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

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

Defendants Joyner and Sturgis appealed their convictions and sentences for multiple counts of Hobbs Act robbery and brandishing a firearm during a crime of violence. The Eleventh Circuit held that the district court did not reversibly err by declining to repeat a jury instruction when it provided the indictment to the jury; the district court's denial of motions to suppress cell site data did not warrant reversal; the district court did not abuse its discretion in denying Joyner's motions for new counsel; the district court did not err in rejecting Joyner's Bruton argument; but, as conceded by the government, Joyner should be resentenced under a correct offense level and guidelines range. Accordingly, the court remanded Joyner's case for resentencing and affirmed in all other respects. View "United States v. Joyner" on Justia Law

The Eleventh Circuit held that its order denying a certificate of appealability (COA) to petitioner in this case should not be reconsidered. The court held that petitioner was not entitled to a COA for two distinct reasons: first, his claim arose from the rule announced in Pena-Rodriguez v. Colorado, 580 U.S. ___, 137 S. Ct. 855 (2017), and that rule did not apply retroactively; and second, he has failed to show cause to overcome his procedural default. View "Tharpe v. Warden" on Justia Law

On remand from the Supreme Court, the Eleventh Circuit affirmed the denial of a petition for a writ of habeas corpus based on petitioner's claim of ineffective assistance of counsel. The Supreme Court held that this court must "look through" an unexplained decision by a state supreme court to the last reasoned decision and presume that the state supreme court adopted the reasoning in the decision by the lower state court. The court held that the superior court concluded that counsel provided petitioner effective assistance where, even if additional potential mitigating evidence had been admitted in petitioner's sentencing, there was no reasonable probability that the outcome of the sentencing trial could be different. Finally, the court denied petitioner's motion to remand or, alternatively, to expand the certificate of appealability and to permit supplemental briefing. View "Wilson v. Warden" on Justia Law

The Eleventh Circuit affirmed defendant's conviction and sentence for charges related to access device fraud and identity theft. The court held that the district court correctly gave the deliberate ignorance instruction to the jury; the evidence was sufficient to support the aggravated identity theft convictions; the district court did not err in denying her a minor role reduction under USSG 3B1.2; the district court did not err in its loss calculation under USSG 2B1.1(b)(1); and the record included ample evidence to support the 14 level increase in defendant's offense level. View "United States v. Maitre" on Justia Law

The Eleventh Circuit affirmed defendant's conviction and sentence for conspiracy to commit healthcare fraud and wire fraud, and conspiracy to defraud the United States and pay healthcare kickbacks. The court held that the district court did not err when it admitted the factual basis for the plea agreement because defendant knowingly and voluntarily signed a valid waiver. The court rejected defendant's arguments that the district court committed other errors at his trial when it calculated his Sentencing Guidelines range. The court vacated, however, the district court's forfeiture order and remanded for a new order where the district court impermissibly held defendant jointly and severally liable for the proceeds of the conspiracy. Accordingly, the court affirmed in part, vacated in part, and remanded. View "United States v. Elbeblawy" on Justia Law