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

The Eleventh Circuit held that the DEA's regulatory definition of "positional isomer" did not unambiguously apply to the use of that term as it pertained to butylone and ethylone in this case. Therefore, the court vacated defendant's conviction of possession with intent to distribute a controlled substance where the substance involved was ethylone. The court explained that ethylone constitutes a controlled substance only if it is a "positional isomer" of butylone. View "United States v. Phifer" on Justia Law

Defendants appealed their convictions for conspiracy to commit interstate transportation of stolen property. The Eleventh Circuit affirmed the convictions and held that, although the delay between indictment and arrest was the result of the Government's negligence, the delay did not amount to a Sixth Amendment speedy trial violation. Applying the Barker factors, the court held that neither the length of the delay, nor the reason for it, weigh heavily against the Government. In this case, the Government's good-faith attempt to arrest defendants was diligent enough to avoid warranting the extraordinary remedy of dismissing their indictments. Finally, defendants failed to prove actual prejudice. View "United States v. Lazaro Oliva" on Justia Law

Plaintiff filed a 42 U.S.C. 1983 action against a police officer and the city, alleging claims of excessive force. In this case, plaintiff was experiencing an episode of diabetic shock when he lost control of his car, came to a stop at an interstate median, and was tased four times by the officer as he attempted to comply with the officer's orders.The Eighth Circuit affirmed the district court's denial of defendants' motions to dismiss, holding that the officer was not entitled to qualified immunity at this stage of the case. The court also held that plaintiff, for purposes of summary judgment, established a constitutional violation. Therefore, the district court properly denied the city's motion for summary judgment. View "Glasscox v. City of Argo" on Justia Law

Defendant appealed his conviction of a federal narcotics conspiracy offense, contending that his trial counsel had a conflict of interest that had an adverse effect on his performance at trial. The Eleventh Circuit held that counsel did have a conflict of interest when he represented a government witness who was then appealing his own sentence after pleading guilty to federal narcotics charges. Although counsel knew that the witness had been found to have obstructed justice in his own criminal case, counsel did not ask the witness about the obstruction scheme at defendant's trial. Therefore, the court remanded for the limited purpose of having the district court conduct an evidentiary hearing on whether counsel's conflict resulted in an adverse effect. View "United States v. Williams" on Justia Law

At issue was whether the standard for denying a motion for directed verdict in a criminal trial in Georgia can accurately gauge whether summary judgment was properly granted to a defendant in a 42 U.S.C. 1983 malicious prosecution case.The district court applied Georgia’s Monroe rule, which provides that denial of a motion for directed verdict in a criminal trial conclusively demonstrates the existence of probable cause, thereby precluding a state civil malicious-prosecution claim based on the prosecution in which the criminal court denied the directed verdict. In applying the rule, the court granted summary judgment to Defendant and against Plaintiff on his section 1983 malicious prosecution claim. The Eleventh Circuit vacated the entry of summary judgment and remanded for further proceedings, holding (1) a district court evaluating a motion for summary judgment on a section 1983 malicious prosecution claim must apply only the federal summary-judgment standard in determining whether summary judgment should be granted; and (2) the district court erred in granting summary judgment based solely on the Monroe rule. View "Blue v. Lopez" on Justia Law

The Eleventh Circuit affirmed Defendants Chacon, Altamirano, Portela, and Dixon's convictions and sentences for conspiracy to distribute 280 grams of cocaine base and several other charges of drug trafficking, firearm possession, armed robbery, and assault. Defendants' convictions stemmed from their participation in a drug conspiracy in Little Havana, Miami.The court held that sufficient evidence supported each defendant's conviction for the drug conspiracy; the district court correctly denied Portela's motion to suppress evidence, sufficient evidence supported his conviction for possession of a firearm in furtherance of a drug-trafficking crime, he was not entitled to a competency hearing, and he waived his right to appeal his sentence; sufficient evidence supported Altamirano's conviction for a violent crime in aid of racketeering; sufficient evidence supported Chacon's convictions for possession of a firearm and for possession of narcotics and the district court did not err when it admitted evidence of his uncharged conduct, when it refused to instruct the jury on entrapment, or when it denied his motion for a mistrial; Chacon's sentence was procedurally and substantively reasonable; and defendants' remaining claims were meritless. View "United States v. Dixon" on Justia Law

The Eleventh Circuit affirmed the district court’s decision denying Appellant’s petition for a writ of habeas corpus, holding that the district court properly denied relief on Appellant’s claim alleging that trial counsel was ineffective at the guilt phase of his trial.Appellant, an inmate in a Georgia prison, filed a 28 U.S.C. 2254 petition in the Southern District of Georgia, asserting eighteen claims. The district court denied the petition in its entirety. At issue on appeal was whether trial counsel provided ineffective assistance during the guilt phase of Appellant’s trial by failing to use certain pretrial statements and police reports to impeach several of the State’s witnesses and by failing to object to the introduction of certain evidence. The Eleventh Circuit affirmed, holding that a fair-minded jurist could agree with the state habeas court’s denial of relief. View "Meders v. Warden, Georgia Diagnostic Prison" on Justia Law

The Eleventh Circuit affirmed the district court’s decision to deny Appellant unconditional release from civil commitment, holding that the district court did not commit clear error in finding that Appellant’s risk of danger to others was due to a “mental disease or defect” under 18 U.S.C. 4243(d).Appellant was found not guilty by reason of insanity by threatening the President of the United States, among other offenses. After a hearing, the district court found that Appellant’s underlying crimes involved a substantial risk of bodily injury to another and that there was a substantial risk that Appellant would harm others in the future. The district court then ordered Appellant civilly committed pursuant to 18 U.S.C. 4243(e). On appeal, Appellant argued that the district court erred in committing him because there was no evidence that he suffered from a present mental disease or defect. The Eleventh Circuit disagreed, holding that the district court did not clearly err in finding (1) Appellant suffered from a mental disease or defect, and (2) Appellant’s dangerousness was due to his mental disease or defect. View "United States v. McIntosh" on Justia Law

The Eleventh Circuit affirmed the district court's denial of petitioner's pro se 28 U.S.C. 2255 motion challenging his sentence in light of Johnson v. United States. The court held that petitioner's Indiana battery convictions were violent felonies under the Armed Career Criminal Act's (ACCA) elements clause. The court explained that a conviction under the Indiana statute necessarily required that the defendant use force capable of causing physical pain or injury. View "DeLeon Colon v. United States" on Justia Law

The Eleventh Circuit affirmed defendant's 132 month sentence for drug trafficking under the Maritime Drug Law Enforcement Act. The court held that the Fifth Amendment did not entitle defendant to relief from his mandatory minimum sentence; in light of international concerns, Congress was entitled to mete out hefty sentences to maritime drug runners; the inherent difficulties of policing drug trafficking on the vast expanses of international waters suggested that Congress could have rationally concluded that harsh penalties were needed to deter would-be offenders; circuit precedents foreclosed defendant's arguments about the constitutionality of the Act and its application to him; and defendant's guilty plea foreclosed his constitutional challenges to his detention. View "United States v. Lemus Castillo" on Justia Law