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

The Eleventh Circuit affirmed the district court's denial of habeas relief to petitioner under 28 U.S.C. 2254. Petitioner was sentenced to death for three murders and two attempted murders of two young children. Petitioner alleged that trial counsel were constitutionally ineffective at sentencing because they relied on residual doubt and because they failed to investigate and present additional mitigating evidence concerning petitioner's childhood, substance abuse, and cognitive deficits.The court held that counsels' performance was not constitutionally deficient. Furthermore, the state court's determination that petitioner suffered no prejudice on account of any alleged deficiencies in the performance of his counsel was neither contrary to nor an unreasonable application of clearly established law, nor was it based on an unreasonable determination of the facts in light of the evidence presented. View "Franks v. GDCP Warden" on Justia Law

The Eleventh Circuit affirmed the district court's denial of petitioner's motion to postpone his execution by several months on the ground that two of his three appointed lawyers are currently unable to meet with him due to circumstances caused by COVID-19. The court held that neither it nor the district court has the authority to postpone petitioner's execution—at least absent a demonstration that a stay is warranted, a showing that petitioner has not attempted to make.Moreover, and in any event, the court held that petitioner is not entitled to relief on the merits where 18 U.S.C. 3596(a), which states that execution shall be implemented in the manner prescribed by the law of the State in which the sentence is imposed, does not extend to ensuring a lawyer's presence at execution. View "LeCroy v. United States" on Justia Law

The Eleventh Circuit granted the government's motion to dismiss defendant's appeal based on his sentence-appeal waiver. The court held that the sentence-appeal waiver is unambiguous and was made knowingly and voluntarily. In this case, when defendant decided to plead guilty and enter into a plea agreement, he waived any right to an appeal or other collateral review of his sentence unless the district court imposes a sentence that exceeds the advisory guideline range, which it did not. Furthermore, the Federal Rule of Criminal Procedure 11 colloquy established that defendant's appeal waiver was knowing and voluntary. View "United States v. Boyd" on Justia Law

The Eleventh Circuit affirmed the district court's denial of federal habeas corpus relief. Petitioner was sentenced to death for malice murder, felony murder, aggravated battery, aggravated sodomy, kidnapping with bodily injury, and aggravated assault.The court held that petitioner is not entitled to habeas relief based on the prosecution's use of peremptory strikes where the Georgia Supreme Court correctly applied the well-established burden-shifting framework, noting that the statistical disparities to which petitioner pointed were insufficient to establish a prima facie case absent "additional facts which may give rise to an inference of discriminatory purpose." The court rejected petitioner's claim of ineffective assistance of counsel during the penalty phase of trial and declined to disturb the state habeas court's conclusion that trial counsel's performance was not deficient. The court also held that the district court did not err in denying petitioner's claim of juror misconduct where he failed to exhaust, and thus has procedurally defaulted, his only argument for overcoming the original procedural default. Finally, for similar reasons, the court affirmed the district court's denial of petitioner's request for an evidentiary hearing. View "Ledford v. Warden, Georgia Diagnostic Prison" on Justia Law

The Eleventh Circuit vacated the district court's order dismissing plaintiff's complaint of malicious prosecution under the Fourth Amendment against defendant, a police officer. In order to succeed on plaintiff's malicious prosecution claim, plaintiff must prove (1) that defendant violated his Fourth Amendment right to be free from seizures pursuant to legal process and (2) that the criminal proceedings against plaintiff terminated in his favor.The court agreed with defendant that the district court correctly incorporated the dismissal order into plaintiff's complaint, but the court disagreed with defendant's argument that plaintiff did not receive a favorable termination. Even though the court considered the dismissal order, the court must construe the order in the light most favorable to plaintiff and resolve all reasonable inferences in his favor. When placed in that light, the court concluded that the order does not eliminate every reasonable inference that plaintiff received a favorable termination. In this case, the court can reasonably infer that plaintiff did not admit to felony murder during the hearing. View "Luke v. Gulley" on Justia Law

