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

The defendant, after serving a prison sentence for a Florida felony drug offense, was released into the state's conditional release program. Three days post-release, he signed a certificate agreeing to various conditions, including submission to searches by his release supervisor. Shortly before his conditional release was scheduled to end, he tested positive for cocaine. The supervisor recommended a warrant for his arrest, which was issued by the Florida Commission on Offender Review. When officers executed the warrant at his residence, the supervisor conducted a warrantless search, finding drugs and a firearm. This led to federal charges including possession of a firearm by a convicted felon and possession with intent to distribute a controlled substance.The United States District Court for the Southern District of Florida denied the defendant’s motion to suppress evidence from the warrantless search, concluding he was still on conditional release at the time and that reasonable suspicion justified the search. The defendant then pleaded guilty to the firearm possession charge. During sentencing, the presentence investigation report recommended a mandatory minimum sentence under the Armed Career Criminal Act (ACCA), listing several prior Florida convictions as possible predicate offenses. The defendant objected, arguing both legally and factually that the convictions did not qualify and that the government had not proven their existence by a preponderance of the evidence.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s denial of the motion to suppress, holding that the defendant was still subject to conditional release and that the search was supported by reasonable suspicion. However, the appellate court vacated the sentence, finding the district court erred by imposing the ACCA enhancement without requiring the government to prove the necessary predicate convictions. The case was remanded for resentencing without the ACCA enhancement. View "USA v. Louis" on Justia Law

A group of former employees participated in an employee stock ownership plan (ESOP) established by a seafood company. In 2016, the plan used borrowed funds to purchase all outstanding shares from several company officers and directors. The employees alleged that the purchase price was grossly inflated due to false financial projections, resulting in significant financial harm to the plan and its participants. The plaintiffs, on behalf of themselves and a proposed class, brought statutory claims under the Employee Retirement Income Security Act (ERISA), asserting breaches of fiduciary duty by the company’s officers, directors, trustee, and committee members.The United States District Court for the Northern District of Georgia dismissed the plaintiffs’ complaint, relying on Eleventh Circuit precedent from Mason v. Continental Group, Inc. and its progeny, which required administrative exhaustion of statutory ERISA claims before filing suit. The district court also denied the plaintiffs’ request to stay the proceedings to pursue administrative remedies, reasoning that both it and the parties were bound by the Eleventh Circuit’s exhaustion requirement. A panel of the Eleventh Circuit affirmed the dismissal, citing the binding nature of Mason.The United States Court of Appeals for the Eleventh Circuit, sitting en banc, reviewed the case and overruled Mason and related decisions to the extent that they held ERISA itself requires exhaustion of statutory claims, including breach of fiduciary duty claims. The court determined that ERISA does not impose such an exhaustion requirement and found that the plan at issue did not mandate exhaustion either. Accordingly, the Eleventh Circuit reversed the district court’s dismissal and remanded the case to the panel for further proceedings. View "Bolton v. Inland Fresh Seafood Corporation of America, Inc." on Justia Law

Two attorneys, licensed in New Jersey and Michigan, sought admission to the Florida Bar and challenged a Florida rule requiring applicants admitted to another bar for more than twelve months to pay a higher application fee. They argued that this "experienced-applicant" rule violated the dormant Commerce Clause by burdening out-of-state applicants both on its face and in practical effect. One attorney paid the fee and then sued, seeking a refund and an injunction; the other attorney did not pay and joined the suit to seek prospective relief.The United States District Court for the Northern District of Florida initially dismissed most claims for lack of standing or based on Eleventh Amendment immunity, but allowed a limited practical-effect claim against the executive director of the Florida Board of Bar Examiners. After further amendments and discovery, the district court denied summary judgment to the plaintiffs and granted summary judgment to the executive director, finding that the rule did not discriminate against out-of-state applicants in practice.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that the Board of Bar Examiners is an arm of the state and therefore immune from suit under the Eleventh Amendment. As to the claim against the executive director, the court found that the experienced-applicant rule did not facially discriminate against out-of-state applicants, as it was based solely on years of admission, not geographic origin. The court further concluded that undisputed evidence showed the rule imposed similar burdens on both in-state and out-of-state applicants and was adopted for legitimate, non-protectionist reasons. The Eleventh Circuit affirmed the district court’s dismissal and summary judgment, holding that neither facial nor practical-effect dormant Commerce Clause claims could succeed. View "Hernandez v. Florida Board of Bar Examiners" on Justia Law

