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

Mannington Mills, Inc. appealed the grant of summary judgment in favor of Home Legend, LLC, that Mannington’s registered copyright in its “Glazed Maple” design was invalid. Mannington and Home Legend both sold laminate wood flooring. The copyright at issue in this case covers Mannington’s decor paper design called “Glazed Maple,” which is a huge digital photograph depicting fifteen stained and apparently time-worn maple planks. That appearance was only an appearance. In 2008, three Mannington employees created the Glazed Maple design not from aged planks but from raw wood. The team did not seek out an actual aged wood floor from which to create the design but instead “envision[ed what] a floor could look like after” twenty or thirty years, including the effects “age and wear and patina” might have on the planks. The United States Register of Copyrights registered Mannington’s copyright in its Glazed Maple design in November 2010. In September 2012, Mannington discovered that its competitor Home Legend was selling laminate flooring products with designs that it alleges were “virtually identical in every respect” to the Glazed Maple design. Mannington requested that Home Legend stop selling the allegedly infringing products. Home Legend responded by filing suit in the district court, seeking a declaratory judgment that Mannington’s copyright was invalid. Mannington counterclaimed for copyright infringement and moved for a preliminary injunction, a motion that the district court denied. At the close of discovery, Home Legend moved for summary judgment, arguing that Mannington’s registered Glazed Maple copyright did not cover copyright-eligible subject matter. The district court granted summary judgment to Home Legend on three alternative grounds. The Eleventh Circuit reversed, finding: Mannington owned a valid copyright, "even if the protection that copyright affords it is not particularly strong." Because much of the expression in Mannington’s finished Glazed Maple design still reflected the uncopyrightable features of each plank, Mannington’s copyright gives it the limited protection of a derivative work. View "Home Legend, LLC v. Mannington Mills, Inc." on Justia Law

Robert Preston appealed the district court’s denial of his federal habeas petition. A jury convicted Preston of premeditated murder for the 1978 killing of Earline Walker and recommended that he be sentenced to death. Nearly thirty years later, Preston filed a habeas petition in federal district court, raising twenty-eight claims. The district court denied habeas relief on all of them. The Eleventh Circuit granted a certificate of appealability on one claim, which alleged that the state failed to present sufficient evidence of premeditation at trial, and that Preston’s conviction, therefore, violated his due process rights. After thorough review, the Eleventh Circuit found no violation, and affirmed the district court’s denial of habeas relief. View "Preston v. Secretary, Florida Dept. of Corrections" on Justia Law

The Valones were Florida residents who filed jointly for bankruptcy under Chapter 13 of the Bankruptcy Code. In their petition, they claimed exemptions for personal property (known as the "wildcard" exemption). The issue this case presented for the Eleventh Circuit's review centered on a district court order affirming a bankruptcy court’s disallowance of an exemption claimed by the Valones in their bankruptcy petition. The Chapter 13 trustee, Jon Waage, objected to their personal property exemption, arguing that, as homeowners filing under Chapter 13 of the Bankruptcy Code, the Valones were ineligible for the exemption. The bankruptcy and district courts agreed. The Eleventh Circuit reversed the district court and remanded with instructions to remand to the bankruptcy court for further proceedings. View "Valone v. Waage" on Justia Law

Defendant Cora Cadia Ford owned and managed a tax preparation business. Through that business, she operated a complex fraud scheme over a period of many years, acquiring personal information under false pretenses, often from victims who were homeless or mentally or physically disabled, and then using that information to file false tax returns and pocket the resulting refunds. She appealed her conviction and sentence on ten counts each of mail fraud, making a false claim, and aggravated identity theft. After careful consideration of all of defendant's alleged errors at the trial court level, the Tenth Circuit affirmed her conviction and sentence. View "United States v. Ford" on Justia Law

The issue in this case arose from alleged anticompetitive conduct in the ductile iron pipe fittings ("DIPF") market by McWane, Inc., a family-run company headquartered in Birmingham, Alabama. In 2009, following the passage of federal legislation that provided a large infusion of money for waterworks projects that required domestic pipe fittings, Star Pipe Products entered the domestic fittings market. In response, McWane, the dominant producer of domestic pipe fittings, announced to its distributors that (with limited exceptions) unless they bought all of their domestic fittings from McWane, they would lose their rebates and be cut off from purchases for 12 weeks. The Federal Trade Commission ("FTC") investigated and brought an enforcement action under Section 5 of the Federal Trade Commission Act, 15 U.S.C. sec. 45. The Administrative Law Judge ("ALJ"), and a divided Commission, found that McWane's actions constituted an illegal exclusive dealing policy used to maintain McWane's monopoly power in the domestic fittings market. The Commission issued an order directing McWane to stop requiring exclusivity from distributors. McWane appealed, challenging nearly every aspect of the Commission's ruling. After thorough review, the Eleventh Circuit found the Commission's factual and economic conclusions were supported by substantial evidence in the record. Accordingly, the Court affirmed the Commission's ruling. View "McWane, Inc. v. Federal Trade Commission" on Justia Law

