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

The case involves an FBI investigation into Jeffrey Alan Siegmeister, the State Attorney for the Third Judicial Circuit of Florida, and Marion Michael O'Steen, a defense attorney. The investigation began after Andy Tong, who was being prosecuted by Siegmeister, informed the FBI that O'Steen would have to pay Siegmeister $50,000 for a favorable case disposition. The investigation concluded with a grand jury indictment against Siegmeister and O'Steen, charging them with multiple counts, including conspiracy to engage in bribery and extortion.In the United States District Court for the Middle District of Florida, Siegmeister entered a plea agreement and pled guilty to several counts, including conspiracy and bribery. O'Steen stood trial on four counts. The jury found O'Steen not guilty on Counts One and Two but guilty on Counts Three and Four. The District Court sentenced O'Steen to concurrent prison terms of 44 months, followed by supervised release, and ordered him to pay fines and restitution.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court found that the jury instructions on Count Three were flawed, as they allowed for a conviction based on an incorrect legal theory. The court also determined that the evidence was insufficient to prove that O'Steen knew of the fifteen-day reporting requirement for filing Form 8300, as required by Count Four. Consequently, the Eleventh Circuit reversed the District Court's judgment and instructed the lower court to enter a judgment of acquittal for O'Steen. View "USA v. O'Steen" on Justia Law

Ronald Rubin filed a lawsuit naming Kimberly Grippa as part of a criminal enterprise. His lawyer sent allegedly defamatory letters to state officials, asking them to investigate the alleged criminal enterprise and included copies of the complaint. Grippa sued Rubin for defamation, claiming the letters harmed her reputation and professional standing. Rubin moved for summary judgment, arguing the letters were protected by Florida’s absolute and qualified litigation privileges and that he could not be held vicariously liable for his lawyer’s actions.The United States District Court for the Northern District of Florida denied Rubin’s motion for summary judgment on all grounds. The court found that the letters were not protected by the absolute litigation privilege because they were sent outside the litigation process and included additional statements beyond those in the complaint. The court also determined that there was a genuine dispute of material fact regarding whether the statements were made with express malice, precluding the qualified litigation privilege. Lastly, the court rejected Rubin’s vicarious liability argument, suggesting that Rubin directed his lawyer’s actions.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that the denial of Florida’s absolute litigation privilege is immediately appealable under the collateral order doctrine but lacked jurisdiction to consider the denial of the qualified litigation privilege or the vicarious liability issue. The court affirmed the district court’s denial of the absolute litigation privilege, concluding that the letters were sent outside the judicial process and included additional defamatory statements. The court dismissed the appeal regarding the qualified litigation privilege and vicarious liability for lack of jurisdiction. View "Grippa v. Rubin" on Justia Law

Dr. Jeffery D. Milner, a physician, brought a qui tam action under the False Claims Act (FCA) against Baptist Health Montgomery, Prattville Baptist, and Team Health. Milner alleged that while working at a hospital owned by the defendants, he discovered that they were overprescribing opioids and fraudulently billing the government for them. He claimed that he was terminated in retaliation for whistleblowing after reporting the overprescription practices to his superiors.Previously, Milner filed an FCA retaliation lawsuit against the same defendants in the U.S. District Court for the Northern District of Alabama, which was dismissed with prejudice for failure to state a claim. The court found that Milner did not sufficiently allege that he engaged in protected conduct under the FCA or that his termination was due to such conduct. Following this dismissal, Milner filed the current qui tam action in the U.S. District Court for the Middle District of Alabama. The district court dismissed this action as barred by res judicata, relying on the Eleventh Circuit's decisions in Ragsdale v. Rubbermaid, Inc. and Shurick v. Boeing Co.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's dismissal. The court held that Milner's qui tam action was barred by res judicata because it involved the same parties and the same cause of action as his earlier retaliation lawsuit. The court found that both lawsuits arose from a common nucleus of operative fact: the defendants' alleged illegal conduct and Milner's discovery of that conduct leading to his discharge. The court also noted that the United States, which did not intervene in the qui tam action, was not barred from pursuing its own action in the future. View "Milner v. Baptist Health Montgomery" on Justia Law

Kh’Lajuwon Murat was released from prison and began his supervised release. The government petitioned the district court to revoke his supervised release due to seven alleged violations, including failing to submit truthful reports, unauthorized travel, associating with criminals, and committing new offenses. Murat admitted to three violations, and the district court revoked his supervised release, sentencing him to five months’ imprisonment and 54 months’ supervised release. The court held the remaining violations in abeyance.The district court held a second hearing on Murat’s final day of imprisonment to address the remaining violations. Murat challenged the court’s jurisdiction, but the court found for the government on one violation and dismissed the others. Murat was sentenced to an additional four months’ imprisonment and 48 months’ supervised release. Murat appealed, arguing that the district court lacked jurisdiction to adjudicate the remaining violations after the first revocation and that the second sentence was illegal.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that the district court retained jurisdiction to adjudicate the remaining violations because the petition was filed before the first revocation. The court explained that revocation does not terminate the term of supervised release, and the district court’s jurisdiction continues during the defendant’s imprisonment. The court also found that the district court’s procedure of holding violations in abeyance and issuing separate revocation orders did not constitute plain error. The judgment and sentence of the district court were affirmed. View "USA v. Murat" on Justia Law

