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

An Alabama inmate, Jamie Mills, who was scheduled for execution on May 30, 2024, for committing two murders in 2004, appealed the denial of his motion for a preliminary injunction. Mills claimed that the State's practice of restraining its condemned prisoners on a gurney before execution would violate his constitutional rights to access the courts, to counsel, to due process, and against cruel and unusual punishment.Mills's case had been reviewed by multiple courts. His death sentence was affirmed by the Alabama Court of Criminal Appeals and the Supreme Court of Alabama. The Supreme Court of the United States denied certiorari. Mills also sought postconviction relief under Alabama Rule of Criminal Procedure 32, which was denied by the trial court and affirmed by the Alabama Court of Criminal Appeals and Supreme Court of Alabama. His federal petition for a writ of habeas corpus was denied by the district court in 2020. This Court denied a certificate of appealability in 2021, and the Supreme Court denied certiorari in 2022.The United States Court of Appeals for the Eleventh Circuit denied Mills's motion for a stay of execution. The court found that Mills had not established that he was substantially likely to succeed on the merits of his appeal or that the equities favor a stay of execution at this late stage. The court rejected Mills's arguments that he was likely to succeed on the merits of his claims under the Sixth, Eighth, and Fourteenth Amendments. The court also found that Mills's delay in seeking a preliminary injunction and a stay was "unnecessary and inexcusable," and that other equities weighed against a stay. View "Mills v. Hamm" on Justia Law

This case involves a mistaken identification by two sheriff's office investigators, Joseph Bultman and Jon Hixon, who identified George Angel Harris as the individual captured on security camera footage using a stolen debit card. Based on this identification, Hixon obtained two arrest warrants for Harris for financial transaction card fraud. Harris was arrested and held in jail for a few hours before being released. The criminal case against him was eventually dismissed.Previously, Harris filed a lawsuit against the investigators under 42 U.S.C. § 1983, alleging they violated his Fourth Amendment rights by causing him to be falsely arrested and unlawfully detained without probable cause. The district court construed Harris' claims as ones for malicious prosecution and granted summary judgment in favor of the investigators on qualified immunity grounds.In the United States Court of Appeals for the Eleventh Circuit, Harris argued that the investigation leading to his arrest was inadequate, that the district court erred in excluding his expert's testimony about the unreasonableness of the investigation, and that Hixon's arrest affidavit was based on conclusory statements without supporting facts, making the warrants for his arrest constitutionally inadequate.The Court of Appeals affirmed the district court's decision. It held that the investigators' mistaken identification of Harris was a reasonable mistake and did not violate Harris' Fourth Amendment rights. The court also found that the district court did not abuse its discretion in excluding Harris' expert's testimony, as it would not have been helpful to a jury. Finally, the court held that even if the arrest warrant application was insufficient, the investigators had probable cause to arrest Harris based on their own knowledge and the brief period of Harris' detention. View "Harris v. Hixon" on Justia Law

The case involves Nihad Al Jaberi, who was convicted and sentenced for attempted smuggling, failure to notify a common carrier, and submitting false or misleading export information. Al Jaberi appealed his convictions and sentences, arguing that there was insufficient evidence of his guilt, his convictions violated the Double Jeopardy Clause, his due process rights were violated due to the Government's failure to correct false witness testimony and prejudicial statements, and his sentences were unreasonable.In February 2021, a federal grand jury indicted Al Jaberi for smuggling firearms from the United States, delivering firearms to a common carrier without giving written notice, and submitting false and misleading export information. The Government presented evidence that Al Jaberi admitted to shipping the firearms to Iraq without informing the common carrier of the firearms. The jury found Al Jaberi guilty on all counts.Al Jaberi appealed his convictions and sentences to the United States Court of Appeals for the Eleventh Circuit. He argued that there was insufficient evidence to convict him, his convictions and sentences violated the Double Jeopardy Clause, his due process rights were violated because the Government failed to correct false witness testimony and made prejudicial statements, and his sentences were unreasonable.The Eleventh Circuit affirmed Al Jaberi’s convictions and sentences. The court found that there was sufficient evidence to convict Al Jaberi on all three charges. The court also found that Al Jaberi’s convictions did not violate the Double Jeopardy Clause, his due process rights were not violated, and his sentence was both procedurally and substantively reasonable. View "United States v. Al Jaberi" on Justia Law

