and declared Meelunie in breach of contract.The United States District Court for the Southern District of Florida held a bench trial and ruled in favor of Meelunie, awarding it $1,409,490.61 for unpaid invoices and interest. The district court found that the contract incorporated Meelunie’s terms and conditions, which included a limitation of liability clause. This clause, according to the district court, barred Sweet Additions from recovering damages for cover costs and lost profits.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court concluded that the sales contract did incorporate Meelunie’s terms and conditions. However, the court held that the limitation of liability clause did not preclude Sweet Additions from recovering direct damages, such as cover costs and lost profits, if they were not special consequential, incidental, or exemplary damages. The Eleventh Circuit vacated the district court’s judgment and remanded the case for further proceedings consistent with its opinion. View "Sweet Additions Ingredient Processors, LLC v. Meelunie America, Inc." on Justia Law

The petitioner, Nakia Courtney Hamilton, a Jamaican citizen, was ordered removed from the United States in 2017 following a conviction for aggravated battery with a deadly weapon. Hamilton, who was admitted to the U.S. as a lawful permanent resident in 2009, has filed three motions to reopen his removal proceedings. His most recent motion sought to apply for a waiver of the immigration consequences of his conviction under 8 U.S.C. § 1182(h).The Board of Immigration Appeals (BIA) denied Hamilton’s third motion to reopen, finding it untimely and procedurally barred. Hamilton argued that the procedural limitations should be equitably tolled based on the Supreme Court’s decision in Niz-Chavez v. Garland, which held that a notice to appear must be a single document containing all required information to trigger the stop-time rule for cancellation of removal. The BIA concluded that Niz-Chavez did not affect Hamilton’s eligibility for a § 1182(h) waiver and thus did not justify reopening the proceedings.The United States Court of Appeals for the Eleventh Circuit reviewed the case and upheld the BIA’s decision. The court found that the stop-time rule in § 1182(h) is triggered by the initiation of removal proceedings, not by the issuance of a compliant notice to appear as required by § 1229(a). The court determined that Hamilton’s removal proceedings were validly initiated when the Department of Homeland Security filed the notice to appear with the immigration court, regardless of whether it included the date and time of the hearing. Consequently, the court held that Hamilton was not eligible for a § 1182(h) waiver and that the BIA did not abuse its discretion in denying his motion to reopen. The petition for review was denied. View "Hamilton v. Attorney General" on Justia Law

John P. Middleton filed a defamation lawsuit against Roy Lee, The Hollywood Reporter LLC, and Gary Baum in the Southern District of Florida. The case stemmed from a professional and personal fallout between Middleton and Lee, which began and ended in California. Middleton had sued Lee in California for millions of dollars, and during the ongoing legal battle, Middleton relocated to Florida. In June 2020, The Hollywood Reporter published an article by Baum that detailed the feud and contained allegedly false statements about Middleton. Middleton claimed these statements were defamatory and filed the lawsuit in June 2022.The district court dismissed Middleton's action, applying California's one-year statute of limitations for defamation claims, which rendered the claims time-barred. The court concluded that Florida's borrowing statute and choice-of-law rules required the application of California law due to the significant relationship factors. The court also denied Middleton's motion to amend the complaint, deeming it futile as the proposed amendments did not alter the determination that California's statute of limitations applied.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that California had the most significant relationship to the defamation claims, considering factors such as the place where the injury and conduct causing the injury occurred, the domicile and residence of the parties, and where the relationship between the parties was centered. Consequently, California's one-year statute of limitations applied, and Middleton's claims were time-barred. The court upheld the dismissal of the action and the denial of the motion to amend the complaint. View "Middleton v. The Hollywood Reporter LLC" on Justia Law

John Doe, using multiple aliases, had a long history with U.S. immigration authorities dating back to 1985. He was twice caught trying to enter the U.S. with fraudulent documents and was deported. In 1988, he was found in Texas and deported again. In 2018, he was detained in Florida, and despite a final deportation order, he refused to cooperate with immigration officials, leading to his indictment on three counts of willfully failing to leave the U.S. under 8 U.S.C. § 1253(a)(1).The United States District Court for the Middle District of Florida denied Doe's request for a jury instruction that would require the government to prove he had been lawfully admitted to the U.S. to convict him under § 1253(a)(1). The court also denied his motion for a judgment of acquittal on the same grounds. Doe was convicted on all counts and sentenced to 51 months in prison.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that § 1253(a)(1) does not require a noncitizen to have been lawfully admitted to the U.S. to be subject to its penalties. The court found that the statutory text and context did not support Doe's interpretation that only admitted noncitizens could be penalized under § 1253(a)(1). The court affirmed the district court's decisions, upholding Doe's convictions and sentence. View "USA v. Doe" on Justia Law

