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

Chanon Miller was arrested by deputies from the Palm Beach County Sheriff’s Office for simple battery against her ex-fiancé. She subsequently sued the Sheriff’s Office and unnamed deputies, alleging violations of her constitutional right to be free from unreasonable seizure, including claims of false arrest, false imprisonment, and malicious prosecution. Miller's complaint was amended to name specific deputies as defendants.The United States District Court for the Southern District of Florida denied the deputies' motion to dismiss based on qualified immunity, stating that the issue was more appropriately resolved at the summary judgment stage or later in the proceedings. The court found that Miller's allegations were sufficient to state a plausible claim for relief and allowed her to file an amended complaint naming the appropriate defendants. The district court reiterated its position when the deputies renewed their motion to dismiss after being named in the amended complaint.The United States Court of Appeals for the Eleventh Circuit reviewed the case and held that the district court erred by failing to adjudicate the defense of qualified immunity at the motion to dismiss stage. The appellate court emphasized that qualified immunity is an immunity from suit, not just a defense to liability, and must be resolved at the earliest possible stage in litigation. The court vacated the district court’s order and remanded the case with instructions to rule on the deputies' entitlement to qualified immunity, requiring a claim-by-claim and defendant-by-defendant analysis. View "Miller v. Ramirez" on Justia Law

Two defendants, Antonio Lemus and Carlos Daniel Canario-Vilomar, were convicted of cocaine-related charges under the Maritime Drug Law Enforcement Act (MDLEA). Lemus was apprehended on December 30, 2021, when U.S. Coast Guard officers intercepted a vessel north of Panama, found cocaine, and determined the vessel was without nationality after Colombia could not confirm its registration. Canario-Vilomar was arrested on December 6, 2021, when a similar vessel was intercepted north of Colombia, and the Dominican Republic could not confirm its registration. Both defendants were charged with conspiracy to possess and distribute cocaine on a vessel subject to U.S. jurisdiction.In the Southern District of Florida, Lemus pled guilty to both counts and was sentenced to 87 months in prison. In the Middle District of Florida, Canario-Vilomar pled guilty to conspiracy, and his motion to dismiss the indictment was denied. He was sentenced to 120 months in prison. Both defendants appealed, arguing that the MDLEA exceeded Congress's authority under the Felonies Clause of the Constitution and that their vessels were not stateless under international law. Canario-Vilomar also argued that his offense occurred in an Exclusive Economic Zone (EEZ), which he claimed was beyond Congress's regulatory authority.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that Congress's authority under the Felonies Clause is not limited by international law, affirming that the MDLEA's definition of a "vessel without nationality" and the inclusion of the EEZ within the "high seas" were constitutional. The court also rejected Canario-Vilomar's due process argument, citing precedent that the MDLEA does not require a nexus to the United States for jurisdiction. Consequently, the Eleventh Circuit affirmed the convictions of both defendants. View "USA v. Canario-Vilomar" on Justia Law

The case involves the appeals of Rolando Williamson, Hendarius Archie, Ishmywel Gregory, and Adrien Taylor, who were convicted of various drug distribution and conspiracy charges. Williamson argued that the district court erred in denying his motions to suppress evidence obtained from warrants to search his house and apartment, claiming the use of pole cameras violated the Fourth Amendment. Archie contended that the district court allowed improper opinion testimony from a case agent. Gregory challenged the district court’s findings on the type and amount of drugs attributable to him at sentencing. All defendants questioned the sufficiency of the evidence supporting their conspiracy convictions.The United States District Court for the Northern District of Alabama convicted the defendants on multiple counts. Williamson was sentenced to life imprisonment for several counts, including engaging in a continuing criminal enterprise and conspiracy to distribute drugs. Taylor was convicted of distributing methamphetamine and using a communication facility to commit a drug trafficking crime. Gregory was convicted of distributing cocaine and conspiracy to distribute drugs. Archie was convicted of conspiracy to distribute marijuana and possession of a firearm in furtherance of a drug trafficking crime.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that the use of pole cameras did not violate Williamson’s Fourth Amendment rights as they surveilled areas exposed to the public. The court found that the case agent’s opinion testimony did not affect Archie’s substantial rights. The evidence was deemed sufficient to support each defendant’s conspiracy conviction. However, Williamson’s conspiracy conviction was vacated as it was a lesser-included offense of his continuing criminal enterprise conviction. Gregory’s sentence was vacated and remanded for resentencing as it exceeded the statutory maximum. The court affirmed the remaining convictions and sentences. View "United States v. Gregory" on Justia Law

