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

The case concerns a defendant who was charged with four federal sex-trafficking offenses involving two victims, one an adult and the other a minor. The defendant, who identified himself as a pimp, transported both victims from Atlanta to Miami in advance of the 2020 Super Bowl, intending for them to perform sex work. The adult victim testified that she was threatened and coerced into working for the defendant, while the minor victim, who was seventeen, did not testify at trial. Evidence included social media posts, communications between the defendant and the victims, and testimony about the defendant’s control over the victims. The minor victim was apprehended during a police sting operation in Miami, and her statements to police were admitted at trial despite her absence as a witness.The United States District Court for the Southern District of Florida presided over the trial. The jury convicted the defendant on all four counts: sex trafficking of the adult victim by force and coercion, transporting the adult victim to engage in sexual activity, sex trafficking of the minor victim, and transporting the minor victim to engage in sexual activity. The defendant was sentenced to 300 months in prison and ten years of supervised release. He appealed, arguing that the admission of the minor victim’s statements violated the Confrontation Clause and hearsay rules, that the jury instructions for two counts constructively amended the indictment, and that the evidence was insufficient for two counts.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that the minor victim’s statements were nontestimonial and thus did not violate the Confrontation Clause, and that any hearsay error was harmless. The court found that while the jury instructions for two counts constructively amended the indictment, these errors did not amount to plain error. The court also concluded that sufficient evidence supported all convictions. The Eleventh Circuit affirmed the convictions. View "USA v. Carter" on Justia Law

In 2004, Clemente Javier Aguirre-Jarquin was arrested and later convicted for the murders of his neighbors, Cheryl Williams and Carol Bareis, in Altamonte Springs, Florida. The investigation by Seminole County Sheriff’s Office (SCSO) focused on Aguirre after bloody clothing and a knife were found near his residence, and forensic analysis by Donna Birks, a latent print examiner, identified Aguirre’s palm print on the murder weapon. Aguirre was tried and sentenced to death in 2006. Over the next decade, new evidence emerged: a 2007 investigation revealed misconduct in the SCSO Latent Print Unit, undermining the reliability of the fingerprint identification, and post-conviction DNA testing failed to link Aguirre to the crime scene but implicated Samantha Williams, the victims’ daughter and granddaughter, who later confessed to involvement in the murders.The Seminole Circuit Court denied Aguirre’s initial motion for a new trial, finding the evidence against him overwhelming. The Supreme Court of Florida affirmed this denial. However, after further post-conviction investigation and new DNA evidence, the Supreme Court of Florida vacated Aguirre’s convictions and ordered a new trial. In 2018, the State dropped all charges against Aguirre.Aguirre then filed suit in the United States District Court for the Middle District of Florida against Birks, lead investigator Robert Hemmert, crime scene analyst Jacqueline Grossi, and the Seminole County Sheriff, alleging violations of his constitutional rights under 42 U.S.C. § 1983 and state law claims. The District Court denied qualified immunity to Birks, Hemmert, and Grossi on several counts and denied state-law immunity to Hemmert and Grossi.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the denial of qualified immunity to Birks on the fabrication of evidence claim and affirmed the denial of state-law immunity to Hemmert and Grossi for intentional infliction of emotional distress. However, the court reversed the denial of qualified immunity to Birks and Hemmert on the malicious prosecution claim and to Hemmert and Grossi on the claim of inadequate investigation, finding no clearly established law requiring the investigation to eliminate all doubts. The case was remanded for further proceedings. View "Aguirre-Jarquin v. Hemmert" on Justia Law

