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

Andrew Butler III was convicted by a jury of knowingly and intentionally possessing five grams or more of methamphetamine with the intent to distribute. The district court sentenced him to 84 months of imprisonment followed by five years of supervised release. Butler appealed, arguing that the district court wrongly revoked his Sixth Amendment right to self-representation and that the evidence was insufficient to support the jury’s verdict.Initially, the district court appointed Assistant Federal Public Defender Elizabeth Vallejo to represent Butler, but he expressed dissatisfaction, leading to her replacement by Robert A. Morris. Butler continued to file pro se motions disparaging Morris, resulting in Morris’s replacement by Richard A. Greenberg. Butler then requested to represent himself, and after a Faretta hearing, the court allowed it, appointing Greenberg as standby counsel. However, Butler’s disruptive behavior, including refusing to attend hearings and threatening not to attend the trial, led the court to revoke his self-representation right and appoint Mutaqee Akbar as his counsel.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that the district court did not err in revoking Butler’s right to self-representation due to his repeated and serious obstructionist misconduct, which spanned months and disrupted the trial schedule. The court emphasized that the right to self-representation is not a license to disrupt court proceedings and that the district court had given Butler multiple warnings and opportunities to comply.Regarding the sufficiency of the evidence, the Eleventh Circuit found that the evidence presented at trial, including the methamphetamine found in the safe in Butler’s hotel room and his incriminating post-arrest recorded call, was sufficient to support the conviction. The court affirmed the district court’s judgment, upholding Butler’s conviction and sentence. View "United States v. Butler" on Justia Law

Robert Turner, a property owner in Suwannee County, Florida, claimed that his homestead property was sold at an impermissibly low amount under Florida law, which deprived him of any surplus after back taxes and costs were deducted. Turner had a homestead exemption on his property, which was automatically renewed until 2015. After failing to pay property taxes, a tax certificate was issued, and a tax deed sale was conducted in 2015. Turner alleged that the sale was unlawful because it did not account for the homestead exemption, and he did not receive proper notice of the sale.Turner initially sought relief in state court, challenging the removal of his homestead exemption, but his complaint was dismissed as untimely. He then filed a federal lawsuit under 42 U.S.C. § 1983, claiming violations of his constitutional rights, including First Amendment retaliation, Fourth Amendment illegal seizure, and due process violations. The federal district court dismissed his complaint, finding that abstention was warranted under the comity doctrine, which prevents federal courts from interfering with state tax administration when state remedies are adequate.The United States Court of Appeals for the Eleventh Circuit reviewed the district court's decision. The court affirmed the dismissal, holding that the relief Turner sought would disrupt Florida's administration of its ad valorem property tax scheme. The court found that Florida provided plain, adequate, and complete state remedies, including the ability to challenge tax deed sales and homestead exemption removals in state court. The court concluded that the district court did not abuse its discretion in abstaining from exercising jurisdiction under the comity doctrine. View "Turner v. Jordan" on Justia Law

Amir Meshal, a professional truck driver, was stopped by Georgia State Police officers for a minor traffic infraction. During the stop, the officers discovered Meshal was on the FBI’s No Fly List. Despite instructions not to detain him based solely on this status, the officers handcuffed Meshal, placed him in a patrol car, and searched his truck. They questioned him about his religion and international travel while waiting for guidance from the FBI. After 91 minutes, the FBI cleared Meshal, and he was released with a warning citation for the traffic infraction.Meshal sued the officers in the United States District Court for the Southern District of Georgia, alleging violations of his Fourth Amendment rights due to the extended detention and the search of his truck. The officers moved to dismiss the complaint on qualified immunity grounds, arguing that Meshal failed to allege a violation of clearly established law. The district court denied the motion, finding that the complaint sufficiently alleged that the officers detained Meshal without arguable reasonable suspicion and searched his truck without arguable probable cause.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court agreed with the district court, holding that the officers were not entitled to qualified immunity at this stage. The court found that the officers lacked even arguable reasonable suspicion to justify prolonging the traffic stop beyond the time necessary to complete tasks related to the traffic infraction. Additionally, the court held that the search of Meshal’s truck was not supported by arguable probable cause. Therefore, the Eleventh Circuit affirmed the district court’s denial of qualified immunity. View "Meshal v. Commissioner, Georgia Department of Public Safety" on Justia Law