The defendant participated in two armed robberies of auto-parts stores in Tampa, Florida, along with a co-defendant. Both men entered the stores wearing masks and brandishing handguns, demanding money from employees and directing them to lie down in the back of the stores while they made their escape. Surveillance footage and subsequent police investigation linked the defendant to the crimes, resulting in his arrest after officers found incriminating evidence in his vehicle. He was charged with two counts of Hobbs Act robbery, one count of conspiracy, and two counts of brandishing a firearm during a crime of violence.The case was first heard in the United States District Court for the Middle District of Florida. The defendant pleaded guilty to all counts except one firearm charge, which was dropped pursuant to a plea agreement. The government agreed to recommend a within-guidelines sentence, but reserved the right to provide relevant information and respond to the defendant’s comments. A pre-sentence investigation report recommended several sentencing enhancements, including a two-level enhancement for physically restraining victims. The district court imposed a sentence of 204 months (17 years), consisting of 120 months for the Hobbs Act charges and a consecutive 84 months for the brandishing charge, after varying upward from the guidelines range based on the defendant’s criminal history.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed three issues: alleged breach of the plea agreement, the propriety of the two-level physical restraint enhancement, and substantive reasonableness of the sentence. The court held that the government did not breach the plea agreement. However, it found that the district court plainly erred in applying the two-level enhancement, due to a recent, retroactively applicable amendment to the Sentencing Guidelines. The court vacated the sentence and remanded for resentencing, while affirming the convictions. View "USA v. Brown" on Justia Law

Three defendants were apprehended by the United States Coast Guard while operating a go-fast vessel approximately 128 miles off the coast of Colombia. When detected, they attempted to flee and discarded 19 bales containing 623 kilograms of cocaine into the sea before being stopped. They were subsequently charged under the Maritime Drug Law Enforcement Act (MDLEA) for conspiracy and possession with intent to distribute cocaine on the high seas.In the United States District Court for the Southern District of Florida, the defendants moved to dismiss the indictment, arguing that the Coast Guard failed to establish U.S. jurisdiction because officers allegedly did not properly confirm that the vessel was “without nationality.” The district court held an evidentiary hearing, where Coast Guard Officer Balboa testified that he individually asked each defendant if they claimed nationality for the vessel, and all declined. The court credited Balboa’s testimony on this point, despite finding he had lied about other details, and concluded U.S. jurisdiction was established. The court denied constitutional and sentencing challenges, then sentenced each defendant to 96 months’ imprisonment, applying a guidelines enhancement for recklessly endangering others during their flight.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that (1) the government must establish MDLEA jurisdiction by a preponderance of the evidence, not beyond a reasonable doubt; (2) the district court did not clearly err in crediting Balboa’s testimony that no claim of nationality was made, thus supporting jurisdiction; (3) the MDLEA is constitutional as applied; and (4) the sentencing enhancement for recklessly creating a substantial risk of serious bodily injury was properly applied. The Eleventh Circuit affirmed the convictions and sentences. View "USA v. Chirino-Lovera" on Justia Law

Federal agents executed a pre-dawn raid targeting a gang member in Atlanta, but mistakenly entered the plaintiffs’ residence, three houses away from the intended address and on a different street. The FBI SWAT team forcibly entered, detonated a flash-bang grenade, and detained the plaintiffs, including a minor, before realizing their error and departing. The raid’s leader, Agent Guerra, later attributed the mistake to his personal GPS device, which he discarded shortly after the incident. Plaintiffs disputed the adequacy of pre-raid preparations and alleged multiple torts and constitutional violations.The plaintiffs filed suit in the United States District Court for the Northern District of Georgia, asserting claims against the United States under the Federal Tort Claims Act (FTCA) for false arrest, assault and battery, trespass, emotional distress, and negligence, as well as a Bivens claim against Agent Guerra and others for Fourth Amendment violations. The district court granted summary judgment to the United States on most FTCA claims under the discretionary-function exception, and to Agent Guerra on the Bivens claim based on qualified immunity. After an intervening Eleventh Circuit decision, the district court granted judgment to the government on the remaining FTCA claims.On appeal, the United States Court of Appeals for the Eleventh Circuit was instructed by the Supreme Court (following Martin v. United States, 605 U.S. 395 (2025)) to re-examine whether the FTCA’s discretionary-function exception barred the plaintiffs’ claims. The Eleventh Circuit held that the discretionary-function exception shielded the United States from all FTCA claims arising from the raid and affirmed their dismissal. However, the court reversed the grant of qualified immunity to Agent Guerra, finding that, when viewing the evidence most favorably to the plaintiffs, his actions violated clearly established Fourth Amendment law. The case was remanded for further proceedings consistent with these holdings. View "Martin v. USA" on Justia Law

In December 2001, a 21-year-old man and his two younger brothers planned and carried out the murders of a woman, Chrissie Williams, and her three-year-old daughter, Katelyn, in Georgia. The crime involved home invasion, use of weapons, and acts of extreme violence and sexual assault. After fleeing the state and being apprehended, the brothers entered plea agreements: the two younger brothers received life sentences with parole eligibility, while the petitioner, after initially negotiating for a similar deal, ultimately rejected a plea offer and decided to plead guilty, influenced by religious beliefs that demanded confession and acceptance of the death penalty.The Superior Court of Paulding County accepted the petitioner’s guilty plea and, following a bench sentencing trial at his request, imposed the death penalty. The Georgia Supreme Court affirmed his convictions and sentences on direct appeal. After a failed “next friend” habeas attempt by a brother, the petitioner filed his own state habeas petition, arguing ineffective assistance of counsel and other constitutional violations. While the state habeas court initially granted relief on the sentencing, the Georgia Supreme Court reversed, reinstating the death sentence. The petitioner then pursued federal habeas relief in the United States District Court for the Northern District of Georgia, which denied relief but granted a certificate of appealability on selected claims.The United States Court of Appeals for the Eleventh Circuit reviewed the case and held that the Georgia Supreme Court’s denial of the petitioner’s claims was not an unreasonable application of clearly established federal law or an unreasonable determination of the facts. The court found that trial counsel’s recommendation to waive a jury for sentencing was reasonable, that no prejudice resulted from counsel’s alleged failure to investigate mitigating evidence due to the petitioner’s own instructions, and that the prosecution’s use of alternative theories in codefendants’ proceedings did not violate constitutional rights. The district court’s denial of habeas relief was affirmed. View "Tate v. Warden GDCP" on Justia Law