In 2023, the Florida Legislature enacted Senate Bill 264, which, among other provisions, imposed restrictions on real property transactions involving persons domiciled in China who are not U.S. citizens or lawful permanent residents. The law included three key requirements: a purchase restriction barring certain Chinese domiciliaries from acquiring Florida real estate, a registration requirement mandating such individuals to register their existing property interests, and an affidavit requirement obligating all purchasers of Florida real estate to attest compliance with the law. Four Chinese citizens residing in Florida on various nonimmigrant visas and a real estate brokerage firm serving Chinese-speaking clients challenged these provisions, alleging violations of the Equal Protection Clause, the Fair Housing Act, the Due Process Clause, and federal preemption.The plaintiffs filed suit in the United States District Court for the Northern District of Florida against several state officials responsible for enforcing SB 264. They sought a preliminary injunction to halt enforcement of the purchase restriction, registration requirement, and affidavit requirement. The district court found that the plaintiffs had standing to challenge all three provisions but denied the preliminary injunction, concluding that the plaintiffs were not substantially likely to succeed on the merits of their claims.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s decision. The Eleventh Circuit held that the plaintiffs lacked standing to challenge the purchase restriction because none had shown an imminent injury from that provision. However, at least one plaintiff had standing to challenge the registration and affidavit requirements. The court affirmed the denial of the preliminary injunction as to the registration and affidavit requirements, finding no substantial likelihood of success on the merits of the constitutional, statutory, or preemption claims. The court reversed and remanded the denial of the preliminary injunction as to the purchase restriction, instructing the district court to deny it without prejudice for lack of standing. View "Shen v. Commissioner, Florida Department of Agriculture and Consumer Services" on Justia Law

Casa Express Corp. obtained a $40 million judgment in the Southern District of New York against the Bolivarian Republic of Venezuela for unpaid bonds and a global note. After Venezuela failed to pay, Casa sought to enforce the judgment in Florida by targeting eight Miami properties owned by corporate entities allegedly controlled by Raul Gorrin Belisario. Casa claimed that Gorrin, through a bribery and currency-exchange scheme involving Venezuelan officials, used misappropriated Venezuelan funds to purchase these properties, and argued that the properties should be subject to a constructive trust in favor of Venezuela.Casa registered the New York judgment in the United States District Court for the Southern District of Florida and initiated supplementary proceedings under Florida law, seeking to execute the judgment against the properties. Casa impleaded Gorrin, several individuals, and six corporate entities as third-party defendants. The defendants moved for judgment on the pleadings, arguing, among other things, that the district court lacked ancillary jurisdiction over Casa’s claims. The magistrate judge recommended dismissal for lack of ancillary jurisdiction, and the district court adopted this recommendation, also finding a lack of personal jurisdiction over Gorrin. Casa appealed.The United States Court of Appeals for the Eleventh Circuit held that the district court lacked ancillary jurisdiction over Casa’s supplementary proceedings. The court reasoned that Casa’s action sought to impose liability on third parties not previously found liable for the New York judgment and was based on new facts and legal theories unrelated to the original breach of contract claims against Venezuela. The Eleventh Circuit affirmed the district court’s jurisdictional ruling, vacated its alternative merits rulings, and remanded with instructions to dismiss the case without prejudice for lack of subject matter jurisdiction. View "Casa Express Corp v. Bolivarian Republic of Venezuela" on Justia Law

Edward T. Saadi, a licensed attorney proceeding pro se, obtained a $90,000 judgment against Pierre Maroun and Maroun’s International, LLC (MILLC) following a jury verdict in a federal defamation suit. Despite the judgment, Saadi was unable to collect payment for nine years. In 2018, Saadi discovered information suggesting Maroun had transferred $250,000 from his personal account to MILLC, allegedly to evade the judgment. Saadi claimed these funds were used to purchase a condominium titled to MILLC but used as Maroun’s residence, and to pay Maroun’s personal expenses. Saadi initiated proceedings supplementary under Florida law, seeking to void the transfer and recover assets.The United States District Court for the Middle District of Florida allowed Saadi to file an impleader complaint against Maroun and MILLC, asserting claims for fraudulent transfer and actual and constructive fraud under Florida statutes. Saadi also sought sanctions when MILLC failed to produce a representative for deposition, but the district court denied the motion, finding the individual was not a managing agent of MILLC. Ultimately, the district court granted summary judgment for Maroun and MILLC, ruling that Saadi’s claims were time-barred under Florida’s statutes of repose and limitations, and that tolling provisions did not apply. The court also found that the remedies Saadi sought were unavailable under the relevant statutes.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s rulings. Finding that several dispositive questions of Florida law lacked controlling precedent and were subject to conflicting interpretations by Florida’s intermediate appellate courts, the Eleventh Circuit certified five questions to the Florida Supreme Court. The court deferred its decision pending the Florida Supreme Court’s response to the certified questions. View "Saadi v. Maroun" on Justia Law

