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

Defendant appealed the district court's denial of its motion for judgment as a matter of law, or in the alternative, motion for a new trial or remittitur. In this Fair Credit Reporting Act (FCRA), the Eleventh Circuit affirmed the district court's denial of defendant's motion for judgment as a matter of law to the extent it challenged the reputational harm claim and the willfulness claim.However, the court vacated the jury's punitive damages award and remanded the case to the district court to enter a judgment awarding plaintiff $1 million in punitive damages. The court held that, although punitive damages were properly awarded, a $3.3 million dollar award was unconstitutionally excessive. View "Williams v. First Advantage Background Services Corp." on Justia Law

The Eleventh Circuit affirmed defendant's convictions for procuring naturalization unlawfully, in violation of 18 U.S.C. 1425(a), and misuse of evidence of an unlawfully issued certificate of naturalization, in violation of 18 U.S.C. 1423.The court held that the annotated Form N-400 was (1) admissible non-hearsay as an adopted admission of a party-opponent under Federal Rule of Evidence 801, and, (2) alternatively, was properly admitted under the public record hearsay exception in Federal Rule of Evidence 803. Furthermore, the officer's red marks in the annotated Form N-400 Application was not testimonial and did not violate the Confrontation Clause. The court also held that the district court did not abuse its discretion by admitting defendant's post-Miranda statement, and the evidence was sufficient to sustain defendant's conviction as to Count 1. View "United States v. Santos" on Justia Law

The Eleventh Circuit affirmed the district court's dismissal of a juror after the juror stated that the Holy Spirit had "told" him to return a certain verdict irrespective of what the evidence showed. The court found no abuse of discretion in the district court's decision to question Juror 13.The court held that the district court did not clearly err when it found that Juror 13 was not capable of returning a verdict based on the evidence adduced at trial, and the district court did not abuse its discretion in dismissing Juror 13 after finding that he was not capable of reaching a verdict based on the evidence.The court also held that Rule 606(b) of the Federal Rules of Evidence did not apply to the court's inquiry into Juror 13's statement. The court rejected defendant's claim that the district court violated the Religious Freedom Restoration Act, the First Amendment, and the Sixth Amendment by excusing Juror 13. Finally, the court held that the district court did not plainly err in issuing the forfeiture order. View "United States v. Brown" on Justia Law

Plaintiff filed suit alleging that, during a purported disciplinary encounter with Defendant Lockhart, he pulled down plaintiff's pants and forcefully penetrated plaintiff's anus with his finger. The district court relied on Boxer X v. Harris, 437 F.3d 1107 (11th Cir. 2006), to dismiss plaintiff's claims.The Eleventh Circuit held that the district court improperly resolved material issues of fact—two relating to the sexual-assault claim and two to the takedown and pepper-spray claims. The court held that, although Boxer X's holding that "severe or repetitive sexual abuse of a prisoner by a prison official can violate the Eighth Amendment," remains good law, Wilkins v. Gaddy, 559 U.S. 34, 37 (2010), clarified that courts cannot find excessive force claims not "actionable" because the prisoner did not suffer "more than de minimis injury." Therefore, Wilkins partly abrogated Boxer X. In this case, the court held that plaintiff presented sufficient evidence on summary judgment to establish both parts of a post-Wilkins Eighth Amendment claim. Accordingly, the court vacated the portion of the district court's judgment granting summary judgment to Lockhart; affirmed in part, and remanded. View "Sconiers v. FNU Lockhart" on Justia Law

The Eleventh Circuit published this opinion in place of its previous opinion, which was vacated by order of the court.The court affirmed the district court's dismissal of a 28 U.S.C. 2254 petition for habeas relief, holding that a district court may, on its own initiative and without hearing from the State, decide that the statute of limitations bars the petition. In this case, petitioner was provided ample notice and opportunity to explain why his petition was timely in his form petition and again when he was given the opportunity to respond to the magistrate judge's Report and Recommendation that his petition be summarily dismissed as untimely. Furthermore, the Secretary was notified of the court's action, had an opportunity to respond, and remained silent. No one contests that the petition was untimely and the State has never indicated a desire to waive the limitations bar. Therefore, the district court did not abuse its discretion in dismissing the petition. View "Paez v. Secretary, Florida Department of Corrections" on Justia Law