A woman was arrested in Randolph County, Alabama, under a system that required arrestees to pay a predetermined bail amount based on the charged offense for immediate release. Those unable to pay had to wait until an initial appearance, which could take up to three days, and frequently did not result in a release determination. Instead, release decisions were often deferred until a preliminary hearing up to four weeks later. The plaintiff, unable to afford bail, filed a class action alleging that the county’s bail practices discriminated against indigent individuals and violated their constitutional rights.The United States District Court for the Middle District of Alabama initially granted a temporary restraining order, releasing the plaintiff. While the case was pending, Randolph County adopted a new, more permissive bail policy. Defendants moved to dismiss the case as moot, arguing the new policy ended the challenged conduct. The district court certified a class of arrestees unable to pay secured bail, but after the Supreme Court denied certiorari in a similar case, Schultz v. Alabama, the district court dismissed most claims as moot, limiting plaintiffs to facial challenges against the new policy, and concluded those remaining claims failed to state a plausible claim for relief.The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s dismissal. The court held that the voluntary cessation doctrine precludes defendants from mooting the case simply by changing the bail policy during litigation. The class may proceed with facial and as-applied challenges to the prior bail practices, as well as as-applied challenges to the current bail practices. However, the court affirmed the district court’s dismissal of facial challenges to the current bail policy. The case was remanded for further proceedings consistent with these holdings. View "Edwards v. Randolph County Sheriff" on Justia Law

A man in his early thirties, who had recently undergone brain surgery for an aggressive form of cancer and was experiencing severe side effects, including irrational and violent behavior, began acting erratically at a rural Alabama home where he was living with family. On the day of the incident, he stopped taking his medications, engaged in increasingly disturbing behavior, damaged property, and physically threatened those around him. After he shattered the window of a sheriff’s vehicle and the windshield of an ambulance, law enforcement was summoned. A deputy attempted to subdue him with a taser, which failed, and was then pursued by the man. The man chased the deputy onto the property of a nearby police captain, who had been alerted to the disturbance and came outside to assist.The United States District Court for the Middle District of Alabama previously reviewed the case. The estate of the deceased sued the police captain under 42 U.S.C. § 1983, claiming excessive use of deadly force in violation of the Fourth Amendment. The district court granted summary judgment for the officer, finding he was entitled to qualified immunity because a reasonable officer could have believed the use of deadly force was necessary under the circumstances.The United States Court of Appeals for the Eleventh Circuit reviewed the case on appeal. The court examined the facts from the perspective of the officer on the scene, emphasizing the man’s violent, erratic conduct, the ineffectiveness of non-lethal force, and the officer’s reasonable perception of a serious physical threat. The Eleventh Circuit held that the use of deadly force did not violate the Fourth Amendment because a reasonable officer could have concluded such force was necessary to prevent serious physical harm or death. The court affirmed the district court’s judgment in favor of the officer. View "Callaway v. Adcock" on Justia Law

A software company managing cloud storage accounts detected that a user had uploaded material suspected to be child sexual abuse content. As required by federal law, the company reported this to the National Center for Missing and Exploited Children (NCMEC), which in turn forwarded a CyberTip containing the information, including the suspect’s phone number, to law enforcement. A detective from the Tallahassee Police Department reviewed the CyberTip and submitted an affidavit to a Florida state court judge to obtain a warrant to search the suspect’s cloud account. The affidavit referenced the reliability of NCMEC’s processes and the detective’s experience, but did not describe the alleged illicit images. The warrant was granted, and the subsequent search uncovered child sexual abuse images. Further investigation led to the identification of a victim and the arrest of the suspect, who was later charged federally.The defendant moved in the United States District Court for the Northern District of Florida to suppress the evidence, arguing that the search warrant affidavit lacked probable cause and that the good faith exception to the exclusionary rule did not apply. The district court agreed, finding that the affidavit was too vague and conclusory, lacking sufficient details to support probable cause or reasonable reliance. As a result, the court suppressed all evidence obtained from the searches.On appeal, the United States Court of Appeals for the Eleventh Circuit considered whether the good faith exception to the exclusionary rule applied, assuming without deciding that the affidavit was deficient in establishing probable cause. The court held that the affidavit contained enough indicia of probable cause, particularly due to the general trustworthiness of NCMEC’s CyberTip program and the detective’s reasonable reliance on established procedures. Therefore, the court reversed the district court’s suppression order and remanded for further proceedings. View "USA v. Gibbs" on Justia Law