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

On June 1, 2018, Officer Jonathan Guzman of the City of Miami Police Department identified a speeding driver in a black Jeep Compass. The driver crashed into another vehicle and fled on foot. During an inventory search of the Jeep, Guzman found a firearm, ammunition, and marijuana. Shortly after, a radio dispatch reported the vehicle as stolen. Officer Michael Bloom arrived at the scene of the reported theft, where Samuel Scott Jr. claimed his Jeep had been stolen. Guzman arrived and recognized Scott as the driver who fled the crash. Scott was arrested for multiple charges, including reckless driving and falsely reporting a crime. The charges were later dropped.Scott filed federal and state law claims in the Southern District of Florida against the officers and the City of Miami, alleging unreasonable search and seizure, false arrest, false imprisonment, and malicious prosecution. The district court granted summary judgment for the defendants, citing qualified and sovereign immunity, and found that the officers had probable cause to arrest Scott based on Guzman’s eyewitness identification.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court’s decision. The court held that Guzman’s eyewitness identification provided sufficient probable cause for Scott’s arrest. The court also found that the officers were entitled to qualified immunity on the federal claims and that the City of Miami was not liable under state law due to the presence of probable cause. Consequently, all of Scott’s claims were dismissed. View "Scott v. City of Miami" on Justia Law

The defendants in this case challenged the constitutionality of 8 U.S.C. § 1326, which criminalizes unlawfully reentering the United States after a prior removal. They argued that the statute violates the equal protection component of the Fifth Amendment’s Due Process Clause by discriminating against Mexican and other Latin American immigrants. Their theory was that the statute’s predecessor, the Undesirable Aliens Act of 1929, was enacted with discriminatory intent, and that § 1326, first codified in 1952 and amended several times thereafter, perpetuates that taint.The United States District Court for the Middle District of Florida denied the defendants’ motions to dismiss their indictments. The court assumed without deciding that the Arlington Heights framework applied but concluded that the defendants had failed to establish a discriminatory purpose behind § 1326’s enactment. The court also concluded that the statute easily satisfied rational-basis review. The defendants then entered conditional guilty pleas or proceeded to a stipulated bench trial, reserving their rights to appeal the constitutional issue. The District Court sentenced the defendants to varying terms of imprisonment and supervised release.The United States Court of Appeals for the Eleventh Circuit reviewed the case and upheld the District Court’s decision. The court found no clear error in the District Court’s conclusion that the defendants had not shown that § 1326 was enacted or maintained for a discriminatory purpose. The court noted that the defendants’ evidence, including historical context, statements by public officials, and statistical disparities, was insufficient to establish that the 1952 Congress acted with discriminatory intent. The court also emphasized that laws do not carry forward “taint” through reenactment unless the later legislature acted with the same constitutionally impermissible purpose. The judgments of the District Court were affirmed. View "USA v. Ferretiz-Hernandez" on Justia Law

Jekyll Island State Park Authority, a Georgia entity, operates the Summer Waves Water Park and owns the federally registered trademark for SUMMER WAVES. In 2021, Jekyll Island discovered that Polygroup Macau Limited, an intellectual property holding company registered in the British Virgin Islands, had registered nearly identical SUMMER WAVES marks. Polygroup Macau’s general counsel had also asked to buy Jekyll Island’s domain name, summerwaves.com. Jekyll Island sued Polygroup Macau for trademark infringement and to cancel Polygroup Macau’s marks. Polygroup Macau moved to dismiss for lack of personal jurisdiction, arguing it did not sell products in the United States using its trademarks.The United States District Court for the Southern District of Georgia granted Polygroup Macau’s motion to dismiss, concluding that Polygroup Macau did not have sufficient contacts with the United States to support personal jurisdiction. The court noted that Polygroup Macau did not sell products in the United States using its trademarks and only permitted other entities to do so, making the connection between Polygroup Macau’s activities and Jekyll Island’s claims too attenuated.The United States Court of Appeals for the Eleventh Circuit reviewed the case and disagreed with the district court’s conclusion. The Eleventh Circuit found that Polygroup Macau had purposefully availed itself of the benefits of United States law by registering and maintaining trademarks with the USPTO, allowing its sister companies to use those trademarks to sell products in the United States, and marketing specifically to U.S. consumers. The court held that the connection between Jekyll Island’s claims and Polygroup Macau’s activities in the United States was close enough to support specific jurisdiction. The Eleventh Circuit reversed the district court’s dismissal and remanded the case for consideration on the merits. View "Jekyll Island-State Park Authority v. Polygroup Macau Limited" on Justia Law

DeShawn Gervin was on probation in Georgia with the sole condition that he not return to the South Georgia Judicial Circuit. He moved to North Carolina but was later imprisoned there for various crimes. A Georgia probation officer, Pamela Florence, learned of his North Carolina offenses and sought a warrant for his arrest in Georgia, falsely claiming he had violated probation by failing to report. Gervin was arrested in North Carolina and extradited to Georgia, where he spent 104 days in jail before a court found he had not violated his probation and ordered his release.Gervin sued Florence and another probation officer, Tandria Milton, under 42 U.S.C. § 1983, alleging violations of his Fourth, Eighth, and Fourteenth Amendment rights. The United States District Court for the Middle District of Georgia granted summary judgment for the defendants on the Eighth and Fourteenth Amendment claims but denied it on the Fourth Amendment claim, characterizing it as a malicious-prosecution claim.The United States Court of Appeals for the Eleventh Circuit affirmed the district court's ruling. The court held that Gervin presented enough evidence to support his Fourth Amendment malicious-prosecution claim. The court found that Florence and Milton recklessly made false statements and omissions that led to Gervin's arrest and prolonged detention, violating his Fourth and Fourteenth Amendment rights. The court also concluded that the probation officers were not entitled to qualified immunity because the constitutional violations were clearly established at the time of their actions. View "Gervin v. Florence" on Justia Law

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