Two individuals, both members of the Gangster Disciples gang, were prosecuted for their roles in a series of violent crimes in Georgia. The Gangster Disciples is a national criminal organization with a hierarchical structure, engaging in various illegal activities. The case centered on the aftermath of a gang member’s murder, which led to retaliatory killings. One defendant, Green, was implicated in the murders of two individuals believed to have violated gang rules, while the other, Chambers, was involved in orchestrating and carrying out another murder, as well as enforcing gang discipline.The United States District Court for the Middle District of Georgia presided over the joint trial of Green, Chambers, and a third co-defendant. The jury convicted Green of participating in a RICO conspiracy, finding he committed or aided in two murders. Chambers was convicted of RICO conspiracy, violent crime in aid of racketeering (VICAR murder), use of a firearm during a crime of violence, and causing death with a firearm. Chambers received two consecutive life sentences plus an additional term, while Green was sentenced to life imprisonment. Chambers’ attempts to delay the trial, including self-representation and last-minute requests for counsel, were denied by the district court, which found his actions to be calculated efforts to disrupt proceedings. Both defendants challenged their convictions and sentences on various grounds, including evidentiary rulings, jury procedures, and sentencing issues.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that the evidence was sufficient to support Green’s RICO conspiracy conviction and that the admission of wiretap evidence, co-conspirator statements, and other challenged exhibits was proper. The court found no abuse of discretion in denying Chambers’ motion for a continuance or in the use of an anonymous jury and shackling procedures. Sentencing and restitution decisions were also affirmed. The Eleventh Circuit affirmed all convictions and sentences, finding no reversible error. View "USA v. Green" on Justia Law

Joseph Simone worked as a Transportation Security Officer (TSO) for the Transportation Security Administration (TSA) at Fort Lauderdale-Hollywood International Airport. He disclosed a heart condition when hired, which did not generally affect his job performance. In 2014, TSA determined Simone was no longer medically qualified and placed him on administrative leave, eventually removing him from federal service in 2015. Simone filed an administrative complaint alleging discrimination and retaliation under the Rehabilitation Act, which was denied by an Equal Employment Opportunity Commission administrative law judge and later on appeal. He then brought suit in federal district court against the Secretary of Homeland Security, asserting four claims under the Rehabilitation Act: disability discrimination, failure to accommodate, retaliation, and unlawful interference.The United States District Court for the Southern District of Florida granted the Secretary’s motion to dismiss. The court relied on the Eleventh Circuit’s prior decision in Castro v. Secretary of Homeland Security, which held that the Aviation and Transportation Security Act (ATSA) exempted TSA from the requirements of the Rehabilitation Act regarding the hiring of security screeners. The district court concluded that ATSA precluded Simone’s claims and rejected his argument that the Whistleblower Protection Enhancement Act (WPEA), enacted in 2012, abrogated Castro and allowed Rehabilitation Act claims against TSA.On appeal, the United States Court of Appeals for the Eleventh Circuit held that the WPEA abrogated Castro and extended Rehabilitation Act protections to TSA security screeners. The court found that the WPEA’s statutory language superseded ATSA’s exemption and allowed TSOs to bring claims under the Rehabilitation Act. The Eleventh Circuit vacated the district court’s dismissal and remanded the case for further proceedings to determine whether Simone satisfied administrative requirements to bring his claims. View "Simone v. Secretary of Homeland Security" on Justia Law

