Justia Government & Administrative Law Opinion Summaries

Articles Posted in US Court of Appeals for the Eleventh Circuit
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B'Quan Ferguson was convicted for possession of a firearm by a felon, a violation of 18 U.S.C. § 922(g)(1). The conviction followed an incident where local police officers in Savannah, Georgia, recognized Ferguson as the subject of an ongoing investigation. The officers found a pistol in Ferguson's vehicle, and a DNA test confirmed that Ferguson's DNA was present on the pistol. Ferguson was subsequently charged with one count of possession of a firearm by a felon.Previously, Ferguson had been convicted under Georgia law for threatening physical harm to a witness, which was considered a "violent felony" under the Armed Career Criminal Act (ACCA). This prior conviction led to Ferguson being classified as an armed career criminal, which mandated a minimum sentence of 15 years. Ferguson objected to this classification, arguing that his Georgia conviction for threatening a witness did not qualify as a violent felony for ACCA enhancement purposes. The district court overruled Ferguson's objection and sentenced him to 180 months' imprisonment.On appeal to the United States Court of Appeals for the Eleventh Circuit, Ferguson argued that his prior Georgia conviction did not qualify as a "violent felony" under ACCA. The court disagreed, concluding that the Georgia statute under which Ferguson was convicted was divisible and that a conviction for threatening physical harm under the statute qualifies as a violent felony under ACCA. The court affirmed the district court's judgment, upholding Ferguson's sentence. View "USA v. Ferguson" on Justia Law

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The case involves Victor Hill, the former Sheriff of Clayton County, Georgia, who was convicted under 18 U.S.C. § 242 for using his position to deprive detainees in his custody of their constitutional rights. Hill ordered individual detainees, who were neither violent nor uncontrollable, into a restraint chair for at least four hours, with their hands cuffed behind their backs and without bathroom breaks. Each detainee suffered injuries, such as “open and bleeding” wounds, lasting scars, or nerve damage.Hill was convicted by a jury in the United States District Court for the Northern District of Georgia. He appealed his conviction to the United States Court of Appeals for the Eleventh Circuit, arguing that he lacked fair warning that his conduct was unconstitutional, that the evidence was insufficient to support his conviction, and that the district court improperly handled allegations of juror misconduct.The Eleventh Circuit rejected Hill's arguments and affirmed his conviction. The court found that case law provided Hill with fair warning that his actions violated constitutional rights. The court also found that the evidence was sufficient to support the jury's conclusion that Hill's conduct had no legitimate nonpunitive purpose, was willful, and caused the detainees’ injuries. Lastly, the court found that the district court did not abuse its discretion in investigating and responding to alleged juror misconduct. View "United States v. Hill" on Justia Law

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The United States Court of Appeals for the Eleventh Circuit reviewed an appeal by Quinton Handlon, a prisoner convicted of producing, coercing, and possessing child pornography. Handlon had requested compassionate release under 18 U.S.C. § 3582(c)(1)(A) because his elderly father needed a caregiver. The district court denied the request as Handlon failed to provide substantial evidence about his father's condition or proving that he was the only available caretaker. Handlon appealed this decision.The Appeals Court upheld the district court's decision, affirming that Handlon's case did not meet the extraordinary and compelling reasons necessary for compassionate release under the policy statement of the U.S. Sentencing Commission. At the time of Handlon's motion, the policy statement recognized four categories for compassionate release, none of which included the incapacitation of a parent when the defendant could serve as a caregiver.The court noted that a recent amendment to the policy statement now includes such a scenario, but clarified that it could not be applied retroactively in this appeal because it was a substantive amendment, not a clarifying one. The court affirmed the denial of Handlon's motion for compassionate release, but hinted that Handlon might be able to file a new motion for compassionate release under the updated policy. View "USA v. Handlon" on Justia Law

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The case involves a challenge to the United States Securities and Exchange Commission's (SEC) denial of a whistleblower award. The petitioner, John Meisel, reported his suspicions about his former tenant's involvement in a Ponzi scheme, which he read about in a newspaper, to the SEC. After the SEC's successful enforcement action against the scheme's perpetrators, Meisel applied for a whistleblower award. The SEC denied his application, reasoning that Meisel's information did not contribute to the enforcement action. Furthermore, his assistance to a court-appointed receiver, who was tasked with recovering funds related to the scheme, did not qualify him for an award as the receiver was not a representative of the Commission. Meisel appealed the denial, claiming it was arbitrary and unsupported by substantial evidence.The United States Court of Appeals for the Eleventh Circuit denied Meisel’s petition for review. The court held that the SEC's denial of the whistleblower award was neither arbitrary nor capricious, nor was it unsupported by substantial evidence. The court found that the SEC had not used Meisel’s information in its enforcement action, and therefore, his information did not lead to its success. The court also held that Meisel's assistance to the receiver did not qualify him for an award because the receiver was an independent court officer, not a representative of the SEC. Lastly, the court determined that Meisel could not qualify for an award in any related actions because he did not qualify for an award in the covered action. View "Meisel v. Securities and Exchange Commission" on Justia Law

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The case involves Purpose Built Families Foundation, a Florida nonprofit that received federal grants from the Department of Veterans Affairs to serve veterans and their families. In 2022, the Department notified the Foundation that activities and payments under five grants would be terminated or withheld due to "major fiscal mismanagement activities". The Foundation sued the Secretary of Veterans Affairs under the Administrative Procedure Act and received a temporary restraining order. Subsequently, the Department withdrew the challenged notices and the Secretary moved to dismiss the action as moot. The district court granted the motion.The United States Court of Appeals for the Eleventh Circuit affirmed the decision of the district court. The court held that the case was moot, as the Department's withdrawal of the notices meant the Foundation's claims could not provide meaningful relief. It also ruled that neither the voluntary-cessation nor the capable-of-repetition-yet-evading-review exceptions to mootness applied. The court stated that the Department's subsequent actions, including a more robust process and new termination notices, were materially different from the original notices. Therefore, a lawsuit challenging the new termination notices would involve materially different allegations and answers. The court concluded that the Foundation would have ample opportunity for judicial review of the legality of the new terminations, once the administrative process was completed. View "Purpose Built Families Foundation, Inc. v. USA" on Justia Law

