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

The Eleventh Circuit vacated the district court's order affirming the denial of plaintiff's application for benefits under the Social Security Act. The court agreed with plaintiff that substantial evidence does not support the ALJ's finding that plaintiff could perform a job that exists in significant numbers in the national economy. The court held that the vocational expert's testimony as to available jobs, on which the ALJ relied, was significantly and admittedly flawed.In this case, the vocational expert used the wrong Standard Occupational Classification (SOC) group code to determine whether there are a significant number of jobs in the national economy that plaintiff could perform. Furthermore, even if the court overlooked this foundational problem, the numbers that the vocational expert cited from the wrong SOC group code substantially overstated the number of available bakery worker jobs that plaintiff could perform. Accordingly, the court remanded for further proceedings. View "Goode v. Commissioner of Social Security" on Justia Law

The Eleventh Circuit affirmed the district court's grant of summary judgment to defendant on plaintiff's Eighth Amendment failure-to-protect claim. In this case, plaintiff, a prisoner, told defendant, a prison official, that another prisoner threatened to kill him.The court held that the reasonableness of a prison official's response to a substantial risk of serious harm depends on the facts the official knew when she learned about the threat. The court explained that sometimes, the facts are so serious and clear that anything less than immediate protective custody for the threatened prisoner would be unreasonable. More often, as here, the court explained that the prison official responds reasonably by taking the time to investigate the threat and look into different options all while making sure the prisoners are being supervised.The court agreed with the district court that, viewing the summary judgment evidence in the light most favorable to plaintiff, defendant reasonably responded to the other prisoner's threat (even if the harm was ultimately not averted). In this case, defendant was available to talk to plaintiff about the threat and told him she had his back, would investigate the threat, and look into moving the other prisoner. Furthermore, her response was reasonable in light of what she knew about plaintiff and the other inmate, the history of their dispute, and the fact that both plaintiff and the other prisoner were in the "good behavior dorm." View "Mosley v. Zachery" on Justia Law

The Eleventh Circuit affirmed the district court's denial of petitioner's 28 U.S.C. 2255 motion seeking to vacate his sentence. In this case, the parties do not dispute that counsels' performance was deficient because of their failure to communicate petitioner's potential total sentence and the application of the sentencing guidelines, failure to seek a negotiated plea, and failure to relay to petitioner the plea offers discussed. However, the court held that petitioner failed to show that, but for counsels' deficient performance, the results of his criminal proceedings would be different. Therefore, petitioner failed to satisfy the second prong of the Strickland analysis by establishing prejudice. View "Carmichael v. United States" on Justia Law

The Eleventh Circuit affirmed defendant's 480 month sentence for receipt of child pornography. The court held that the district court did not err in concluding that there was sufficient indicia of reliability for the hearsay evidence at issue; the district court's above-guidelines sentence fit comfortably under 18 U.S.C. 3553(a) provisions; and defendant's sentence was not substantively unreasonable in light of defendant's repeated acts of sexual abuse of children over a period of at least two decades. View "United States v. Hall" on Justia Law

In 2015, plaintiffs filed suit challenging Alabama's 2011 Photo Voter Identification Law passed by the Alabama legislature as House Bill 19 and codified at Ala. Code 17-9-30. The voter ID law took effect in June 2014 and requires all Alabama voters to present a photo ID when casting in-person or absentee votes. Plaintiffs sought declaratory and injunctive relief, alleging that the law has a racially discriminatory purpose and effect that violates the United States Constitution and the Voting Rights Act (VRA).The Eleventh Circuit affirmed the district court's grant of summary judgment in favor of the Secretary, holding that plaintiffs failed to identify any genuine disputes of material facts and no reasonable factfinder could find, based on the evidence presented, that Alabama's voter ID law is discriminatory. The court held that the burden of providing a photo ID pursuant to Ala. Code 17-9-30 in order to vote is a minimal burden on Alabama's voters—especially when Alabama accepts so many different forms of photo ID and makes acquiring one simple and free for voters who lack a valid ID but wish to obtain one. Therefore, the Alabama voter ID law does not violate the Fourteenth and Fifteenth Amendments of the Constitution, nor does it violate the Voting Rights Act. View "Greater Birmingham Ministries v. Secretary of State for the State of Alabama" on Justia Law

