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

Kelly was suspected of illegal drug activity after Detective Jonathan Smith observed a drug sale involving a black male who left the scene in a red vehicle with a white female passenger. Shortly after, Deputy Cody Jett received an anonymous tip indicating Heather McDonald would arrive in a red Hyundai at a McDonald’s restaurant, accompanied by a black male driver, and that both individuals possessed heroin and were dealing drugs. Deputy Jett verified an arrest warrant for McDonald. At the restaurant, Jett observed a vehicle matching the tip, McDonald, and a black male later identified as Kelly. After Kelly and McDonald responded to Jett’s instructions, McDonald attempted to flee and was apprehended, while Kelly was detained and eventually admitted there were drugs in the vehicle. Officers subsequently obtained a search warrant, found additional evidence, and arrested Kelly for driving with a suspended license and several drug offenses.The United States District Court for the Middle District of Florida initially denied the officers’ motion to dismiss under Heck v. Humphrey, finding it could not conclude at that stage that Kelly’s Fourth Amendment claims were barred. Later, upon motions for summary judgment, the district court granted summary judgment in favor of the officers, holding that Heck barred Kelly’s suit because success would imply the invalidity of his convictions. The district court did not address qualified immunity.The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo and declined to base its decision on Heck. Instead, the appellate court found that both Deputy Jett and Detective Smith were entitled to qualified immunity because there was probable cause to detain Kelly, given the corroborated anonymous tip and observed circumstances. The Eleventh Circuit affirmed the summary judgment in favor of the officers. View "Kelly v. Jett" on Justia Law

The defendant, a law enforcement officer, was accused of knowingly engaging in sexual contact with his nine-year-old daughter during a family cruise to the Bahamas. The incident occurred in a public dining room on the cruise ship, where witnesses observed the defendant repeatedly reaching under his daughter’s dress and touching her upper and inner thighs, with some testimony indicating attempts to touch her groin area. One witness recorded the incident, and security personnel were alerted. Upon the ship’s return to Miami, law enforcement detained and questioned the defendant, who denied any sexual intent, claiming his actions were innocent.The United States District Court for the Southern District of Florida conducted a jury trial in which the government presented video evidence, eyewitness testimony, and expert opinions. The defense offered character witnesses and expert testimony negating any sexual motivation or psychiatric disorder, and the defendant testified in his own defense. The jury found him guilty of violating 18 U.S.C. § 2244(a)(5). After trial, it was discovered that the jury had access to an unredacted indictment containing forfeiture allegations referencing statutes related to child pornography, though the case did not involve such materials. The defendant filed motions for acquittal and for a new trial, arguing insufficient evidence of intent and prejudice from the jury’s exposure to extrinsic evidence.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that the evidence presented at trial was sufficient for a rational jury to find the necessary criminal intent beyond a reasonable doubt, and that the district court did not abuse its discretion in concluding that the government had rebutted the presumption of prejudice arising from the jury’s exposure to the unredacted indictment. The Eleventh Circuit affirmed the conviction and denial of a new trial. View "USA v. Sigmon" on Justia Law

A mother reported to the City Schools of Decatur, Georgia, that her five-year-old Black daughter had been sexually assaulted by a male classmate in a kindergarten restroom. She was dissatisfied with the school district’s response to the report, alleging that school staff delayed action, failed to adequately investigate the incident, and made a child protective services referral that implicated her in neglect. The mother also claimed the district’s response was influenced by the race of her family, given that her daughter is Black and the alleged perpetrator was a Black boy adopted by White parents.After the report, the school principal and staff took several steps: contacting a school resource officer and social workers, informing district administrators, ensuring both children were supervised during restroom visits, and referring the matter to the Department of Family and Children Services (DFCS) for both the victim and alleged perpetrator. The mother took her daughter to the hospital for examination, and the girl was later moved to a different classroom and eventually transferred to another school at her mother’s request. DFCS investigated and closed the case against the mother as unsubstantiated. The Department of Education’s Office for Civil Rights later found the district’s Title IX response was inadequate under its regulations, though it found no retaliation.In the United States District Court for the Northern District of Georgia, summary judgment was granted for the school district on both the Title IX (sex discrimination) and Title VI (race discrimination) claims. The court found the district’s response did not amount to deliberate indifference, as required under Title IX, and that there was insufficient evidence of racial discrimination under Title VI.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed. The court held that the district’s actions—including an immediate investigation, protective measures, and student transfers—were not clearly unreasonable and did not constitute deliberate indifference under Title IX. The court also held that the plaintiff failed to present sufficient evidence of intentional race discrimination under Title VI. View "Thomas v. City Schools of Decatur" on Justia Law