Eduardo Ulises Martinez was investigated by the U.S. Fish & Wildlife Service after a tip that he was traveling internationally and possibly bringing back ivory. Upon his return to Miami International Airport, Customs and Border Protection found three ivory pieces in his luggage, which he initially denied were ivory. Subsequent searches of his home and business uncovered numerous sculptures containing ivory. Martinez, an experienced art dealer, admitted knowing about the legal requirements to declare ivory imports and exports but had not done so. The government charged him with multiple counts of smuggling ivory into and out of the United States, as well as obstruction of justice for attempting to influence a witness’s testimony and misrepresent the provenance of seized items.The United States District Court for the Southern District of Florida denied Martinez’s pretrial motion to dismiss the smuggling charges, rejecting his argument that the antique and de minimis exceptions to ivory import/export restrictions absolved him of the duty to declare the items. The court also granted the government’s motion in limine to exclude evidence about these exceptions, finding them irrelevant to the smuggling charges. At trial, Martinez was convicted on most counts, except for three on which he was acquitted. His post-trial motions for acquittal and a new trial were denied, and he was sentenced to 51 months’ imprisonment, with the court adopting the government’s valuation of the seized statues.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed Martinez’s convictions and sentence. The court held that the antique and de minimis exceptions did not eliminate the obligation to declare ivory, and evidence about them was properly excluded. The court also found no error in the exclusion of certain interview statements, the sufficiency of the evidence for obstruction of justice, the government’s closing argument, or the sentencing methodology and valuation. The judgment of the district court was affirmed. View "USA v. Martinez" on Justia Law

Six women who were formerly incarcerated at the Jasper City Jail in Alabama alleged that they suffered repeated sexual abuse by jailers, primarily by one officer, while serving as inmates. The plaintiffs described a range of sexual assaults and harassment, with one plaintiff also alleging abuse by a second jailer. The jail operated under the authority of the City of Jasper’s police chief, with a chief jailer and other supervisory staff responsible for daily operations. Jail policies expressly prohibited sexual contact between staff and inmates, and there were procedures for reporting grievances, but the plaintiffs claimed these mechanisms were ineffective or inaccessible.After the alleged abuse, the Alabama State Bureau of Investigation began an inquiry, leading to the resignation of the primary alleged abuser and, later, his indictment on state charges. The plaintiffs filed six separate lawsuits, later consolidated, asserting claims under 42 U.S.C. § 1983 for Eighth Amendment violations against the police chief, chief jailer, and the City, as well as claims under the Trafficking Victims Protection Reauthorization Act (TVPRA). One plaintiff also brought claims against a second jailer. The United States District Court for the Northern District of Alabama granted summary judgment to all defendants, finding insufficient evidence that the supervisory officials or the City had knowledge of, or were deliberately indifferent to, the alleged abuse, and that the claims against one jailer failed for lack of proper service.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The court held that the plaintiffs failed to establish a causal link between the actions or inactions of the supervisory officials or the City and the alleged constitutional violations, as there was no evidence of a widespread custom or policy of tolerating sexual abuse, nor of deliberate indifference or failure to train. The court also found that certain claims were time-barred and that the TVPRA claims failed due to lack of evidence that the City knowingly benefited from or had knowledge of the alleged trafficking. View "Bridges v. Poe" on Justia Law

The defendant was indicted in 2017 on multiple federal charges related to the online enticement of minors and child pornography. He and the government jointly requested a psychiatric evaluation due to his autism and developmental history. Two competency hearings were held, one in 2019 and another in 2021, with expert testimony from psychologists and psychiatrists. The experts agreed he was autistic, but disagreed on his competency to stand trial. The defense argued that his autism and related impairments rendered him unable to understand the proceedings or assist in his defense, while government experts found him competent.After the first hearing, the magistrate judge recommended finding the defendant incompetent, but the United States District Court for the Middle District of Florida rejected this recommendation and found him competent, emphasizing his ability to understand the legal process and consult with counsel. The defendant later signed a plea agreement but requested a second competency hearing before entering a guilty plea. At the second hearing, new expert testimony was presented, and the magistrate judge recommended finding him competent. The district court adopted this recommendation, overruled the defendant’s objections, and accepted his guilty plea, sentencing him to 156 months in prison.On appeal to the United States Court of Appeals for the Eleventh Circuit, the defendant argued that the lower courts erred by placing the burden of proving incompetency on him and that the evidence showed he was not competent. The Eleventh Circuit held that the allocation of the burden of proof was immaterial because the evidence was not in equipoise; the district court’s finding of competency was not clearly erroneous. The court also rejected the argument that a higher standard of “decisional competency” applied, affirming that the correct standard was the ability to understand the proceedings and assist in the defense. The conviction was affirmed. View "USA v. Marks" on Justia Law