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The Sixth Circuit affirmed the dismissal of property owners' takings and conversion claims against a county treasurer, ruling that the official was entitled to sovereign immunity. The court held that because Michigan law compelled the treasurer's actions regarding tax foreclosures and surplus proceeds, he acted as an arm of the State.
The Eleventh Circuit affirmed a 168-month sentence for firearm possession by a convicted felon, rejecting claims that the sentence was procedurally or substantively unreasonable. The court held that the district court did not clearly err in finding the defendant contributed to his girlfriend's death during a high-speed chase and that the upward variance was justified under the abuse-of-discretion standard.
The Eleventh Circuit affirmed the denial of Renell Jones's habeas petition, ruling that Florida state courts reasonably applied federal law regarding his Miranda waiver and invocation of counsel. The court held that a detective's mischaracterization of a rights form as a literacy test did not invalidate the waiver, and that Jones's statements regarding an attorney were too equivocal to require police to stop questioning.
The Eleventh Circuit granted appointed counsel's motion to withdraw from representation after an independent review found no arguable issues of merit for the appeal. The court affirmed the district court's denial of the defendant's motion for sentence reduction under 18 U.S.C. § 3582(c)(2).
The Eleventh Circuit affirmed the district court's award of attorneys' fees to a relator under the False Claims Act, rejecting a defense based on the relator's unrelated prior misconduct. The court held that the unclean hands doctrine does not apply when the relator's past crimes have no immediate relation to the specific qui tam suit at issue.
The Federal Circuit affirmed the Court of Federal Claims' denial of a plaintiff's renewed motion for relief from judgment under Rule 60(b)(6). The court held that the plaintiff's takings and breach-of-contract claims remained barred by the six-year statute of limitations and that the motion did not present extraordinary circumstances warranting relief.
The Eleventh Circuit affirmed the district court's refusal to compel arbitration, holding that VyStar Credit Union failed to prove the formation of a valid arbitration agreement under Florida state law. The court ruled that unilateral amendments to membership agreements via notice attached to account statements were insufficient to establish mutual assent to the new arbitration provision.
The Eleventh Circuit granted appointed counsel's motion to withdraw from representing LaRonce Howell after an independent review found no arguable issues for appeal. The court affirmed Howell's conviction and sentence based on this assessment.
The Eleventh Circuit affirmed the district court's denial of a pro se plaintiff's Rule 60 motion, ruling that her allegations of fraud on the court were patently frivolous and unsupported by evidence. The court applied the law of the case doctrine, noting it had previously rejected identical claims in a prior appeal.
The Eleventh Circuit affirmed a 36-month prison sentence for a supervised release violation, rejecting the defendant's claim that the sentence was substantively unreasonable. The court held that the district court properly weighed the severity of the defendant's drug violations and his lack of candor regarding his treatment plan.
