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

Articles Posted in Criminal Law
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In the case before the United States Court of Appeals for the Eleventh Circuit, Thanquarius R. Calhoun was appealing the denial of his federal habeas petition following his conviction for felony murder and other crimes in the state of Georgia. Calhoun had led police on a high-speed chase that resulted in a passenger's death after law enforcement used a Precision Immobilization Technique (PIT) maneuver to stop his vehicle.Calhoun's appeal argued that he received ineffective assistance of counsel because his defense counsel did not present a defense or request a jury instruction on the theory that the PIT maneuver, and not his own actions, was the proximate or intervening cause of the passenger's death.Under Georgia law, as interpreted by the Supreme Court of Georgia, a defendant's act is not the "legal cause" of an injury or damage if some other act "intervenes." However, if the intervening act "could reasonably have been anticipated, apprehended, or foreseen by the original wrong-doer, the causal connection is not broken, and the original wrong-doer is responsible for all of the consequences resulting from the intervening act." In other words, proximate cause is not affected by a reasonably foreseeable intervening cause.The Eleventh Circuit, giving deference to the Supreme Court of Georgia's interpretation of Georgia law, found that the PIT maneuver was reasonably foreseeable given Calhoun's reckless behavior during the police chase. As a result, the use of the maneuver did not break the causal chain linking Calhoun's actions to the passenger's death. Thus, Calhoun had not carried his burden to show a reasonable probability that the outcome of his trial would have been different if his counsel had argued that the PIT maneuver was an intervening cause. Therefore, the court affirmed the denial of Calhoun's habeas petition. View "Calhoun v. Warden, Baldwin State Prison" on Justia Law

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In a dispute that arose from a gang-related murder, the United States Court of Appeals for the Eleventh Circuit was called to examine whether the placement of two suspects (who were allegedly involved in the same crime) in a room together constituted an interrogation under Miranda rights. The case involved Jimmie Bowen, a member of the New Moneii gang, who was convicted for the murder of Pierre Roche and injuring two others. After his arrest, Bowen invoked his right to counsel, at which point the police ceased questioning him. However, they moved him to another room where Bernard Jones, another member of the gang and the alleged getaway driver, was present. The ensuing conversation between Bowen and Jones resulted in Bowen making incriminating statements, which were used in his trial. Bowen appealed, arguing that his placement in the room with Jones violated his Miranda rights. The district court agreed with Bowen, but the Court of Appeals reversed that decision. The appeals court found that the Supreme Court's precedent was unclear on whether placing two suspects in a room together constitutes an interrogation under Miranda. The court held that because reasonable jurists could disagree about whether Bowen was "interrogated" in the interview room, federal courts lack the power to overturn his state criminal conviction. The appellate court further noted that the fact that Bowen incriminated himself does not necessarily mean it was "reasonably likely" that he would do so when Jones was placed in the room. The court concluded that the case fell into a gray area not clearly defined by Supreme Court precedent, and thus, Bowen's challenge did not warrant federal habeas relief. As such, the court reversed the district court's decision and remanded for further proceedings. View "Bowen v. Secretary, Florida Department of Corrections" on Justia Law

Posted in: Criminal Law
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In this case, the United States Court of Appeals for the Eleventh Circuit reviewed appeals from Eric Robert Rudolph, who had pled guilty to six federal arson charges and four counts of using a destructive device during a crime of violence in order to avoid the death penalty. As part of his plea deal, Rudolph had waived his rights to appeal his conviction and sentence, and to collaterally attack his sentence in any post-conviction proceeding. Despite this, Rudolph filed two petitions for habeas corpus under 28 U.S.C. § 2255, seeking to vacate several of his sentences. He argued that his convictions for using an explosive during a crime of violence were unlawful in light of new Supreme Court precedent.The Eleventh Circuit found that Rudolph’s § 2255 motions were, in fact, collateral attacks on his sentences, which his plea agreements did not permit. The court held that § 2255 is a mechanism for attacking sentences, not convictions. The court also rejected Rudolph's argument that his appeal waivers were unenforceable because he hadn't known he was waiving the right to collaterally attack his convictions, pointing out that the waivers explicitly included motions under § 2255. The court further declined to adopt a so-called "miscarriage of justice" exception to the enforceability of appeal waivers, which some other courts have recognized. The court affirmed the district courts' decisions denying Rudolph’s § 2255 motions. View "Rudolph v. United States" on Justia Law