A prison inmate was transferred from Phillips State Prison in Georgia, where he had stabbed a high-ranking member of the Bloods gang, to Baldwin State Prison after being placed in protective custody due to the imminent threat of retaliation. The transfer request cited his need for mental health services and mentioned the risk posed by his known enemy, but did not specify risks at Baldwin. Upon arriving at Baldwin, the inmate was placed in the general population, and after briefly requesting protective custody—which he later withdrew—he was stabbed to death by another inmate, allegedly a Bloods member. The parents and estate of the deceased sued five Georgia Department of Corrections officials, alleging that each was deliberately indifferent to the risk of harm under the Eighth Amendment.The United States District Court for the Middle District of Georgia initially dismissed certain wrongful death claims as time-barred, but allowed Eighth Amendment claims by the estate against all five defendants to proceed. The district court ultimately granted summary judgment in favor of the defendants, holding that each was entitled to qualified immunity because there was no violation of clearly established law and no evidence of subjective awareness by any defendant that their conduct caused a substantial risk of harm.The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s rulings de novo. The Eleventh Circuit affirmed the district court’s judgment, holding that none of the defendants possessed the requisite subjective knowledge that their actions or inactions placed the inmate at substantial risk of serious harm. Applying the deliberate indifference standard established in Wade v. McDade and Farmer v. Brennan, the court concluded that all defendants were protected by qualified immunity, as there was no constitutional violation. View "McClinton v. Warden" on Justia Law

The case concerns an automobile accident in which the insured, Consul, rear-ended another driver, Choisser, causing injuries and significant vehicle damage. Consul’s insurer, Progressive, provided coverage with $10,000 bodily injury and $10,000 property damage limits. After the accident, Progressive determined Consul was fully at fault. Progressive and Choisser’s attorney began settlement negotiations, during which Progressive sought a release of any loss of consortium claim from Choisser’s wife and required transfer of the vehicle title for what it deemed a total loss. Choisser’s attorney objected to these conditions, stating he did not represent the wife and disputing the total loss valuation. Negotiations stalled, and Choisser ultimately sued Consul. The property damage claim settled, but the bodily injury claim proceeded to trial, resulting in a judgment exceeding $1 million against Consul.Following the judgment, Consul sued Progressive in the United States District Court for the Middle District of Florida, alleging bad faith in Progressive’s settlement negotiations and communications. Progressive moved for summary judgment, arguing it had acted reasonably under the circumstances. The district court granted summary judgment in Progressive’s favor, concluding there was no evidence of bad faith and that Progressive’s actions were reasonable, including its handling of the consortium waiver and title transfer issues.On appeal, the United States Court of Appeals for the Eleventh Circuit held that summary judgment was improper. The appellate court found that genuine disputes of material fact existed regarding whether Progressive acted in bad faith, particularly concerning the reasonableness of requiring the consortium waiver, the handling of the vehicle title, and communication with Consul. The Eleventh Circuit vacated the district court’s judgment and remanded the case for further proceedings, holding that a reasonable jury could find Progressive failed to fulfill its duty of good faith under Florida law. View "Consul v. Progressive American Insurance Company" on Justia Law

