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

Two Florida residents who use medical marijuana in compliance with state law sought to purchase firearms but were denied after disclosing their marijuana use on a federal form. A third individual, a lawful gun owner, wished to participate in Florida’s medical marijuana program but refrained due to concerns about federal prosecution. All three, along with the Florida Commissioner of Agriculture, challenged the constitutionality of federal statutes and regulations that prohibit “unlawful users” of controlled substances—including marijuana—from possessing or purchasing firearms. The complaint did not allege that the plaintiffs had been convicted of any crimes or that their marijuana use rendered them dangerous.The United States District Court for the Northern District of Florida assumed the plaintiffs were protected by the Second Amendment but dismissed the complaint. The court applied the historical analysis required by District of Columbia v. Heller and New York State Rifle & Pistol Association v. Bruen, concluding that the federal prohibitions were consistent with the nation’s tradition of disarming individuals engaged in criminal conduct or deemed dangerous, such as felons, the mentally ill, or habitual drug users.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the case de novo. The court held that, at the motion to dismiss stage, the government failed to show that the plaintiffs—state-law-compliant medical marijuana users—were relevantly similar to either felons or dangerous individuals, the two historical analogues offered to justify the federal restrictions. The court emphasized that the complaint did not allege facts showing the plaintiffs were dangerous or had committed felonies. Accordingly, the Eleventh Circuit vacated the district court’s dismissal and remanded the case for further proceedings, holding that the plaintiffs had plausibly alleged a violation of their Second Amendment rights as applied to them. View "Florida Commissioner of Agriculture v. Attorney General of the United States" on Justia Law

A tenured English professor at a public university objected to the administration’s decision to resume in-person instruction during the Covid-19 pandemic. The professor, who had health concerns and was partially vaccinated, communicated his opposition by emailing students about his forced return to the classroom, attaching correspondence with his department chair, and using an unconventional email signature. The university responded by reassigning his courses, placing him on paid leave, and proposing a five-day suspension without pay, along with requirements for improved email professionalism. The professor then filed a lawsuit alleging violations of his First Amendment and procedural due process rights.The United States District Court for the Northern District of Florida dismissed the complaint. The court found that the professor’s email did not constitute protected speech under the First Amendment, as it was gratuitous information in a logistical message sent in his professional capacity. The court also rejected the procedural due process claim for failure to exhaust state-law remedies. The court’s dismissal order allowed the professor until July 3 to amend his complaint, instructing the clerk to enter judgment if no amendment was filed. The professor did not amend, and the clerk did not immediately enter judgment. On July 14, the court issued another order directing entry of judgment, which the clerk entered that day. The professor filed his notice of appeal on August 10.The United States Court of Appeals for the Eleventh Circuit reviewed whether the appeal was timely. Applying its precedent from Schuurman v. Motor Vessel Betty K V, the court held that the thirty-day appeal period began on the last day set for amending the complaint, not the later date when judgment was entered. Because the notice of appeal was filed more than thirty days after the amendment deadline, the court dismissed the appeal for lack of jurisdiction. View "Burt v. President of University of Florida" on Justia Law

A defendant was indicted for his role in a drug-trafficking organization operating across California, Georgia, and Nevada. He pleaded guilty to illegal reentry but not guilty to other charges, including conspiracy to possess with intent to distribute marijuana and possession with intent to distribute marijuana. At trial, the district court, over the defendant’s objection, empaneled an anonymous jury, concealing jurors’ names but allowing some personal information to be shared during voir dire. The government presented evidence of the defendant’s involvement in transporting cash and marijuana, and the defendant testified in his own defense, admitting to marijuana sales in California but denying involvement in the broader conspiracy alleged.The United States District Court for the Northern District of Georgia presided over the trial. The jury convicted the defendant of conspiracy to possess with intent to distribute less than 100 kilograms of marijuana and possession with intent to distribute marijuana, but acquitted him on money-laundering and firearm charges. At sentencing, the court attributed a significant drug quantity to the defendant, considered evidence including conduct for which he was acquitted, and imposed concurrent sentences of 120 months on each count, below the calculated guideline range. The defendant objected to the use of acquitted conduct and the calculation of the guideline range, but the court overruled these objections.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that any error in empaneling an anonymous jury was harmless because several factors justified the measure and the court minimized prejudice. The appellate court also found no abuse of discretion in refusing a multiple-conspiracies instruction, held that considering acquitted conduct at sentencing was permissible under existing precedent, and concluded that the sentence imposed was both substantively and procedurally reasonable. The Eleventh Circuit affirmed the convictions and sentence. View "United States v. Touray" on Justia Law

