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

The Eleventh Circuit held that the district court erred in issuing an injunction against the County and the Director of the Miami-Dade Corrections and Rehabilitations Department (MDCR), requiring defendants to employ numerous safety measures to prevent the spread of COVID-19 and imposing extensive reporting requirements. Metro West inmates had filed a class action challenging the conditions of their confinement under 42 U.S.C. 1983 and seeking habeas relief under 28 U.S.C. 2241 for the named plaintiffs with a "medically vulnerable" subclass of inmates.The court held that plaintiffs failed to show a substantial likelihood of success on the merits of their constitutional claim for deliberate indifference. The court explained that the district court erred in relying on the increased rate of infection, and in concluding that defendants' inability to ensure adequate social distancing constituted deliberate indifference. In this case, the court simply could not conclude that, when faced with a perfect storm of a contagious virus and the space constraints inherent in a correctional facility, defendants acted unreasonably by "doing their best." The court also agreed with defendants that the district court erred in its likelihood-of-success-on-the-merits analysis because it failed to consider "two threshold issues": (1) the heightened standard for municipal liability under Monell v. Department of Social Services, 436 U.S. 658 (1978), and (2) exhaustion under the Prison Litigation Reform Act. Finally, the court held that the district court erred in holding, without any meaningful analysis, that plaintiffs would suffer irreparable injury absent an injunction. Furthermore, the district court erred in its determination of the balance-of-the-harms and public-interest factors. View "Swain v. Junior" on Justia Law

The Eleventh Circuit reversed the district court's grant of defendant's motion to suppress evidence obtained after officers, pursuant to arrest warrants, arrested defendant and his wife, secured them outside of their home, and then reentered the home to conduct a protective sweep without a warrant. The court found that the totality of the circumstances demonstrates that the officer had a reasonable suspicion that a dangerous person might have been in the house and that the protective sweep was justified. In this case, multiple cars indicated multiple people on the property; the tips about the drugs indicated multiple people who may have had access to weapons; and the wife's refusal to follow police directions indicated that, if other people were in the house, they might have likewise been non-compliant. View "United States v. Yarbrough" on Justia Law

The Eleventh Circuit affirmed the district court's judgment overruling defendant's objection to the admission of the firearm evidence. The court rejected defendant's contention that the probative value was substantially outweighed by the danger of unfair prejudice where the firearm was found in close proximity to the personal identifying information (PII) in a small closet, it tied defendant directly to the PII, and it had substantial probative value in proving that defendant actually possessed the PII. The court held that the district court did not abuse its discretion in concluding that firearms are not so inherently prejudicial as to substantially outweigh the probative value here. View "United States v. McGregor" on Justia Law

The Eleventh Circuit affirmed defendant's convictions and sentence for distribution of methamphetamine, conspiracy to distribute methamphetamine, and possession of methamphetamine with intent to distribute.The court held that defendant failed to establish good cause sufficient to overcome the untimely filing of his motion to suppress. The court also held that the district court did not plainly err by denying defendant's motion to suppress where the officer had probable cause to stop defendant's vehicle for a traffic infraction because the vehicle was following too closely to another vehicle. Furthermore, the investigating officers' collective knowledge of the ongoing criminal investigation justified the stop of defendant's vehicle. Finally, the court held that there was no clear error in the district court's finding that defendant did not accept responsibility for purposes of USSG 3E1.1. View "United States v. Andres" on Justia Law

The Eleventh Circuit affirmed defendant's conviction and sentence for possession with intent to distribute marijuana, assaulting a federal officer, discharging a firearm in relation to a crime of violence, and being a felon in possession of a firearm.The court joined five sister circuits and held that an assault conviction in violation of 18 U.S.C. 111(b) qualifies as a crime of violence under 18 U.S.C. 924(c); the district court did not abuse its discretion by excluding evidence relevant to defendant's self-defense theory at trial; the evidence was sufficient to support defendant's conviction on the section 111 and 924(c) counts; defendant's prior Georgia convictions for possession with intent to distribute marijuana qualified as predicate offenses for both the Armed Career Criminal Act and the Sentencing Guidelines; the district court did not clearly err in denying defendant a two-level sentencing reduction for acceptance of responsibility by pleading guilty to the possession charges; defendant's 360-month sentence was substantively reasonable and the district court did not abuse its discretion; and Rehaif v. United States, 139 S. Ct. 2191 (2019), does not require vacating defendant's conviction for possessing a firearm as a felon. View "United States v. Bates" on Justia Law