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In this case decided by the United States Court of Appeals for the Eleventh Circuit, Raquan Emahl Gray was convicted of conspiracy to commit a controlled-substances offense, after helping transport a car filled with drugs to a state prison. Gray appealed his conviction, arguing that the government failed to prove that he knowingly possessed a Schedule II controlled substance, namely methamphetamine, rather than a controlled substance generally. The appeals court affirmed Gray's conviction, holding that the government only needed to prove general knowledge to obtain a controlled-substances conviction, which it did. Gray also argued that the district court erred when it denied his renewed motion for judgment of acquittal due to his failure to timely renew the motion at the conclusion of the evidence. The appeals court acknowledged that Gray's renewed motion was timely, but deemed the district court's error as harmless because enough evidence supported Gray's conviction. View "United States v. Gray" on Justia Law

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Inmate Germaine Smart alleged that prison officials Ronald England, Gary Malone, and Larry Baker violated his First Amendment rights by retaliating against him for reporting an alleged sexual assault by England. Smart claimed that England sexually assaulted him during a pat-down search, but after an internal investigation, Smart's allegations were found to be unfounded and England charged Smart with lying. The United States Court of Appeals for the Eleventh Circuit ruled that the officials did not violate Smart's First Amendment rights. The court stated that a prisoner's violation of a prison regulation is not protected by the First Amendment, and in this case, the prison tribunal's finding that Smart lied, which was based on due process and some evidence, was conclusive. Therefore, the officials were entitled to qualified immunity. View "Smart v. England" on Justia Law

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In the case before the United States Court of Appeals for the Eleventh Circuit, the plaintiff, Taquila Monroe, was a former employee of Fort Valley State University's Head Start and Early Head Start department. She sued the Board of Regents of the University System of Georgia (the "Board") under the False Claims Act's (FCA) anti-retaliation provision, alleging that she was terminated for reporting mismanagement and misuse of federal and state funds meant for the Head Start programs. The district court granted the Board's motion to dismiss, citing the Board's sovereign immunity. The central issue on appeal was whether the FCA's anti-retaliation provision abrogates sovereign immunity for lawsuits against states, and whether the Board is an arm of the state entitled to the same immunity.The Eleventh Circuit affirmed the district court's decision. The court concluded that Congress did not unequivocally express its intent to subject states to suits under the FCA's anti-retaliation provision, and therefore did not abrogate sovereign immunity. The court also held that the Board is an arm of the state and thus entitled to sovereign immunity. In reaching these conclusions, the court considered how Georgia law defines the Board, the degree of control the state exercises over the Board, the Board's source of funding, and who would be responsible for a judgment against the Board. The court found that all of these factors pointed to the Board being an arm of the state that is entitled to sovereign immunity. View "Monroe v. Board of Regents of the University System of Georgia" on Justia Law

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In a case heard by the United States Court of Appeals for the Eleventh Circuit, plaintiffs Jennifer Dupree and Detrich Battle challenged the dismissal of their Title V claims under the Americans with Disabilities Act (ADA) on the basis of sovereign immunity. Dupree, who worked for the Georgia Department of Human Services, and Battle, an employee of the Georgia Department of Corrections, had requested accommodations at their respective workplaces due to their health conditions. After their requests were denied and their employment terminated, they filed claims under Title V, alleging retaliation.The court, however, found that sovereign immunity applies to Title V claims when brought in conjunction with Title I claims. This meant that the plaintiffs' claims could not proceed. Importantly, the court clarified that dismissals based on sovereign immunity, a jurisdictional issue, should be entered without prejudice. Not specifying this in the dismissal could lead to misunderstandings about the nature of the dismissal. Therefore, the court vacated and remanded the case for the limited purpose of allowing the district court to dismiss the case without prejudice. View "Dupree v. Owens" on Justia Law

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In the case before the United States Court of Appeals for the Eleventh Circuit, Young Israel of Tampa, Inc., an Orthodox Jewish synagogue, sued the Hillsborough Area Regional Transit Authority (HART) for rejecting its proposed advertisement for a Chanukah on Ice event. The synagogue argued that HART’s policy, which prohibited advertisements that “primarily promote a religious faith or religious organization,” violated the Free Speech Clause of the First Amendment. The district court granted summary judgment in favor of Young Israel on two grounds: 1) HART’s policy violated the First Amendment because it discriminated on the basis of viewpoint, and 2) even if the policy was viewpoint neutral, it was unreasonable because it lacked objective and workable standards and was inconsistently and haphazardly applied. The court subsequently issued a permanent injunction against HART, prohibiting it from rejecting any advertisement on the ground that it primarily promotes a religious faith or religious organization, including any future policies.On appeal, the Eleventh Circuit affirmed the district court’s decision, but on narrower grounds. The appellate court concluded that HART's policy was unreasonable under the Supreme Court's decision in Minnesota Voters Alliance v. Mansky because it failed to define key terms, lacked any official guidance, and vested too much discretion in those who applied it. The court declined to address the question of whether the policy constituted impermissible viewpoint discrimination. However, the court concluded that the permanent injunction issued by the district court needed to be revised to apply only to HART’s current policy, rather than any future policies, and remanded the case to the district court for that purpose. View "Young Israel of Tampa, Inc. v. Hillsborough Area Regional Transit Authority" on Justia Law