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

The United States Court of Appeals for the Eleventh Circuit affirmed the convictions of sisters Tierzah, Charis, and Elisa Mapson in connection with a shooting incident. The victims were Joshua Thornton, the father of Tierzah's daughter, and his wife. The government charged the sisters with interstate domestic violence, interstate stalking, discharging a firearm in furtherance of a crime of violence, and conspiracy to commit these offenses. The jury found that the shooting was part of a scheme by the sisters to kill Mr. Thornton over a child custody dispute.In their appeal, the sisters argued that the evidence was insufficient to support the jury’s verdicts. Charis also challenged the admission of testimony that she once owned a firearm, claiming it was prejudicial hearsay. Elisa and Charis contested the admissibility of data obtained from automated license plate readers (ALPRs), arguing that its acquisition constituted a warrantless search in violation of their Fourth Amendment rights.The court of appeals found sufficient evidence to support the jury’s verdicts. The court also rejected Charis's challenge to the hearsay evidence, ruling it was admissible as an admission by a party opponent. The court further concluded that the ALPR data was admissible because the good-faith exception to the exclusionary rule applied, and its introduction did not require expert testimony. View "United States v. Mapson" on Justia Law

In a case heard by the United States Court of Appeals for the Eleventh Circuit, the defendant, Adam Joseph Owens, was arrested as part of a federal-state task force's investigation into a large drug ring. Owens was initially charged with multiple crimes but pleaded guilty to possessing a firearm in furtherance of a drug trafficking crime. The district court imposed a 120-month prison sentence, double the 60-month recommendation by the Sentencing Guidelines. The court argued this upward variance was due to Owens planning to sell drugs while in jail awaiting sentencing and his involvement in the overdose death of one of his customers.Owens appealed against these findings. The appellate court, however, affirmed the district court's sentence, concluding that the findings were not clearly erroneous. The court relied on the testimony of the warden of the detention center where Owens was held and a police sergeant who testified about the victim's death. It was found that Owens was involved in drug dealing in jail and was responsible for selling drugs that led to the victim's death. The court noted that the district court's factual findings at sentencing were not clearly erroneous and thus upheld Owens's sentence. View "United States v. Owens" on Justia Law

The case is about an appeal by Jayson Wright against his conviction for producing child pornography. Wright had pleaded guilty to one count of producing child pornography by a parent or legal guardian and one count of producing child pornography, both in violation of 18 U.S.C. § 2251(b) and (e), and 18 U.S.C. § 2251(a) and (e) respectively, and was sentenced to a total of 720-months’ imprisonment. Wright appealed his conviction on the grounds that the district court violated Rule 11 of the Federal Rules of Criminal Procedure in taking his guilty plea on the § 2251(a) charge. He argued that there was not an adequate factual basis supporting his guilty plea and that the district court did not adequately explain the nature of his charge.Wright argued that the minor needed to have volitionally participated in the sexual act to sustain his conviction under 18 U.S.C. § 2251(a) and (e). He contended that he was prejudiced and his conviction should be reversed because the district court did not mention a volitional requirement during the plea colloquy, and he would not have pleaded guilty had he known about what he contends is the volitional requirement.The United States Court of Appeals for the Eleventh Circuit affirmed the decision of the district court. The appellate court held that 18 U.S.C. § 2251(a) does not require the minor to volitionally participate in the sexual act. Therefore, the district court did not commit plain error in taking Wright’s guilty plea without finding that the minor volitionally participated in the sexual act. View "United States v. Wright" on Justia Law

