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

Ephren Taylor, II, formerly CEO of City Capital Corporation, was indicted in 2014 for orchestrating a fraudulent investment scheme that targeted African American and Christian communities. Taylor promoted investments and promissory notes, misrepresenting their returns and using new investor funds to pay business expenses, resulting in losses exceeding $16 million for over 400 victims. He pleaded guilty to conspiracy to commit wire and mail fraud and was sentenced to 235 months in prison, later reduced to 223 months, with restitution ordered.Taylor filed a pro se motion under 28 U.S.C. § 2255 in the United States District Court for the Northern District of Georgia, alleging ineffective assistance of counsel and various judicial errors. The District Court, after adopting a magistrate judge’s report and recommendation, denied the motion, finding Taylor’s claims either procedurally defaulted, waived, or unsupported by the record. Taylor’s subsequent Rule 59(e) and Rule 60(b) motions were also denied, and he filed multiple additional motions, including to amend or supplement his § 2255 petition and to modify conditions of supervised release. The District Court denied these later motions, determining they were unauthorized second or successive filings under 28 U.S.C. §§ 2244(b) and 2255(h), and that it lacked jurisdiction due to Taylor’s pending appeal.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the District Court’s denial of Taylor’s motions to reopen, supplement, and amend his original § 2255 motion, holding they were unauthorized second or successive filings barred by AEDPA’s gatekeeping provisions. The Eleventh Circuit also affirmed that Taylor’s challenges to the legality or constitutionality of his supervised release conditions could not be raised under 18 U.S.C. § 3583(e)(2). However, the court vacated the District Court’s denial of Taylor’s motion to modify conditions of supervised release and remanded for consideration of the relevant statutory factors. View "United States v. Taylor" on Justia Law

Joshua Gaines pleaded guilty in Alabama state court to receiving stolen property in the third degree, a Class D felony under Alabama law. Due to his criminal history, Alabama statutes at the time prohibited the court from sentencing him to any actual prison time for this offense. Instead, Gaines received a 24-month suspended sentence and was placed on probation for two years, with the possibility of community corrections or other non-prison alternatives, but not incarceration in a prison or jail. After his conviction, Gaines was notified that federal law prohibited him from possessing a firearm. Six months later, he was found in possession of a gun and admitted ownership.The United States District Court for the Northern District of Alabama tried Gaines on two counts: possession of a firearm by a person convicted of a crime punishable by imprisonment for a term exceeding one year, in violation of 18 U.S.C. § 922(g)(1), and possession of an unregistered firearm. After the government rested, Gaines moved for a judgment of acquittal, arguing that his prior conviction did not meet the federal statute’s requirement. The district court denied the motion, and the jury convicted him on the § 922(g)(1) count but acquitted him on the other. Gaines was sentenced to 51 months in prison and three years of supervised release.The United States Court of Appeals for the Eleventh Circuit reviewed the case and held that § 922(g)(1) requires a defendant-specific inquiry: the statute applies only if the defendant was actually subject to a sentence of more than one year of imprisonment in a prison or jail. Because Alabama law precluded any prison time for Gaines’s offense, his conviction did not qualify. The Eleventh Circuit vacated Gaines’s conviction and remanded with instructions to grant his motion for judgment of acquittal. View "USA v. Gaines" on Justia Law

An inmate in Georgia, who practices veganism as part of his religious beliefs, was enrolled in a prison program that provided vegan meals to accommodate religious diets. He was removed from this program twice after prison officials discovered he had purchased non-vegan food items from the prison store, such as chicken soup and Cheetos. The inmate claimed he bought these items to sell to other prisoners and would have stopped if he had known it could result in removal from the program. At the time of his removals, the prison’s policy did not explicitly list non-vegan purchases as grounds for removal, though this was later added. The inmate also alleged that only Black inmates were removed from the program, while similarly situated white inmates were not.The United States District Court for the Middle District of Georgia granted summary judgment to the prison officials on the inmate’s claims under the First, Eighth, and Fourteenth Amendments, as well as most of his claims under the Religious Land Use and Institutionalized Persons Act (RLUIPA). The court found that the officials were entitled to qualified immunity on the First Amendment and due process claims, that there was no evidence of discriminatory intent or similarly situated comparators for the equal protection claim, and that the non-vegan meals provided were nutritionally adequate. The court also dismissed the remaining RLUIPA claim as moot after the inmate was reenrolled in the vegan meal program.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that the officials were entitled to qualified immunity, that there was insufficient evidence to support the equal protection and Eighth Amendment claims, and that the RLUIPA claims either failed on the merits or were moot because the inmate had been reinstated in the vegan meal program. View "Sumrall v. Georgia Department of Corrections" on Justia Law

