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

Two men wearing masks and armed with guns entered a Miami convenience store and exchanged gunfire with the store clerk during a failed robbery attempt. The suspects fled the scene, and shortly afterwards, a Ford Explorer registered to Rodrick Maurice Hamilton crashed nearby. Blood and a cellphone belonging to Hamilton were found in the vehicle. Hamilton’s girlfriend testified that he directed her to falsely report the vehicle stolen, and he later told her he was leaving for Georgia. Investigators also discovered evidence linking Hamilton and co-conspirator Untarius Alexander to the robbery, including phone records, location data, and clothing matches from surveillance footage. Both men were indicted and prosecuted in federal court.The United States District Court for the Southern District of Florida conducted a jury trial, resulting in Hamilton’s conviction for conspiracy and attempt to commit Hobbs Act robbery. The district court sentenced Hamilton to 170 months in prison, which included a twenty-month upward departure from the Sentencing Guidelines range. The government’s motion to dismiss a firearm charge was granted in light of United States v. Taylor, 596 U.S. 845 (2022). Hamilton appealed his convictions and sentence, raising several challenges, including the propriety of a jury flight instruction, alleged prosecutorial misconduct, the handling of a juror’s post-verdict statement, and the sentencing process.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court’s judgment. The court held that the flight instruction was proper, the prosecutor’s comments during closing arguments did not violate Hamilton’s Fifth Amendment rights, and the district court acted within its discretion by denying a new trial and declining to investigate the juror’s post-verdict remarks under Rule 606(b). In addition, the appellate court found no procedural or substantive error in the upward departure at sentencing, as proper notice was given and the sentence was justified by Hamilton’s criminal history and the need for deterrence. View "United States v. Hamilton" on Justia Law

Between December 2007 and February 2008, the defendant and accomplices robbed seven Florida convenience stores and attempted to rob two others, occasionally stealing cash and cigarettes. In April 2009, a federal grand jury indicted him on twenty-two counts related to conspiracy, robbery, attempted robbery, and using or brandishing a firearm during crimes of violence. A jury convicted him on eighteen counts, and the United States District Court for the Southern District of Florida sentenced him to 196 years in prison, primarily due to consecutive mandatory minimum sentences under 18 U.S.C. § 924(c).After the Supreme Court’s decisions in Johnson v. United States, United States v. Davis, and United States v. Taylor clarified the definition of “crime of violence” under § 924(c), the defendant filed petitions under 28 U.S.C. § 2255. The Eleventh Circuit permitted a limited successive motion challenging only his § 924(c) conviction predicated on attempted Hobbs Act robbery (Count Sixteen). The district court vacated that count and held a de novo resentencing, ultimately imposing a new 173-year sentence. The defendant argued for application of the more lenient sentencing provisions of the First Step Act of 2018 (“FSA”) and sought to challenge his other § 924(c) convictions, but the district court declined both requests. On appeal, the Eleventh Circuit originally affirmed.After the Supreme Court decided Hewitt v. United States, which held that defendants resentenced after the FSA’s enactment are eligible for its revised penalties, the Eleventh Circuit granted rehearing. The United States Court of Appeals for the Eleventh Circuit held that the FSA applies retroactively to the defendant’s resentencing and vacated his sentence, remanding for resentencing under the FSA. The court affirmed that the district court lacked jurisdiction to consider new challenges to other counts not authorized by the appellate court. View "United States v. Ragland" on Justia Law

Three individuals were involved in a conspiracy to rob a marijuana dealer at his home on the Big Cypress Seminole Indian Reservation. During the attempted robbery, a bystander was shot and killed, and the perpetrators fled without obtaining money or drugs. One of the defendants later discussed the crime with a third party, who reported the information to law enforcement and recorded a conversation, further implicating the participants. Additional evidence, including surveillance footage, cell site records, and ballistics, corroborated the involvement of the defendants.The United States District Court for the Middle District of Florida heard the case. One defendant moved to dismiss the indictment, arguing that because both he and the victim were enrolled members of Indian tribes and the offense occurred in Indian country, and since the charged crimes were not listed in the Major Crimes Act, the court lacked jurisdiction. The district court disagreed and denied the motion, allowing the prosecution to proceed. During trial, another defendant objected to the admission of prior convictions without an explicit balancing of probative value and prejudicial effect. The court admitted the evidence without making such a finding. The jury ultimately found the defendants guilty on various counts, and the defendants appealed.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that federal courts possess jurisdiction over generally applicable federal crimes, such as Hobbs Act robbery, even when committed by an Indian against another Indian in Indian country. The court also found that the district court erred by not conducting an on-the-record balancing before admitting evidence of prior convictions, but deemed this error harmless given the strength of the government’s case. The convictions of all three defendants were affirmed. View "USA v. Brice" on Justia Law

The defendant was charged with possessing two firearms as a convicted felon and with possession of methamphetamine with intent to distribute, following a shooting and possible abduction at a motel in Hialeah, Florida. Surveillance footage and subsequent police investigation linked the defendant to the incident via a work van registered to his business, J&M Electric, and to a residential property where evidence was found. The defendant, his girlfriend, and his stepfather Soriano were associated with the property. After a violent altercation, Soriano temporarily relocated but retained access and possessions at the residence. Police obtained Soriano’s consent to search the property, and later, a search warrant; they found firearms, ammunition, and a large quantity of methamphetamine, along with items indicating drug trafficking.The United States District Court for the Southern District of Florida conducted a jury trial, during which the government presented evidence, including surveillance videos, forensic analyses, and a YouTube video filmed at the defendant’s residence. The jury convicted the defendant on two counts: felon in possession of a firearm and possession with intent to distribute methamphetamine, but acquitted him of possession of a firearm in furtherance of a drug trafficking crime. The district court dismissed one firearm count to avoid double jeopardy and sentenced the defendant to concurrent 96-month terms.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It affirmed the district court’s denial of the defendant’s motion to suppress evidence, finding Soriano had actual authority to consent to the search. The appellate court also upheld evidentiary rulings, denial of the Rule 29 motion for acquittal, rejection of the prosecutorial misconduct claim, and the application of the sentencing guidelines. The court held there was no cumulative error and affirmed both convictions and the sentence. View "United States v. Estadella" on Justia Law