An Army veteran serving a lengthy prison sentence in Florida applied for and received disability benefits for service-related post-traumatic stress disorder. Initially, the Veterans Benefits Administration approved his claim at a 70 percent rate, later increasing it to 80 percent. However, after his felony conviction and incarceration, the Administration reduced his monthly benefits to a 10 percent rate pursuant to 38 U.S.C. § 5313, which limits disability payments for veterans incarcerated for more than 60 days due to a felony.The veteran filed a pro se complaint in the United States District Court for the Middle District of Florida, naming the United States Congress as defendant. He alleged that the statute reducing his benefits violated the Bill of Attainder Clause and the Equal Protection component of the Fifth Amendment, seeking both prospective and retroactive relief. A magistrate judge recommended dismissal, assuming without deciding that the court had jurisdiction over facial constitutional challenges, but finding the claims frivolous. The district court adopted this recommendation, dismissing the complaint and declining to address the plaintiff’s general objections.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that sovereign immunity barred the suit against Congress, as Congress has not waived immunity for constitutional claims arising from its enactment of legislation. The court further held that any amendment to name a different defendant would be futile because the Veterans’ Judicial Review Act provides an exclusive review scheme for challenges to veterans’ benefits decisions, channeling all such claims—including constitutional challenges—through the administrative process and ultimately to the Court of Appeals for Veterans Claims and the Federal Circuit. The Eleventh Circuit vacated the district court’s judgment and remanded with instructions to dismiss the case without prejudice for lack of jurisdiction. View "Johnson v. United States Congress" on Justia Law

Arthur Huggins, a community member in Manatee County, Florida, regularly attended local school board meetings to criticize the School Board and Superintendent Cynthia Saunders for their decision to take control of Lincoln Memorial Academy, a Black-owned charter school, and remove its administration. Huggins was known for his outspoken opposition, including public comments and calls for investigations into the Board’s actions. At a November 2019 board meeting, after standing at the back of the room due to back pain, Huggins was ordered by the school district’s Chief of Security, at Saunders’s direction, to sit or leave. When Huggins explained his situation, he was removed from the meeting by a police officer and prevented from delivering his public comment. The incident was later publicized, and the Board and Saunders issued apologies.Huggins filed suit in state court against the School Board, Saunders, and several individuals, alleging violations of his First Amendment rights, among other claims. The case was removed to the United States District Court for the Middle District of Florida. The district court dismissed Huggins’s federal claims with prejudice, finding that the individual defendants were entitled to qualified immunity and that Huggins had not established municipal liability against the Board or the City of Bradenton. The court also denied Huggins’s request to amend his complaint a second time and declined to exercise supplemental jurisdiction over his state law claims.The United States Court of Appeals for the Eleventh Circuit reversed the district court’s dismissal of Huggins’s First Amendment claims against Saunders, holding that Saunders was not entitled to qualified immunity and that Huggins plausibly alleged both viewpoint discrimination and retaliation. The court affirmed the dismissal of claims against the other defendants and the denial of leave to amend, but vacated the district court’s decision declining supplemental jurisdiction over state claims, remanding for further proceedings. View "Huggins v. School District of Manatee County" on Justia Law

