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

Federal agents discovered that an individual was sharing files containing child pornography over a peer-to-peer network. After obtaining a search warrant, law enforcement searched his residence and seized several digital devices. Forensic analysis revealed that he had downloaded and shared over 300 images and 150 videos depicting minors engaged in sexually explicit conduct. He was indicted in the United States District Court for the Middle District of Florida on one count of possessing and accessing with intent to view child pornography involving a minor under twelve years of age. The defendant waived his right to a jury trial and proceeded to a bench trial based on stipulated facts, after which the district court found him guilty.Prior to sentencing, the United States Probation Office prepared a Presentence Investigation Report, which calculated his total offense level as 30, including a five-level enhancement for offenses involving 600 or more images. The calculation treated each video as equivalent to 75 images, based on Sentencing Commission commentary. The defendant objected, arguing that the guideline’s text did not support this interpretation, but the district court overruled the objection and imposed a sentence of 97 months’ imprisonment and 15 years of supervised release. The court also ordered restitution of $3,000 to each of thirteen victims, totaling $39,000, and denied the defendant’s request for a jury to determine restitution. The written judgment included standard conditions of supervised release, which were not individually enumerated at sentencing.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s judgment. The court held that the sentencing guideline unambiguously requires each video frame containing child pornography to be counted as one image, but since the defendant conceded that his conduct exceeded the threshold for the highest enhancement, the sentence was affirmed. The court also held that neither the Fifth nor Sixth Amendments require a jury to determine restitution amounts, and that the district court was not required to disaggregate losses caused by the initial abuse. Finally, the court found no error in the district court’s pronouncement of supervised release conditions. View "USA v. Kluge" on Justia Law

Brandon Fulton alleged that Fulton County took his horses without justification and without paying for them, violating the Fifth Amendment's Takings Clause. He initially sought relief under 42 U.S.C. § 1983 but could not establish that the County acted under an official policy or custom, as required by Monell v. Department of Social Services of New York City.The United States District Court for the Northern District of Georgia dismissed Fulton’s § 1983 claim and denied his motion to amend his complaint to sue directly under the Takings Clause. The district court reasoned that plaintiffs must sue under § 1983 for constitutional takings claims against municipalities and that Fulton failed to allege an official policy or custom causing the violation.The United States Court of Appeals for the Eleventh Circuit reviewed the case and concluded that the Takings Clause of the Fifth Amendment directly authorizes a suit for "just compensation" in federal court. The court held that the Takings Clause is self-executing and guarantees a monetary remedy when the government takes private property. The court emphasized that the Takings Clause provides a direct cause of action independent of § 1983, especially when no other adequate remedy exists. The court vacated the district court's order and remanded the case for further proceedings, allowing Fulton to amend his complaint to sue directly under the Takings Clause. View "Brandon Fulton v. Fulton County Board of Commissioners" on Justia Law

Todd Joseph Harbuck was charged with possessing a firearm as a convicted felon and possessing a stolen firearm. The indictment alleged that Harbuck qualified for an enhanced sentence under the Armed Career Criminal Act (ACCA) due to his prior convictions, including a South Carolina conviction for assault with intent to kill. Harbuck pleaded guilty to possessing a firearm as a convicted felon but contested the ACCA enhancement, arguing that his South Carolina conviction should not qualify as a "violent felony" and that the ACCA is unconstitutionally vague.The United States District Court for the Southern District of Georgia reviewed Harbuck's objections. The court examined the South Carolina conviction and determined that it qualified as a felony under the ACCA. The court also concluded that the crime was a violent felony under the ACCA, leading to a sentence of fifteen years and eight months in prison. Harbuck appealed the sentence.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court applied the categorical approach to determine whether the South Carolina conviction for assault with intent to kill qualified as a violent felony under the ACCA. The court concluded that the crime's elements, which include an unlawful attempt to commit a violent injury with malicious intent, met the ACCA's definition of a violent felony. The court also rejected Harbuck's argument that the ACCA's elements clause is unconstitutionally vague, citing Supreme Court precedent that upheld the clarity of the elements clause.The Eleventh Circuit affirmed the district court's sentence and judgment, holding that Harbuck's South Carolina conviction for assault with intent to kill qualifies as a predicate violent felony under the ACCA and that the ACCA's elements clause is not unconstitutionally vague. View "USA v. Harbuck" on Justia Law