Tim Daniels, a commercial fisherman in Florida, challenged the constitutionality of regulations by Florida’s Fish and Wildlife Conservation Commission (FWC) that restrict where and how Florida-registered vessels can harvest Florida pompano in federal waters. Daniels argued that federal law preempts state regulations affecting fishing in federal waters and that Florida’s regulations violate the Equal Protection Clause by only restricting Florida-registered vessels.The United States District Court for the Southern District of Florida granted summary judgment for the FWC, concluding that Florida’s regulations do not violate the Privileges and Immunities Clause, the Supremacy Clause, the Commerce Clause, or the Equal Protection Clause. The court also determined that Daniels lacked standing to sue.The United States Court of Appeals for the Eleventh Circuit reviewed the case and concluded that Daniels has standing to sue because he faces a credible threat of prosecution under Florida’s regulations, which affects his commercial fishing activities. The court found that Daniels’s injury is directly traceable to Florida’s regulations and can be redressed by a favorable judicial decision.On the merits, the Eleventh Circuit held that the Magnuson-Stevens Fishery Conservation and Management Act does not preempt Florida’s regulations. The court reasoned that the Act allows states to regulate fishing vessels registered under their laws in federal waters when there is no federal fishery management plan or regulations in place. The court also held that Florida’s regulations do not violate the Equal Protection Clause because they are rationally related to the legitimate governmental purpose of conserving and managing pompano stock, and the regulations only apply to Florida-registered vessels, which are within the state’s jurisdiction.The Eleventh Circuit affirmed the District Court’s decision, upholding Florida’s pompano regulations. View "Daniels v. Executive Director of the Florida Fish and Wildlife Conservation Commission" on Justia Law

Rhonda Fleming, an inmate at Federal Correctional Institution Tallahassee (FCIT), filed a pro se lawsuit against Warden Erica Strong and the United States, alleging Eighth Amendment violations due to her exposure to mold, asbestos, and COVID-19, which she claimed caused severe health issues. Fleming sought injunctive relief and damages under Bivens and the Federal Tort Claims Act (FTCA). She alleged that despite her complaints, the prison officials, including Warden Strong, failed to address the hazardous conditions, leading to her contracting COVID-19 twice and requiring hospitalization.The United States District Court for the Northern District of Florida partially granted and partially denied the defendants' motion to dismiss. The magistrate judge recommended dismissing most of Fleming's claims, including all claims against Strong, citing that Bivens did not provide a remedy for her Eighth Amendment claim. However, the district court disagreed, finding that Fleming's Eighth Amendment claim was similar to a previously recognized Bivens claim and allowed it to proceed. The district court did not address the issue of qualified immunity.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court had to determine whether it had jurisdiction to hear an interlocutory appeal from the district court's order recognizing a Bivens cause of action. The Eleventh Circuit joined four other circuits in holding that the collateral-order doctrine does not extend to Bivens-extension orders that do not address qualified immunity. The court emphasized that qualified immunity adequately protects government officials from the burdens of litigation and that separation-of-powers concerns with Bivens extensions do not justify immediate appeal. Consequently, the Eleventh Circuit dismissed the appeal for lack of jurisdiction. View "Fleming v. FCI Tallahassee Warden" on Justia Law

Carey Dale Grayson, an Alabama prisoner, sought a preliminary injunction to halt his scheduled execution by nitrogen hypoxia, arguing that the method violated the Eighth Amendment due to the risk of conscious suffocation and other potential harms. Grayson proposed alternative methods of execution, including nitrogen gas with sedation and a sequential injection of ketamine followed by fentanyl.The United States District Court for the Middle District of Alabama denied Grayson's motion, finding that he did not demonstrate a substantial likelihood of success on the merits of his Eighth Amendment claim. The court held an evidentiary hearing where expert testimonies were presented. The court found that Grayson's evidence was speculative and did not show that the nitrogen hypoxia protocol created an unacceptable risk of pain. The court also found that the proposed alternatives were not feasible or readily implemented.The United States Court of Appeals for the Eleventh Circuit reviewed the district court's decision for abuse of discretion. The appellate court affirmed the district court's denial of the preliminary injunction, agreeing that Grayson failed to show a substantial likelihood of success on the merits. The court noted that the district court's factual findings were not clearly erroneous and that the nitrogen hypoxia protocol had been successfully used in previous executions without evidence of conscious suffocation or other significant issues. The appellate court concluded that the district court did not abuse its discretion in denying the preliminary injunction. View "Grayson v. Commissioner, Alabama Department of Corrections" on Justia Law

In 2010, four individuals sued the Revolutionary Armed Forces of Colombia (FARC) under the Anti-Terrorism Act, resulting in a default judgment of $318 million against FARC. Unable to collect from FARC, the plaintiffs sought to garnish assets of Samark José López Bello and his companies, alleging they were agents or instrumentalities of FARC. The district court initially ruled in favor of the plaintiffs, but the Eleventh Circuit reversed, mandating a jury trial to determine the agency status of López and his companies.On remand, the district court scheduled a jury trial and allowed discovery. The plaintiffs sought to depose López and requested documents. López and his companies filed motions for protective orders to avoid discovery, which the district court denied, warning of sanctions for non-compliance. López failed to appear for his deposition and did not comply with document requests. Consequently, the district court entered default judgments against López and his companies, citing willful disobedience and the inability to compel compliance due to López's fugitive status.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court affirmed the district court's entry of default judgments, finding no abuse of discretion. The Eleventh Circuit held that the district court correctly interpreted its scheduling order to allow discovery and found that López's failure to comply with discovery orders was willful. The court also determined that less severe sanctions would not ensure compliance, given López's fugitive status. The Eleventh Circuit dismissed the argument that the district court lacked jurisdiction due to an appeal of the protective order denials, as those orders were not final or immediately appealable. View "Stansell v. Lopez Bello" on Justia Law