Police in Manatee County, Florida, began investigating an individual known as “Dre” following a tip that he was selling drugs and collecting payments through Cash App. Surveillance linked “Dre” to a residence in Bradenton, which was then associated with Andre Adams Jr. Officers observed frequent, brief visits to the home and witnessed Adams hand items to visitors. Trash recovered from the property contained evidence of drugs, and Cash App records revealed Adams received over $67,000 in small payments, with some transactions referencing drug slang. Adams had no reported employment during this period. A search warrant was obtained for the residence, where officers found substantial evidence of drug trafficking, including narcotics, cash, firearms, and paraphernalia. A subsequent search of a storage unit rented by Adams uncovered more drugs, cash, and firearms.A federal grand jury indicted Adams on charges of possessing drugs with intent to distribute, possessing a firearm in furtherance of a drug trafficking crime, and possessing a firearm as a convicted felon. Adams moved to suppress evidence, arguing the search warrant affidavit omitted material information, and sought a hearing under Franks v. Delaware. A magistrate judge recommended denying his motions, finding Adams failed to submit a sworn statement as required, and the district court adopted this recommendation. Adams’s evidentiary objections to the introduction of his financial records and employment history were also denied, as was his request for a specific jury instruction on “mere presence.” At trial, the jury convicted Adams on all counts.The United States Court of Appeals for the Eleventh Circuit reviewed and affirmed the district court’s decisions. The appellate court held that Adams was not entitled to a Franks hearing, the evidentiary rulings were proper or harmless, the jury instructions were adequate, the evidence was sufficient to support the convictions, and the 228-month sentence was substantively reasonable. View "USA v. Adams" on Justia Law

Several Medicaid enrollees in Florida, whose benefits were terminated due to income-based eligibility determinations, challenged the adequacy of the notices they received from the state. These notices, generated by Florida’s Department of Children and Families (DCF), typically stated that Medicaid benefits would end because “household income is too high,” but did not include essential individualized information such as the household size used, the countable income figure, the income threshold applied, or the specific Medicaid eligibility category considered. In some cases, the notices also included contradictory or confusing information about which household members were affected. Many recipients later learned that their coverage had been terminated or restored in error, but the notices did not provide enough detail for them to understand or contest the agency’s decisions.The case was brought as a class action in the United States District Court for the Middle District of Florida, focusing on whether the notices met the requirements of due process. After a bench trial, the district court found that the written notices were confusing, lacked sufficient individualized detail to explain the state’s decisions, and failed to enable recipients to understand or meaningfully challenge their benefit terminations. The court also found that other sources of information available to recipients, such as call centers or online resources, did not cure these deficiencies. The district court issued a declaratory judgment and a permanent injunction, requiring Florida to provide clear and case-specific information in future notices before terminating Medicaid benefits for income ineligibility.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s judgment. The court held that Florida’s notice system, considered as a whole, did not satisfy due process because it was not reasonably calculated to adequately inform recipients of the reasons for benefit termination or enable them to decide whether to contest the action. View "Chianne D. v. Secretary, Florida Agency for Health Care Administ" on Justia Law

The defendant, previously convicted of serious felonies, was indicted for possessing a firearm as a felon after officers found a firearm in his vehicle during a traffic stop. He initially pleaded not guilty, but later changed his plea to guilty. While released on bond awaiting sentencing—subject to home detention and an ankle monitor—the defendant requested and received removal of the home detention condition. Shortly before sentencing, he was arrested for armed robbery. The incident involved two masked men robbing a victim at gunpoint, stealing cash, jewelry, and a cell phone. Circumstantial evidence, including location data from the defendant’s ankle monitor and a tracking device registered to him, placed him at the scene and linked him to the crime.The United States District Court for the Middle District of Florida held a bond revocation hearing, found probable cause the defendant violated his release conditions, revoked his bond, and later conducted a sentencing hearing. The presentence report initially recommended a reduction for acceptance of responsibility, but after the robbery charge, a revised report removed the reduction and increased the guideline range. The prosecution sought an upward variance based on the new criminal conduct. At sentencing, the district court considered testimony and evidence from both hearings, denied the reduction for acceptance of responsibility, and imposed a 96-month sentence, citing the defendant’s continued dangerous conduct.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that the district court did not reversibly err in finding the defendant committed armed robbery by a preponderance of the evidence, did not plainly err in considering the robbery to deny the offense-level reduction for acceptance of responsibility, and did not impose an unreasonable sentence. The court affirmed the conviction and sentence. View "USA v. Lemaine" on Justia Law

