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

James Harding was charged with conspiracy to possess with intent to distribute heroin and possession with intent to distribute heroin. The charges stemmed from a conspiracy that allegedly took place in the Southern District of Alabama between early 2018 and April 2019. During the trial, the United States introduced evidence from a separate investigation that took place over two years after the alleged end of the charged conspiracy. This evidence, which was found at Harding's home in the Northern District of Alabama, included multiple firearms and almost two kilograms of heroin. The district court admitted this evidence as intrinsic to the charged conspiracy and, alternatively, as admissible under Federal Rule of Evidence 404(b). Harding was found guilty of both charges.The United States Court of Appeals for the Eleventh Circuit found that the district court abused its discretion by admitting the evidence from the separate investigation as intrinsic to the charged conspiracy. The court reasoned that the evidence did not arise from the same transactions, was not necessary to complete the story of the charged crime, and was not inextricably intertwined with the charged crime. The court also found that the district court abused its discretion by failing to provide a limiting instruction regarding the evidence from the separate investigation. The court concluded that the errors were not harmless and could have influenced the jury's verdict. As a result, the court vacated Harding's convictions and sentence and remanded the case for a new trial. View "United States v. Harding" on Justia Law

The case revolves around a products liability lawsuit filed by Virginia Redding against Coloplast Corporation. Redding alleged that vaginal mesh devices inserted inside her body were defectively designed. Coloplast argued that Redding's suit was time-barred under Florida's four-year statute of limitations for products liability lawsuits, as her claim accrued more than four years before she filed suit. The district court sided with Redding, and Coloplast appealed.The case was previously reviewed by the United States District Court for the Middle District of Florida. The district court denied Coloplast's motion for summary judgment, arguing that Redding's suit was time-barred. The court found that the facts in a similar case, Eghnayem v. Boston Scientific Corporation, were "strikingly similar" to Redding's case and compelled the conclusion that Redding's injuries were not sufficiently different from the symptoms that could have occurred as a result of the surgeries to put her on notice.The United States Court of Appeals for the Eleventh Circuit affirmed the district court's decision. The court concluded that the evidence, viewed in the light most favorable to Redding, did not overwhelmingly establish that she knew or should have known about a compensable injury arising out of Coloplast's mesh before September 18, 2010, such that a reasonable jury could not conclude otherwise. As a result, Redding's claims were not time-barred under Florida's four-year statute of limitations. View "Redding v. Coloplast Corp." on Justia Law

The case involves Tristan Tanner, an employee of Stryker Corporation of Michigan, who appealed against the district court's decision granting summary judgment in favor of Stryker. Tanner had filed claims for interference with his rights under the Family and Medical Leave Act (FMLA) and for retaliation for his exercise of those rights. Tanner had requested paternity leave for the birth of his child and had taken time off work before the birth of his child, during which he accrued "occurrence points" under Stryker's attendance policy. He was terminated after accruing more than the allowed number of points.The district court had granted summary judgment in favor of Stryker, finding that Tanner was not entitled to FMLA leave for his absences before his child's birth. The court also found that Stryker had legitimate, non-discriminatory reasons for terminating Tanner, namely his accrual of eight occurrence points due to repeated unexcused absences.In the United States Court of Appeals for the Eleventh Circuit, the court affirmed the district court's decision. The court held that the days Tanner spent in Connecticut waiting for his child to be born were not covered under FMLA. The court also found that Tanner had not provided evidence to create a genuine issue of material fact as to whether Stryker's reason for his termination was pretextual. Therefore, the court concluded that summary judgment in Stryker's favor was appropriate for both Tanner's FMLA retaliation and interference claims. View "Tanner v. Stryker Corporation of Michigan" on Justia Law