Dale Peters appealed a final order denying his request for transfer of Writ of Execution proceedings to California and a hearing by granting the government's Application for an Amended Writ of Execution, resulting from a restitution judgment entered against him. Peters was convicted of one count of conspiring to defraud the United States and thirty-one counts of filing false and fictitious claims on the United States in an extensive tax-fraud conspiracy. In early 2013, the district judge entered final judgment against Peters, which included 144 months of imprisonment and restitution of $5,362,039.69. The Eleventh Circuit affirmed his conviction and sentence. Later that year, the government filed an Application for Writ of Execution to levy on real property Peters owned in Sonora, California. His last known address was stated to be an apartment located in San Mateo. A deputy clerk entered a Writ of Execution on Peters' real property. Peters filed a Response to the Amended Application and Amended Writ of Execution, demanding a hearing and transfer of proceedings to the district, where he resided. Peters contended: (1) the property was exempt from levy, and (2) the restitution order was not final, because his criminal appeal was pending. The district judge concluded Peters' real property was not exempt from levy, because his restitution order had not been stayed. He found transfer of the Writ of Execution proceedings was not appropriate and granted the government's Amended Application for Writ of Execution. Peters appealed that final order. The Elevent Circuit reversed, finding the district judge erred in denying Peters' request to transfer his Amended Writ of Execution proceeding to California for a hearing. The final order granting the government's application for an Amended Writ of Execution after Peters' request for transfer was vacated, and the case remanded to the district judge to enter an order transferring Peters' Amended Writ of Execution proceeding to the California district court with jurisdiction for a hearing and decision. View "United States v. Peters" on Justia Law

Petitioner Drew Walker, a citizen of Jamaica, was admitted to the United States as a lawful permanent resident in 1990. In 2001, Walker pleaded no contest to three counts of uttering a forged instrument in Florida. One of the counts involved an amount over $10,000. In 2010, the Department of Homeland Security commenced removal proceedings against Walker. The Department alleged that Walker was removable because he committed a crime involving deceit or fraud in which the loss to the victim or victims exceeds $10,000. The Department later alleged that Walker was also removable because he had been convicted of multiple crimes involving moral turpitude, not arising out of a single scheme of criminal misconduct. Walker admitted his convictions but argued that they did not qualify as removable offenses. An immigration judge ruled that Walker was removable on both grounds. Walker appealed that decision to the Board of Immigration Appeals, which held that Walker’s convictions were aggravated felonies and crimes of moral turpitude. The Board dismissed Walker’s appeal. After its review, the Eleventh Circuit concluded that the offense of uttering a forged instrument necessarily involves an act of deceit. It was both an aggravated felony offense and a crime involving moral turpitude. The Court, therefore, denied Walker’s petition for review. View "Walker v. Holder" on Justia Law

Donald Creel pleaded guilty to receipt of child pornography, and received an enhanced sentence when the district court ruled that he "[d]istribut[ed]" child pornography through a file sharing program on his computer. The issue this case posed for the Eleventh Circuit's review centered on whether the definition of "[d]istribution" of child pornography under the Sentencing Guidelines, U.S.S.G. 2G2.2(b)(3)(F) (Nov. 2013), included an element of mens rea. Because distribution of child pornography did not require an offender to know that he made child pornography accessible to others, the Eleventh Circuit affirmed Creel’s sentence. View "United States v. Creel" on Justia Law

Petitioner Rachel Parks appealed an administrative law judge's denial of her application for supplemental security income on behalf of her minor son, D.P. D.P. suffered from attention deficit hyperactivity disorder and borderline intellectual functioning. An administrative law judge denied Parks’s application because D.P. did not suffer from a condition that entitled him to supplemental security income. Parks filed a request for review with the Appeals Council, and she submitted new evidence of D.P.’s academic struggles. The Appeals Council supplemented the record with the new evidence, but denied review. Parks then filed a complaint in the district court, which affirmed the denial of her application. She argued on appeal to the Eleventh Circuit: (1) the administrative law judge's denial of Parks's application was not supported by substantial evidence; and (2) the Social Security Appeals Council needed to make explicit findings of fact about new evidence that it added to the record when it denied review. Because the administrative law judge’s decision was supported by substantial evidence and the Appeals Council was not required to make specific findings about Parks’s new evidence, the Eleventh Circuit affirmed. View "Parks v. Commissioner, Social Security Administration" on Justia Law

The issues presented to the Eleventh Circuit in these consolidated appeals of Donald LaFond, Jr. and Jason Widdison, both convicted for second degree murder, was whether the district court abused its discretion in four rulings: (1) the admission of evidence of the defendants’ memberships in gangs; (2) an order that the jurors be identified anonymously; (3) a refusal to give two requested jury instructions about self-defense; and (4) an order that Widdison’s hands remain shackled during his sentencing hearing. Widdison and LaFond, both of whom were inmates in a federal prison, attacked Kenneth Mills, another inmate, who died a month later from his injuries. The government presented evidence that Widdison and LaFond were members of white supremacist gangs who attacked Mills, a white inmate, because he refused to take any action to have his black cellmate replaced. Widdison and LaFond responded that they acted in self-defense after Mills drew a knife to attack LaFond. A jury convicted Widdison and LaFond of second degree murder. Both Widdison and LaFond raised the issue about the admission of evidence of their gang memberships, and Widdison raised the other three issues. The Eleventh Circuit concluded, after review, that the district court did not abuse its discretion when it admitted evidence of the defendants’ memberships in gangs to prove motive or intent, when it ordered that the jurors be identified anonymously to protect their safety, and when it refused to give jury instructions about self-defense that were unsupported by the evidence. The Court also held that the constitutional rule against shackling does not apply to a sentencing hearing before a judge. View "United States v. LaFond" on Justia Law