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

Thirteen states sued the Treasury Secretary and related officials to challenge a tax offset provision in the American Rescue Plan Act, a coronavirus stimulus package passed by Congress in 2021. That offset provision prohibits states from using Rescue Plan funds “to either directly or indirectly offset a reduction in [their] net tax revenue” that results from a change in law that “reduces any tax.” The States argued that this “tax mandate” exceeds Congress’s authority under the Constitution. The district court agreed and permanently enjoined enforcement of the offset provision. The Secretary appealed.   At issue was whether the States’ challenge presents a justiciable controversy and if so, whether the offset provision is unconstitutional. The Eleventh Circuit affirmed, concluding that the district court answered both questions correctly. The court explained that all four elements weigh in favor of granting a permanent injunction. The district court did not misapply the law nor base its determination on clearly erroneous facts. It did not abuse its discretion. We also agree with the district court that the permanent injunction fully redresses the States’ harm in this case—declaratory relief is unnecessary. The court reiterated, however, that the permanent injunction applies only to Section 802(c)(2)(A), which is severable from the remaining provisions of the Act. View "State of West Virginia, et al v. U.S. Department of the Treasury, et al" on Justia Law

Deputy sheriffs arrested Plaintiff based on a warrant for another man of the same name, detained him, and released him when his identity was verified three days later. Plaintiff sued the deputies for violating his alleged due process right to be free from over-detention under 42 U.S.C. Section 1983. The district court dismissed Plaintiff’s complaint for failure to state a claim.   At issue was whether an individual detained for three days based on mistaken identity for a valid arrest warrant has stated a claim for relief under the Fourteenth Amendment for his over-detention. The Eleventh Circuit affirmed. The court reasoned that under Baker v. McCollan, no violation of due process occurs if a detainee’s arrest warrant is valid and his detention lasts an amount of time no more than three days. And both conditions are met here. The court explained that Plaintiff was arrested on a valid warrant and held for only three days. Thus, under Baker, Plaintiff’s complaint did not state a claim for a violation of his due process rights. View "David Sosa v. Martin County, Florida, et al." on Justia Law

The jury convicted Petitioner of second-degree murder and robbery. The verdict form included interrogatories about the firearm enhancement. After he was resentenced, Petitioner filed a third motion that asserted two grounds for relief. Petitioner filed a federal petition for a writ of habeas corpus that asserted the same two claims for relief that he alleged in his third Florida Rule 3.850 motion. The district court denied the petition and denied Petitioner’s motion for reconsideration. It determined that both of Petitioner’s claims were procedurally barred.   On appeal from the denial of a petition for a writ of habeas corpus the Eleventh Circuit was required to decide whether trial counsel provided ineffective assistance by requesting that the jury be instructed on lesser included offenses. The Eleventh Circuit affirmed the denial of the petition finding that Petitioner’s trial counsel did not render ineffective counsel. Further, the court wrote that because Petitioner’s claim that insufficient evidence supported his conviction was denied by the state courts based on an adequate and independent state procedural ground, he is also not entitled to relief on that claim. View "Demetrius Carey v. Department of Corrections" on Justia Law

The Florida Legislature passed the Combatting Violence, Disorder, and Looting, and Law Enforcement Protection Act, also known as House Bill 1 (“HB 1”), 2021 Fla. Leg. Sess. Laws Serv. ch. 2021-6. HB 1 redefined the crime of “riot.” After HB 1’s passage, Dream Defenders and other organizations that lead protests for racial justice challenged the new definition as unconstitutional, alleging that it infringed their members’ First Amendment right to engage in peaceful protest. The district court agreed with the plaintiffs that the new statutory definition was vague and overbroad and, therefore likely to chill or deter their members’ exercise of their First Amendment rights. The court entered a preliminary injunction that prevented the defendants, Governor DeSantis and three sheriffs, from taking any steps to enforce the law using the new definition.   The Eleventh Circuit deferred its decision as to the preliminary injunction in this case until the Florida Supreme Court has had the opportunity to consider the following certified question:What meaning is to be given to the provision of Florida Stat. § 870.01(2) making it unlawful to “willfully participate[] in a violent public disturbance involving an assembly of three or persons, acting with a common intent to assist each other in violent and disorderly conduct, resulting in . . . [i]njury to another person; . . . [d]amage to property; . . . or [i]mminent danger of injury to another person or damage to property”? View "Dream Defenders, et al v. Governor of the State of Florida, et al" on Justia Law