The case involves Martha Isabel Rosales-Mendez, a Honduran native who illegally entered the United States. After being apprehended by border patrol agents, she was served with a notice to appear for a removal hearing. The agents recorded an address provided by her boyfriend over the phone, which turned out to be incorrect. Consequently, Rosales-Mendez did not receive the second notice setting the date and time of her removal hearing, leading to her being ordered removed in absentia when she failed to appear.Rosales-Mendez's case was initially reviewed by an immigration judge who ordered her removal in absentia after she failed to attend the hearing. She later discovered the removal order and moved to reopen the removal proceeding, arguing lack of notice. However, the immigration judge denied the motion. The Board of Immigration Appeals affirmed the decision, stating that since Rosales-Mendez failed to provide a correct address, the officials were excused from providing her notice of her removal hearing.The United States Court of Appeals for the Eleventh Circuit denied Rosales-Mendez's petition for review. The court held that immigration officials were not required to give notice of a removal hearing to an alien who provided them an inaccurate home address. The court reasoned that Rosales-Mendez, through her boyfriend, provided an incorrect address and failed to correct it, thereby forfeiting her right to actual notice of her removal hearing. The court concluded that Rosales-Mendez was properly ordered removed in absentia. View "Rosales-Mendez v. U.S. Attorney General" on Justia Law

The case involves PB Legacy, Inc., a Texas-based shrimp breeding company, and American Mariculture, Inc., a Florida-based company that operated a shrimp breeding facility. PB Legacy had a contract with American Mariculture to breed shrimp. However, PB Legacy failed to fulfill its contractual obligations, including removing its shrimp from the facility on time. When American Mariculture threatened to harvest the abandoned shrimp, PB Legacy sued in state court. After a failed attempt to resolve the dispute, American Mariculture used the shrimp to launch a competing company, American Penaeid, Inc. PB Legacy then sued American Mariculture, Penaeid, and their CEO, Robin Pearl, in federal court, alleging conversion, defamation, trade secret misappropriation, breach of contract, unfair competition, and unjust enrichment.The case proceeded to a jury trial in the United States District Court for the Middle District of Florida. During the trial, the district judge had to leave before the jury returned its verdict. The parties agreed to have a magistrate judge receive the verdict. However, the magistrate judge also responded to several jury questions and rejected a request for clarification about the verdict. The jury awarded $4.95 million in damages to PB Legacy on each of their federal and state trade secret claims. Post-trial motions were filed and denied.The case was appealed to the United States Court of Appeals for the Eleventh Circuit. The defendants argued that the magistrate judge lacked authority to preside over the last three days of trial because the parties did not consent to the magistrate judge’s exercise of Article III authority. The court agreed, stating that while the parties had consented to the magistrate judge receiving the verdict, they had not consented to the magistrate judge performing non-ministerial duties such as responding to jury questions and rejecting a request for clarification about the verdict. The court vacated the judgment, remanded for a new trial, and dismissed the cross-appeal as moot. View "TB Foods USA, LLC v. American Mariculture, Inc." on Justia Law

The case revolves around a warrantless search of a probationer's home, which was also occupied by a non-probationer. The probationer, Tremayne Linder, was on probation for burglary and attempted armed robbery. His probation conditions included a clause that allowed for warrantless searches of his residence. The non-probationer, Lakesia Harden, was Linder's girlfriend and was aware of his probation status. The police, suspecting marijuana use, conducted a warrantless search of Linder's home and found drugs in a shared closet. Harden was subsequently arrested and charged with possession of marijuana and methamphetamine with intent to distribute.The case was first heard in the United States District Court for the Southern District of Georgia. Harden moved to suppress the drugs and her post-arrest statements as fruits of the allegedly unlawful search. However, the district court denied the suppression motions. At trial, the government admitted the drugs and Harden's statements into evidence, and the jury found her guilty as charged in the indictment. Harden appealed the denial of her suppression motions.The case was then reviewed by the United States Court of Appeals for the Eleventh Circuit. The court held that a warrantless search of a probationer's home, based on reasonable suspicion and a probation condition allowing warrantless searches, is not rendered unreasonable because the home was occupied by another person who knew about the probation. The court affirmed the district court's decision, ruling that the search was reasonable and did not violate the Fourth Amendment. View "USA v. Harden" on Justia Law

The United States Coast Guard seized a vessel in the Dominican Republic's Exclusive Economic Zone (EEZ) that bore no nationality indicators. The crew claimed Colombian nationality for the vessel, but Colombia could not confirm or deny the vessel's registry, rendering it stateless under the Maritime Drug Law Enforcement Act (MDLEA). The vessel was found to contain drugs, leading to the arrest and prosecution of the crew members, Jhonathan Alfonso, Jose Jorge Kohen, and Jose Miguel Rosario-Rojas, under the MDLEA.The defendants moved to dismiss the indictment, arguing that the MDLEA was unconstitutional as applied to them because they were arrested in the EEZ, which they asserted is not part of the "high seas" as defined by customary international law. The district court denied the motion, concluding that it had subject matter jurisdiction under the MDLEA. The defendants subsequently pleaded guilty to conspiracy to possess with intent to distribute a controlled substance while on board a vessel subject to the jurisdiction of the United States.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court's decision. The court concluded that the EEZ is part of the "high seas" and thus within Congress’s authority under the Felonies Clause. The court also concluded that the defendants could not show any plain error with regard to the MDLEA’s definition of a vessel without nationality as including vessels where registry is asserted but cannot be confirmed or denied by the foreign country. View "United States v. Alfonso" on Justia Law

