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

A recently enacted Georgia law restricts minors’ ability to create accounts on social media platforms. The statute requires covered platforms to verify users’ ages, prohibits minors under sixteen from creating accounts without parental consent, and limits how personal data may be used for advertising to minors. The law defines “social media platform” broadly, but includes numerous exceptions for platforms with different primary functions. An internet trade association, representing major social media companies, challenged the law before its effective date, arguing that it violates the First Amendment, is unconstitutionally vague, and is preempted by Section 230 of the Communications Decency Act.The United States District Court for the Northern District of Georgia granted a preliminary injunction, preventing enforcement of the law. The court found that the association had associational and third-party standing, that the law was likely a content-based speech restriction failing strict scrutiny, was unconstitutionally vague, and was preempted by federal law.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed whether the association had standing and whether it demonstrated a likelihood of success on the merits. The circuit court held that the association had associational standing to challenge the law on behalf of its members. However, the court concluded that the association failed to meet the burden required for a facial First Amendment challenge under the standard set forth in Moody v. NetChoice, LLC, because it did not adequately address the full range of the law’s applications and did not demonstrate that unconstitutional applications substantially outweighed constitutional ones. The court also found that the vagueness and Section 230 preemption claims were unlikely to succeed. The Eleventh Circuit affirmed the standing determination, vacated the preliminary injunction, and remanded the case for further proceedings. View "NetChoice v. Attorney General, State of Georgia" on Justia Law

Florida enacted a statute (HB3) restricting minors’ access to social media platforms that employ certain “addictive features,” such as infinite scrolling, push notifications, and auto-play. Platforms meeting defined criteria—including algorithmic content selection and significant minor usage—must prohibit account creation by those under 14 and require parental consent for those aged 14–15. The Computer & Communications Industry Association and NetChoice, representing affected platforms, challenged the law on First Amendment grounds, asserting both facial and as-applied claims.The United States District Court for the Northern District of Florida initially denied a preliminary injunction for lack of associational standing, but after the plaintiffs amended their complaint and renewed their motion, the court granted a preliminary injunction. The district court found that the trade groups had standing, abstention under Younger v. Harris was unwarranted, and that although HB3 was a content-neutral regulation, it was insufficiently tailored to survive intermediate scrutiny, thus likely unconstitutional.On appeal, the United States Court of Appeals for the Eleventh Circuit first held that the plaintiffs had associational standing to challenge HB3 on behalf of their members. The court also determined that the district court properly declined to abstain under Younger because substantial proceedings had already occurred in federal court before the state enforcement action was initiated. Addressing the merits, the Eleventh Circuit concluded that HB3 is a content-neutral regulation implicating the First Amendment, but it likely survives intermediate scrutiny due to its age-based tailoring and focus on addictive features. The court rejected the facial challenge, holding that the plaintiffs had not demonstrated, as required by Moody v. NetChoice, LLC, that HB3’s unconstitutional applications substantially outweighed its constitutional ones. The disposition affirmed in part, reversed in part, vacated in part, and remanded for further proceedings. View "Computer & Communications Industry Association v. Attorney General, State of Florida" on Justia Law

A defendant was indicted in federal court for knowingly possessing a firearm as a convicted felon, in violation of 18 U.S.C. § 922(g)(1). He pleaded guilty to the charge. At sentencing, his presentence investigation report calculated a higher base offense level under the U.S. Sentencing Guidelines because of a prior Florida conviction for attempted manslaughter, which was treated as a “crime of violence.” The defendant also received enhancements for involvement with a stolen firearm and drugs, and a reduction for acceptance of responsibility. The recommended Guidelines range was 84 to 105 months. The defendant objected, arguing that his prior conviction was not a “crime of violence” and requested his federal sentence run concurrently with an expected state court sentence.The United States District Court for the Southern District of Florida overruled his objections, found that attempted manslaughter was a crime of violence, and imposed an 84-month sentence, to run consecutively to any state sentence. The court stated that it would have imposed the same sentence even if it had ruled differently on the Guidelines issue. The defendant appealed, challenging the crime of violence finding, the consecutive sentence, and raising a new constitutional challenge to § 922(g)(1).The United States Court of Appeals for the Eleventh Circuit held that the district court erred in finding Florida attempted manslaughter to be a “crime of violence” under the Guidelines, and that its statement about imposing the same sentence did not render the error harmless due to procedural timing. The court affirmed that it was not an abuse of discretion to impose a consecutive sentence and rejected the constitutional challenge, finding it foreclosed by precedent. The sentence was vacated, and the case was remanded for resentencing. View "USA v. Johnson" on Justia Law

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