Several plaintiffs, including United States Sugar Corporation, Okeelanta Corporation, and Sugar Cane Growers Cooperative of Florida, challenged the United States Army Corps of Engineers' approval of the Everglades Agricultural Area Project (EAA Project). The plaintiffs argued that the Corps violated the Administrative Procedure Act by using the wrong water supply baseline in its Savings Clause analysis and by failing to conduct a separate analysis for the standalone operation of the storm water treatment area (STA). They also claimed that the Corps violated the National Environmental Policy Act (NEPA) by not evaluating the effects of the standalone STA operation in its Environmental Impact Statement (EIS).The Southern District of Florida granted summary judgment in favor of the Corps. The district court held that the Corps did not violate the Savings Clause by using the LORS 2008 baseline instead of the year 2000 baseline, as the water supply loss reflected in LORS 2008 was due to structural integrity issues with the Herbert Hoover Dike, not an implementation of the Plan. The court also found that the Corps' decision to use LORS 2008 was reasonable and that the plaintiffs had standing to bring their claims.The United States Court of Appeals for the Eleventh Circuit affirmed the district court's decision on the plaintiffs' first claim, agreeing that the Corps did not violate the Savings Clause. The court also affirmed the district court's decision on the plaintiffs' third claim, holding that the Corps did not violate NEPA by failing to include the standalone STA operation in its EIS, as the standalone STA had independent utility and could be evaluated in a supplemental EIS.However, the Eleventh Circuit reversed the district court's decision on the plaintiffs' second claim, finding that it was not ripe for review because the Corps had not made a final decision authorizing the standalone operation of the STA. The court remanded the case with instructions to dismiss the second claim for lack of finality and ripeness. View "United States Sugar Corp. v. Army Corps of Engineers" on Justia Law

In 2000, Reginald Bertram Johnson abducted and raped 14-year-old C.A. at gunpoint. Following the assault, C.A. was examined by Dr. Scott Silla at a rape treatment center, where biological specimens were collected. Eight years later, a DNA match linked Johnson to the specimens. At trial, the prosecution introduced Dr. Silla’s report to support the chain of custody for the specimens, despite Johnson’s objection that the report’s admission violated the Confrontation Clause since Dr. Silla did not testify. Johnson was convicted and later filed a habeas corpus petition, which was denied.The Florida District Court of Appeal upheld Johnson’s convictions, ruling that the report was properly authenticated as a business record and that the Confrontation Clause was not violated because Johnson had the opportunity to cross-examine other witnesses involved in the collection and testing of the specimens. The Supreme Court of Florida and the U.S. Supreme Court denied further review. Johnson then exhausted his state post-conviction remedies.The United States Court of Appeals for the Eleventh Circuit reviewed the case, focusing on whether the admission of Dr. Silla’s report without his testimony violated Johnson’s confrontation rights. The court assumed, without deciding, that there was a Confrontation Clause violation but found that any error was harmless. The court concluded that other evidence, including the DNA match and testimonies from C.A., Nurse Carter, Detective Signori, and forensic analyst Sharon Hinz, provided significant corroboration. Thus, the court affirmed the denial of Johnson’s habeas petition, holding that Johnson could not prove actual prejudice from the report’s admission. View "Johnson v. Florida Dept. of Corrections" on Justia Law

The appellants, Madhu Sudhan Kanapuram and Swathi Pillarisetty, are Indian citizens legally residing in the United States on temporary employment-based visas. They filed Form I-485 applications for adjustment of status to obtain EB-2 immigrant visas. Their applications were initially within the priority date cutoff, but due to a retrogression policy, the Final Action Date was pushed back, placing their applications outside the priority cutoff date. After waiting 19 months without a decision, they filed a lawsuit alleging that the U.S. Citizenship and Immigration Services (USCIS) and the Department of State violated the Administrative Procedure Act (APA) by unlawfully withholding and unreasonably delaying the adjudication of their applications.The United States District Court for the Northern District of Georgia dismissed the case, concluding that 8 U.S.C. § 1252(a)(2)(B) barred judicial review of claims asserting delays in the adjudication of pending Form I-485 applications. The appellants then sought review of this dismissal.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's dismissal. The Eleventh Circuit held that 8 U.S.C. § 1252(a)(2)(B)(ii) precludes judicial review of challenges to USCIS delays in adjudicating Form I-485 applications because the statute grants the Department of Homeland Security (DHS) and USCIS broad discretion over the adjustment of status process. The court concluded that the decision to delay adjudication due to the retrogression policy falls within this discretionary authority. Therefore, the court affirmed the district court's order of dismissal, holding that it lacked jurisdiction to review the appellants' APA claims. View "SudhanKanapuram v. Director, US Citizenship and Immigration Services" on Justia Law