A member of the Church of Christ, Stephen Jarrard, participated in a county jail's volunteer ministry program but was later dismissed and denied reentry. He sued, claiming his dismissal violated his free speech rights under the First Amendment. The district court granted summary judgment against Jarrard, rejecting his claims.The United States District Court for the Northern District of Georgia initially reviewed the case. The court applied the Pickering test, typically used for government employees, and concluded that Jarrard's speech was not constitutionally protected. The court also found that even if his speech were protected, the law was not clearly established, granting qualified immunity to the jail officials.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court determined that the Pickering test was not appropriate for Jarrard, who was not a de facto government employee. Instead, the court applied the usual forum analysis and found that the jail officials engaged in viewpoint discrimination by excluding Jarrard based on his beliefs about baptism. The court also held that the jail's policies violated the First Amendment by giving officials unbridled discretion in evaluating volunteer applications. The court concluded that these actions could not survive strict scrutiny and that the law was clearly established, denying qualified immunity to the officials.The Eleventh Circuit reversed the district court's decision granting summary judgment and remanded the case for further proceedings on Jarrard's claims. View "Jarrard v. Sheriff of Polk County" on Justia Law

George Wagner III filed for Chapter 7 bankruptcy, omitting a show horse he had purchased for his daughter from his bankruptcy petition. Wagner claimed he believed the horse belonged to his daughter, as it was registered under her name with the United States Equestrian Federation. The bankruptcy court held a bench trial and found Wagner, his wife, and his daughter credible in their belief that the horse was the daughter’s property. Consequently, the bankruptcy court granted Wagner a discharge of his debts.The United States District Court for the Southern District of Florida vacated the bankruptcy court’s order, concluding that Wagner knowingly and fraudulently omitted the horse from his bankruptcy case. The district court pointed to Wagner’s email communications during his divorce proceedings, the timing of the insurance policy transfer, and the handling of lease proceeds as evidence of fraudulent intent. The district court remanded the case to the bankruptcy court to enter judgment denying discharge.The United States Court of Appeals for the Eleventh Circuit reviewed the case and reversed the district court’s order. The appellate court emphasized the need to defer to the bankruptcy court’s credibility determinations, which were supported by the testimony and documentary evidence. The appellate court found that the bankruptcy court did not clearly err in concluding that Wagner did not possess fraudulent intent in omitting the horse from his bankruptcy case. Therefore, the appellate court affirmed the bankruptcy court’s order of discharge. View "OHI Asset (VA) Martinsville SNF, LLC v. Wagner" on Justia Law

Jeremy Hitt, a Remote Control Operator for CSX Transportation, Inc., was terminated after receiving three workplace violations within a three-year period. Hitt's first violation occurred in 2017 for failing to leave unattended train cars at a specified location. In the summer of 2018, Hitt refused to work during a lightning storm, citing safety concerns, and later refused to operate the train at a speed he considered unsafe. His second violation was in November 2018 for failing to secure his train properly. The third violation occurred in January 2019 when Hitt failed a banner test by using the emergency brake to stop the train.The United States District Court for the Northern District of Alabama granted summary judgment to CSX, concluding that Hitt failed to provide sufficient evidence of causation to support his claim under the Federal Railroad Safety Act (FRSA). The court found that Hitt could not establish that his protected activity (refusing to work during the lightning storm) was a contributing factor to his termination.The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court held that Hitt failed to establish causation, as there was no evidence that his protected activity contributed to his termination. The court noted that the decision-makers who terminated Hitt were unaware of his protected activity and that Hitt's supervisor, who allegedly retaliated against him, had no influence over the termination decision. The court also found that the temporal gap between the protected activity and the adverse action was too long to establish causation based on temporal proximity alone. Thus, the court concluded that Hitt could not prove the elements of his FRSA claim. View "Hitt v. CSX Transportation Inc" on Justia Law

Three members of the Gangster Disciples, Vertuies Wall, Lawrence Grice, and Lewis Mobley, were indicted on charges including conspiracy under the Racketeer Influenced and Corrupt Organizations Act (RICO) and drug trafficking. The indictment included notice of enhanced sentencing under 18 U.S.C. § 1963(a). Mobley was found competent to stand trial despite a defense expert's testimony about his mental illness. The trial lasted five weeks, with over sixty witnesses testifying about the gang's criminal activities, including murder and drug trafficking. The jury found all three defendants guilty of RICO conspiracy, with Grice also convicted of drug trafficking conspiracy.In the United States District Court for the Northern District of Georgia, the jury found Mobley and Wall guilty of RICO conspiracy involving murder, which subjected them to enhanced sentencing. Mobley was also convicted of attempted murder and related firearms offenses. Grice was convicted of RICO conspiracy and drug trafficking conspiracy. The district court sentenced Mobley to 480 months and Wall to 360 months, both under the enhanced sentencing provision. Grice received a sentence based on his convictions.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court affirmed the district court's findings, holding that the evidence was sufficient to support the convictions and the enhanced sentences. The court found no error in the jury instructions or the special verdict form regarding the enhanced sentencing provision. The court also held that any potential error in the jury instructions was harmless beyond a reasonable doubt. Additionally, the court rejected challenges to the admission of testimony about non-testifying coconspirators' convictions and found no cumulative error affecting the defendants' substantial rights. The court affirmed the defendants' convictions and sentences. View "United States v. Wall" on Justia Law