A transgender woman from Mexico, identified as A.P.A., who unlawfully immigrated to the United States as a child, faced deportation proceedings after being convicted of driving under the influence. In response, A.P.A. petitioned for asylum, withholding of removal, and protection under the Convention Against Torture (“CAT”), citing past abuse by a custodial uncle in Mexico and fear of future persecution and torture due to her transgender status. The immigration judge denied these requests, and the Board of Immigration Appeals (“BIA”) affirmed the decision.The BIA determined that A.P.A.'s asylum claim was untimely and did not meet the exception to the one-year deadline based on "changed" or "extraordinary circumstances." The BIA also concluded that A.P.A. had not shown past persecution or a well-founded fear of future persecution in Mexico as a transgender woman. The BIA denied A.P.A.'s request for CAT relief for the same reasons.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court concluded that it lacked jurisdiction to review the denial of the asylum application based on its timeliness, as per the statute and previous court decisions. The court also found that substantial evidence supported the BIA’s decision that A.P.A. was not likely to suffer future persecution or torture as a transgender woman in Mexico. Therefore, the court denied the petition for review in part and dismissed it in part. View "A.P.A. v. U.S. Attorney General" on Justia Law

Sylvan Plowright filed a lawsuit against Miami-Dade County, its police chief, and two of its police officers after one of the officers, Sergio Cordova, fatally shot Plowright’s dog, Niles, during an investigation. The district court dismissed Plowright’s complaint, concluding that Cordova was entitled to qualified immunity because he did not violate any clearly established right when he shot Niles.The United States Court of Appeals for the Eleventh Circuit disagreed with the lower court's decision. The court held that the use of deadly force against a domestic animal constitutes a seizure of its owner’s property subject to the Fourth Amendment’s reasonableness requirement. The court found that under the facts alleged in the complaint, no reasonable officer in Cordova’s position could have believed that Niles posed an imminent danger, and therefore, his decision to shoot Niles falls short of that requirement. The court reversed the dismissal of Plowright’s § 1983 claim against Cordova and remanded for further proceedings. The court also reversed the dismissal of Plowright’s claim for intentional infliction of emotional distress against Cordova. However, the court affirmed the dismissal of Plowright’s intentional-infliction-of-emotional-distress claim against a second officer, as well as his claims against the county and its police chief. View "Plowright v. Miami Dade County" on Justia Law

The case involves Jay Diamond, who was convicted of impersonating a federal officer in an attempt to avoid a speeding ticket and to avoid being arrested for falsely impersonating a federal officer. The incidents occurred when Diamond was pulled over for speeding and he told the officer that he was an air marshal. He presented a badge that read "United States Federal Air Marshal." However, upon investigation, it was found that Diamond was never employed as a federal air marshal or through the Transportation Security Administration (TSA).In the lower courts, Diamond argued that the government failed to present sufficient evidence to establish that he acted as a federal officer and that the district court erred in admitting evidence of his alleged prior bad acts and in instructing the jury. The district court denied Diamond's motion to exclude his ex-wife's testimony about his prior instances of impersonating a federal officer or military member. The court also denied Diamond's request for a jury instruction on the misdemeanor offense in 18 U.S.C. § 701, which Diamond argued was a lesser included offense of his alleged § 912 crime.In the United States Court of Appeals for the Eleventh Circuit, Diamond's convictions were affirmed. The court found that the evidence was sufficient to support Diamond’s § 912 convictions. The court also ruled that the district court did not abuse its discretion in admitting Diamond's ex-wife's testimony. Furthermore, the court found that 18 U.S.C. § 701 is not a lesser included offense of § 912, and therefore the district court did not err in refusing to give Diamond's requested § 701 instruction. View "United States v. Diamond" on Justia Law