The case in question involves a receiver, Burton Wiand, appointed after the collapse of a $78 million Ponzi scheme operated by Oasis, who sued ATC Brokers Ltd. (where Oasis held accounts), David Manoukian (owner of ATC Brokers), and Spotex LLC (which provided software to Oasis). Wiand alleged common-law tort claims against the defendants and fraudulent-transfer claims against ATC Brokers only. The district court dismissed Wiand’s complaint with prejudice, ruling that Wiand lacked standing to sue ATC Brokers and Manoukian and that Spotex was immune under the Communications Decency Act.The United States Court of Appeals for the Eleventh Circuit found that the district court erred in dismissing the fraudulent-transfer claims for lack of standing. The court explained that a receiver for a Ponzi estate has standing to maintain fraudulent-transfer claims on behalf of the estate. However, the court agreed with the district court that Wiand lacked standing to maintain the tort claims, as the Oasis corporate entities were not separate and distinct from the Ponzi scheme, and Wiand couldn't allege an injury to sustain his tort claims.As a result, the court reversed the dismissal of the fraudulent-transfer claims and remanded for further proceedings, and vacated the dismissal with prejudice of the tort claims and remanded with instructions to dismiss without prejudice. View "Wiand v. ATC Brokers Ltd." on Justia Law

Jesus Gabriel Navarro Guadarrama, a Mexican citizen, pursued a review of the Board of Immigration Appeals' decision dismissing his appeal for adjustment of status and the subsequent denial of his motion to reconsider. Navarro Guadarrama contended that the Board used an incorrect legal standard in considering his application.Navarro Guadarrama entered the U.S. in 1995 and was later convicted of several crimes. His criminal record led to the initiation of removal proceedings against him. Navarro Guadarrama applied for adjustment of status under 8 U.S.C. § 1255(i), which enables an alien illegally in the U.S. to seek relief from removal if they meet certain requirements. His application was denied by an Immigration Judge (IJ) and the Board due to his criminal record and evidence of bad character.Navarro Guadarrama petitioned the court to review the Board's decision. He argued that the Board used the legal standard from a previous case, Matter of Mendez-Moralez, which applies to aliens requiring waivers, instead of Matter of Arai, which applies to those who don't require waivers.The United States Court of Appeals for the Eleventh Circuit held that it had jurisdiction to consider Navarro Guadarrama’s petitions for review and that the Board did not apply the wrong legal standard. The court found that even if the Board cited the "wrong" case, there was no indication that, in substance, it applied the wrong standard. Therefore, the court denied the petitions for review. View "Guadarrama v. U.S. Attorney General" on Justia Law

The case involved an appeal by two brothers, Jonathan and Daniel Markovich, who were convicted for operating fraudulent drug rehabilitation clinics in Florida. They were found guilty of various charges, including health-care fraud, wire fraud, kickbacks, money laundering, and bank fraud, resulting in fraudulent claims of over $100 million.The brothers appealed their convictions on several grounds. They argued that the district court violated their constitutional rights by denying their motion to compel the prosecution to obtain and disclose confidential medical records possessed by third parties. They also claimed that the court violated Federal Rules of Evidence by admitting unreliable and confusing expert testimony about the clinics' medical and billing practices. Additionally, they argued that the court abused its discretion by admitting lay summary testimony about medical and billing records.The United States Court of Appeals for the Eleventh Circuit affirmed the convictions. The court ruled that the prosecution had no duty to seek out potentially exculpatory evidence not in its possession. It also determined that the expert testimony was clear and reliable, and the summary testimony was proper. The court found that any challenge to bank-fraud counts was forfeited due to a lack of explanation or supporting legal authority. Finally, the court ruled that the district court did not abuse its discretion by denying the brothers' motion for a new trial based on newly discovered evidence. View "United States v. Markovich" on Justia Law

Creditors obtained a $1.6 million default judgment against Rodney Dorand and sought to satisfy the judgment with funds from Dorand's individual retirement account, held by Morgan Stanley. An Alabama court approved the transfer of funds, but before the transfer occurred, Dorand filed for Chapter 7 bankruptcy, asserting that the retirement account was exempt property of his bankruptcy estate. The bankruptcy court agreed with Dorand. The United States Court of Appeals for the Eleventh Circuit affirmed this decision, stating that the Alabama judgment did not extinguish Dorand’s interest in his account before he filed his bankruptcy petition.Rodney Dorand had been sued by creditors for damages arising from a failed condominium development. After the state court issued a writ of garnishment to Morgan Stanley, Dorand argued that the retirement account was exempt from garnishment, but the state court rejected this argument. However, before the funds were transferred, Dorand filed for bankruptcy. The bankruptcy court determined that the retirement account was Dorand’s exempt property and that the Alabama judgment against garnishee Morgan Stanley “does not affect the [retirement account’s] exempt status.”The Alabama judgment did not terminate all of Dorand's interests in his property. While the judgment had given Morgan Stanley a limited right to transfer Dorand’s funds, it had not exercised that right before Dorand filed for bankruptcy. The Court of Appeals affirmed that the retirement account was part of Dorand’s bankruptcy estate, as Dorand had an interest in the retirement account when he filed for bankruptcy. View "The Alabama Creditors v. Dorand" on Justia Law

