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

In consolidated criminal appeals, the Eleventh Circuit held that a conviction for Hobbs Act robbery does not qualify as a "crime of violence" under the Sentencing Guidelines, U.S.S.G. 4B1.2(a). The court agreed with its sister circuits and defendants, holding that because the offense can be committed by a threat to person or property, the statute is too broad to qualify as a crime of violence either under the elements clause or as an enumerated robbery or extortion offense. Therefore, Hobbs Act robbery cannot serve as a predicate for a career offender sentencing enhancement. Accordingly, the court vacated each defendant's sentence and remanded for further proceedings. View "United States v. Eason" on Justia Law

The Eleventh Circuit affirmed defendants' sentence for defrauding hundreds of undocumented aliens into paying about $740,000 for falsified federal immigration forms. The court held that the district court committed no plain error in holding defendant jointly and severally liable for repaying the proceeds of their illegal conduct. In this case, defendants failed to establish that they did not mutually obtain, possess, and benefit from their criminal proceeds. The court also held that defendants' sentences were not procedurally unreasonable and that the Sentencing Guidelines direct that they be sentenced for fraud and deceit. The court wrote that United States v. Baldwin, 774 F.3d 711, 733 (11th Cir. 2014), was controlling here. In Baldwin, the court upheld the district court's application of USSG 2B1.1 on facts comparable to those in this case. View "United States v. Pazos Cingari" on Justia Law

Plaintiffs and 229 former workers at the Grede Foundry filed suit against ten entities that manufactured, sold, supplied, and distributed the products they believe harmed them. After defendants removed the case to federal court, the district court granted plaintiffs' motion to remand to state court. The Eleventh Circuit vacated the district court's grant of plaintiffs' motion to remand, holding that the local event exception to the Class Action Fairness Act's grant of federal jurisdiction applies to any continuing set of circumstances in a single location, regardless of when and how the harm came about. The court held that "an event or occurrence" refers to a series of connected, harm-causing incidents that culminate in one event or occurrence giving rise to plaintiffs' claims. In this case, the complaint does not allege a continuous, related course of conduct culminating in one harm-causing event or occurrence, and thus it does not fall within the local event exception. Accordingly, the court remanded for further proceedings. View "Spencer v. Specialty Foundry Products Inc." on Justia Law

Plaintiff, an inmate who was diagnosed with gender dysphoria, filed a 42 U.S.C. 1983 action alleging violations of her Eighth Amendment rights, and seeking declaratory and injunctive relief. The Eleventh Circuit held that plaintiff's challenges to the prior freeze-frame policy and the FDC's initial denial of hormone therapy are moot in light of the FDC's subsequent repeal and replacement of the policy and its provision of hormone treatment. The court rejected the merits of plaintiff's claim that the FDC violated the Eighth Amendment by refusing to accommodate her social-transitioning requests (to grow out her hair, use makeup, and wear female undergarments). In light of the disagreement among the testifying professionals about the medical necessity of social transitioning to plaintiff's treatment and the "wide-ranging deference" that the court pays to prison administrators' determinations about institutional safety and security, the court could not say that the FDC consciously disregarded a risk of serious harm by conduct that was "more than mere negligence" and thereby violated the Eighth Amendment. Rather, the court concluded that the FDC chose a meaningful course of treatment to address plaintiff's gender-dysphoria symptoms, which was sufficient to clear the low deliberate-indifference bar. Accordingly, the court vacated the district court's order, dismissed as moot in part, and reversed in part. View "Keohane v. Florida Department of Corrections Secretary" on Justia Law

The Eleventh Circuit affirmed the denial of the Chapter 7 Trustee's request to use his powers under the bankruptcy code to avoid Wells Fargo's security interest in debtor's real property. The court rejected the Trustee's argument that, under Georgia law, security deeds in land were required to be attested at least by two witnesses. Rather, the court stated that the deed (1) must be attested by or acknowledged before an officer and (2) must also be attested or acknowledged by one additional witness. The court explained that the use of the word "or" in "attested or acknowledged" plainly contemplates these two acts as alternative methods of authenticating a security deed. In this case, where the language of the statute is plain and unambiguous, the court stated that judicial construction was not only unnecessary but forbidden. Furthermore, this common-sense reading of the statute was reflected in Supreme Court of Georgia precedent. View "Gordon v. Wells Fargo Bank, NA" on Justia Law

