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

Coats, then a convicted felon, was arrested after making several (recorded) controlled drug sales to a confidential informant (CI). Coats was housed at the Wilkinson County jail, where the CI was also in custody. Coats gained access to the CI and punched him. That incident resulted in additional state charges for battery and influencing a witness, to which he pleaded guilty.Coats then pled guilty as a felon in possession of a firearm, 18 U.S.C. 922(g)(1). The district court sentenced Coats to serve 235 months' imprisonment under the Armed Career Criminal Act (ACCA), which applies when a defendant who is convicted under section 922(g) has three prior convictions for a “serious drug offense” or a “violent felony.” Coats had a 2003 Georgia burglary conviction, which the court determined was a violent felony under ACCA. The court denied an acceptance-of-responsibility reduction to his sentencing range, citing his obstructive conduct preceding his guilty plea.The Eleventh Circuit affirmed. Any Rehaif error was nonprejudicial; Coats was not informed of section922(g)’s essential "knowledge" requirement, but he made no attempt to show that he would not have pled guilty but for that error. Of the 12 criminal convictions identified in his PSR, at least four were for felonies. Coats did not dispute the PSR’s description of his criminal history. The burglary conviction qualifies as an ACCA violent felony and the district court did not clearly err in refusing to award an acceptance-of-responsibility reduction. View "United States v. Coats" on Justia Law

Bradshaw was a designated pilot examiner for the Federal Aviation Administration (FAA), with the authority to issue an applicant an airman certificate, 49 U.S.C. 44703(a). In 2018, the FAA discovered that Bradshaw had certified a pilot applicant without conducting a complete flight test and terminated Bradshaw’s designation. A three-member FAA appeal panel affirmed.The Eleventh Circuit denied a petition for review. The FAA did not fall short of its own requirements and did not violate Bradshaw’s constitutional right to due process. FAA-designated pilot examiners do not have a property or liberty interest in their designation. Bradshaw’s other constitutional claim—that the FAA violated his right to equal protection because other categories of FAA designees are afforded a hearing before their designation can be terminated—was also without merit. View "Bradshaw v. Federal Aviation Administration" on Justia Law

Plaintiff and two of his children filed a 30-count pro se complaint in federal district court asserting a wide variety of constitutional, statutory, and tort claims against 18 named defendants. The district court dismissed the entire complaint on Rooker-Feldman grounds.The Eleventh Circuit vacated the district court's dismissal of the complaint, concluding that the court's own review of the complaint shows that several of the claims plaintiffs raised do not fall within that doctrine's narrow bounds. The court clarified that Rooker-Feldman is a limited doctrine that applies only when litigants try to appeal state court losses in the lower federal courts. In this case, the district court erred by dismissing plaintiffs' complaint in one fell swoop without considering whether each individual claim sought "review and rejection" of a state court judgment. The court also concluded that the Rooker-Feldman doctrine does not apply to three federal claims plaintiffs raised before this court, seeking damages for issues collateral to a state court judgment rather than relief from that judgment itself. Accordingly, the court remanded for further proceedings. View "Behr v. Campbell" on Justia Law

Plaintiffs, owners and operators of greyhound-racing businesses, filed suit against the Florida Attorney General, seeking a declaration that a newly enacted state law prohibiting gambling on greyhound racing is unlawful and an injunction to prevent her from enforcing it. The district court dismissed the complaint without prejudice based on lack of standing.The Eleventh Circuit affirmed the district court's dismissal of the complaint, holding that plaintiff's alleged injuries are not traceable to any conduct of the Attorney General—either in enforcing or threatening to enforce the law or otherwise—and that plaintiffs' injuries would not be redressable by relief from this court. Therefore, plaintiffs lack Article III standing to bring their claims against the Florida Attorney General. View "Support Working Animals, Inc. v. Governor of Florida" on Justia Law

The Eleventh Circuit granted the petition for panel rehearing, withdrew its prior opinion, and issued the following opinion.The court concluded that the ALJ gave little or no weight to three pieces of evidence in the record indicating that plaintiff's mental illness prevents him from maintaining a job: (1) the opinions of plaintiff's treating psychiatrist, (2) the opinions of a consulting psychologist who examined plaintiff at the request of the SSA, and (3) plaintiff's own testimony as to the severity of his symptoms. In this case, the ALJ did not articulate adequate reasons for discounting this evidence, which provided support for a finding of disability. Accordingly, the court reversed and remanded to the agency for further proceedings. View "Simon v. Commissioner, Social Security Administration" on Justia Law