A Florida minister and licensed clinical Christian psychologist, who had provided court-mandated batterers’ intervention program (BIP) services for decades, sought certification from the Florida Department of Children and Families (DCF) to continue offering these services to individuals ordered by courts to attend BIPs following domestic violence convictions. The DCF denied his application because his curriculum incorporated a faith-based approach and addressed issues such as substance abuse and anger management, which conflicted with state regulations prohibiting faith-based ideology and requiring a specific psychoeducational model. The provider had previously operated without proper certification and had been denied certification in the past for similar reasons.After the DCF’s 2022 denial, the provider filed suit in the United States District Court for the Northern District of Florida, alleging that the regulation violated his rights under the Free Speech and Free Exercise Clauses of the First Amendment. The District Court granted summary judgment in favor of DCF, holding that court-ordered BIPs constitute government speech, and thus the state could set their content without implicating the First Amendment.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the District Court’s decision de novo. The Eleventh Circuit affirmed, holding that the curriculum and presentation of court-ordered BIPs are government speech. The court found that the state has historically used BIPs to communicate its own message, that participants would reasonably associate the program’s content with the government, and that the state exercises substantial control over the content. Because the programs are government speech, the provider’s Free Speech and Free Exercise claims could not proceed. The court also rejected the facial challenge to the regulation and affirmed the District Court’s judgment. View "Nussbaumer v. Secretary, Florida Dept of Children and Families" on Justia Law

A manufacturer of fasteners and related parts entered into a long-term supply agreement with a home appliance company, which later spun off its outdoor products division into a separate entity. The agreement, intended to make the manufacturer the exclusive supplier for a broad range of parts, quickly became the subject of disputes over its scope and the parties’ obligations. The parties attempted to resolve their disagreements through a settlement memorandum and a consent order, but further conflicts arose regarding price increases, performance, and payment for inventory.The United States District Court for the Southern District of Georgia was first asked to interpret the scope of the parties’ agreements. It found the original contract too indefinite to enforce in its entirety but held that subsequent agreements and the parties’ course of performance clarified which parts were covered. The district court also sanctioned the manufacturer for discovery violations, specifically for failing to produce product-level cost data, and struck its lost profits claim. The court denied the manufacturer’s motion for sanctions against the defendants for alleged spoliation, finding the motion untimely and the missing evidence irrelevant. The court granted summary judgment to the defendants on the manufacturer’s price increase claim, finding insufficient evidence to support the requested increases, and denied the manufacturer’s motion to amend its complaint to add a claim for prejudgment interest due to undue delay.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed each of the manufacturer’s challenges. The court held that the district court properly interpreted the scope of the agreements, did not abuse its discretion in imposing or denying discovery sanctions, correctly granted summary judgment on the price increase claim, and appropriately excluded certain evidence at trial. The Eleventh Circuit affirmed all orders and the final judgment in favor of the defendants. View "Whitesell Corporation v. Husqvarna Outdoor Products, Inc." on Justia Law

A woman who had a long history of calling her local sheriff’s office—often to complain about gunfire she believed was coming from private property near her home—called both the non-emergency number and 911 on Thanksgiving Day 2018 to report gunshots. Dispatchers informed her that deputies had previously investigated and determined the gunfire was lawful and that no further response would be made. Despite these explanations, she persisted, escalating her complaint to a 911 call. She declined offers to speak with deputies and refused contact when a deputy came to her home. Based on her repeated calls and refusal to accept the dispatchers’ explanations, two sheriff’s office employees initiated an investigation and swore out an affidavit for her arrest under a Georgia statute prohibiting disruptive or harassing conduct during 911 calls. The local district attorney later dismissed the charge.The woman then filed a civil suit in the United States District Court for the Southern District of Georgia, alleging violations of her First and Fourth Amendment rights, including claims of retaliatory arrest and malicious prosecution. The district court denied qualified immunity to the two officers on the First Amendment retaliation and malicious prosecution claims, finding genuine disputes of material fact regarding probable cause and the officers’ conduct in seeking the arrest warrant.On appeal, the United States Court of Appeals for the Eleventh Circuit considered whether the officers were entitled to qualified immunity. The court held that the officers were entitled to rely on the collective knowledge of the sheriff’s office dispatchers, who were aware of the plaintiff’s history of similar calls and the lawful nature of the gunfire. The court concluded that, given this collective knowledge, the officers had at least arguable probable cause to seek the plaintiff’s arrest under the relevant Georgia statute. As a result, the Eleventh Circuit reversed the district court’s denial of qualified immunity. View "Prospero v. Sullivan" on Justia Law

A physician licensed in Florida worked at a weight management clinic, where he was responsible for maintaining a federal registration to dispense controlled substances. After a report of missing controlled substances at the clinic, local police and the Drug Enforcement Administration (DEA) began investigating. The investigation revealed that the physician had issued numerous prescriptions for controlled substances without proper documentation of a doctor-patient relationship, failed to maintain required records, did not properly report or store controlled substances, and dispensed medication in violation of labeling requirements. The physician claimed that another clinic employee had forged his signature on some prescriptions and denied personal wrongdoing.The DEA issued an Order to Show Cause, notifying the physician of its intent to revoke his registration and deny pending applications, citing violations of federal and state law. The physician submitted a Corrective Action Plan but did not request a hearing. The DEA Administrator reviewed the evidence, including expert testimony and the physician’s admissions, and found that the physician’s continued registration would be inconsistent with the public interest. The Administrator revoked the registration and denied all pending applications, emphasizing the physician’s failure to accept responsibility and the inadequacy of his proposed corrective measures.The United States Court of Appeals for the Eleventh Circuit reviewed the DEA’s final order under an abuse of discretion standard, deferring to the agency’s factual findings if supported by substantial evidence. The court held that the physician received adequate procedural due process, as he was given notice and an opportunity for a hearing, which he declined. The court also rejected the argument that the DEA was required to find knowing or intentional misconduct under Ruan v. United States, holding that such a mens rea requirement does not apply to administrative revocation proceedings under 21 U.S.C. § 824. The petition for review was denied. View "Ashraf v. Drug Enforcement Administration" on Justia Law