The United States Court of Appeals for the Eleventh Circuit affirmed the convictions of sisters Tierzah, Charis, and Elisa Mapson in connection with a shooting incident. The victims were Joshua Thornton, the father of Tierzah's daughter, and his wife. The government charged the sisters with interstate domestic violence, interstate stalking, discharging a firearm in furtherance of a crime of violence, and conspiracy to commit these offenses. The jury found that the shooting was part of a scheme by the sisters to kill Mr. Thornton over a child custody dispute.In their appeal, the sisters argued that the evidence was insufficient to support the jury’s verdicts. Charis also challenged the admission of testimony that she once owned a firearm, claiming it was prejudicial hearsay. Elisa and Charis contested the admissibility of data obtained from automated license plate readers (ALPRs), arguing that its acquisition constituted a warrantless search in violation of their Fourth Amendment rights.The court of appeals found sufficient evidence to support the jury’s verdicts. The court also rejected Charis's challenge to the hearsay evidence, ruling it was admissible as an admission by a party opponent. The court further concluded that the ALPR data was admissible because the good-faith exception to the exclusionary rule applied, and its introduction did not require expert testimony. View "United States v. Mapson" on Justia Law

The case involved an appeal by two brothers, Jonathan and Daniel Markovich, who were convicted for operating fraudulent drug rehabilitation clinics in Florida. They were found guilty of various charges, including health-care fraud, wire fraud, kickbacks, money laundering, and bank fraud, resulting in fraudulent claims of over $100 million.The brothers appealed their convictions on several grounds. They argued that the district court violated their constitutional rights by denying their motion to compel the prosecution to obtain and disclose confidential medical records possessed by third parties. They also claimed that the court violated Federal Rules of Evidence by admitting unreliable and confusing expert testimony about the clinics' medical and billing practices. Additionally, they argued that the court abused its discretion by admitting lay summary testimony about medical and billing records.The United States Court of Appeals for the Eleventh Circuit affirmed the convictions. The court ruled that the prosecution had no duty to seek out potentially exculpatory evidence not in its possession. It also determined that the expert testimony was clear and reliable, and the summary testimony was proper. The court found that any challenge to bank-fraud counts was forfeited due to a lack of explanation or supporting legal authority. Finally, the court ruled that the district court did not abuse its discretion by denying the brothers' motion for a new trial based on newly discovered evidence. View "United States v. Markovich" on Justia Law

The case involves Andre Dubois, who was convicted on several federal firearm offenses. These offenses arose when Dubois attempted to ship a box containing firearms from Georgia to Dominica. The United States Court of Appeals for the Eleventh Circuit was asked to address five issues on appeal.Firstly, the court dismissed Dubois's argument that a recent Supreme Court case overturned the precedent upholding a ban on felons possessing firearms. The court held that the Supreme Court case did not abrogate the precedent, and therefore Dubois's argument failed.Secondly, the court affirmed that there was sufficient evidence for a reasonable jury to find that Dubois knew he was in possession of a firearm.Thirdly, the court found that Dubois's prior conviction for possession with intent to distribute marijuana under Georgia law qualified as a "controlled substance offense" under the federal Sentencing Guidelines, triggering a higher base offense level.Fourthly, the court rejected Dubois's argument that the application of a sentencing enhancement for possession of a stolen gun violated his due process rights.Finally, the court held that the district court had not erred in imposing a $25,000 fine on Dubois, as there was sufficient evidence to suggest that he could afford to pay the fine.Therefore, Dubois's convictions and sentence were affirmed. View "USA v. Dubois" on Justia Law