Defendant challenges his convictions of healthcare fraud, illegal kickbacks, and money laundering and the related restitution award and forfeiture judgment. After Defendant filed this appeal, President Trump commuted his sentence of imprisonment and rendered any challenge to it moot. In his remaining challenges, Defendant argued that his indictment should have been dismissed because of prosecutorial misconduct, that the district court erroneously admitted expert opinion testimony against him, that the admissible evidence against him was insufficient to sustain his convictions, and that the restitution award and forfeiture judgment should be vacated.   The Eleventh Circuit affirmed. The court explained that that the presidential commutation renders Defendant’s appeal of his prison sentence moot but does not otherwise affect his appeal. Second, the court explained that the district court did not abuse its discretion when it declined to dismiss the indictment or to disqualify the prosecutors due to misconduct. Third, the court affirmed the admission of the expert-opinion testimony. Fourth, the court affirmed the restitution amount as not clearly erroneous. And fifth, the court held that there was sufficient evidence for the jury to convict Defendant of money laundering and that the forfeiture judgment based on money laundering was lawfully calculated. View "USA v. Philip Esformes" on Justia Law

Defendant was convicted of producing and possessing child pornography in violation, respectively, of 18 U.S.C. Sections 2251(a) and 2252A(a)(5)(b). On appeal, Defendant claimed raised three grounds of error, 1.) the government failed to trigger federal jurisdiction; 2.) the district court erred when it discharged an impaneled-but-not-yet sworn jury in his absence, and 3.) the evidence was legally insufficient to support his conviction.The Eleventh Circuit affirmed, finding that by transferring content from his phone to a hard drive that was manufactured overseas, federal jurisdiction was triggered. The court noted that Defendant's counsel consented to the jury not being sworn and that doing so outside of his presence didn't raise constitutional concerns. Finally, the court found the evidence presented by the government to be sufficient to support Defendant's convictions. View "USA v. Clark Downs" on Justia Law

Defendant, the School Board of St. Johns County (the “School Board”), is responsible for providing “proper attention to health, safety, and other matters relating to the welfare of students” within the St. Johns County School District (the “School District”). Plaintiff, is a transgender boy. The case involves the practice of separating school bathrooms based on biological sex. This appeal required the court to determine whether separating the use of male and female bathrooms in public schools based on a student’s biological sex violates (1) the Equal Protection Clause of the Fourteenth Amendment, U.S. Const. amend. XIV, Sections 1, and (2) Title IX of the Education Amendments Act of 1972. The district court enjoined the School Board from prohibiting Plaintiff’s use of the male bathrooms and granted Plaintiff $1,000 in compensatory damages.   The Eleventh Circuit reversed and remanded the district court’s order. The court explained that commensurate with the plain and ordinary meaning of “sex” in 1972, Title IX allows schools to provide separate bathrooms on the basis of biological sex. That is exactly what the School Board has done in this case; it has provided separate bathrooms for each of the biological sexes. And to accommodate transgender students, the School Board has provided single-stall, sex-neutral bathrooms, which Title IX neither requires nor prohibits. Nothing about this bathroom policy violates Title IX. Further, the court wrote that whether Title IX should be amended to equate “gender identity” and “transgender status” with “sex” should be left to Congress—not the courts. View "Drew Adams v. School Board of St. Johns County, Florida" on Justia Law