A student with Down syndrome, C.B., attends school in the Henry County School District in Georgia. Under the Individuals with Disabilities Education Act (IDEA), the school district was required to develop an individualized education program (IEP) for C.B. After reviewing C.B.’s progress in fourth grade, the school district’s IEP team decided to move C.B. from an interrelated resource (IRR) class to a mild intellectual disability (MID) class for language arts and math. C.B.’s parents disagreed with this new placement, believing the IRR class was less restrictive and more appropriate. They also objected to the school district’s decision to place C.B. on an alternative assessment track, rather than the regular statewide assessment.Following the school district’s decision, C.B.’s parents requested a due process hearing before the Georgia Office of State Administrative Hearings. The administrative law judge conducted a five-day hearing and found that the school district had complied with IDEA in making the placement decision and that the Georgia Alternate Assessment was appropriate for C.B. The United States District Court for the Northern District of Georgia affirmed the administrative law judge’s findings regarding the placement, concluding that the least restrictive environment requirement under IDEA did not apply to the choice between different types of special education classes. The district court also found C.B.’s claim regarding the alternative assessment moot, since C.B. was no longer required to take the alternative assessment.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision regarding the placement in the MID class, holding that the least restrictive environment requirement under IDEA does not apply to placement decisions among special education classes. However, the court reversed the district court’s mootness determination on the assessment claim and remanded the case for further proceedings on that issue. View "C.B. v. Henry County School District" on Justia Law

The petitioner, a citizen of Sierra Leone and lawful permanent resident, was convicted in the District of Columbia in 2014 of attempted first-degree sexual abuse and kidnapping. The factual basis for his conviction included both forceful digital penetration and forceful penile penetration. After serving his prison sentence, the Department of Homeland Security initiated removal proceedings, alleging that his conviction qualified as an aggravated felony under the Immigration and Nationality Act, specifically as “rape” or “an attempt to commit an aggravated felony,” and also as a crime of violence.In removal proceedings before the Immigration Judge, the petitioner admitted the factual allegations but disputed that his conviction was an aggravated felony, arguing that the D.C. statute criminalized digital penetration, which he claimed was not covered by the generic federal definition of rape. The Immigration Judge ordered removal, finding the conviction constituted attempted rape. The Board of Immigration Appeals affirmed, relying on its precedent that the generic definition of rape included digital penetration, and dismissed other removability grounds as unnecessary. The Board also denied the petitioner’s requests for a waiver of inadmissibility, but remanded for further consideration of his claim under the Convention Against Torture, directing the Immigration Judge to consider aggregate risks of torture. After additional hearings, the Immigration Judge again denied relief, and the Board affirmed, declining to revisit removability.The United States Court of Appeals for the Eleventh Circuit reviewed only the Board’s removability determination. It held that the generic federal definition of “rape” under 8 U.S.C. § 1101(a)(43)(A) does not include digital penetration, joining other circuits. Consequently, the Board erred in concluding the petitioner’s conviction categorically matched the federal definition of rape. The court vacated the Board’s decision and remanded for further proceedings on other removability grounds. View "Barrie v. Attorney General" on Justia Law

Javier Hernandez was a participant in a transnational criminal operation that smuggled Cuban migrants into Mexico for eventual entry into the United States. His primary role involved stealing boats from Southwest Florida, which he delivered to co-conspirators in Mexico. These vessels were used to transport migrants from Cuba or were sold to support the smuggling enterprise, including bribing law enforcement. Hernandez also transported stolen vehicles to Mexico for similar purposes. He was compensated for each delivery and admitted to earning substantial profits from these activities.Federal authorities identified Hernandez through investigative techniques including cell-site location tracking and the recovery of his cell phone, which had been seized by Mexican authorities. The government obtained and executed a warrant to search his phone, extracting relevant data. After initial technical difficulties, a second extraction was performed after the warrant’s nominal expiration date but while the phone was still in government custody. Hernandez was indicted in the United States District Court for the Southern District of Florida on five counts, including conspiracy to encourage unlawful entry, transportation of stolen vessels, trafficking in vehicles with altered VINs, and money laundering. He moved to suppress the evidence from the second extraction, but the district court denied the motion, applied several sentencing enhancements, and imposed a sentence of ninety-five months.On appeal, the United States Court of Appeals for the Eleventh Circuit held that the second extraction did not violate Federal Rule of Criminal Procedure 41 or the Fourth Amendment, as Rule 41(e)(2)(B) allows for off-site copying and review of electronic information after the warrant period. The court also found that even if there were a procedural violation, suppression would not be warranted due to the agents’ good faith and lack of prejudice. The court determined that the evidence was sufficient to sustain all convictions and found no reversible error in the sentencing calculations or guideline enhancements. The Eleventh Circuit affirmed the district court’s judgment. View "USA v. Hernandez" on Justia Law

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