Posted in: Criminal Law
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Joseph Sanfilippo, the defendant, appealed his conviction for wire fraud, arguing that the district court erred in denying his motion to dismiss the indictment because it was issued after the expiration of the federal statute of limitations. The United States Court of Appeals for the Eleventh Circuit dismissed Sanfilippo's appeal. The court reasoned that Sanfilippo had entered an unconditional guilty plea to one of eight counts in the indictment and, under precedent, waived his ability to appeal the district court’s denial of his motion to dismiss the indictment. The court found no evidence in the record indicating that the district court and the government had consented to Sanfilippo reserving his ability to appeal the district court’s denial of his motion to dismiss, which would be required for a conditional plea under Rule 11(a)(2). Therefore, the court concluded that Sanfilippo's plea was not conditional under Rule 11(a)(2), and he had waived his ability to appeal the district court’s denial of his motion to dismiss. View "USA v. Sanfilippo" on Justia Law

Posted in: Criminal Law
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The United States Court of Appeals for the Eleventh Circuit affirmed the conviction and sentence of Jonathan Daniels, who was found guilty of ten counts of Hobbs Act robbery and sentenced to 180 months imprisonment. Daniels challenged the conviction on several grounds. He argued that the district court erred by not accepting his proposed jury instruction on eyewitness identifications, that cumulative evidentiary errors prejudiced his right to a fair trial, and that the evidence was insufficient to convict him under Count 7 of the superseding indictment. He also contended that the sentence he received was unreasonable. The Court of Appeals disagreed with all of Daniels' arguments, finding that the district court had not abused its discretion in its jury instruction, that there were no cumulative errors that compromised Daniels' right to a fair trial, and that there was sufficient evidence for a reasonable jury to convict him under Count 7. The court also found that the sentence was not substantively unreasonable. The court thus affirmed Daniels' convictions and sentence. View "United States v. Daniels" on Justia Law

Posted in: Criminal Law
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The case concerns Tia Deyon Pugh, who was charged with impeding law enforcement during a civil disorder in violation of 18 U.S.C. § 231(a)(3) during a protest in Mobile, Alabama. She smashed a police car window with a baseball bat, thus obstructing law enforcement officers in their official duties during the civil disorder. Pugh challenged the constitutionality of Section 231(a)(3) on four grounds, arguing that it: (1) exceeds Congress’s power to legislate under the Commerce Clause, (2) is a substantially overbroad regulation of activities protected by the First Amendment, (3) is a content-based restriction of expressive activities in violation of the First Amendment, and (4) is vague in violation of the Fifth Amendment’s Due Process Clause. The district court rejected these arguments, and Pugh was found guilty by a jury.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed Pugh’s conviction. The court held that Section 231(a)(3) does not exceed Congress's power under the Commerce Clause as the statute's jurisdictional element is sufficient to limit its scope to constitutional applications. The court also found that the statute does not violate the First Amendment as it does not broadly prohibit protected speech and expressive conduct. Furthermore, the court ruled that the statute is not a content-based restriction and does not violate the Fifth Amendment's Due Process Clause due to vagueness. The court concluded that the statute constitutionally applies to Pugh's conduct, and she may not challenge the statute on vagueness grounds based on its application to others. View "USA v. Pugh" on Justia Law

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In 1993, Anthony Mungin was convicted of first-degree murder and sentenced to death. Mungin argued that his lawyer was ineffective during the guilt phase of his trial. In the United States Court of Appeals for the Eleventh Circuit, Mungin presented four claims of ineffective assistance of counsel. Two were initially raised in his federal habeas petition, while the other two were added later. The court found that the first two claims failed under Strickland v. Washington, 466 U.S. 668 (1984), and habeas caselaw. The other two claims were deemed inadmissible in federal court because they did not relate back to the initial habeas petition and were therefore barred by the statute of limitations. The court corrected its precedent on the standard of review, stating that under Krupski v. Costa Crociere S.p.A, 560 U.S. 538 (2010), they review those decisions de novo. The district court's denial of Mungin’s petition for a writ of habeas corpus was affirmed. View "Mungin v. Secretary, Florida Department of Corrections" on Justia Law

