Every decision we've summarized from United States Court of Appeals for the Eleventh Circuit.
The Eleventh Circuit dismissed an appeal sua sponte because the district court's order did not resolve all claims or parties in the underlying case. The appellate court held that the order was not final under 28 U.S.C. § 1291 and did not qualify as an immediately appealable interlocutory order.
The Eleventh Circuit affirmed the district court's order returning two children to Venezuela under the Hague Convention, ruling that the mother failed to meet her burden of proving any affirmative defense. The court held that a party cannot reopen a final judgment under Rule 60(b) simply because their prior counsel made a strategic decision to concede a specific defense at trial.
The Eleventh Circuit affirmed the denial of David Antoine Luster's motion for compassionate release, ruling that his claim of an unusually long sentence did not constitute an extraordinary and compelling reason for relief. The court held that the district court properly weighed the severity of Luster's bank robbery convictions and firearm offenses against the non-retroactive changes in law under the First Step Act.
The Eleventh Circuit affirmed the denial of federal habeas relief, holding that the petitioner failed to demonstrate cause and prejudice to overcome the procedural default of his sufficiency-of-evidence claim. The court further ruled that the district court correctly lacked jurisdiction to consider a Rule 60(b) motion after the petitioner had filed a notice of appeal.
The Eleventh Circuit affirmed the denial of habeas relief, holding that the petitioner failed to demonstrate the cause and prejudice necessary to overcome a procedural default. The court further ruled that the district court correctly lacked jurisdiction over a post-appeal Rule 60(b) motion once a notice of appeal was filed.
The Eleventh Circuit affirmed a 78-month sentence for child pornography possession, ruling that a sentencing error regarding video image counts did not affect the defendant's substantial rights. Although the district court incorrectly applied a rule counting each video as 75 images, the correct legal standard would likely have resulted in an even higher image count.
The Eleventh Circuit affirmed Charles Long's 78-month sentence for child pornography possession, ruling that while the district court erred in applying a 75-image-per-video rule, the mistake did not affect Long's substantial rights. The court held that applying the correct one-frame-one-image standard would likely result in a significantly higher image count, meaning no reasonable probability exists that a lower sentence would have been imposed.
The Eleventh Circuit affirmed Charles Long's sentence for possession of child pornography, ruling that while the district court erred by relying on outdated commentary to count videos, Long failed to prove the error affected his substantial rights. The court held that applying the correct one-frame-one-image rule would likely increase, rather than decrease, the total image count, meaning no prejudice existed.
The Eleventh Circuit affirmed the dismissal of a Title VII hostile work environment claim, ruling that a single racially charged remark by a partner was not severe or pervasive enough to alter the conditions of employment. The court further held that the plaintiff's additional allegations were too vague to survive dismissal and that the district court did not abuse its discretion in denying leave to file a second amended complaint.
The Eleventh Circuit affirmed the denial of habeas relief, holding that the petitioner failed to demonstrate cause and prejudice to overcome the procedural default of his due process claim. Consequently, the court found the underlying sufficiency of the evidence claim unreviewable, leaving the conviction and sentence in effect.