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

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

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

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

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

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

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

In the United States Court of Appeals for the Eleventh Circuit, the case involved Peter Sotis, who was convicted for violating export controls. He had conspired to export diving equipment, specifically rebreathers, to Libya without a license, despite the Department of Commerce requiring a license to export certain products to Libya that implicate the United States’ national security interests.Sotis challenged the sufficiency of the evidence to support each count of his conviction, the opinion testimony presented at trial, and the reasonableness of his 57-month sentence. He argued that there was insufficient evidence to prove willfulness, to prove that he and another individual had acted in conspiracy, and to prove that the rebreathers were closed-circuit, which would have resulted in a material and prejudicial variance from the indictment. He also claimed that one expert witness and one lay witness invaded the province of the jury by opining on an ultimate issue in the case.The Court of Appeals found that there was sufficient evidence for a reasonable jury to find that Sotis had sufficient knowledge of the illegality of his conduct to have willfully violated the export control laws. The Court also found that the government sufficiently proved that Sotis conspired with another individual to violate the export control laws. Moreover, the Court rejected Sotis's argument that there was a material variance between the indictment and the evidence presented at trial.Regarding the expert and lay witness testimonies, the Court held that the testimonies were not improper. The Court also found that the district court did not err in applying the sentencing guidelines and that Sotis's sentence was not substantively unreasonable. As a result, the Court affirmed Sotis's conviction and sentence. View "USA v. Sotis" on Justia Law

The U.S. Court of Appeals for the Eleventh Circuit considered an appeal by Mark Meadows, former White House chief of staff under President Donald Trump, who sought to move his state criminal prosecution to federal court. The state of Georgia had indicted Meadows for crimes related to alleged interference in the 2020 presidential election. Meadows argued that because these actions were taken in his official capacity, they should be heard in federal court according to the federal-officer removal statute (28 U.S.C. § 1442(a)(1)). The district court denied this request because Meadows' charged conduct was not performed under the color of his federal office. The court of appeals affirmed this decision. It ruled that the federal-officer removal statute does not apply to former federal officers and even if it did, the alleged actions leading to this criminal action were not related to Meadows’ official duties. The court concluded that the former chief of staff’s role does not include influencing state officials with allegations of election fraud or altering valid election results in favor of a particular candidate, regardless of the chief of staff's role with respect to state election administration. Therefore, Meadows was not entitled to invoke the federal-officer removal statute. View "The State of Georgia v. Meadows" on Justia Law

The case revolves around a defendant, Reginald McCoy, who was charged in 1990 with conspiracy to possess and possession of 50 grams or more of crack cocaine with the intent to distribute. He was convicted and sentenced to life imprisonment. In 2019, McCoy filed a motion to reduce his sentence under § 404(b) of the First Step Act, which allows some defendants to have their sentences reevaluated under reduced statutory penalties for crack cocaine offenses that were implemented after their sentences became final. He argued that he should be able to object to the drug-quantity finding made at his original sentencing as he did not have reason to do so at the time because he did not know that the statutory sentencing thresholds would be lowered in the future. However, the district court denied McCoy's motion, concluding that it lacked the authority to reduce the sentence because McCoy was already serving the lowest statutory penalty available to him under the Fair Sentencing Act, which was life imprisonment. The court also ruled that it would not have exercised its discretion to reduce the sentence even if McCoy was eligible due to the large quantity of crack cocaine attributable to him and his "ongoing and excessive disciplinary infractions" while incarcerated.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court's decision. The court held that the First Step Act does not grant authority to relitigate a drug quantity finding made at the original sentencing. It also rejected McCoy's argument that the retroactive application of the Fair Sentencing Act via the First Step Act violates due process. The court reasoned that it is impossible for courts to provide notice of a hypothetical future law whose passage is uncertain and whose operative text is uncertain. The court concluded that McCoy was not entitled to notice in 1991 of what the Fair Sentencing Act and the First Step Act would provide decades later. View "USA v. McCoy" on Justia Law

In the United States Court of Appeals for the Eleventh Circuit, the court reviewed the conviction of the defendant, Jirard Kincherlow, for coercing or enticing a minor into engaging in prostitution, in violation of 18 U.S.C. § 2422(b). The defendant had connected a fourteen-year-old girl, J.D., with adult men to engage in sexual activity for money, and advised her on how to make more money as a prostitute through social media messages. The defendant appealed his conviction on the grounds that the evidence was insufficient to support his conviction, that the district court erred in its instructions to the jury, and that a variance between the language of the indictment and the jury charge denied him due process notice of the charge against him.The court held that the evidence was sufficient to support the defendant's conviction. The court ruled that presenting the opportunity or paying money for a minor to engage in prostitution qualifies as inducement under § 2422(b), and the defendant's actions went beyond merely offering an opportunity. The court also held that the district court did not err in denying the defendant's motion for judgment of acquittal. The court found that the district court did not err in its instructions to the jury regarding the definition of "induce". Lastly, the court held that the variance between the indictment and the proof did not affect the defendant's substantial rights and his ability to defend himself. Therefore, the court affirmed the defendant's conviction. View "USA v. Kincherlow" on Justia Law