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

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

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