The Eleventh Circuit vacated the district court's entry of a bar order barring appellants' claims against the settling appellees based on its conclusion that the bar order was essential to appellees' settlement because the order was essential to facilitating all settlement payments. The court held that the district court abused its discretion in entering the order, because a bar order was not essential to resolving the parties' dispute. In this case, the settling parties would have settled their dispute even without the bar order. View "Securities and Exchange Commission v. Quiros" on Justia Law

Plaintiffs filed suit challenging a city ordinance and resolution subjecting alarm companies to a series of fines when a false alarm is sounded at one of the properties which they service. The district court dismissed the substantive and procedural due process claims.The court held that the ordinance and resolution at issue easily survive rational basis scrutiny where imposing a fine on the alarm companies is rationally related to the City's strong interests in reducing the number of false alarms that heavily burden its police and fire departments and waste public resources. The court also held that plaintiffs lack standing to pursue their procedural due process claim as nonjusticiable where there is no cognizable injury for standing purposes when a party fails to attempt an appeal and instead merely points to some procedural elements within a regulation, without alleging how those features injured them or even might potentially cause them some concrete harm. View "The Georgia Electronic Life Safety & System Assoc. v. The City of Sandy Springs" on Justia Law

The Eleventh Circuit affirmed defendant's conviction for attempted online enticement of a minor and six counts of attempted transfer of obscene matter to a minor. The court held that the district court did not err in denying defendant's motion to suppress statements he made while questioned in his house because he was not in custody at the time; the evidence was sufficient to convict defendant of count 7, the attempted transfer of obscene matter to a minor; and the court rejected defendant's contention that the six counts were flawed because they did not specify which of the 67 images and which of the three videos he sent were obscene. The court rejected defendant's remaining contentions. View "United States v. Deason" on Justia Law

In this multidistrict litigation (MDL), plaintiffs contend that a Colombian paramilitary group killed their family members, and that Chiquita paid the paramilitary group over $1.7 million to quell labor unrest and drive other guerilla groups out of the banana-growing regions of Colombia. All plaintiffs obtained a protective order prohibiting the disclosure of "private facts" that could reveal their identities or personal information.The Eleventh Circuit affirmed the district court's decision to revoke the privacy protections, holding that the district court acted within its discretion when it held that plaintiffs failed to meet their necessary burdens. In this case, the district court had ample comparator evidence to support its ruling; the evidence does not compel the finding that litigants pursuing tort claims against a paramilitary-affiliated entity in the United States face similar risks of harm; and the court rejected the idea that the district court's pseudonym ruling conflicts with its forum non conveniens ruling. Furthermore, the district court engaged in balancing sufficient to satisfy Federal Rule of Civil Procedure 26(c), where it weighed plaintiffs' safety interests against Chiquita's interests in administrative feasibility. View "Carrizosa v. Chiquita Brands International, Inc." on Justia Law

Plaintiffs, Charles and Myra Corley, filed suit in state court against dozens of companies that allegedly supplied products containing asbestos that caused Charles's malignant mesothelioma. After removal to federal court, the Judicial Panel on Multidistrict Litigation then transferred the suit to the Eastern District of Pennsylvania, which eventually returned it to the Northern District of Alabama. After the Northern District of Alabama granted plaintiffs' motion to voluntarily dismiss the last two companies in the suit, plaintiffs then sought review of an order entered by the Eastern District of Pennsylvania denying their motion to reconsider a partial summary judgment in favor of several companies. In the motion, plaintiffs argued for the first time that the district court should apply maritime law, not state law, to determine the merits of their claims.The Eleventh Circuit held that an order granting a voluntary dismissal without prejudice is a final order; the court has territorial jurisdiction to review an interlocutory decision by an out-of-circuit district court that merged into the final judgment of a district court in this circuit; and plaintiffs have standing to appeal from the final judgment accompanying an order granting the motion for a voluntary dismissal. Finally, the court affirmed the judgment against plaintiffs, holding that the district court did not abuse its discretion by refusing to allow plaintiffs to argue that a different substantive law governed their complaint at this late stage in the litigation. View "Corley v. Long-Lewis, Inc." on Justia Law