Jessica Nelson discovered errors in the informational section of her credit report from Experian, including an incorrect spelling of her maiden name, addresses to her mother’s home and attorney’s office, and a variation of her social security number. She spent time and money attempting to correct these errors by sending letters to Experian, which directed her to contact the furnishers of the information. Despite her efforts, some errors remained uncorrected, and Experian did not inform her of the corrections made.Nelson sued Experian in Alabama state court under the Fair Credit Reporting Act, alleging that Experian failed to conduct a reasonable reinvestigation into her information. Experian removed the case to federal court and sought judgment in its favor. The district court denied Experian’s motion for judgment on the pleadings, concluding that Nelson had standing based on her out-of-pocket expenses and time spent correcting the information. However, the district court later granted summary judgment in Experian’s favor on the merits of Nelson’s claim. Nelson appealed.The United States Court of Appeals for the Eleventh Circuit reviewed the case and focused on whether Nelson had standing under Article III. The court held that spending money and time to correct errors on a credit report that has not been published to a third party or otherwise affected the plaintiff does not satisfy the standing requirements of Article III. The court found that Nelson’s efforts to correct the information were self-imposed and did not constitute a concrete injury. Additionally, the court rejected Nelson’s argument that the errors increased her risk of identity theft, finding it too speculative to constitute an imminent harm.The Eleventh Circuit vacated the district court’s judgment and remanded the case for further proceedings consistent with its opinion. View "Nelson v. Experian Information Solutions Inc." on Justia Law

Walmart, Inc. faced allegations from Immigration and Customs Enforcement (ICE) for 11,103 violations of immigration-related recordkeeping requirements at 20 locations. These cases were assigned to an Administrative Law Judge (ALJ) in the Department of Justice’s Office of the Chief Administrative Hearing Officer (OCAHO). Before the ALJ could rule on the merits, Walmart filed a lawsuit in federal district court, challenging the constitutionality of the "good cause" removal procedure for ALJs under 5 U.S.C. § 7521(a) of the Administrative Procedure Act (APA). Walmart argued that this removal procedure infringed upon the President’s executive power under Article II of the Constitution.The United States District Court for the Southern District of Georgia ruled in favor of Walmart, declaring § 7521(a) unconstitutional and permanently enjoining the Department and its Chief ALJ from adjudicating ICE’s complaints against Walmart. The district court refused to sever § 7521(a) from the rest of the statute.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the case. The Eleventh Circuit held that the APA’s § 7521(a) is constitutional as applied to the Department’s ALJs in OCAHO. The court reasoned that the ALJs perform purely adjudicative functions, have limited duties, and lack policymaking or administrative authority. Additionally, the decisions of the ALJs are subject to plenary review by the Attorney General, who is removable at will by the President, ensuring sufficient executive control.The Eleventh Circuit vacated the district court’s permanent injunction and reversed its entry of summary judgment for Walmart. The court also noted that even if § 7521(a) were unconstitutional, the proper remedy would be to sever the "good cause" removal restriction, leaving the rest of the APA intact. View "Walmart, Inc. v. King" on Justia Law

Steven Morgan was convicted by a jury of three drug-trafficking crimes for smuggling cocaine from the Caribbean into South Florida. The scheme involved shipping jars of shaving gel with false bottoms containing cocaine. The operation was discovered when law enforcement dogs in Puerto Rico alerted on packages containing cocaine. A controlled delivery led to Morgan's arrest, during which two cellphones were found near him. Morgan initially claimed ownership of both phones but later stated only the iPhone was his.The United States District Court for the Southern District of Florida suppressed Morgan's statement in the patrol car and his statements made 18 months later but admitted the LG phone's contents, finding Morgan had abandoned it. The court also allowed the government to introduce Morgan's initial statement claiming ownership of both phones but later reversed this decision during the trial.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that the district court did not err in finding Morgan had abandoned the LG phone, thus allowing its contents to be admitted. The court also found that the Fifth Amendment did not require suppression of the phone's contents, as Morgan's statement was voluntary despite being obtained in violation of Miranda. The court affirmed the district court's denial of a mistrial after an agent referred to Morgan's suppressed statement, finding no substantial prejudice. The court also upheld the admission of testimony from Agent Gaviria and expert testimony from Agent Suarez, finding no plain error in the government's expert disclosures. Finally, the court found no cumulative error warranting reversal and affirmed Morgan's conviction. View "United States v. Morgan" on Justia Law

Joseph Heid filed a lawsuit under 42 U.S.C. § 1983 against Orange County Sheriff's Deputies Mark Rutkoski and Forrest Best, alleging they used unreasonable force in violation of the Fourth Amendment. The incident occurred after Heid had a domestic dispute, left his house, and later returned armed with a rifle. He engaged in a gunfight with deputies in his backyard and then re-entered his house. When he exited the house again, Deputies Rutkoski and Best, believing he was still armed, shot him multiple times.In the Circuit Court of the Ninth Judicial Circuit, Heid was found guilty of several charges, including Attempted Second Degree Murder of a Law Enforcement Officer and Resisting an Officer with Violence. Heid then filed a civil lawsuit, and the United States District Court for the Middle District of Florida denied the deputies' motion for summary judgment, which asserted qualified immunity. The District Court found there was a genuine factual dispute regarding whether the deputies used excessive force and whether Heid posed a threat when he exited the house.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court concluded that Deputies Rutkoski and Best did not violate Heid's Fourth Amendment rights. The court reasoned that the deputies reasonably believed Heid was armed and dangerous based on the information they had, including Heid's recent gunfight with other deputies and his rapid exit from the house. The court held that the use of force was reasonable under the circumstances and that the deputies were entitled to qualified immunity. The judgment of the District Court was reversed, and the case was remanded. View "Heid v. Rutkoski" on Justia Law