Defendant appealed her conviction for conspiring to distribute and distributing controlled substances, in violation of 21 U.S.C. 846, 841, and conspiring to commit and committing health care fraud, in violation of 18 U.S.C. 1349, 1347. Defendant's conviction stemmed from a large governmental investigation of a pill mill. The district court sentenced defendant to 120 months in prison for each count, to run concurrently.The Eleventh Circuit reversed defendant's conviction for health care fraud under Count 24 where the government concedes, and the court agrees, that the evidence was insufficient to support the conviction. The court explained that Indian Nat Insurance—an entity not named in the indictment—was billed for the prescriptions pertaining to this count. The court affirmed the remainder of defendant's convictions and the district court's evidentiary rulings. Finally, in regards to the contested jury instruction, the court found no plain error affected defendant's substantial rights. The court remanded for further proceedings. View "United States v. Akwuba" on Justia Law

To root out police corruption in Miami, the FBI created a reverse sting operation, having agents pose as would-be drug dealers. Officer Anderson became the subject of the investigation and eventually agreed to act as a cooperating witness, wearing a recording device. Anderson identified Officer Harris as having corruptly engaged in misconduct. At the FBI’s direction, Anderson set up the “protection” operation, during which officers Harris and Archibald protected “drug couriers” as they delivered containers purportedly filled with cocaine to hotels. Both were convicted of conspiracy to possess with intent to distribute cocaine, attempted possession with intent to distribute cocaine, and possession of a firearm in furtherance of a drug trafficking crime.The Eleventh Circuit affirmed, finding the evidence sufficient to support their convictions. With respect to an entrapment defense, the evidence was sufficient for a reasonable jury to find beyond a reasonable doubt that the defendant was predisposed to take part in the charged crimes. Archibald was not entitled to a duress instruction. The court rejected claims of perjury and government misconduct with respect to grand jury proceedings. The defendants failed to establish that the prosecutor struck an African American juror because of race, in violation of “Batson.” The district court did not err by not providing the jury with a read-back of Archibald’s testimony. View "United States v. Harris" on Justia Law

EWC, which runs a nationwide beauty brand European Wax Center and holds the trademark "European Wax Center," filed suit under the Anti-Cybersquatting Consumer Protection Act (ACPA), against defendant, who used GoDaddy.com to register the domain names "europawaxcenter.com" and "euwaxcenter.com." EWC alleged that defendant registered his domain names with a bad faith intent to profit from their confusing similarity to EWC's "European Wax Center" mark.The Eleventh Circuit affirmed the district court's grant of summary judgment in favor of EWC, concluding that no reasonable juror could conclude that "europawaxcenter" and "euwaxcenter" are not confusingly similar to "European Wax Center" -- they are nearly identical to the mark in sight, sound, and meaning. View "Boigris v. EWC P&T, LLC" on Justia Law

At issue in this case are the terms of a recorded easement that runs with two beachfront lots in Walton County, Florida. After the County enacted an ordinance purporting to establish the public's right to use the dry-sand area of all beaches for recreational purposes, two beachfront property owners filed suit alleging that the ordinance triggered the easement's abandonment clause.The Eleventh Circuit reversed the district court's grant of summary judgment in favor of the County, holding that the ordinance triggered the abandonment clause and that no other source of law—Florida common law, separate provisions in the easement, a Walton County resolution, or a consent judgment—forestalls or limits the abandonment clause's operation. Accordingly, the court remanded for further proceedings. View "A Flock of Seagirls LLC v. Walton County Florida" on Justia Law

The Eleventh Circuit affirmed the district court's denial of defendant's motion to clarify, modify, and terminate early his term of supervised release. The court also affirmed a July 2017 sealed order, which required him to disclose details about work he performs as part of the security company he owns and operates and to inform prospective clients of his sex offender status. Defendant is serving his supervised release term of ten years as part of his sentence for accessing with intent to view child pornography.The court concluded that the district court did not add an occupational restriction or otherwise modify the conditions of defendant's supervised release when it entered the July 2017 sealed order, and therefore no evidentiary hearing was required and the district court was not required to address the U.S.S.G. 5F1.5 factors. The court also concluded that the district court did not abuse its discretion in denying defendant's motion to modify the conditions of his supervised release which sought the elimination of the internet restriction. As with the motion to modify, the record establishes that the district court considered the relevant 18 U.S.C. 3553(a) factors and did not abuse its discretion in denying summarily the motion for early termination. View "United States v. Cordero" on Justia Law