In this case, plaintiffs Lee Anne and John Savoia-McHugh sued defendant Michael Glass, alleging misconduct related to real estate investment transactions. Despite being served with the complaint, Glass did not respond to the complaint, the amended complaint, written discovery requests, a motion to compel, or a subpoena over a period of 15 months. Consequently, the plaintiffs requested and were granted an entry of default. Glass later engaged counsel and moved to set aside the default, arguing that his delayed appearance was not willful, that he had established meritorious defenses, and that setting aside the default would not prejudice the plaintiffs. However, the district court denied his motion and entered a default judgment against him.The United States Court of Appeals for the Eleventh Circuit affirmed the district court's decision, holding that Glass willfully defaulted. The court noted that despite Glass's contention that he was not served with the complaint or the amended complaint, he acknowledged receipt of several other legal documents related to the case. Furthermore, Glass's excuse that he was confused and did not understand the need to act until the magistrate judge’s order was deemed inadequate. As a result, the court concluded that Glass displayed an intentional or reckless disregard for the judicial proceedings, which negated a finding of good cause to set aside the default. View "Savoia-McHugh v. Glass" on Justia Law

The case involves Purpose Built Families Foundation, a Florida nonprofit that received federal grants from the Department of Veterans Affairs to serve veterans and their families. In 2022, the Department notified the Foundation that activities and payments under five grants would be terminated or withheld due to "major fiscal mismanagement activities". The Foundation sued the Secretary of Veterans Affairs under the Administrative Procedure Act and received a temporary restraining order. Subsequently, the Department withdrew the challenged notices and the Secretary moved to dismiss the action as moot. The district court granted the motion.The United States Court of Appeals for the Eleventh Circuit affirmed the decision of the district court. The court held that the case was moot, as the Department's withdrawal of the notices meant the Foundation's claims could not provide meaningful relief. It also ruled that neither the voluntary-cessation nor the capable-of-repetition-yet-evading-review exceptions to mootness applied. The court stated that the Department's subsequent actions, including a more robust process and new termination notices, were materially different from the original notices. Therefore, a lawsuit challenging the new termination notices would involve materially different allegations and answers. The court concluded that the Foundation would have ample opportunity for judicial review of the legality of the new terminations, once the administrative process was completed. View "Purpose Built Families Foundation, Inc. v. USA" on Justia Law

In this lawsuit, Keith Sylvester alleged that Detective James Barnett violated his Fourth Amendment rights by causing his arrest and detention without probable cause. Sylvester's parents were murdered and their house set on fire. Detective Barnett led the investigation and suspected Sylvester was the culprit, ultimately obtaining an arrest warrant for him. Sylvester spent over a year in jail until the charges were dropped. Sylvester claimed that Barnett lacked probable cause when he applied for the arrest warrant, arguing that key exonerating evidence was omitted from the affidavit.The district court granted Detective Barnett summary judgment, stating that the record did not establish that Barnett knew about the exonerating information when he wrote the warrant affidavit. The court concluded that, based on the totality of circumstances known to Barnett at the time of the arrest, his suspicion of Sylvester was reasonable.On appeal, the United States Court of Appeals for the Eleventh Circuit reversed the lower court's decision. The appellate court found that there were material facts omitted from the warrant affidavit. When those omissions were corrected, the affidavit failed to establish even arguable probable cause for Sylvester's arrest. The court further held that a reasonable jury could find that Barnett intentionally or recklessly left out information that exonerated Sylvester. If a jury finds such misconduct, qualified immunity would not shield Barnett from liability. Therefore, the case was remanded for further proceedings. View "Sylvester v. Barnett" on Justia Law