The Eleventh Circuit affirmed defendant's convictions for distributing furanyl fentanyl, a controlled substance analogue, in counterfeit oxycodone pills that caused the death of a 34-year-old woman. The court held that the government introduced sufficient evidence to permit a reasonable jury to find beyond a reasonable doubt that the furanyl fentanyl defendant distributed caused the woman's death; the district court had subject matter jurisdiction over the first two drug counts of the indictment; the district court did not err, much less plainly err, in instructing the jury on scienter; the district court did not clearly err in finding that defendant voluntarily consented to the search of his bags at the airport and in denying the motion to suppress; the district court did not abuse its discretion in declining to further investigate any juror misconduct; and there was no cumulative error requiring reversal. View "United States v. Benjamin" on Justia Law

The Eleventh Circuit affirmed the district court's denial of petitioner's motion to vacate his sentence under 28 U.S.C. 2255. The court held that petitioner cannot prove that his counsel rendered ineffective assistance, because petitioner's prior convictions in Alabama categorically qualify as predicate offenses under both the Armed Career Criminal Act and the career-offender provision of the Guidelines, and his prior conviction in Georgia qualifies as a predicate offense under the Act. Therefore, counsel did not perform deficiently by failing to raise a meritless objection. View "Hollis v. United States" on Justia Law

The Eleventh Circuit affirmed defendant's conviction for two counts of being a felon in possession of a firearm. The court held that the district court did not abuse its discretion in permitting one of his arresting officers to offer testimony at trial on the correlation between guns and drug activity and to suggest that defendant was selling drugs; the court declined to evaluate the applicability of the Armed Career Criminal Act (ACCA), because the district court would have imposed the same sentence regardless of whether the mandatory minimum applied; and the court rejected defendant's claim under Rehaif v. United States, 139 S. Ct. 2191 (2019), and held that there was no plain error in the district court's failure to instruct the jury of the knowledge-of-status element and any error from the lack of a knowledge-of-status element in defendant's plea colloquy did not affect his substantial rights. Finally, the court remanded for clarification of the judgment to reflect the sentence the district court said it would have imposed if the Armed Career Criminal Act did not apply. View "United States v. McLellan" on Justia Law

The Eleventh Circuit affirmed the district court's denial of petitioner's 28 U.S.C. 2255 motion to vacate his sentence. The court held that defendant's prior 1996 Florida convictions for robbery qualified as violent felonies under the Armed Career Criminal Act's (ACCA) elements clause, and rejected his contention that the court's decision in his direct appeal carved out a narrow exception to pre-1997 Florida robbery convictions obtained in Florida's Fourth District Court of Appeal. The court also held that petitioner's prior Florida felony battery conviction was a violent felony under the ACCA in light of the court's holding in United States v. Vail-Bailon, 868 F.3d 1293 (11th Cir. 2017) (en banc), cert. denied, 138 S. Ct. 2620 (2018). View "Welch v. United States" on Justia Law

The Eleventh Circuit affirmed defendant's conviction and sentence for being a felon in possession of a firearm. The court held that, given the totality of the circumstances, it was reasonable for officers, mistaking a dog's whimper for a person in distress, to enter defendant's home without a warrant. Therefore, defendant's challenge to the district court's denial of his motion to suppress evidence failed.The court upheld the district court's imposition of a 22 offense level finding because defendant possessed a semiautomatic firearm capable of accepting a large capacity magazine under USSG 2K2.1(a)(3)(A)(i) (2016). The court also upheld defendant's sentencing enhancement under USSG 2K2.1(b)(4)(B) for possessing a rifle that had an obliterated serial number. View "United States v. Evans" on Justia Law