Norwegian Cruise Lines Ltd. obtained the injunction barring the Florida Surgeon General from enforcing a prohibition against businesses requiring proof of vaccination as a condition of service. But Norwegian recently filed a suggestion of mootness stating that it no longer requires proof of vaccinations on its cruises. Yet, Norwegian’s filings make clear that it has not suspended its vaccination requirements permanently or categorically. It also continues to defend its entitlement to equitable relief by asking us to leave the preliminary injunction intact.   The Eleventh Circuit denied Norwegian’s motion to dismiss the appeal as moot. The court explained that it agrees with the Surgeon General that a “live dispute” exists because Norwegian has not established that it has relaxed its vaccination requirements permanently or categorically. “The possibility that a party may change its mind in the future is sufficient to preclude a finding of mootness.” The court explained Norwegian has offered no evidence of its vaccine policies or its intentions for the future beyond the boilerplate statement that it is not requiring COVID-19 vaccination for now and for the foreseeable future. Indeed, Norwegian appears to concede that it has not abolished its policy forevermore.’The court saw no reason to believe that Norwegian will not seek to reinstate its policy given its continued insistence that the Florida law is unconstitutional. View "Norwegian Cruise Line Holdings Ltd, et al. v. State Surgeon General" on Justia Law

Petitioner is a Florida prisoner serving three death sentences. After pursuing a direct appeal and postconviction relief in the Florida state courts, Petitioner filed a federal habeas petition under 28 U.S.C. Section 2254, alleging, in relevant part, that his counsel rendered constitutionally ineffective assistance during the penalty phase. After the district court denied Petitioner’s Section 2254 petition on the merits, the Eleventh Circuit granted a certificate of appealability (“COA”) on one issue: “Whether the district court erred in denying Jennings’s claim that his trial counsel rendered ineffective assistance in the penalty phase of his capital trial by failing to conduct further investigation into Petitioner’s childhood and background.”   The Eleventh Circuit concluded that the Florida Supreme Court’s decision that Petitioner failed to establish prejudice was not contrary to, or an unreasonable application of, clearly established federal law, and the court affirmed on that ground. The court wrote that given the facts of this case, it was not unreasonable for the state court to conclude that Defendant was not prejudiced by counsel’s failure to present the mitigation evidence in question during the penalty phase. As an initial matter, there is a significant probability that much of the omitted mitigation evidence, when combined with that adduced at trial, would have undermined some of the mitigating factors that the trial court found. Furthermore, there were significant aggravating factors present in this case. View "Brandy Bain Jennings v. Secretary, Florida Department of Corrections" on Justia Law

Plaintiff as pulled over by a deputy of the Jackson County Sheriff’s Office for erratic driving. During the stop, the deputy noticed an open container of beer and decided to issue a warning citation. The deputy wrote—but never delivered—the ticket. Instead, a few minutes into the stop, he ordered Plaintiff out of the truck so he could walk his drug-sniffing dog around the vehicle. Plaintiff resisted the deputy’s commands verbally and then physically. The deputy arrested him for obstruction and Plaintiff suffered minor injuries. His truck was searched, but no drugs were found. The obstruction charge was later dismissed. A couple years after this encounter, Plaintiff filed claims against the deputy and the Jackson County Sheriff under 42 U.S.C. Section 1983 and Florida common law.   The Eleventh Circuit vacated he district court’s summary judgment on the Section 1983 claim against the deputy, but only with respect to the issue of whether the deputy unlawfully prolonged the traffic stop in violation of Plaintiff’s Fourth Amendment rights. The court also vacated the district court’s summary judgment on the false imprisonment claim against both the deputy and the Jackson County Sheriff, but only with respect to the issues of whether the deputy tortiously detained Plaintiff by (1) unlawfully prolonging the traffic stop and (2) arresting Plaintiff without probable cause. The court affirmed the district court’s summary judgment in all other respects. View "Michael Baxter v. Louis Roberts, III, et al." on Justia Law