11th Cir.

United States Court of Appeals for the Eleventh Circuit

Every decision we've summarized from United States Court of Appeals for the Eleventh Circuit.

Apr 3 2026
6:23-cv-01971-JA-LHP Per Curiam

KENNETH BYNDOM v. WAFFLE HOUSE, INC a Foreign Profit Corporation EAST COAST WAFFLES, INC a Foreign Profit Corporation

The Eleventh Circuit affirmed summary judgment for Waffle House, ruling that an employee's stabbing of a customer was an independent criminal act outside the scope of employment. The court held that the employer was not liable under Florida law because the assault was not reasonably foreseeable and the employee had stepped away from his duties at the time of the incident.

Civil Securities Summary Judgment
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Apr 3 2026
1:24-cr-20173-JB-1 Per Curiam

UNITED STATES OF AMERICA v. TOMAS ALKSNYS

The Eleventh Circuit affirmed a thirty-six-month sentence for bank fraud and money laundering, rejecting the defendant's challenges to the sentencing guidelines calculations. The court found no plain error in the district court's application of the mass-marketing enhancement and its denial of a minor-role reduction.

Criminal Fraud Sentencing Guidelines
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Apr 3 2026
1:24-cv-00041-AW-ZCB Per Curiam

EDWARD LEE BROWN v. ATTORNEY GENERAL, STATE OF FLORIDA SECRETARY, FLORIDA DEPARTMENT OF CORRECTIONS

The Eleventh Circuit dismissed Edward Lee Brown's appeal sua sponte because he filed his notice of appeal prematurely. The court held that a magistrate judge's report and recommendation is not a final judgment, and the district court's later adoption of that report cannot cure the defect of a premature filing.

Constitutional Habeas Corpus - General (28 USC 2241)
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Apr 2 2026
2:22-cr-00026-LGW-BWC-4 Per Curiam

UNITED STATES OF AMERICA v. RACHAEL BYRD

The Eleventh Circuit granted the Government's motion to dismiss Rachael Byrd's appeal, enforcing the sentence-appeal waiver contained in her plea agreement. The court held that such waivers remain binding if made knowingly and voluntarily, regardless of any sentencing comments or alleged legal errors raised by the appellant.

Criminal Other Criminal
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Apr 2 2026
1:25-cv-01186-TCB Per Curiam

Willie J. Mitchell, Sr. v. The State Court of Georgia, Judge Susan E. Edlein, Jamie Mack, Dennis J. Murphy, Officer Jason Wescott, et al.

The Eleventh Circuit affirmed the district court's dismissal of Willie Mitchell Sr.'s amended complaint, ruling that his claims were frivolous and failed to state a valid cause of action. The court held that despite prior orders to clarify his allegations, Mitchell's complaint remained a deficient 'shotgun pleading' barred by statutes of limitations, immunity doctrines, and a lack of private rights of action.

Civil Rights - Section 1983 Criminal Obstruction of Justice Statute of Limitations
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Apr 2 2026
8:04-cr-00327-VMC-NHA-1 Per Curiam

UNITED STATES OF AMERICA v. EFRAIN RODRIGUEZ-CANDELARIA

The Eleventh Circuit affirmed the district court's denial of a compassionate release motion, ruling that a defendant's extensive criminal history and the need for public safety outweighed his rehabilitation efforts. The court held that the district court did not abuse its discretion when it found the statutory sentencing factors favored maintaining the original sentence.

Compassionate Release Criminal Drug Trafficking Supervised Release
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Apr 2 2026
7:23-cv-00114-WLS-ALS Per Curiam

PAUL GEORGE BETTENCOURT v. UNIT MANAGER DELISHA BRYANT Individual and Official Capacity

The Eleventh Circuit affirmed the dismissal of an inmate's Eighth Amendment claim because he failed to exhaust administrative remedies under the Prison Litigation Reform Act. The court held that the prison's grievance process remained available to the plaintiff despite his inability to use writing utensils and a limit on pending grievances.

Civil Rights - PLRA / Prisoner Civil Rights - Section 1983 Criminal Robbery & Extortion
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Apr 1 2026
8:18-cr-00064-SDM-TGW-1 Per Curiam

UNITED STATES OF AMERICA v. JOSHUA WILLIAMS

The Eleventh Circuit affirmed the revocation of Joshua Williams's supervised release, ruling that the district court properly admitted hearsay evidence and that the record contained sufficient proof of the alleged violations. The court held that the defense's failure to object to the evidence waived the right to challenge the admission under the *Frazier* balancing test.

Criminal Firearms Supervised Release
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