In a case before the United States Court of Appeals for the Eleventh Circuit, the plaintiffs, Honeyfund.com Inc, Chevara Orrin, Whitespace Consulting LLC, and Primo Tampa LLC, challenged a Florida law known as the Individual Freedom Act. This law bans certain mandatory workplace trainings that espouse or promote a set of beliefs related to race, color, sex, or national origin deemed offensive by the state. The plaintiffs asserted that the Act violated their rights to free speech and was both vague and overbroad. The district court granted a preliminary injunction, with the understanding that the Act was both unconstitutionally vague and an unlawful content- and viewpoint-based speech restriction. Florida appealed this decision.The appellate court held that the Act was indeed a violation of the First Amendment. The court rejected Florida's argument that the Act regulated conduct, not speech, noting that the Act's restrictions were based on the content and viewpoint of the speech in the prohibited meetings. The court applied strict scrutiny, determining that the Act was not narrowly tailored to serve a compelling state interest. It also rejected Florida’s attempt to tie the Act to Title VII, a federal law prohibiting employment discrimination, stating that having similar asserted purposes did not make the two laws equivalent. The plaintiffs' claim of irreparable injury due to an ongoing violation of the First Amendment was also acknowledged. The court thus affirmed the district court's order preliminarily enjoining the operation of the provision. View "Honeyfund.Com Inc v. Governor, State of Florida" on Justia Law

This case relates to the admission of an investigator's testimony from a preliminary hearing in a subsequent trial. The appellant, Maurice Kent, was a member of a violent gang and was charged with RICO conspiracy and five other substantive crimes, including the attempted murder of Shadeed Muhammad. The government alleged that the gang murdered a former member, Qualeef Rhode, for cooperating with the police’s investigation into the attempted murder. The government introduced an investigator’s testimony from a preliminary hearing in a related case, which identified Rhode as cooperating with law enforcement to implicate Kent in the attempted murder. Kent argued that this testimony was hearsay and its admission violated his Confrontation Clause rights.The United States Court of Appeals for the Eleventh Circuit rejected Kent's arguments and affirmed the decision of the district court. The court held that the investigator's testimony was not hearsay because it was offered for the effect it had on the listeners (other gang members) and not for the truth of the matter asserted. It was relevant because it influenced Kent and the other gang members who heard the testimony at the preliminary hearing, providing them with a motive to murder Rhode. The court also determined that the district court had sufficiently reduced the risk that the jury would improperly consider the out-of-court statement for the truth of the matter asserted by redacting the most prejudicial portions of the testimony and instructing the jury to consider the testimony only for its effect on the listeners. Therefore, the admission of the testimony did not violate Kent's rights under the Confrontation Clause. View "United States v. Kent" on Justia Law

In this case, three individuals and the Firearms Policy Coalition (FPC), an advocacy group, challenged a Georgia law that prohibits individuals under the age of 21 from obtaining licenses to carry firearms. They sued three county probate judges, who issue carry licenses, and Georgia’s Commissioner of Public Safety, who designs the carry license application form. The district court dismissed the case, concluding that the plaintiffs lacked standing to sue any of the defendants and that the case was both moot and unripe. On appeal, the United States Court of Appeals for the Eleventh Circuit held that the plaintiffs have standing to sue the probate judges, but not the Commissioner of Public Safety. The court found that the plaintiffs' alleged injury - the inability to carry firearms due to their age - is traceable to the actions of the probate judges who issue the licenses, and could be redressed by a court order directed at them. However, the court held that the plaintiffs' injuries are not fairly traceable to, nor redressable by a court order against, the Commissioner of Public Safety, who merely designs the application form and lacks enforcement authority. The court also held that the case was neither moot nor unripe with respect to the probate judges, reversing the district court's dismissal of the case in part and remanding the case to the district court for further proceedings. View "Baughcum v. Jackson" on Justia Law

In this case before the United States Court of Appeals for the Eleventh Circuit, Robert Franklyn Lodge, a native and citizen of Jamaica, challenged the constitutionality of a federal law regarding derivative citizenship. Lodge, born out of wedlock and abandoned by his mother, was brought to the United States by his naturalized father. After being convicted of aggravated felonies, the Department of Homeland Security sought to remove Lodge, who argued that he had derived citizenship from his father under a since-repealed statute. The immigration judge ordered Lodge removed to Jamaica, and the Board of Immigration Appeals dismissed Lodge’s appeal.Lodge argued that the former statute discriminated against unmarried fathers based on sex and against black children based on race. He asked the court to declare him a citizen, arguing that the statute, if cured of its constitutional defects, would have permitted his father to transmit citizenship to him. However, the court found that Lodge would not have derived citizenship from his father even under a version of the statute cured of its alleged constitutional defects. Consequently, the court denied Lodge's petition for review and deemed his motion to transfer as moot. View "Lodge v. United States Attorney General" on Justia Law