In August of 2020, Matthew Ostrander, a homeless fugitive, was arrested in Gainesville, Florida, for failing to register as a sex offender following a 2007 child pornography conviction. At the time of his arrest, Ostrander possessed four electronic devices, three of which contained 480 computer-generated images (CGI) of children involved in sexual activity. These images did not depict real children. Ostrander was charged with knowing possession of an obscene visual depiction of a minor engaging in sexually explicit conduct in violation of 18 U.S.C. § 1466A(b)(1), (d)(4).The United States District Court for the Northern District of Florida denied Ostrander's motion to dismiss the possession charge, ruling it was untimely and without merit. After a two-day trial, a jury found Ostrander guilty. Ostrander appealed, challenging the constitutionality of the statute and the sufficiency of the evidence and alleging prosecutorial misconduct.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that the statute was not facially unconstitutional, as it was neither overbroad nor vague. The court found that the statute's legitimate sweep outweighed any potential unconstitutional applications. The court also determined that the evidence was sufficient to sustain Ostrander's conviction, as a reasonable jury could find him guilty beyond a reasonable doubt based on the evidence presented. Finally, the court found no prosecutorial misconduct that would have affected the jury's verdict. The Eleventh Circuit affirmed Ostrander's conviction. View "U.S. v. Ostrander" on Justia Law

Adam and Miranda Steines, along with Andrew Ormesher, filed a class action lawsuit against Westgate, a resort company, alleging violations of the Military Lending Act (MLA). The Steines, who purchased a timeshare in Orlando and financed it through a loan from Westgate, claimed that Westgate's loan documents did not comply with the MLA's requirements, including the prohibition of mandatory arbitration clauses. The Steines sought rescission of their timeshare, injunctive relief, damages, and restitution.The United States District Court for the Middle District of Florida held an evidentiary hearing and denied Westgate's motions to compel arbitration and dismiss the complaint. The court found that the MLA applied to the timeshare loan and that the MLA's prohibition on mandatory arbitration clauses overrode the Federal Arbitration Act (FAA). Westgate appealed the decision, arguing that the district court should not have addressed the arbitrability issue and that the MLA did not override the FAA.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's decision. The court held that the question of whether the MLA overrides the FAA is a matter for the court to decide, not the arbitrator. The court found that the MLA explicitly prohibits mandatory arbitration clauses in consumer credit contracts involving servicemembers, thereby overriding the FAA. Additionally, the court agreed with the district court's finding that the timeshare loan did not qualify as a "residential mortgage" under the MLA, as the timeshare units were more akin to hotel rooms than residential dwellings.As a result, the Eleventh Circuit dismissed the interlocutory appeal for lack of jurisdiction, affirming that the MLA's provisions rendered the FAA inapplicable in this case. View "Steines v. Westgate Palace, L.L.C." on Justia Law

Candace Hensley sustained injuries from a trip and fall accident at a Westin Hotel in Indianapolis, Indiana, on May 2, 2017. She and her husband, Timothy Hensley, filed a lawsuit in the State Court of Gwinnett County, Georgia, against Westin Hotel and Westin Hotel Management, L.P. (WHM), alleging negligence and loss of consortium. Merritt Hospitality, LLC (Merritt) and WHM responded, asserting that Merritt was incorrectly named and that Westin Hotel was not a legal entity. The Hensleys amended their complaint to include Merritt and Marriott International, Inc. (Marriott). The case was removed to the United States District Court for the Northern District of Georgia based on diversity jurisdiction.Hartford Casualty Insurance Company, which had paid workers’ compensation benefits to Mrs. Hensley, intervened to protect its subrogation lien. The district court applied Indiana tort law and granted summary judgment in favor of the defendants, concluding that they either did not control the hotel premises or lacked actual knowledge of the hazard. The court also dismissed Hartford’s claim, as it depended on the Hensleys' success. The Hensleys appealed the decision.The United States Court of Appeals for the Eleventh Circuit reviewed the case and determined that the district court lost subject matter jurisdiction when Hartford, an indispensable party, intervened, destroying complete diversity. The appellate court vacated the district court’s summary judgment order and remanded the case with instructions to remand it to the State Court of Gwinnett County, Georgia. The main holding was that Hartford’s intervention as a matter of right and its status as an indispensable party required the case to be remanded to state court due to the lack of complete diversity. View "Hensley v. Westin Hotel" on Justia Law