Sonny Ramdeo, while working as a payroll director for Promise Healthcare, recommended the company hire PayServ Tax, which he falsely claimed was a subsidiary of Ceridian Corporation. In reality, PayServ was Ramdeo’s own company, and he diverted over $20 million from Promise to fund a charter airline service. After Promise’s auditors discovered discrepancies, Ramdeo was arrested and pled guilty to wire fraud and money laundering. He was sentenced to twenty years in prison, followed by three years of supervised release, and ordered to pay $21,442,173 in restitution.Ramdeo challenged his conviction and restitution amount on direct appeal, which was unsuccessful. He then sought a writ of audita querela to contest the restitution amount, which the district court recharacterized as a petition for coram nobis and subsequently denied. The Eleventh Circuit declined to address the merits of his claim. Ramdeo also filed a 28 U.S.C. § 2255 petition, which the district court denied as frivolous and meritless. The Eleventh Circuit affirmed this decision. Ramdeo later filed a pro se petition for a writ of error coram nobis, arguing ineffective assistance of counsel, prosecutorial misconduct, and new financial evidence. The district court denied the petition, stating that prisoners in federal custody are ineligible for coram nobis relief.The United States Court of Appeals for the Eleventh Circuit reviewed the case and determined that being in custody does not categorically bar a petitioner from seeking coram nobis relief for non-custodial aspects of their sentence, such as restitution. The court vacated the district court’s order and remanded the case for further proceedings, emphasizing that coram nobis is an extraordinary remedy available when no other remedy is available, and the petitioner presents sound reasons for not seeking relief earlier. View "Ramdeo v. United States" on Justia Law

Eric Brenes-Colon was arrested following an investigation into his co-conspirator's trafficking of firearms and large quantities of cocaine, marijuana, and MDMA. Brenes-Colon obtained cocaine from Puerto Rico and provided it to his co-conspirator for distribution. During a search of the co-conspirator's apartment, where Brenes-Colon was living, agents found drugs, drug paraphernalia, a firearm, cash, and evidence linking Brenes-Colon to the apartment. He was charged with conspiracy to distribute and possess with intent to distribute 500 grams or more of cocaine, possession with intent to distribute 500 grams or more of cocaine, and possession with intent to distribute MDMA. Brenes-Colon pleaded guilty to all charges.The United States District Court for the Middle District of Florida sentenced Brenes-Colon to 108 months’ imprisonment. The court emphasized the seriousness of his criminal activities due to the large volume of drugs trafficked, stating that illegal drugs are the leading cause of death for Americans aged 18 to 35. Brenes-Colon appealed, arguing that the court's statement was a clearly erroneous fact and that it constituted procedural error in determining his sentence.The United States Court of Appeals for the Eleventh Circuit reviewed the case for plain error, as Brenes-Colon did not object to his sentence in the lower court. The appellate court found that the district court did not commit plain error. It held that the district court was entitled to rely on its experience and common sense in sentencing, and that the statement about the deadliness of illegal drugs was not required to be supported by empirical studies in the record. The appellate court affirmed the district court's sentence, concluding that Brenes-Colon did not demonstrate that the alleged error affected his substantial rights or the fairness of the judicial proceedings. View "United States v. Brenes-Colon" on Justia Law

Richard Spizzirri and his fourth wife, Holly Lueders, entered into a prenuptial agreement requiring Spizzirri’s estate to transfer $6 million to Lueders and $3 million to her children upon his death. After Spizzirri’s death, the estate paid the stepchildren and deducted the payments as “claims against the estate” for tax purposes. The Commissioner of Internal Revenue issued a notice of deficiency, denying these deductions, leading the estate to petition the tax court for review.The U.S. Tax Court ruled that the transfers to the stepchildren were not deductible as “claims against the estate” because they were neither “contracted bona fide” nor “for an adequate and full consideration in money or money’s worth.” The estate failed to shift the burden of proof to the Commissioner, as it did not provide credible evidence to support the deductions. The court found that the payments were essentially donative in character, as they were made to keep Lueders happy and maintain the marriage, rather than as part of an arm’s length transaction.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the tax court’s decision. The appellate court agreed that the payments to the stepchildren were not contracted bona fide, as they were related to Lueders’s expectation of inheritance and lacked the characteristics of a bona fide transaction. The court emphasized that the payments were made with donative intent and were not part of an ordinary business transaction. Therefore, the estate was not entitled to deduct the $3 million transfer to the stepchildren as “claims against the estate.” View "Estate of Spizzirri v. Commissioner of Internal Revenue" on Justia Law