Two Black celebrities brought suit after being stopped by Clayton County, Georgia police officers on the jet bridge while boarding flights at Hartsfield-Jackson Atlanta International Airport. The officers, as part of a drug interdiction program, stopped passengers after they had cleared security and boarding checks, requested and retained their identification and boarding passes, questioned them about drugs, and asked to search their luggage. Both plaintiffs alleged they felt coerced, were not free to leave, and believed they had no choice but to comply. They further alleged that the program disproportionately targeted Black passengers and that the stops were neither random nor consensual.The United States District Court for the Northern District of Georgia dismissed all claims. It found the encounters were voluntary and not seizures under the Fourth Amendment, that any searches were consensual, and that the plaintiffs failed to plausibly allege racial discrimination or a policy supporting municipal liability. The court also granted qualified immunity to the individual officers.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that the plaintiffs plausibly alleged they were subjected to unreasonable seizures and, in one case, an unreasonable search, in violation of the Fourth Amendment. The court found that the circumstances—officers blocking the plaintiffs’ paths, retaining their documents, and questioning them in a confined space—amounted to seizures, and that the search was not voluntary. However, the court affirmed qualified immunity for the individual officers, as the law was not clearly established. The court also found that the plaintiffs plausibly alleged a policy or custom by Clayton County that could support municipal liability under Monell. The court affirmed dismissal of the equal protection claims, finding insufficient allegations of discriminatory intent. The court reversed in part, allowing the Fourth Amendment claims against Clayton County to proceed. View "Andre v. Clayton County" on Justia Law

Law enforcement officers in Baldwin County, Alabama, stopped a vehicle for a traffic violation and discovered three occupants: Timothy Buchanan, Jaleeshia Robinson, and Tyre Crawford. A search of the vehicle revealed forged and stolen identification cards, credit cards, and checks, as well as equipment for producing counterfeit checks. Buchanan admitted to cashing fraudulent checks using stolen or forged identification, and evidence showed he was in frequent communication with his co-defendants about the scheme. Robinson, who cooperated with the government, testified that Buchanan’s role was to cash checks, while she and Crawford created the fraudulent documents and stole checks from mailboxes.The United States District Court for the Southern District of Alabama presided over Buchanan’s jury trial. The jury acquitted him of one count of aggravated identity theft but convicted him on conspiracy to commit bank fraud, possession of five or more identification documents with intent to use or transfer, possession of counterfeited or forged securities, a second count of aggravated identity theft, and possession of stolen mail. The district court sentenced Buchanan to 116 months’ imprisonment and ordered restitution. Buchanan challenged the sufficiency of the evidence for several convictions, the application of a sentencing enhancement for sophisticated means, and the calculation of restitution.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It affirmed Buchanan’s convictions, holding that sufficient evidence supported his convictions under an aiding and abetting theory, and that his aggravated identity theft conviction was not plainly erroneous under Dubin v. United States, 599 U.S. 110 (2023), because the use of another’s identification was central to the predicate offense. However, the court vacated the sentence in part, finding error in the application of the sophisticated means enhancement and in the restitution calculation, and remanded for further proceedings on those issues. View "United States v. Buchanan" on Justia Law

A dispute arose after a rare vehicle, originally owned by a Wisconsin man, was stolen and shipped to Europe. Richard Mueller inherited the vehicle and sold part of his interest to Joseph Ford. Years later, TL90108 LLC (“TL”) purchased the vehicle overseas and, upon attempting to register it in the United States, was notified that Ford and Mueller were the owners of record. Ford and Mueller sued TL in Wisconsin state court for a declaratory judgment and replevin. The trial court dismissed the case on statute-of-repose grounds, but the Wisconsin Court of Appeals reversed, and the Wisconsin Supreme Court granted review. While the appeal was pending, Ford filed for Chapter 11 bankruptcy but did not list TL as a creditor or provide it with formal notice of the bankruptcy proceedings or relevant deadlines.The United States Bankruptcy Court for the Southern District of Florida set a deadline under Federal Rule of Bankruptcy Procedure 4007(c) for creditors to file complaints objecting to the discharge of debts. TL did not file a complaint before this deadline, as it was unaware of the relevant facts supporting a fraud claim until later discovery in the Wisconsin litigation. After learning of Ford’s alleged fraud, TL moved to extend the deadline and file a complaint under 11 U.S.C. § 523(c), arguing for equitable tolling and asserting a due process violation due to inadequate notice. The bankruptcy court denied the motion, relying on the Eleventh Circuit’s precedent in In re Alton, which held that equitable tolling does not apply to Rule 4007(c) deadlines.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the bankruptcy court’s decision. The court held that its prior decision in In re Alton remains binding and precludes equitable tolling of Rule 4007(c)’s deadline, even in light of subsequent Supreme Court decisions. The court also held that TL’s actual notice of the bankruptcy proceeding satisfied due process, and thus, the deadline could not be extended on that basis. View "TL90108 LLC v. Ford" on Justia Law

