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

Plaintiffs, Guatemalan labor organizers, filed suit alleging that Del Monte and its subsidiaries were responsible for armed kidnapping, intimidation, and torture on a Guatemalan banana plantation in 1999. The court had dismissed plaintiffs' claims for forum non conveniens; plaintiffs then filed a complaint in Guatemala but the local court refused to hear the case; without appealing, plaintiffs sought to reinstate their action in federal court; and the district court refused to reopen the case in the absence of exceptional circumstances under Federal Rule of Civil Procedure 60(b)(6). The court affirmed, concluding that the district court did not abuse its discretion in refusing reinstatement when plaintiffs created the procedural plight they now challenged. View "Aldana, et al. v. Del Monte Fresh Produce N.A., et al." on Justia Law

Plaintiff filed suit against defendants alleging that her teenage daughter - who suffers from severe emotional, mental, and physical disabilities - was sexually assaulted by another student while in defendant's care. The district court concluded that plaintiff's amended complaint failed to state a plausible claim for relief and dismissed with prejudice. On appeal, defendant challenged the district court's denial of her motions for partial reconsideration and for leave to amend. Because plaintiff failed to demonstrate "extraordinary circumstances" warranting the reopening of the final judgment, the district court did not abuse its discretion in denying her motion for partial reconsideration. Further, the district court did not abuse its discretion in denying plaintiff's motion for leave to amend her complaint. The court affirmed the judgment of the district court. View "M. G. v. St. Lucie Cty. Sch. Bd., et al." on Justia Law

Offshore appealed the district court's order permitting a lone claimant to pursue personal injury claims in state court after Offshore had invoked the Limitation of Liability Act (Limitation Act), 46 U.S.C. 30501. The court concluded that the district court did not abuse its considerable discretion in determining that the claimant could proceed first in state court with her tort claim before the district court adjudicated the boat owner's efforts to limit its liability to the value of the vessel. Accordingly, the court affirmed the judgment of the district court. View "Offshore of Palm Beaches, Inc. v. Lynch" on Justia Law

Petitioner appealed the dismissal of his federal habeas petition and the court granted him a certificate of appealability on the issue of whether the district court improperly determined that his 28 U.S.C. 2254 habeas petition was time-barred based on its finding that he was not entitled to equitable tolling. In light of Maples v. Thomas, the court held that attorney negligence, however gross or egregious, did not qualify as "extraordinary circumstances" for purposes of equitable tolling; abandonment of the attorney-client relationship, such as may have occurred in Holland v. Florida was required. Because petitioner was not abandoned by his post-conviction attorney, he failed to establish the "extraordinary circumstances" necessary to warrant equitable tolling of the section 2244(d) limitations period. Accordingly, the court affirmed the judgment of the district court. View "Cadet v. Secretary, FL Dep't of Corrections" on Justia Law

Defendants were convicted of sixteen counts of Hobbs Act robbery, 18 U.S.C. 1951, conspiracy, and use and carrying of firearms during the commission of a violent crime. The court held that the good faith reliance exception to the exclusionary rule under Davis v. United States applied to this case because the officers' conduct comported with clear, binding precedent that pre-dated the United States v. Jones opinion; the court affirmed the district court's denial of defendants' motion to suppress; the district court did not abuse its discretion in any of its evidentiary rulings; a reasonable trier of fact could have found Defendant Lowe of conspiracy to commit Hobbs Act robbery, and the charges related to the other armed robberies at issue; and, because there was no evidence that Lowe took any action in furtherance of the Kendall CVS robbery, the court vacated his conviction on those counts and remanded for sentencing. View "United States v. Ransfer" on Justia Law

Defendant appealed his sentence after being convicted of three counts of Hobbs Act robbery, 18 U.S.C. 1951(a) and (b), and four other counts relating to his possession and use of firearms during those robberies. The court concluded that the district court did not commit error, much less plain error, in imposing a mandatory life sentence under 18 U.S.C. 3559(c) without any jury findings about the existence of defendant's prior convictions. Relying on the court's precedent in United States v. Holmes and United States v. Cespedes, the court rejected defendant's contention that the combination of section 3559(c) and 21 U.S.C. 851, which resulted in his mandatory life sentence, violated "the Nondelegation Doctrine, Separation of Powers principles, and the U.S. Constitution" by impermissibly giving the executive branch "the power to prosecute and the power to sentence." Accordingly, the court affirmed the judgment of the district court. View "United States v. Harris" on Justia Law

Plaintiff, as representative of the estate of his father, filed suit against several entities with whom his father, Ronald Louis Smith, Sr., recorded music in the late 1970s. The estate alleged infringement of Smith's copyright in a musical composition entitled "Spank," along with a claim for breach of contract and a claim seeking a declaration of the validity of copyright transfer terminations the estate filed under 17 U.S.C. 203. Where a publisher has registered a claim of copyright in a work not made for hire, the court concluded that the beneficial owner has statutory standing to sue for infringement. The court held that the estate has adequately alleged facts to support its statutory standing to sue for infringement of the "Spank" copyright. Because the district court concluded that amendment of the complaint would be futile because the estate lacked statutory standing, the district court abused its discretion in denying leave to amend the complaint. Accordingly, the court reversed the district court's denial of the estate's motion to amend the complaint. View "Smith, Jr. v. Casey, et al." on Justia Law

Defendant pleaded guilty to conspiracy to commit a Hobbs Act, 18 U.S.C. 1951, robbery and the commission of a Hobbs Act robbery. On appeal, defendant challenged his sentence. The court concluded that the district court did not err in applying a two-level bodily injury enhancement under U.S.S.G. 2B3.1(b)(3)(A) where defendant's objection was untimely and where the victim sustained a bodily injury within the meaning of the guidelines. Accordingly, the court affirmed the judgment of the district court. View "United States v. Aguilar-Ibarra" on Justia Law

Defendant appealed his sentence and convictions of drug and firearms charges. Defendant raised several issues on appeal. The court concluded that the district court did not err in denying defendant's motion to suppress three searches because the first search at issue was a valid protective sweep; in regards to the second search at issue, defendant agreed to a warrantless search of his residence; and in regards to the third search at issue, the lessee of the property voluntarily consented to the search. The court concluded that defendant's remaining challenges were without merit. Accordingly, the court affirmed the judgment of the district court. View "United States v. Yeary" on Justia Law

Defendant was convicted of offenses stemming from his involvement in an operation of a series of companies that marketed and sold fraudulent business opportunities. Defendant raise several issues on appeal. The court concluded that the district court erred in adding a two-level sentencing enhancement for defendant's alleged violation of a prior court order where defendant received the enhancement because he violated an order he never actually received from a case his attorney presumably should have handled. The court reversed and remanded for resentencing. The court affirmed as to all other issues raised on appeal. View "United States v. Mathauda" on Justia Law