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

Plaintiff filed suit against Marod to compel it to bring one of its stores into compliance with Title III of the Americans with Disabilities Act (ADA), 42 U.S.C. 12181-12189. The district court dismissed the claim, concluding that plaintiff lacked standing. The court concluded that plaintiff had standing to seek injunctive relief against defendant where plaintiff has been to the store in the past, he wants to return, and his frequent trips directly past the store render it likely that he would do so were it not for the alleged ADA violations. Accordingly, the court reversed the district court's dismissal of plaintiff's claim. View "Houston v. Marod Supermarkets, Inc." on Justia Law

The court sua sponte reconsidered its original opinion in this matter and substituted this opinion for its original. This appeal by R.J. Reynolds of money judgments in favor of the survivors of two smokers required the court to decide whether a decision of the Supreme Court of Florida in an earlier class action was entitled to full faith and credit in federal court. Because R.J. Reynolds had a full and fair opportunity to be heard in the Florida class action and the application of res judicata under Florida law did not cause an arbitrary deprivation of property, the court affirmed the judgments against R.J. Reynolds and in favor of the survivors of the smokers. View "Walker v. R.J. Reynolds Tobacco Co." on Justia Law

Plaintiff filed suit against Officer Seymour and Sergeant Parker under 42 U.S.C. 1983 for false arrest. Plaintiff was arrested in the parking lot of a bar after Officer Seymour, who was working off-duty but in full uniform, asked her to move her car before it was towed. Plaintiff responded by cursing and speaking loudly. The court affirmed the district court's denial of qualified immunity to Officer Seymour because the facts viewed in the light most favorable to plaintiff showed that Officer Seymour lacked arguable probable cause to arrest plaintiff. The court concluded, however, that the district court erred in denying qualified immunity to Sergeant Parker, who was not present during the alleged false arrest. Accordingly, the court reversed the district court's judgment in regards to Sergeant Parker. View "Wilkerson v. Seymour" on Justia Law

Atlanticus brought an antitrust counterclaim against Akanthos and other hedge funds. Atlanticus' counterclaim was identical to the complaint that Atlanticus brought in another antitrust lawsuit between the same parties. The district court dismissed the complaint in the other lawsuit and the court affirmed. The court concluded that res judicata barred Atlanticus from pursuing the present appeal and denied the noteholders' motion for fees and costs under Federal Rule of Appellate Procedure 38. Accordingly, the court affirmed the dismissal of the antitrust counterclaim, denied the noteholders' motion to dismiss the appeal as moot, and denied the noteholders' motion for fees and costs. View "Akanthos Capital Mgmt., et al. v. Atlanticus Holdings Corp." on Justia Law

Petitioner was convicted of malice murder and sentenced to life in prison. On appeal, petitioner challenged the district court's denial of his 28 U.S.C. 2254 habeas petition. Petitioner argued that the state trial court's instructions to the jury on venue, an essential element of the crime charged, improperly shifted the burden of proof from the state to him. The court concluded that the Georgia Supreme Court's decision was not contrary to, or involved an unreasonable application of, clearly established Federal law where the court found that any Sandstrom v. Montana error was harmless. At trial, the prosecution had presented substantial evidence to support its theory that the victim was killed in Troup County, Georgia. Further, the court concluded that the 25-year delay in resolving petitioner's motion for a new trial did not violate his constitutional rights where the Supreme Court has never held that there was a constitutional right to a speedy direct appeal in a state criminal case. Accordingly, the court affirmed the judgment. View "Owens v. McLaughlin" on Justia Law

Defendant appealed his conviction and sentence for two counts of robbery and one count of brandishing a firearm during and in relation to a crime of violence. The court concluded that even if the district court erred in admitting an eyewitness's identification testimony, any such error was harmless in light of the overwhelming evidence of defendant's guilt. Further, the district court did not err by using defendant's Alabama youthful offender adjudication to classify him as a career offender under U.S.S.G. 4B1.1. Accordingly, the court affirmed defendant's conviction and sentence. View "United States v. Elliot" on Justia Law

Defendant appealed his convictions and sentence for conspiracy to commit wire fraud and wire fraud. The court concluded that there was sufficient evidence for a reasonable trier of fact to find defendant guilty beyond a reasonable doubt. The court concluded, however, that the record did not support a finding that defendant's offense involved more than 50 victims. Accordingly, the court vacated defendant's sentence and remanded to the district court for resentencing with a 2-level enhancement under U.S.S.G. 2B1.1(b)(2)(A) rather than a 4-level enhancement under U.S.S.G. 2B1.1(b)(2)(B). View "United States v. Rodriguez" on Justia Law

Petitioner filed a 28 U.S.C. 2254 petition for a writ of habeas corpus that challenged his convictions and death sentence on multiple grounds. At issue on appeal was whether trial counsel rendered ineffective assistance to petitioner in the penalty phase of his capital murder trial in allegedly failing to investigate and present mitigation evidence. The court affirmed the district court's denial of petitioner's section 2254 petition after considering the state court record, the evidentiary record in the district court, and the parties' submissions. View "Puiatti v. Secretary, FL Dept. of Corrections" on Justia Law

Defendant, convicted of interference with commerce by violence (Count 1) and using and carrying a firearm during and in retaliation of a crime of violence (Count 2), appealed his sentence of 209 months' imprisonment. The court concluded that there was no basis for it to conclude that an alleged Alleyne v. United States error seriously affected the fairness, integrity, or public reputation of judicial proceedings as to Count 2; the district court did not clearly err in imposing a two-level enhancement under U.S.S.G. 3C1.1 for obstruction of justice; and the district court did not abuse its discretion in imposing an above-guidelines sentence as to Count 1. Accordingly, the court affirmed the judgment of the district court. View "United States v. McKinley" on Justia Law

Defendant, convicted of four counts of distributing crack cocaine, appealed the district court's denial of his 18 U.S.C. 3582(c)(2) motion to reduce his sentence. The court held that a defendant subject to a statutory mandatory minimum was eligible for section 3582(c)(2) relief when he was sentenced above that minimum and a retroactive guidelines amendment lowers the high-end of his applicable guidelines range. In this instance, defendant was subject to a statutory mandatory minimum sentence of 120 months' imprisonment, but a retroactive amendment to the sentencing guidelines lowered his applicable guidelines range from 120 to 125 months' imprisonment to simply 120 months. The court vacated the district court's order and remanded because the district court erroneously concluded that it lacked the authority to consider defendant's motion. View "United States v. Hargrove" on Justia Law