Stewart and Michael Parnell were involved in the management and sales operations of Peanut Corporation of America (PCA), which produced peanut products in Georgia. In 2009, PCA’s plant was identified as the source of a nationwide salmonella outbreak, resulting in over 700 illnesses and nine reported deaths. Evidence at trial showed that the Parnells knowingly shipped untested or contaminated peanut products with fraudulent certificates and failed to notify customers when contamination was discovered. The outbreak had significant health and economic impacts, particularly in southwest Georgia, a major peanut-producing region.The Parnells were indicted on multiple counts related to food adulteration, misbranding, fraud, and obstruction of justice. Their joint trial took place in the Albany Division of the Middle District of Georgia, where both were convicted on most counts and sentenced to lengthy prison terms. The United States Court of Appeals for the Eleventh Circuit affirmed their convictions and sentences on direct appeal. Subsequently, each filed a motion under 28 U.S.C. § 2255 in the United States District Court for the Middle District of Georgia, arguing, among other things, that their trial counsel was ineffective for not seeking a change of venue due to presumed jury prejudice from pretrial publicity. The district court denied both motions, finding the attorneys’ decision was a reasonable strategic choice.On appeal, the United States Court of Appeals for the Eleventh Circuit considered whether presumed jury prejudice under Skilling v. United States, 561 U.S. 358 (2010), could establish both deficient performance and prejudice under Strickland v. Washington, 466 U.S. 668 (1984), for an ineffective assistance claim. The court held that a presumption of jury prejudice does not automatically establish deficient performance; both prongs of Strickland must be independently satisfied. The court found the defense teams’ strategic decision not to seek a venue change was reasonable and affirmed the denial of § 2255 relief. View "Parnell v. USA" on Justia Law

Over a ten-day period in April 2020, a series of armed robberies targeted MetroPCS stores in the Miami area. The perpetrator, later identified as Francisco Louis, used a consistent method and attire, including a black Mercedes with a distinctive dent. After a police chase, Louis was apprehended, and evidence linking him to the robberies was recovered from his car, satchel, and residence. He was charged with six counts of Hobbs Act robbery.After his arrest, Louis spent several months in state custody before being transferred to federal custody in January 2021. The United States District Court for the Southern District of Florida granted four government-requested continuances for his arraignment and indictment, citing COVID-19 pandemic restrictions. Louis was indicted in April 2021, and his trial was initially set for August 2021. However, Louis, through counsel, requested three additional continuances to prepare for trial, resulting in the trial beginning in March 2022. He was convicted on all counts and sentenced to 218 months in prison.On appeal to the United States Court of Appeals for the Eleventh Circuit, Louis argued violations of both the Speedy Trial Act and the Sixth Amendment’s speedy trial guarantee, as well as challenges to the sufficiency of the evidence, jury instructions, and certain evidentiary rulings. The Eleventh Circuit held that Louis had waived his statutory Speedy Trial Act claim by failing to file a valid motion to dismiss before trial. Regarding the Sixth Amendment claim, the court found that although the delay was presumptively prejudicial, the reasons for delay were attributable to the pandemic and Louis’s own requests, and he failed to show actual prejudice. The court also rejected his other challenges and affirmed the conviction and sentence. View "USA v. Louis" on Justia Law