John Labriola, a media aide for the Miami-Dade Board of County Commissioners, wrote an inflammatory opinion piece criticizing the Equality Act, using derogatory language towards the LGBT community. Following public backlash and internal complaints, the County suspended him without pay, mandated anti-discrimination training, and eventually terminated him for not completing the training.Labriola sued Miami-Dade County in the United States District Court for the Southern District of Florida, alleging retaliation for exercising his First Amendment rights, compelled speech, and that the County's anti-discrimination policy was unconstitutionally overbroad. The district court granted summary judgment in favor of the County on all counts, applying the Pickering-Connick test to Labriola's free speech and free exercise claims, and ruling that his free-press claim was invalid because he was not a journalist.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court affirmed the district court's decision, holding that Labriola's free speech and free exercise claims failed the Pickering-Connick balancing test, as his speech impeded the County's ability to perform its duties efficiently and disrupted workplace harmony. The court also rejected Labriola's free-press claim, noting that even though the district court erred in stating he couldn't bring the claim as a non-journalist, his claim failed on the merits. Additionally, the court found no evidence to support Labriola's compelled speech claim, as the required training did not compel him to express views he disagreed with. Lastly, the court dismissed Labriola's overbreadth challenge to the County's anti-discrimination policy, as he failed to demonstrate that the policy was substantially overbroad.The Eleventh Circuit affirmed the district court's grant of summary judgment to Miami-Dade County on all counts. View "Labriola v. Miami-Dade County" on Justia Law

Katie Wood, a transgender woman teaching at a public high school in Florida, challenged the enforcement of Fla. Stat. § 1000.071(3), which prohibits her from using the honorific “Ms.” and the gendered pronouns “she,” “her,” and “hers” in exchanges with students during class time. Wood argued that this statute violated her First Amendment right to free speech and sought a preliminary injunction to prevent its enforcement.The United States District Court for the Northern District of Florida granted Wood a preliminary injunction, finding that she had shown a substantial likelihood of success on the merits of her First Amendment claim. The district court reasoned that Wood’s use of her preferred honorific and pronouns constituted speech as a private citizen on a matter of public concern, and that her interest in expressing her gender identity outweighed the state’s interest in promoting workplace efficiency.The United States Court of Appeals for the Eleventh Circuit reviewed the case and disagreed with the district court’s findings. The appellate court held that Wood had not demonstrated a substantial likelihood that Fla. Stat. § 1000.071(3) infringed her free speech rights. The court concluded that when Wood used her preferred honorific and pronouns in the classroom, she was speaking as a government employee, not as a private citizen. Consequently, her speech was not protected under the First Amendment in this context. The Eleventh Circuit vacated the preliminary injunction and remanded the case to the district court for further proceedings consistent with its opinion. View "Wood v. Florida Department of Education" on Justia Law

Shadon Edwards was suspected of being a high-level organizer in a drug-trafficking organization in South Florida. After obtaining an arrest warrant, law enforcement officials observed Edwards driving, followed him, and arrested him. A search incident to his arrest revealed a loaded Glock 43 nine-millimeter semi-automatic pistol. Edwards was indicted for knowingly possessing a firearm and ammunition as a convicted felon, in violation of 18 U.S.C. § 922(g)(1). He filed a motion to suppress the gun and ammunition, which the district court denied. Edwards then pleaded guilty without expressly preserving or waiving his right to appeal.The district court for the Southern District of Florida accepted Edwards's guilty plea and sentenced him to 180 months in prison, applying an enhancement under the Armed Career Criminal Act (ACCA) based on three prior convictions. Edwards did not object to the ACCA enhancement at sentencing. He later sought to appeal the denial of his suppression motion and the ACCA enhancement.The United States Court of Appeals for the Eleventh Circuit reviewed the case. Edwards argued that his guilty plea was not knowing and voluntary because he was not informed that he would waive his right to appeal the suppression motion. The court found no plain error, noting that there was no indication during the plea hearing that Edwards misunderstood the consequences of his plea. Edwards also contended that the ACCA enhancement was improper because the government did not prove beyond a reasonable doubt that his prior offenses occurred on different occasions, as required by Erlinger v. United States. The court held that Edwards failed to show a reasonable probability that a jury would have found the offenses occurred on the same occasion, thus not meeting the plain-error standard.Lastly, Edwards challenged the constitutionality of § 922(g) under the Commerce Clause. The court reaffirmed its precedent that § 922(g) is constitutional both facially and as applied, given the firearm and ammunition had moved in interstate commerce. The Eleventh Circuit affirmed the district court's judgment. View "United States v. Edwards" on Justia Law