Fu Jing Wu and Wai Lam set up investment funds for foreign investors, promising opportunities to immigrate to the United States through the EB-5 visa program. They fraudulently diverted millions of dollars from these funds. An investor, Chun Liu, sued them in a Florida court. Wu and Lam removed the case to federal court and moved to compel arbitration based on a purchase agreement. The district court denied the motion to compel arbitration and remanded the case to state court for lack of subject-matter jurisdiction.The United States District Court for the Southern District of Florida reviewed the case. The court found that Wu was not a signatory to the purchase agreement containing the arbitration clause and thus could not enforce it. Consequently, the court ruled that it lacked subject-matter jurisdiction under the Federal Arbitration Act and remanded the case to state court.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that 28 U.S.C. § 1447(d) barred appellate review of the district court's order that both denied the motion to compel arbitration and remanded the case for lack of subject-matter jurisdiction. The court concluded that the denial of the motion to compel arbitration was intrinsic to the jurisdictional decision and could not be reviewed separately. Therefore, the Eleventh Circuit dismissed Wu and Lam’s appeal for lack of jurisdiction. View "Wu v. Liu" on Justia Law

Johnathan Morris was pulled over by a Miami police officer after running a stop sign, leading to a brief car chase. Upon stopping, officers found controlled substances on Morris and two firearms with ammunition in his vehicle. Morris, a convicted felon, was charged and later convicted by a jury of possession of a firearm and ammunition by a felon, possession of a controlled substance with intent to distribute, and possession of a firearm in furtherance of a drug trafficking crime. He was sentenced to 138 months in prison.Morris appealed his convictions and sentence, raising four challenges to his convictions and one to his sentence. He argued that the evidence was insufficient to convict him, the district court erred in denying his motion to suppress evidence from the traffic stop, the court should have included a special interrogatory on the verdict form requiring the jury to agree unanimously on which firearm he possessed, and the jury instruction on his flight from police was improper. He also contended that his sentence was unreasonable.The United States Court of Appeals for the Eleventh Circuit reviewed the case and found Morris's arguments unpersuasive. The court held that 18 U.S.C. § 922(g) does not require jury unanimity on the specific firearm or ammunition possessed when there is evidence of possession of more than one firearm or ammunition. The court concluded that possession of a particular firearm or ammunition is a means of committing the crime, not an element, and thus, the district court did not err in refusing to include the special interrogatory on the verdict form. Consequently, the Eleventh Circuit affirmed Morris's convictions and sentence. View "United States v. Morris" on Justia Law

The plaintiff, Afaf Beshay Malak, applied for disability insurance benefits (DIB) in 2021, citing several disabilities including pinched nerves, osteoarthritis, fibromyalgia, and chronic headaches. Her application was denied initially and upon reconsideration by disability examiners. Malak then had a hearing before an Administrative Law Judge (ALJ), who followed the five-step evaluation process for disability claims. The ALJ determined that Malak had severe impairments but did not meet the criteria for a listed impairment. The ALJ assessed Malak’s Residual Functional Capacity (RFC) and found she could perform sedentary work with certain limitations. The ALJ concluded that Malak could perform her past work as a financial institution manager and other jobs in the national economy, thus finding her not disabled.Malak appealed the ALJ’s decision to the Appeals Council, which denied her request for review, making the ALJ’s decision the final decision of the Commissioner of Social Security. Malak then appealed to the district court, which affirmed the ALJ’s denial of her DIB claim. Malak subsequently appealed to the United States Court of Appeals for the Eleventh Circuit.The Eleventh Circuit reviewed the case to determine if the ALJ’s decision was supported by substantial evidence. Malak argued that the ALJ failed to consider her medically related absences and the side effects of her treatments. The court held that the ALJ is not required to consider the time needed for medical appointments when determining RFC, as RFC assessments focus on functional limitations caused by medically determinable impairments. The court also found that the ALJ properly considered the effectiveness and side effects of Malak’s treatments, noting that the medical evidence showed positive responses to treatments without significant side effects. The Eleventh Circuit affirmed the district court’s decision, upholding the denial of Malak’s DIB claim. View "Malak v. Commissioner of Social Security" on Justia Law