Automotive body shops filed suit against major automobile insurance companies, alleging claims for relief under the Sherman Act and state law based on the insurance companies' alleged anticompetive practices. The Eleventh Circuit held that it lacked jurisdiction to decide the merits of the Indiana and Utah appeals because the orders dismissing the first amended complaints became final judgments under Hertz Corporation v. Alamo Rent-ACar, Incorporated, 16 F.3d 1126 (11th Cir. 1994), when the deadline to amend expired. However, the court held that it had jurisdiction to review the order dismissing the Mississippi body shops’ antitrust claims. The court also held that the district court correctly dismissed the antitrust claims; the district court did not abuse its discretion in denying the Mississippi body shops' motion to reconsider its dismissal of their antitrust claims; and the district court correctly dismissed most of the Mississippi body shops' claims under state law. Accordingly, the court vacated in part, affirmed in part, and remanded for further proceedings. View "Automotive Alignment & Body Service, Inc. v. State Farm Mutual Automobile Insurance Co." on Justia Law

The Eleventh Circuit denied petitioner's emergency motion for appointment of substitute counsel and for a limited stay. Petitioner was scheduled to be executed on March 5, 2020, for his capital murder convictions for intentionally killing three on-duty police officers. The court held that petitioner was not entitled to substitution of counsel, because he failed to establish that appointing new counsel is in the interest of justice. The court also held that petitioner was not entitled to a stay, because he failed to justify his extreme delay in filing this motion for a stay. View "Woods v. Warden, Holman Correctional Facility" on Justia Law

The Eleventh Circuit denied appellant's motion for a stay of execution. The court held that appellant was not entitled to a stay of execution for at least two reasons: first, equity weighs heavily against granting the motion because of its untimeliness and the State and the victims' interest in enforcement of criminal sentences; and second, appellant failed to establish a substantial likelihood of success on the merits of his procedural due process, equal protection clause, and Eighth Amendment claims. The court also held that when, as here, a district court dismisses a plaintiff's federal claims, the court has encouraged dismissal of the remaining state-law claims too. Therefore, the district court did not abuse its discretion and the court denied appellant's motion for a stay of execution. The court granted appellant's motion for excess words. View "Woods v. Commissioner, Alabama Department of Corrections" on Justia Law

Federal Rule of Civil Procedure 41(d) does not apply when a plaintiff, after dismissing the first federal action, files a subsequent action in state court. In this case, after voluntarily dismissing his federal action, plaintiff filed a second action in state court against defendant based on or including the same claim. The Eleventh Circuit held that the district court correctly determined that defendant was not entitled to costs under Rule 41(d) because plaintiff filed the second action against him in state court. View "Sargeant v. Hall" on Justia Law

Plaintiffs, current and former alien detainees, filed a class action under the Trafficking Victims Protection Act (TVPA) and Georgia law, alleging that CoreCivic, a private contractor which owns and operates the Stewart Detention Center, coerces alien detainees to perform labor at the detention center by, inter alia, the use or threatened use of serious harm, criminal prosecution, solitary confinement, and the withholding of basic necessities. The Eleventh Circuit affirmed the district court's denial of CoreCivic's motion to dismiss the complaint and held that the TVPA applies to private for-profit contractors operating federal immigration detention facilities. Specifically, the court held that, under the plain language of the statute, the TVPA covers the conduct of private contractors operating federal immigration detention facilities; the TVPA does not bar private contractors from operating the sort of voluntary work programs generally authorized under federal law for aliens held in immigration detention facilities; but private contractors that operate such work programs are not categorically excluded from the TVPA and may be liable if they knowingly obtain or procure the labor or services of a program participant through the illegal coercive means explicitly listed in the TVPA. View "Barrientos v. CoreCivic, Inc." on Justia Law