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

The Eleventh Circuit affirmed Defendants Blake and Moore's conviction of child sex trafficking for managing a prostitution ring involving at least two girls under the age of eighteen. The court held that the district court did not abuse its discretion by denying defendants' motion to sever; the bypass order did not exceed the district court's authority and the evidence gathered as a result of that order did not have to be suppressed; there was no error in the district court's decision not to suppress the evidence gathered as a result of the Mircrosoft warrant and the Facebook warrants; the court rejected Moore's claims with respect to her trial; and defendants' sentences were reasonable. View "United States v. Blake" on Justia Law

The Eleventh Circuit affirmed defendant's sentence of 685 months in prison for multiple armed robbery and carjacking crimes committed while he was a juvenile. The court held that defendant did not assert any valid ground for vacating his convictions where the district court did not err in its suppression rulings; the district court properly dismissed defendant's original indictment without prejudice; defendant's second indictment was timely; and the district court's evidentiary rulings did not warrant reversal. The court also held that the district court did not err in sentencing defendant. In this case, defendant's sentence complied with Graham v. Florida, 560 U.S. 48 (2010), because defendant had some meaningful opportunity to obtain release during his lifetime. Finally, defendant's sentence was not vindictive. View "United States v. Mathurin" on Justia Law

The Eleventh Circuit affirmed defendant's sentence of 685 months in prison for multiple armed robbery and carjacking crimes committed while he was a juvenile. The court held that defendant did not assert any valid ground for vacating his convictions where the district court did not err in its suppression rulings; the district court properly dismissed defendant's original indictment without prejudice; defendant's second indictment was timely; and the district court's evidentiary rulings did not warrant reversal. The court also held that the district court did not err in sentencing defendant. In this case, defendant's sentence complied with Graham v. Florida, 560 U.S. 48 (2010), because defendant had some meaningful opportunity to obtain release during his lifetime. Finally, defendant's sentence was not vindictive. View "United States v. Mathurin" on Justia Law

The Eleventh Circuit affirmed defendant's conviction and sentence for attempting to carry out a terrorist plot and for possessing a firearm not registered to him. The court held, after careful and thorough review, that all of the Foreign Intelligence Surveillance Act (FISA), 50 U.S.C. 1801 et seq., statutory requirements were satisfied, that the FISA-derived evidence in this case was legally acquired, and that the FISA surveillance and searches were made in conformity with the FISA Court's order of authorization and approval. Therefore, the district court did not abuse its discretion in denying defendant's motions seeking disclosure of the FISA applications, the FISA Court orders, or any remaining FISA-derived evidence. The court also held that the district court did not abuse its discretion in denying defendant's motion seeking disclosure of the FISA materials; the district court did not abuse its discretion in denying defendant's motion for a mistrial based on the prosecutor's misstatement; and there was no plain error in sentencing defendant where the evidence did not support defendant's allegation that the government introduced the subject of weapons of mass destruction to defendant. View "United States v. Osmakac" on Justia Law

The Eleventh Circuit affirmed defendant's conviction and sentence for attempting to carry out a terrorist plot and for possessing a firearm not registered to him. The court held, after careful and thorough review, that all of the Foreign Intelligence Surveillance Act (FISA), 50 U.S.C. 1801 et seq., statutory requirements were satisfied, that the FISA-derived evidence in this case was legally acquired, and that the FISA surveillance and searches were made in conformity with the FISA Court's order of authorization and approval. Therefore, the district court did not abuse its discretion in denying defendant's motions seeking disclosure of the FISA applications, the FISA Court orders, or any remaining FISA-derived evidence. The court also held that the district court did not abuse its discretion in denying defendant's motion seeking disclosure of the FISA materials; the district court did not abuse its discretion in denying defendant's motion for a mistrial based on the prosecutor's misstatement; and there was no plain error in sentencing defendant where the evidence did not support defendant's allegation that the government introduced the subject of weapons of mass destruction to defendant. View "United States v. Osmakac" on Justia Law

The Eleventh Circuit vacated its prior opinion and substituted the following opinion in its place.The court dismissed defendant's appeal of the district court's denial of his motion requesting a judicial recommendation to the Bureau of Prisons (BOP) for placement in a residential reentry center (RRC) 12 months prior to the end of his sentence. The court held that the denial of a request for a judicial recommendation was not a final order subject to appellate review. Therefore, the court lacked jurisdiction over the appeal. View "United States v. Martin" on Justia Law

The Eleventh Circuit vacated its prior opinion and substituted the following opinion in its place.The court dismissed defendant's appeal of the district court's denial of his motion requesting a judicial recommendation to the Bureau of Prisons (BOP) for placement in a residential reentry center (RRC) 12 months prior to the end of his sentence. The court held that the denial of a request for a judicial recommendation was not a final order subject to appellate review. Therefore, the court lacked jurisdiction over the appeal. View "United States v. Martin" on Justia Law

The Eleventh Circuit affirmed defendant's convictions for possessing a firearm and ammunition while being illegally or unlawfully in the United States. Citing textual support, prior precedent, congressional acquiescence, and analogous common law, the court held that there was no mens rea requirement with respect to the status element of 18 U.S.C. 922(g). Therefore, the district court did not err when it gave its jury instruction stating that the government was not required to prove that defendant knew that he was illegally or unlawfully in the United States. The court also held that the district court did not err when it instructed the jury that an alien illegally or unlawfully in the United States was an alien whose presence within the United States was forbidden or not authorized by law. View "United States v. Rehaif" on Justia Law

The Eleventh Circuit dismissed defendant's motion requesting a judicial recommendation to the Bureau of Prisons (BOP) for placement in a residential re-entry center (RRC) 12 months prior to the end of his sentence. Defendant contended that a prolonged placement at an RRC would help aid his re-integration into society. The court held that the denial of a request for a judicial recommendation was not a final order subject to appellate review. Moreover, the relief requested, if granted, would violate the prohibition on federal courts issuing non-binding advisory opinions. View "United States v. Martin" on Justia Law

The Eleventh Circuit affirmed the denial of defendant's renewed motion for a sentence reduction under 18 U.S.C. 3582(c)(2), holding that the district court had authority to entertain defendant's renewed motion but did not err in denying it. In this case, the district court found that defendant's life sentence was sufficient, but not greater than necessary, to address the 18 U.S.C 3553(a) factors. The district court clearly and thoroughly explained that life imprisonment remained an appropriate sentence based on the serious and heinous nature of defendant's crimes, the need for adequate deterrence, and the need to protect the public from future crimes. View "United States v. Caraballo-Martinez" on Justia Law