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

In the case reviewed, Jason Gatlin was convicted of sex trafficking of a minor, production of child pornography, and witness tampering in the United States Court of Appeals for the Eleventh Circuit. The appeal focused on several issues including the evidence supporting the convictions, the district court's action in directing the jury to continue deliberating after they reached an inconsistent verdict, the proper application of sentencing enhancements and the reasonableness of the sentence, and whether the order of restitution violated Gatlin's constitutional rights.The court affirmed Gatlin's convictions and sentences for sex trafficking of a minor and production of child pornography. The court found there was sufficient evidence to support these convictions. However, the court reversed Gatlin's conviction for witness tampering, finding that the evidence only established a remote or simply hypothetical possibility that the witness's recantation statements would reach a federal officer.Regarding the sentencing, the court affirmed the district court's application of the custody, care, or supervisory control enhancement and the repeat offender enhancement. It also found Gatlin's life sentence was reasonable.As to the restitution order, the court also affirmed it, holding that it did not violate Gatlin's Sixth Amendment rights. The court concluded that the district court did not err in its calculation of the restitution amount and did not violate Gatlin's rights. View "USA v. Gatlin" on Justia Law

In this case, the United States Court of Appeals for the Eleventh Circuit reviewed an appeal of a lower court's denial of qualified immunity to a jail intake officer, Keyvon Sellers. The case arose from an incident in which a black man, Jayvon Hatchett, attacked and killed his white cellmate, Eddie Nelson, in county jail. Before the attack, Hatchett had told Sellers that he had previously stabbed a white man after watching videos of white police officers shooting black men. Despite this admission, Sellers did not inform other jail staff of Hatchett's racially motivated violence. Nelson's survivors sued Sellers, alleging that his failure to share this information constituted deliberate indifference to a substantial risk of serious harm to Nelson, in violation of the Fourteenth Amendment.The Court of Appeals affirmed the district court's decision, finding that a reasonable jury could conclude that Sellers violated Nelson's clearly established constitutional right by failing to protect him from a known risk of harm. The court concluded that Sellers had fair warning that his inaction was unconstitutional. Therefore, he was not entitled to qualified immunity. View "Nelson v. Sellers" on Justia Law

In this case, Eliezer and Valeria Taveras (the appellants) appealed the decision of the United States District Court for the Middle District of Florida when it abstained from exercising federal jurisdiction over their case, pending the conclusion of a related state case under the Colorado River abstention doctrine. The Taveras' case centered around a dispute concerning the validity of a mortgage and an allegedly fraudulent promissory note secured by a parcel of real property they had purchased in 2006. The appellants contended that the district court improperly abstained from exercising jurisdiction and erroneously denied their motion to amend the complaint. The United States Court of Appeals for the Eleventh Circuit affirmed the decision of the district court. The court found that the district court did not abuse its discretion in abstaining under the Colorado River doctrine as the federal and state proceedings involved substantially similar issues and parties. It also found that the district court properly denied the Taveras' motion to amend the complaint because the proposed amendments would not have changed the outcome of the abstention analysis. View "Taveras v. Bank of America" on Justia Law

In this appeal, Marcus Raper contested the Social Security Administration’s (SSA) 2020 denial of his claim for disability insurance benefits. Raper raised three arguments: (1) that the administrative law judge's (ALJ) initial lack of constitutional appointment under the Appointments Clause tainted his later constitutionally appointed review of his case, (2) that the ALJ failed to clearly articulate good cause for not fully crediting his treating physician’s medical opinion, and (3) that the ALJ wrongly discredited his subjective complaints of pain by not properly considering evidence other than objective medical evidence.The United States Court of Appeals for the Eleventh Circuit affirmed the lower court’s decision. First, the court found no Appointments Clause violation as the ALJ's initial decision, made when he was unconstitutionally appointed, had been vacated on the merits and the case was remanded to the same ALJ who was then constitutionally appointed. Second, the court held that the ALJ articulated good cause for discounting Raper's treating physician’s opinion, finding the opinion inconsistent with the record. Lastly, the court found that the ALJ had properly considered Raper’s subjective complaints in light of the record as a whole and adequately explained his decision not to fully credit Raper’s alleged limitations on his ability to work. View "Raper v. Commissioner of Social Security" on Justia Law