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In the case reviewed, Jason Gatlin was convicted of sex trafficking of a minor, production of child pornography, and witness tampering in the United States Court of Appeals for the Eleventh Circuit. The appeal focused on several issues including the evidence supporting the convictions, the district court's action in directing the jury to continue deliberating after they reached an inconsistent verdict, the proper application of sentencing enhancements and the reasonableness of the sentence, and whether the order of restitution violated Gatlin's constitutional rights.The court affirmed Gatlin's convictions and sentences for sex trafficking of a minor and production of child pornography. The court found there was sufficient evidence to support these convictions. However, the court reversed Gatlin's conviction for witness tampering, finding that the evidence only established a remote or simply hypothetical possibility that the witness's recantation statements would reach a federal officer.Regarding the sentencing, the court affirmed the district court's application of the custody, care, or supervisory control enhancement and the repeat offender enhancement. It also found Gatlin's life sentence was reasonable.As to the restitution order, the court also affirmed it, holding that it did not violate Gatlin's Sixth Amendment rights. The court concluded that the district court did not err in its calculation of the restitution amount and did not violate Gatlin's rights. View "USA v. Gatlin" on Justia Law

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In this appeal before the United States Court of Appeals for the Eleventh Circuit, the defendants, David Fey and Shari Lynn Gunter, were convicted of distributing methamphetamine and conspiring to kill and killing a witness to their crimes. The court was required to decide on three issues: (1) whether the district court abused its discretion by admitting evidence that Fey had attempted to hire someone to kill a witness cooperating with federal officials and if so, whether that error was harmless; (2) whether the district court plainly erred by declining to instruct the jury on spoliation; and (3) whether the district court erred by overruling Fey and Gunter’s objection to testimony about a coconspirator’s death and by declining to declare a mistrial.The Eleventh Circuit affirmed the district court's decisions on all three issues. First, it held that, although the prosecutors failed to identify the testimony about Fey's solicitation of a witness's murder as evidence under Federal Rule of Evidence 404(b), this error was harmless. The court reasoned that Fey and Gunter had ample notice of this testimony before trial and there was sufficient evidence to support the juries' convictions on the charges related to the witness's murder, even without this testimony.Second, the court found that the district court did not plainly err in declining to give a spoliation instruction to the jury about the destruction of the victim's tissue samples. The court noted that, even if such an instruction could be given in a criminal trial, it would be required only when the absence of material evidence is predicated on bad faith, not negligence.Finally, the court held that the district court did not err in overruling Fey and Gunter’s objection to testimony about the overdose death of a coconspirator. The court reasoned that the testimony did not imply that Fey and Gunter were involved in the coconspirator's death and did not prejudice their substantial rights. Therefore, the district court did not abuse its discretion in denying a mistrial. View "USA v. Fey" on Justia Law

Posted in: Criminal Law
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The United States Court of Appeals for the Eleventh Circuit affirmed the judgment of the United States District Court for the Middle District of Florida. The case involved Asdrubal Quijada Marin and Juan Carlos Acosta Hurtado, two Venezuelan nationals who were apprehended by the United States Coast Guard in the Caribbean Sea. They were convicted after a bench trial for conspiracy to possess with intent to distribute five kilograms or more of cocaine while aboard a vessel subject to the jurisdiction of the United States and possession with intent to distribute five kilograms or more of cocaine on a vessel subject to the jurisdiction of the United States, pursuant to the Maritime Drug Law Enforcement Act.On appeal, Marin and Acosta Hurtado challenged the court's jurisdiction, arguing that the indictment should have been dismissed for lack of jurisdiction and the evidence should have been suppressed due to violation of their Fourth Amendment rights. They also contended that their detention at sea for 48 days prior to indictment constituted unnecessary delay and outrageous government conduct.The Court of Appeals held that the District Court properly exercised jurisdiction over Marin and Acosta Hurtado under the Maritime Drug Law Enforcement Act because Cameroon, the flag nation of the vessel, had consented to United States jurisdiction over the crew of the vessel. It also held that the Northland’s stop and search of the Zumaque Tracer did not violate the Fourth Amendment, so the District Court did not err in denying the motion to suppress evidence based on a Fourth Amendment violation. The Court also held that the District Court did not err in denying Acosta Hurtado’s motion to dismiss based on unnecessary delay arguments. Lastly, the Court held that Acosta Hurtado's claim of outrageous government conduct was meritless. View "USA v. Hurtado" on Justia Law