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

Defendants appealed the grant of a preliminary injunction in this case. The Eleventh Circuit dismissed the appeal as moot pursuant to Grupo Mexicano de Desarrollo S.A. v. Alliance Bond Fund, Inc., 527 U.S. 308, 315, 119 S. Ct. 1961, 1966 (1999), because the district court issued a permanent injunction and entered final judgment. View "West Alabama Women's Center v. Miller" on Justia Law

The Eleventh Circuit affirmed the denial of a petition for habeas relief based on the ineffective assistance of counsel at the guilt phase of petitioner's trial. Petitioner alleged that she was denied effective assistance because a revolving door of trial attorneys, collectively, left her unable to muster an adequate defense. The state court deemed her challenge procedurally defaulted. Although the court did not rule out that an ineffective assistance of counsel claim could be based on the lack of continuity of counsel, and the court agreed that petitioner could show cause why she failed to raise her claim at the appropriate time in state court, the court concluded that petitioner could not demonstrate that the lack of continuity of counsel prejudiced her case. Therefore, petitioner could not overcome the procedural default and could not demonstrate a meritorious claim of ineffective assistance of counsel. View "Harris v. Commissioner, Alabama Department of Corrections" on Justia Law

The Eleventh Circuit affirmed defendant's sentence at the bottom of the guideline range after he pleaded guilty to being a felon in possession of a firearm and ammunition. The court held that Florida's domestic-battery-by-strangulation statute qualifies as a "crime of violence" under the elements clause because it requires conduct that categorically requires the use of violent force. Therefore, the district court did not err by sentencing defendant as an armed career criminal based in part by his prior Florida conviction for domestic battery by strangulation. View "United States v. Dixon" on Justia Law

The Eleventh Circuit affirmed the district court's denial of a 28 U.S.C. 2254 petition for writ of habeas corpus, alleging that defense counsel rendered ineffective assistance in the investigation and presentation of mitigation evidence during his penalty phase proceedings. The court held that the state court's denial of petitioner's ineffective trial counsel claim was not contrary to, or an unreasonable application of, clearly established federal law, nor was it based on an unreasonable determination of the facts. In this case, petitioner has not shown a reasonable probability that, had he presented all mitigating evidence, the outcome of the proceedings would have been different. The court explained that petitioner's claims about his counsel's investigation were immaterial and irrelevant to the prejudice analysis. View "Krawczuk v. Secretary, FL DOC" on Justia Law

The Eleventh Circuit vacated defendant's 259 month sentence after he was convicted of multiple crimes stemming from his drug-dealing and identity-theft activities. The court held that the district court did not clearly err in applying the firearm enhancement under USSG 2D1.1(b)(1) and the premises enhancement under USSG 2D1.1(b)(12). However, the district court plainly erred in not allowing plaintiff to allocute before pronouncing sentence. Accordingly, the court remanded for resentencing. View "United States v. George" on Justia Law

The Eleventh Circuit granted the State's motion to vacate the district court's certification of appealability and denied petitioner's stay of execution. Petitioner contended that his federal Due Process, Equal Protection, and Eighth Amendment rights were violated by the state court's failure to give retroactive effect to (1) Chapter 2017-1, a revised version of Florida Statute 921.141 (Florida's capital sentencing statute), and (2) the U.S. Supreme Court's decision in Hurst v. Florida. The court assumed without deciding that the current petition was not a second or successive one for purposes of 28 U.S.C. 2244(b) purposes, and held that the Florida Supreme Court's rejection of petitioner's constitutional-statutory claim was not contrary to, or an unreasonable application of, the holding of a Supreme Court decision. View "Lambrix v. Secretary, DOC" on Justia Law

In light of the Eleventh Circuit's decision in United States v. Vail-Bailon, 868 F.3d 1293 (11th Cir. 2017), the court vacated its prior panel opinion and substituted this opinion, which has been revised only in Section II.D.The court denied defendant's motion for panel rehearing as moot. The court held that because the district court correctly counted defendant's felony battery conviction under Florida Statute 784.04 as a violent felony, defendant therefore had at least three prior violent felony convictions and the imposition of the Armed Career Criminal Act (ACCA) enhancement was required. The court affirmed defendant's conviction and sentence. View "United States v. Green" on Justia Law

After the Florida Supreme Court rejected petitioner's appeal from the denial of his guilt stage ineffective assistance claim on remand, he filed in federal district court a 28 U.S.C. 2254 petition for writ of habeas corpus. The Eleventh Circuit reversed the district court's grant of relief, holding that the district court relied on evidence that had not even been before the Florida Supreme Court in the first appeal from the denial of state collateral relief. In this case, petitioner did not raise a cumulative error claim, but the district court granted relief based on the cumulative effect or combined impact, of defense counsel's errors at the penalty phase and sentencing phase. The court held that the Florida Supreme Court did not unreasonably deny petitioner relief and the district court erred in granting habeas relief. View "Reaves v. Secretary, Florida DOC" on Justia Law

The Eleventh Circuit reversed and remanded for an evidentiary hearing on an ineffective assistance of counsel claim involving the failure to challenge the quantity of methamphetamine attributed to petitioner. Because there was nothing in the trial record to contradict petitioner's allegations, at this stage of the proceedings, the court must accept that unusable liquids were counted in calculating the drug quantities that determined his mandatory minimum sentence and his advisory guidelines base offense level. The court also must accept that the liquids could not have produced any more than 2.4 grams of methamphetamine. The court held that counsel's failure to challenge the weight calculations amounted to deficient performance, particularly because the drug quantities were the basis of petitioner's mandatory minimum sentence and higher guidelines range. Furthermore, counsel's deficient performance prejudiced petitioner. View "Griffith v. United States" on Justia Law

The Eleventh Circuit affirmed the dismissal of plaintiff's 42 U.S.C. 1983 action against five ADOC officials. Plaintiff alleged that the Alabama Sex Offender Registration and Community Notification Act (ASORCNA) and the ADOC classification manual violated his procedural due process, substantive due process, and ex post facto rights. The court held that the district court did not err in dismissing the procedural due process claim because he was convicted of a crime that constituted a sex offense under Alabama law at the time of his conviction and thus was not entitled to any additional process before being classified as a sex offender by prison officials. Furthermore, plaintiff failed to raise a cognizable substantive due process claim and ex post facto claim. View "Waldman v. Alabama Prison Commissioner" on Justia Law