A couple, the Marons, alleged that Florida's Disposition of Unclaimed Property Act violated the Takings Clause of the Fifth Amendment. They claimed that the Act allowed the state to take their unclaimed property without compensating them for the earnings accrued while the property was in the state's custody. The Act requires holders of unclaimed property to deliver it to the state's Department of Financial Services, which then uses the property for public purposes, including investing it. The Marons argued that they were entitled to these earnings.The United States District Court for the Northern District of Florida dismissed the Marons' suit. The court reasoned that the state could constitutionally escheat the property altogether, so it could also keep the property in its custody without compensating for the earnings. The court also addressed jurisdictional issues, concluding that the Marons had standing and that their claim was not fully barred by sovereign immunity, but ultimately found that the Marons failed to state a claim.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court concluded that the district court had jurisdiction over the Marons' takings claim, as the Marons had standing, the claim was ripe, and it was not barred by sovereign immunity. However, the appellate court disagreed with the district court's analysis on the merits. The appellate court held that the Act did not transfer title of the unclaimed property to the state, but merely placed it in the state's custody. The court vacated the district court's judgment and remanded the case for further proceedings to determine whether the Marons' property was directly appropriated by the state and whether the Act provided just compensation. View "Maron v. Chief Financial Officer of Florida" on Justia Law

Curtis Solomon, Devin Chance, and Jamaur Lewis were convicted of multiple counts, including Hobbs Act conspiracy, Hobbs Act robbery, and carrying a firearm during a crime of violence. Their convictions for conspiracy to carry a firearm during a crime of violence were vacated following the Supreme Court's decision in Johnson v. United States. The district court amended their judgments by removing the vacated counts but reimposed the same sentences on the remaining counts without providing an explanation for denying their requests for de novo resentencing.The appellants appealed the amended judgments, arguing that the district court erred by not explaining its decision to deny de novo resentencing and contending that Hobbs Act robbery is not a crime of violence under 18 U.S.C. § 924(c). The United States Court of Appeals for the Eleventh Circuit reviewed the case.The Eleventh Circuit held that it lacked jurisdiction to consider the appellants' challenge to the district court's refusal to conduct a de novo resentencing because no certificate of appealability (COA) had been issued on that question. However, the court found that it had jurisdiction to consider the appellants' challenge to their § 924(c) convictions based on Hobbs Act robbery.On the merits, the Eleventh Circuit reaffirmed its precedent that Hobbs Act robbery is a crime of violence under § 924(c)(3)(A). The court concluded that the Supreme Court's decision in United States v. Taylor, which held that attempted Hobbs Act robbery is not a crime of violence, did not disturb its prior holdings that completed Hobbs Act robbery qualifies as a crime of violence. Therefore, the appellants' § 924(c) convictions based on Hobbs Act robbery were affirmed.The court affirmed the appellants' § 924(c) convictions and dismissed the appeal in part for lack of jurisdiction regarding the challenge to the district court's denial of de novo resentencing. View "USA v. Solomon" on Justia Law

Arturs Spila, a Latvian national, entered the United States in May 2018 and deposited over $284,000 in cash into three bank accounts over three months. The cash originated from a fraudulent scheme where victims were hired for fake work-from-home jobs, instructed to cash checks, and mail the cash to Spila. The checks bounced, and the victims were not reimbursed. Spila then wired over $200,000 from these accounts, mostly to international recipients, in small transactions to avoid mandatory reporting.A federal grand jury indicted Spila for conspiracy to commit money laundering under 18 U.S.C. § 1956(h). The Northern District of Georgia district court admitted emails between Spila and his co-conspirators as evidence and allowed a forensic accountant to testify as a lay witness. The jury convicted Spila, and he was sentenced to 32 months in prison and one year of supervised release. Spila appealed, arguing insufficient evidence of his knowledge that the money came from a felony, prosecutorial misconduct during closing arguments, improper authentication of emails, and improper lay witness testimony.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that the government presented sufficient evidence to prove Spila knew the money came from unlawful activity, even if he did not know it was a felony. The court found no prosecutorial misconduct, as the prosecutor's comments were fair responses to defense arguments. The court also ruled that the district court did not abuse its discretion in admitting the emails as self-authenticating documents and allowing the forensic accountant to testify as a lay witness. The Eleventh Circuit affirmed Spila's conviction. View "United States v. Spila" on Justia Law