In this appeal before the United States Court of Appeals for the Eleventh Circuit, the defendants, David Fey and Shari Lynn Gunter, were convicted of distributing methamphetamine and conspiring to kill and killing a witness to their crimes. The court was required to decide on three issues: (1) whether the district court abused its discretion by admitting evidence that Fey had attempted to hire someone to kill a witness cooperating with federal officials and if so, whether that error was harmless; (2) whether the district court plainly erred by declining to instruct the jury on spoliation; and (3) whether the district court erred by overruling Fey and Gunter’s objection to testimony about a coconspirator’s death and by declining to declare a mistrial.The Eleventh Circuit affirmed the district court's decisions on all three issues. First, it held that, although the prosecutors failed to identify the testimony about Fey's solicitation of a witness's murder as evidence under Federal Rule of Evidence 404(b), this error was harmless. The court reasoned that Fey and Gunter had ample notice of this testimony before trial and there was sufficient evidence to support the juries' convictions on the charges related to the witness's murder, even without this testimony.Second, the court found that the district court did not plainly err in declining to give a spoliation instruction to the jury about the destruction of the victim's tissue samples. The court noted that, even if such an instruction could be given in a criminal trial, it would be required only when the absence of material evidence is predicated on bad faith, not negligence.Finally, the court held that the district court did not err in overruling Fey and Gunter’s objection to testimony about the overdose death of a coconspirator. The court reasoned that the testimony did not imply that Fey and Gunter were involved in the coconspirator's death and did not prejudice their substantial rights. Therefore, the district court did not abuse its discretion in denying a mistrial. View "USA v. Fey" on Justia Law

The United States Court of Appeals for the Eleventh Circuit ruled in a dispute between Travelers Property Casualty Company of America and Talcon Group LLC. Talcon, an underground utility contractor, had an insurance policy with Travelers. Two residential homes under construction and connected to Talcon were destroyed by fire. Talcon filed a claim with Travelers, which was denied on the grounds that the policy only covered their underground utility operations and related site development work, not home construction. Talcon argued that the policy was ambiguous and should cover the homes as they were newly constructed during the policy period. The Court of Appeals, affirming the district court's summary judgment in favor of Travelers, held that the policy unambiguously did not cover the construction of the two homes. The court noted that when viewed together with Talcon's insurance application, the policy clearly restricts coverage to Talcon's underground utility and site development work. The court also stated that the policy's exclusion of pre-existing buildings did not imply coverage for all new construction, only buildings related to Talcon's specified operations. View "Travelers Property Casualty Company of America v. Talcon Group LLC" on Justia Law

The United States Court of Appeals for the Eleventh Circuit affirmed the judgment of the United States District Court for the Middle District of Florida. The case involved Asdrubal Quijada Marin and Juan Carlos Acosta Hurtado, two Venezuelan nationals who were apprehended by the United States Coast Guard in the Caribbean Sea. They were convicted after a bench trial for conspiracy to possess with intent to distribute five kilograms or more of cocaine while aboard a vessel subject to the jurisdiction of the United States and possession with intent to distribute five kilograms or more of cocaine on a vessel subject to the jurisdiction of the United States, pursuant to the Maritime Drug Law Enforcement Act.On appeal, Marin and Acosta Hurtado challenged the court's jurisdiction, arguing that the indictment should have been dismissed for lack of jurisdiction and the evidence should have been suppressed due to violation of their Fourth Amendment rights. They also contended that their detention at sea for 48 days prior to indictment constituted unnecessary delay and outrageous government conduct.The Court of Appeals held that the District Court properly exercised jurisdiction over Marin and Acosta Hurtado under the Maritime Drug Law Enforcement Act because Cameroon, the flag nation of the vessel, had consented to United States jurisdiction over the crew of the vessel. It also held that the Northland’s stop and search of the Zumaque Tracer did not violate the Fourth Amendment, so the District Court did not err in denying the motion to suppress evidence based on a Fourth Amendment violation. The Court also held that the District Court did not err in denying Acosta Hurtado’s motion to dismiss based on unnecessary delay arguments. Lastly, the Court held that Acosta Hurtado's claim of outrageous government conduct was meritless. View "USA v. Hurtado" on Justia Law