A group called Moms for Liberty, along with several individual members, filed a lawsuit against Brevard Public Schools and members of the Brevard County School Board. The plaintiffs claimed that their speech was unconstitutionally restricted at school board meetings. They argued that the Board's policies prohibiting "abusive," "personally directed," and "obscene" speech were unconstitutional. The plaintiffs sought declaratory and injunctive relief, as well as nominal damages.The United States District Court for the Middle District of Florida granted summary judgment in favor of the Board. The district court concluded that the plaintiffs lacked standing because they could not show an actual or imminent injury. It also held that the Board's policies did not objectively chill the plaintiffs' protected speech. Despite finding no standing, the district court went on to rule that the Board's policies were constitutional.The United States Court of Appeals for the Eleventh Circuit reviewed the case and reversed the district court's decision. The Eleventh Circuit found that the plaintiffs had standing to seek both retrospective and prospective relief. The court held that the Board's policy on "abusive" speech was unconstitutional because it was viewpoint-based and prohibited offensive speech. The policy on "personally directed" speech was also found to be unreasonable and inconsistently enforced, making it unconstitutional. Lastly, the court ruled that the prohibition on "obscene" speech was unreasonably applied to restrict protected speech, particularly when it involved reading from books available in school libraries. The case was remanded for further proceedings consistent with the Eleventh Circuit's opinion. View "Moms for Liberty v. Brevard Public Schools" on Justia Law

The case involves Bradley Rodriguez, who applied for disability benefits and supplemental security income, claiming a disability due to a traumatic brain injury, bipolar disorder, and depression. His application was denied by an Administrative Law Judge (ALJ) with the Social Security Administration (SSA). The Appeals Council also denied his request for review. Rodriguez then filed a federal lawsuit challenging the denial of benefits, raising several constitutional issues regarding the appointment of SSA ALJs, Appeals Council members, and the Commissioner of the SSA. He also argued that the ALJ’s decision was not supported by substantial evidence.The United States District Court for the Southern District of Florida granted summary judgment in favor of the Commissioner of the SSA. The court found that the ALJ was properly appointed, the Appeals Council members were not principal officers requiring presidential appointment and Senate confirmation, and the for-cause removal provision for the Commissioner was unconstitutional but severable. The court also held that Rodriguez was not entitled to a new hearing because he did not show that the unconstitutional removal provision caused him any harm. Additionally, the court determined that the ALJ’s decision was supported by substantial evidence.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court’s decision. The court held that the Commissioner had the statutory authority to appoint SSA ALJs and properly exercised that authority through ratification in July 2018. The Appeals Council members were deemed inferior officers, not principal officers, and thus did not require presidential appointment and Senate confirmation. The court also agreed that the for-cause removal provision for the Commissioner was unconstitutional but severable, and Rodriguez did not demonstrate entitlement to retrospective relief. Finally, the court found that the ALJ’s decision was supported by substantial evidence, including medical records and vocational expert testimony. View "Rodriguez v. Social Security Administration" on Justia Law

Transgender residents of Alabama sought to change the sex designation on their driver’s licenses without undergoing sex-change surgery, as required by Alabama’s Policy Order 63. This policy mandates that individuals wishing to change the sex on their driver’s license must submit either an amended birth certificate or a letter from the physician who performed the reassignment surgery. Plaintiffs argued that this policy violated the Equal Protection and Due Process Clauses of the Fourteenth Amendment, as well as the Free Speech Clause of the First Amendment.The United States District Court for the Middle District of Alabama ruled in favor of the plaintiffs, declaring Policy Order 63 unconstitutional under the Equal Protection Clause. The district court found that the policy classified individuals by sex and applied intermediate scrutiny, concluding that Alabama had not provided an adequate justification for the policy.The United States Court of Appeals for the Eleventh Circuit reviewed the case and reversed the district court’s decision. The appellate court held that Policy Order 63 does not impose a sex-based classification and therefore does not trigger heightened scrutiny. Instead, the policy was subject to rational basis review, which it survived. The court found that the policy rationally advances Alabama’s legitimate interest in maintaining consistent requirements for amending sex designations on state documents.The appellate court also rejected the plaintiffs’ due process and First Amendment claims. It held that the policy does not violate the right to informational privacy or the right to refuse medical treatment, as it does not force individuals to undergo surgery to obtain a driver’s license. Additionally, the court determined that the policy does not compel speech, as the information on driver’s licenses constitutes government speech, not private speech. Thus, the Eleventh Circuit reversed the district court’s judgment and upheld the constitutionality of Policy Order 63. View "Corbitt v. Secretary of the Alabama Law Enforcement Agency" on Justia Law