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

Davion Rivers was convicted of possessing a firearm as a convicted felon and sentenced to 188 months in prison. Rivers appealed, arguing that the district court erred in denying his motions to suppress evidence and in sentencing him under the Armed Career Criminal Act (ACCA) without a jury determining whether his prior offenses occurred on different occasions.The district court denied Rivers's motions to suppress the firearm found on his person and a spent shotgun shell from his residence. The court found that the officers' approach to Rivers's residence was lawful under the knock-and-talk exception and that the search warrant for the residence was supported by probable cause. Rivers was convicted by a jury, and the district court applied the ACCA enhancement based on Rivers's prior drug offenses, finding that they occurred on different occasions.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court affirmed Rivers's conviction, finding no error in the denial of the suppression motions. The court held that the officers' approach to the residence was lawful and that the search warrant was supported by probable cause.However, the court vacated Rivers's sentence under the ACCA, citing the Supreme Court's decision in Erlinger v. United States, which requires that a jury, not a judge, must determine whether prior offenses occurred on different occasions. The court found that the district court's judicial fact-finding violated Rivers's constitutional rights and that the error was not harmless beyond a reasonable doubt. The case was remanded for resentencing consistent with the Supreme Court's ruling in Erlinger. View "United States v. Rivers" on Justia Law

Bruce Henry, who pled guilty to possessing child pornography in 2013, challenged Alabama Code § 15-20A-11(d)(4), which prohibits adult sex offenders convicted of a sex offense involving a child from residing or conducting overnight visits with a minor, including their own child. Henry, who has completed his prison term, married, and fathered a son, argued that the statute violated his First Amendment right of intimate association and the Fourteenth Amendment’s guarantees of equal protection and due process.The United States District Court for the Middle District of Alabama denied Henry’s motion for a preliminary injunction but later partially granted his motion for summary judgment, finding the statute facially unconstitutional. The district court concluded that the statute was not narrowly tailored to further Alabama’s compelling interest in protecting children and issued an injunction against its enforcement.The United States Court of Appeals for the Eleventh Circuit reviewed the case and agreed that the statute violated Henry’s fundamental right to live with his child. The court held that the statute was overinclusive, underinclusive, and not narrowly tailored to achieve its goal. However, the court also concluded that the district court abused its discretion in facially enjoining the statute, as Henry had not shown that it was unconstitutional in all its applications. The court vacated the district court’s injunction and remanded the case for further proceedings consistent with its opinion. View "Henry v. Sheriff of Tuscaloosa County" on Justia Law

Several adult-entertainment establishments and individual dancers in Jacksonville, Florida, challenged a city ordinance that effectively prohibits erotic dancers under the age of 21 from performing in adult-entertainment venues. The ordinance also requires dancers aged 21 and older to obtain a Work Identification Card through a licensing process. The plaintiffs argued that the age restriction and the licensing scheme violated the First Amendment.The United States District Court for the Middle District of Florida upheld both the age restriction and the licensing scheme. The court concluded that the age restriction is a content-neutral regulation aimed at reducing human trafficking and other criminal activities associated with adult-entertainment establishments. Applying intermediate scrutiny, the court found that the restriction furthered a substantial government interest and was appropriately tailored. The court also held that the licensing scheme did not impose an unconstitutional prior restraint, as it provided sufficient procedural protections, including a 14-day period for the sheriff to approve or deny applications and the ability for applicants to continue dancing while their applications were pending.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the ordinance's age restriction must be treated as a content-neutral regulation of expressive activity and is thus subject to intermediate scrutiny, which it survives. The court found that the restriction furthers the city's substantial interest in combatting human trafficking and is narrowly tailored to achieve that interest. Additionally, the court concluded that the licensing scheme includes sufficient procedural safeguards to avoid being an unconstitutional prior restraint, as it requires the sheriff to make licensing decisions within a reasonable time and allows dancers to continue performing while their applications are under review. View "Wacko's Too, Inc. v. City of Jacksonville" on Justia Law

A class of incarcerated juvenile offenders in Florida, all sentenced to life in prison with the possibility of parole under a now-defunct sentencing scheme, sued the Commissioners of the Florida Commission on Offender Review. They claimed that the parole system violated the Eighth Amendment's prohibition against cruel and unusual punishment and the Fourteenth Amendment's due process rights. The plaintiffs argued that the parole system did not provide a meaningful opportunity for release based on demonstrated maturity and rehabilitation.The United States District Court for the Middle District of Florida granted summary judgment to the Commissioners, dismissing the plaintiffs' claims. The court found that Florida's parole system did not violate the Eighth Amendment or the Fourteenth Amendment's Due Process Clause. The plaintiffs appealed the decision.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that Florida's parole system does not violate the Eighth Amendment for either homicide or non-homicide juvenile offenders. For homicide offenders, the system is not a sham and provides a genuine possibility of parole, satisfying the requirements set forth in Miller v. Alabama. For non-homicide offenders, the system offers a meaningful opportunity for release based on demonstrated maturity and rehabilitation, as required by Graham v. Florida.Regarding the due process claim, the court concluded that the plaintiffs did not have a constitutionally protected liberty interest in parole under either state law or the Eighth Amendment. Therefore, their procedural due process claim failed. The Eleventh Circuit affirmed the district court's grant of summary judgment to the Commissioners. View "Howard v. Coonrod" on Justia Law