In the United States Court of Appeals for the Eleventh Circuit, the case involved Peter Sotis, who was convicted for violating export controls. He had conspired to export diving equipment, specifically rebreathers, to Libya without a license, despite the Department of Commerce requiring a license to export certain products to Libya that implicate the United States’ national security interests.Sotis challenged the sufficiency of the evidence to support each count of his conviction, the opinion testimony presented at trial, and the reasonableness of his 57-month sentence. He argued that there was insufficient evidence to prove willfulness, to prove that he and another individual had acted in conspiracy, and to prove that the rebreathers were closed-circuit, which would have resulted in a material and prejudicial variance from the indictment. He also claimed that one expert witness and one lay witness invaded the province of the jury by opining on an ultimate issue in the case.The Court of Appeals found that there was sufficient evidence for a reasonable jury to find that Sotis had sufficient knowledge of the illegality of his conduct to have willfully violated the export control laws. The Court also found that the government sufficiently proved that Sotis conspired with another individual to violate the export control laws. Moreover, the Court rejected Sotis's argument that there was a material variance between the indictment and the evidence presented at trial.Regarding the expert and lay witness testimonies, the Court held that the testimonies were not improper. The Court also found that the district court did not err in applying the sentencing guidelines and that Sotis's sentence was not substantively unreasonable. As a result, the Court affirmed Sotis's conviction and sentence. View "USA v. Sotis" on Justia Law

In a case before the United States Court of Appeals for the Eleventh Circuit, several clients of Wyndham Vacation Resorts (Resorts) sought to arbitrate disputes with Resorts, but their petitions were rejected by the American Arbitration Association (AAA) because Resorts had failed to comply with AAA’s policies. The clients then sued Resorts in federal court. Resorts moved to stay the litigation and direct arbitration, but the district court denied the motion, reasoning that Resorts cannot rely on the Federal Arbitration Act (FAA) to compel arbitration because it had defaulted in its obligation to arbitrate by failing to comply with AAA's policies.The appellate court held as follows: First, the three clients who originally sought to arbitrate their claims against Resorts, only to see their petitions rejected due to Resorts’ noncompliance with AAA policies, may proceed to litigation. Second, three other clients who never formally submitted their claims against Resorts to the AAA, but whose agreements with Resorts contained identical arbitration provisions, may also proceed to litigation. However, two clients who had an agreement with different Wyndham-related entities must return to the district court for further consideration of the FAA’s applicability to their dispute.The court found that the district court correctly concluded that Resorts could not compel arbitration under the FAA. However, the court found that the district court's decision was too broad regarding the other Wyndham-related entities, Development and WorldMark, because there was no evidence that they had violated the AAA’s policies. As a result, the court vacated and remanded the case for further proceedings concerning these entities. View "Bedgood v. Wyndham Vacation Resorts, Inc., et al." on Justia Law

The U.S. Court of Appeals for the Eleventh Circuit considered an appeal by Mark Meadows, former White House chief of staff under President Donald Trump, who sought to move his state criminal prosecution to federal court. The state of Georgia had indicted Meadows for crimes related to alleged interference in the 2020 presidential election. Meadows argued that because these actions were taken in his official capacity, they should be heard in federal court according to the federal-officer removal statute (28 U.S.C. § 1442(a)(1)). The district court denied this request because Meadows' charged conduct was not performed under the color of his federal office. The court of appeals affirmed this decision. It ruled that the federal-officer removal statute does not apply to former federal officers and even if it did, the alleged actions leading to this criminal action were not related to Meadows’ official duties. The court concluded that the former chief of staff’s role does not include influencing state officials with allegations of election fraud or altering valid election results in favor of a particular candidate, regardless of the chief of staff's role with respect to state election administration. Therefore, Meadows was not entitled to invoke the federal-officer removal statute. View "The State of Georgia v. Meadows" on Justia Law