After Charles Sowers died of lung cancer caused by smoking cigarettes, plaintiff filed suit against the manufacturer of the cigarettes, R.J. Reynolds, under Florida's wrongful death statute. A jury found the company liable for his death and awarded compensatory damages.The Eleventh Circuit found no merit in R.J. Reynolds' contentions that it was entitled to a new trial based on an evidentiary ruling and based on statements plaintiff's attorney made in closing. The court also held that plaintiff is entitled to a trial on the issue of whether she should receive punitive damages on the negligence and strict liability claims and, if so, how much. Furthermore, the new trial on punitive damages that plaintiff is entitled to will not open up the liability and compensatory damages judgment that she has already obtained in the first trial. In this case, the findings underlying the first jury's comparative fault verdict are concerned solely with determining the amount of compensatory damages that will be awarded, and those findings do not overlap with the punitive damages findings that the remand jury will be called on to make in the course of deciding whether to punish R.J. Reynolds and attempt to deter others from similar conduct.Finally, unless it is successful in getting the court's judgment vacated or reversed, R.J. Reynolds will have to pay plaintiff the compensatory damages award, plus any applicable interest, promptly after the court's mandate issues instead of delaying payment until after the trial on punitive damages and any resulting appeal from the judgment in that trial is completed. Accordingly, the court affirmed in part, reversed in part, and remanded with instructions. View "Sowers v. R.J. Reynolds Tobacco Co." on Justia Law

The people of Florida amended their state constitution to restore the voting rights of convicted felons. Before regaining the right to vote, felons must complete all the terms of their sentences, including imprisonment, probation, and payment of any fines, fees, costs, and restitution. Felons sued, challenging the requirement that they pay their fines, fees, costs, and restitution before regaining the right to vote. They alleged the requirement violated the Equal Protection Clause as applied to felons who cannot pay; imposed a tax on voting in violation of the Twenty-Fourth Amendment; was void for vagueness; and adopted requirements that make it difficult for them to determine whether they are eligible to vote. The district court permanently enjoined the condition's enforcement.The Eleventh Circuit reversed. States may restrict voting by felons in ways that would be impermissible for other citizens. Laws governing felon disenfranchisement and re-enfranchisement are generally subject to rational basis review; “reform may take one step at a time.” Florida has legitimate interests in disenfranchising convicted felons, even those who have completed their sentences, and in restoring felons to the electorate after justice has been done and they have been fully rehabilitated. Fines, which are paid to the government as punishment for a crime, and restitution, which compensates crime victims, are not taxes. Felons and law enforcement can readily discern exactly what conduct is prohibited: a felon may not vote or register to vote if he knows that he has failed to complete all terms of his criminal sentence. View "Jones v. Governor of Florida" on Justia Law

Plaintiff, a Georgia inmate at Baldwin State Prison, filed a pro se 42 U.S.C. 1983 complaint alleging, among other claims, that medical staff at the prison failed to give him proper medical treatment in violation of the Eighth Amendment. The district court dismissed plaintiff's claim based on his failure to exhaust administrative remedies.The Eleventh Circuit vacated and remanded for further proceedings on the availability of administrative remedies under Ross v. Blake, 136 S. Ct. 1850 (2016). Although the district court was correct to dismiss plaintiff's argument that his mental capacities made the grievance procedure unavailable, the court held that plaintiff's argument that misleading prison assistance caused his grievance errors should have been considered. In this case, plaintiff alleged and provided some evidence that he received misleading assistance in the prison grievance process. View "Geter v. Akunwanne" on Justia Law

The Eleventh Circuit affirmed the bankruptcy court's conclusion that debtors' 2001 tax liability was not dischargeable under 11 U.S.C. 523(a)(1)(C) because debtors "willfully attempted . . . to evade or defeat" that liability. The court found substantial evidence of attempted evasion and concluded that the bankruptcy court did not clearly err in finding that debtors acted willfully when they redirected their funds away from paying their debt and toward their personal luxuries. The court has held that excessive discretionary spending constitutes circumstantial evidence of willfulness. Furthermore, the bankruptcy court also inferred willfulness from debtor's exploitation of the offer-in-compromise process. View "Feshbach v. Department of Treasury Internal Revenue Service" on Justia Law

The Eleventh Circuit affirmed the district court's grant of summary judgment for Dish Networks in plaintiff's action for breach of contract and violations of the Fair Credit Reporting Act (FCRA). Plaintiff alleges that Dish negligently and willfully violated the FCRA by requesting and obtaining a consumer report from a consumer reporting agency after an identity thief fraudulently submitted some of plaintiff's personal information to Dish. Plaintiff also alleges that Dish's actions violated a settlement agreement that the parties signed after a similar incident occurred several years ago involving the same parties.The court held that Dish had a "legitimate business purpose" under the FCRA when it obtained plaintiff's consumer report. The court also held that Dish did not violate the settlement agreement where the district court correctly found that plaintiff's claim failed to establish the breach element. View "Domante v. Dish Networks, LLC" on Justia Law