Several college volleyball players accused their coach of physical, verbal, psychological, and sexual abuse. The players alleged that the coach engaged in a pattern of sexual harassment and abuse, including inappropriate touching and forcing players to engage in uncomfortable physical interactions. They also claimed that the coach's misconduct was reported to various university administrators and assistant coaches, who either witnessed or were informed of the abuse.The United States District Court for the Southern District of Alabama dismissed the players' Title IX and § 1983 claims with prejudice for failure to state a claim. The court found that the players had abandoned their breach-of-contract claims and dismissed those with prejudice. The court also declined to exercise supplemental jurisdiction over the remaining state-law claims, dismissing them without prejudice.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's dismissal. The court held that the players failed to state a Title IX claim because only certain university administrators were "appropriate persons" to receive notice of the misconduct, and the players did not provide sufficient actual notice of sexual harassment to those individuals. The court also found that the university did not act with deliberate indifference upon receiving the notice.Regarding the § 1983 claims, the court held that the players did not show that the university employees' conduct violated clearly established substantive-due-process principles. The court concluded that the employees were entitled to qualified immunity because the players did not provide case law with indistinguishable facts, a broad statement of principle, or conduct so egregious that it clearly violated constitutional rights.The Eleventh Circuit affirmed the district court's order dismissing the players' Title IX and § 1983 claims. View "DeMarcus v. University of South Alabama" on Justia Law

In 2000, Reginald Bertram Johnson abducted and raped 14-year-old C.A. at gunpoint. Following the assault, C.A. was examined by Dr. Scott Silla at a rape treatment center, where biological specimens were collected. Eight years later, a DNA match linked Johnson to the specimens. At trial, the prosecution introduced Dr. Silla’s report to support the chain of custody for the specimens, despite Johnson’s objection that the report’s admission violated the Confrontation Clause since Dr. Silla did not testify. Johnson was convicted and later filed a habeas corpus petition, which was denied.The Florida District Court of Appeal upheld Johnson’s convictions, ruling that the report was properly authenticated as a business record and that the Confrontation Clause was not violated because Johnson had the opportunity to cross-examine other witnesses involved in the collection and testing of the specimens. The Supreme Court of Florida and the U.S. Supreme Court denied further review. Johnson then exhausted his state post-conviction remedies.The United States Court of Appeals for the Eleventh Circuit reviewed the case, focusing on whether the admission of Dr. Silla’s report without his testimony violated Johnson’s confrontation rights. The court assumed, without deciding, that there was a Confrontation Clause violation but found that any error was harmless. The court concluded that other evidence, including the DNA match and testimonies from C.A., Nurse Carter, Detective Signori, and forensic analyst Sharon Hinz, provided significant corroboration. Thus, the court affirmed the denial of Johnson’s habeas petition, holding that Johnson could not prove actual prejudice from the report’s admission. View "Johnson v. Florida Dept. of Corrections" on Justia Law

A voter in Sarasota County, Florida, who is not affiliated with any political party, challenged Florida's closed primary election system. He argued that the system forces him to either join a political party to have a meaningful vote or forfeit his right to vote in primary elections, which he claimed was unconstitutional. The district court dismissed his case, concluding that he lacked standing and failed to state a claim for relief.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court found that the voter had standing to sue the Sarasota County Supervisor of Elections because his exclusion from primary elections was traceable to the Supervisor and could be redressed by a court order. However, the court determined that the voter lacked standing to sue the Florida Secretary of State, as the Secretary did not have direct control over the Supervisor's actions.On the merits, the court applied the Anderson-Burdick framework to evaluate the voter's First and Fourteenth Amendment claims. The court concluded that the burdens imposed by Florida's closed primary system on the voter's rights were minimal. The court found that the state's interests in preserving political parties as viable and identifiable interest groups and enhancing candidates' electioneering efforts outweighed the minimal burdens on the voter's rights.The court vacated the district court's order and remanded the case with instructions to dismiss the claims against the Florida Secretary of State without prejudice and to dismiss the claims against the Sarasota County Supervisor of Elections with prejudice. View "Polelle v. Florida Secretary of State" on Justia Law

Gray Television, a broadcaster in Alaska, sought review of a final forfeiture order by the Federal Communications Commission (FCC). The FCC had imposed the maximum forfeiture penalty on Gray for violating the prohibition on owning two top-four stations in a single designated market area (DMA). Gray acquired the CBS network affiliation of KTVA-TV for its own station, KYES-TV, which resulted in Gray owning two top-four stations in the Anchorage DMA. Gray did not seek a waiver from the FCC for this transaction.The FCC issued a Notice of Apparent Liability for Forfeiture (NAL) against Gray, proposing a penalty of $518,283, the statutory maximum. Gray responded, arguing that the transaction did not violate the rule because KYES was already a top-four station according to Comscore ratings data. Gray also contended that the FCC failed to provide fair notice of its interpretation of the rule and that the enforcement action violated the First Amendment and the Communications Act.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court affirmed the FCC's determination that Gray violated the rule, finding that the FCC reasonably relied on Nielsen ratings data, which showed that KYES was not a top-four station at the time of the transaction. The court also held that the FCC's interpretation of the rule was reasonable and that Gray had fair notice of the rule's application to its transaction.However, the court vacated the forfeiture penalty and remanded for further proceedings. The court found that the FCC failed to provide adequate notice to Gray that the proposed penalty was based on a finding of egregiousness, which violated due process. Additionally, the court held that the FCC did not adequately explain its consideration of Gray's good faith in determining the penalty amount. View "Gray Television, Inc. v. Federal Communications Commission" on Justia Law

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