This case involved the enforcement of a judgment CFTC obtained against defendant which, among other things, ordered defendant to pay $1,543,892 within 10 days in restitution to the investors who fell victim to his commodity-fraud scheme.The Eleventh Circuit vacated the district court's contempt adjudication and its modification of the restitution provisions of its judgment, holding that those provisions constitute a money judgment enforceable under the Federal Debt Collection Procedures Act, but not by the district court's civil contempt power. Therefore, the court need not consider defendant's arguments that the district court erred in considering exempt assets or defendant's wife's income in its determination of defendant's ability to pay. View "U.S. Commodity Futures Trading Commissioner v. Escobio" on Justia Law

The Eleventh Circuit reversed defendant's sentence imposed after he pleaded guilty to possessing a firearm and ammunition as a convicted felon. The court held that defendant's prior Georgia conviction for making terroristic threats under O.C.G.A. 16-11-37(a) (2010), is not a predicate violent felony under the elements clause of the Armed Career Criminal Act. The court held that because section 16-11-37(a) is indivisible and overbroad under Mathis v. United States, 136 S. Ct. 2243, 2249 (2016), a violation of that statute categorically does not constitute a predicate offense under the elements clause. Accordingly, the court remanded for resentencing. View "United States v. Oliver" on Justia Law

Plaintiff filed suit under the False Claims Act (FCA) and Georgia law, alleging that the county had engaged in a fraudulent scheme related to billing for ambulance services and had fired him in retaliation for his whistleblowing. On appeal, plaintiff challenged the district court's grant of summary judgment to the county on the FCA claim. The district court concluded that although plaintiff had engaged in "protected conduct" he had not created a genuine issue of material fact that he had been fired because of that conduct.The Eleventh Circuit held that the but-for causation standard applies to claims under the antiretaliation provision of the FCA just as it does to the antiretaliation provision of Title VII and the antidiscrimination provision of the Age Discrimination in Employment Act. The court declined to apply the motivating factor standard of causation to the FCA, explaining that it did not want to use legislative history to get around the plain meaning of a statute's text. In this case, plaintiff failed to show that the harm would not have occurred but for his protected conduct. View "Nesbitt v. Candler County, Georgia" on Justia Law

The Eleventh Circuit affirmed the district court's revocation of defendant's supervised release after defendant was arrested while on supervised release for unlawful possession of marijuana in the first degree, certain persons forbidden to possess a firearm, and possession of drug paraphernalia. At issue was whether the evidence seized during defendant's arrest should have been suppressed during his revocation of supervised release proceedings.The court held that neither this court nor the Supreme Court has held that the exclusionary rule applies in that context. Furthermore, defendant failed to offer anything to indicate why, in light of the Supreme Court's holding in the state parole revocation context, the exclusionary rule should apply to the supervised release revocation proceedings at issue here. View "United States v. Hill" on Justia Law

Plaintiff and the Association filed suit under Title II of the Americans with Disabilities Act and Section 504 of the Rehabilitation Act against several Florida entities and officials, challenging defendants' failure to provide captioning for live and archived videos of Florida legislative proceedings.The Eleventh Circuit affirmed the district court's ruling that Congress validly abrogated defendants' Eleventh Amendment immunity for the claims under Title II regardless of whether the right is "fundamental." The court agreed with the district court's holding that Congress validly abrogated defendants' Eleventh Amendment immunity because a fundamental right was at stake and, in the alternative, Congress validly abrogated defendants' Eleventh Amendment immunity even if a fundamental right was not at stake. Furthermore, Congress's identification of discrimination in public services and voting establishes the necessary history of discrimination for the rights implicated here: access to public legislative information relevant to voting, and Title II is an appropriate response to this history and pattern of unequal treatment.The court also affirmed the district court's holding that plaintiffs were entitled to pursue declaratory and injunctive relief against state officials under the doctrine of Ex parte Young for allegedly ongoing violations of Title II. Finally, the court held that the district court did not abuse is discretion in ordering discovery prior to resolving the question of sovereign immunity. View "National Association of the Deaf v. Florida" on Justia Law