A Georgia inmate was sentenced to death after being convicted by a jury of two counts of malice murder, along with other crimes, based on evidence that he and an accomplice burglarized a residence, set fire to another nearby home, and killed two victims. The inmate confessed to the crimes and was linked by physical evidence. After exhausting his appeals in the Georgia Supreme Court and being denied certiorari by the United States Supreme Court, he filed a state habeas petition, which was denied, and the Georgia Supreme Court denied his application for a certificate of probable cause to appeal.Following these state proceedings, the inmate filed a federal habeas corpus petition in the United States District Court for the Southern District of Georgia, raising nine claims with approximately sixty subclaims. The Warden argued that most claims were procedurally defaulted, unexhausted, or insufficiently pleaded under Rule 2(c) of the Rules Governing Section 2254 Cases. The district court dismissed six subclaims as insufficiently pleaded, some on its own motion (sua sponte), and denied the petitioner’s motion for reconsideration and for leave to amend the petition, reasoning that the petitioner had long been aware of the pleading requirements and had delayed seeking leave to amend.On appeal, the United States Court of Appeals for the Eleventh Circuit addressed the narrow question of whether the Constitution required the district court to give the petitioner notice and an opportunity to amend before dismissing subclaims sua sponte for insufficient pleading. The Eleventh Circuit held that the petitioner had adequate notice of the pleading requirements and the possibility of dismissal under the applicable rules and case law, and that he had sufficient opportunity to be heard, including through his original petition and motion for reconsideration. The court therefore affirmed the district court’s denial of the habeas petition. View "O'Kelley v. Warden, Georgia Diagnostic Prison" on Justia Law

The defendant was convicted in 1997 of participating in a conspiracy to rob drug dealers at gunpoint, resulting in the theft of large amounts of money and drugs. He received a total sentence of 468 months, which included consecutive sentences for two convictions under 18 U.S.C. § 924(c) related to firearm use during crimes of violence and drug trafficking. At the time, sentencing law required a 20-year consecutive sentence for a “second or subsequent” § 924(c) conviction, even if both convictions arose from the same prosecution.Following a 2018 amendment to § 924(c), which eliminated the “stacking” requirement for first-time offenders with multiple convictions in a single prosecution, the defendant moved for a sentence reduction under 18 U.S.C. § 3582(c)(1)(A)(i) in the United States District Court for the Southern District of Florida. He argued that the change in law, though not retroactive, constituted an “extraordinary and compelling” reason for a reduction under a 2023 Sentencing Commission policy statement (U.S.S.G. § 1B1.13(b)(6)). The district court granted the motion, reduced the defendant’s second § 924(c) sentence from 20 to 5 years, and ordered his release.The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s decision. The appellate court held it had jurisdiction over the government’s appeal. On the merits, the court concluded that the district court erred because, under Rutherford v. United States, 608 U.S. 454 (2026), the 2018 non-retroactive amendment to § 924(c) cannot, as a matter of law, constitute an “extraordinary and compelling” reason for a sentence reduction under § 3582(c)(1)(A)(i). The Eleventh Circuit reversed the district court’s order and directed reinstatement of the original sentence. View "USA v. Rizo" on Justia Law