Alan Dershowitz, a prominent law professor and attorney, represented President Donald Trump during his first impeachment trial in January 2020. During the Senate proceedings, Dershowitz made statements regarding the scope of impeachable offenses, suggesting that if a president acts with a mixed motive—including the belief that their reelection is in the public interest—such conduct should not be considered an impeachable offense unless it involves personal financial gain. His remarks were widely criticized and interpreted by various media outlets, including CNN, as asserting that a president could do anything to get reelected if he believed it was in the public interest.Following this coverage, Dershowitz alleged that CNN intentionally misrepresented his statements to defame him, omitting key context and orchestrating a scheme to damage his reputation. He filed a defamation suit in the United States District Court for the Southern District of Florida. The district court granted summary judgment in favor of CNN, finding that Dershowitz, as a public figure, failed to provide evidence that CNN acted with actual malice—meaning knowledge of or reckless disregard for the falsity of its statements.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s decision de novo. The appellate court affirmed the summary judgment, holding that Dershowitz did not present evidence showing that CNN’s commentators or producers entertained serious doubts about the truth of their reporting or acted with reckless disregard for its falsity. The court found that the evidence indicated the commentators sincerely believed their interpretations, and that groupthink or ideological alignment did not amount to actual malice. Thus, Dershowitz’s defamation claim could not proceed. View "Dershowitz v. Cable News Network, Inc." on Justia Law

NCR Corporation established five “top hat” retirement plans to provide supplemental life annuity benefits to senior executives. Each plan promised participants a fixed monthly payment for life, with language allowing NCR to terminate the plans so long as no action “adversely affected” any participant’s accrued benefits. In 2013, NCR terminated the plans and paid participants lump sums it claimed were actuarially equivalent to the promised annuities, using mortality tables, actuarial calculations, and a 5% discount rate. NCR knew that, statistically, about half of the participants would outlive the lump sums if they continued to withdraw the same monthly benefit, resulting in some participants receiving less than they would have under the original annuity.Participants filed a class-action lawsuit in the United States District Court for the Northern District of Georgia, alleging breach of contract and seeking either replacement annuities or sufficient cash to purchase equivalent annuities. The district court certified the class and granted summary judgment for the participants, finding that NCR’s lump-sum payments adversely affected the accrued benefits of at least some participants, in violation of the plan language. The court ordered NCR to pay the difference between the lump sums and the cost of replacement annuities, plus prejudgment and postjudgment interest.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s summary judgment order de novo. The Eleventh Circuit held that the plan language was unambiguous and did not permit NCR to unilaterally replace life annuities with lump sums that reduced the value of accrued benefits for any participant. The court affirmed the district court’s judgment, including the remedy of requiring NCR to pay the cost of replacement annuities and awarding prejudgment interest. View "Hoak v. NCR Corp." on Justia Law

The case centers on allegations that Okaloosa County, the sponsor of Destin Executive Airport, and Jay Odom, a fixed-base operator, violated federal and Florida False Claims Acts. The dispute arose after Odom, who owned Destin Jet, allegedly acquired the only competing fixed-base operator, Miracle Strip Aviation (later Regal Air), resulting in a single entity controlling all aeronautical services at the airport. Despite this consolidation, the County continued to certify to the Federal Aviation Administration (FAA) that it was not granting any exclusive rights, a requirement for receiving federal funding. In 2019, Robert Smith, a pilot and relator, sought to establish a competing fixed-base operator but was denied by the County, prompting him to file suit alleging false certifications in grant applications.The United States District Court for the Northern District of Florida dismissed Smith’s amended complaint with prejudice. The court found that the False Claims Act’s public disclosure bar applied because the essential allegations had already been reported in two 2014 news articles, which described the consolidation and the resulting grant assurance violations. The district court also determined that Smith’s complaint failed to meet the heightened pleading standard for fraud and denied his request for leave to further amend the complaint.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the dismissal de novo. The Eleventh Circuit held that Smith’s claims were barred by the False Claims Act’s public disclosure provision, as the news articles had already disclosed substantially the same allegations. The court further found that Smith was not an original source of the information, as his additional details did not materially add to the public disclosures. The Eleventh Circuit affirmed the district court’s dismissal and its denial of leave to amend, concluding that any amendment would be futile. View "Smith v. Odom" on Justia Law