Justia Constitutional Law Opinion Summaries

Defendant-Appellee Dorothy Collier came home from work early one day to find Plaintiff-Appellant Larry Butler alone and naked with her teenaged daughter. He hid in a closed when he heard someone entering the house. As it happened, Defendant worked as a corrections officer for a described "boot camp facility for minors" run by Defendant-Appellee Palm Beach County Sheriff's Office. She wore her uniform and gun belt with pistol. When she entered the room, saw her naked daughter and demanded an explanation, she discovered Plaintiff hiding in the closet. Defendant drew her gun. Plaintiff tried to explain that the daughter invited her to the house, but Defendant insisted he broke in. Defendant handcuffed the still-naked Plaintiff, and forced him to his knees. Defendant allowed Plaintiff to get dressed (at all times, under gunpoint), and eventually Plaintiff was allowed to leave the house. But before he had time to leave Defendant "warned him about the consequences of filing charges or even 'thinking about' reporting the incident." She told Butler that if he reported what had happened, she "would submit a report to discredit him and would engage in some 'creative writing' if necessary to justify the filing of charges against him for trespassing on the property." Despite those threats, Plaintiff eventually reported the incident to law enforcement. Plaintiff filed suit in Florida against Defendant individually and in her official capacity as a corrections officer, and the Palm Beach County Sheriff for violation of his civil rights under 42 U.S.C. 1983. The case was removed from state to federal court. The district court concluded that the allegations in the amended complaint showed no more than Defendant acting as a private individual because nothing she allegedly did to Plaintiff relied on or invoked her authority as a law enforcement officer. For that reason, the court dismissed Plaintiff's 1983 claims. Upon review, the Eleventh Circuit affirmed: "If the allegations are true, [Defendant's] treatment of [Plaintiff] was badder than old King Kong and meaner than a junkyard dog. She might even have acted like the meanest hunk of woman anybody had ever seen. Still, the fact that the mistreatment was mean does not mean that the mistreatment was under color of law."

This case arose from a 1999 class action suit against the maker of silicone breast implants. The U.S. District Court for the Northern District of Alabama approved a mandatory, limited fund class settlement which resolved tens of thousands of claims arising from injuries allegedly caused by defective implants manufactured by Inamed Corporation. In 2006, Zuzanna Juris filed an individual suit in California state court naming Inamed and its successor Allergan, alleging injuries caused by her Inamed implants. Defendants contended that Juris' lawsuit was barred by the 1999 class settlement. Juris countered that she could avoid the settlement's res judicata effect on due process grounds. The district court held that the class settlement precluded Juris from prosecuting the California case. Juris appealed, arguing, inter alia, that the method the Alabama court approved for distributing class notice was constitutionally deficient because she did not receive actual, individual notice. Upon review, the Eleventh Circuit concluded that Juris' assertion that she should have received actual, individual notice rested on a "faulty premise." Even assuming a heightened notice standard applied in this case, the Court concluded that Juris was unable to demonstrate that the notice in the class proceeding was constitutionally deficient. Finding no other error in the district court's holding that the class settlement precluded Juris' California case, the Eleventh Circuit affirmed that court's judgment.

Plaintiff-Appellant Valinda Kornhauser filed suit to challenge the decision of the Commissioner of Social Security that denied her claim for disability benefits. The District Court referred the case to a Magistrate Judge for a report and recommendation ("R&R"). After receiving and considering memoranda on the matter, the Magistrate Judge issued an R&R recommending that the District Court vacate the Commissioner's decision and remand the case to the Commissioner for further proceedings. In his R&R, the Magistrate Judge, in addition to explaining why Plaintiff was entitled to a vacatur, observed that the memorandum her attorney had submitted failed to comply with Middle District of Florida Local Rule 1.05(a). The non-compliance, according to the Magistrate Judge, consisted of "smaller margins than authorized" by the rule and "footnotes . . . smaller than ten-point type." In a footnote to this observation, he stated: "These intentional violations would justify striking the memorandum. However, this sanction would unfairly punish the plaintiff. Consequently, I propose that, when plaintiff's counsel seeks attorney's fees, that the typical request for a cost-of-living increase be denied." Following the entry of judgment, Plaintiff petitioned the District Court for an award of attorney's fees under the Equal Access to Justice Act ("EAJA"). The parties stipulated to the amount of attorney fees, but after its consideration of the petition, the Magistrate Judge issue an R&R recommending that the district court award a lower amount in fees as have been stipulated because of Plaintiff's brief being submitted with small margins and unacceptable font sizing. Plaintiff's attorney filed an objection to the R&R, asking the district court not to adopt it because she did not intend to violate the local rule. Finding that the sanction was a reasonable exercise of the Magistrate Judge's disciplinary authority, the district court adopted the R&R with the sanction. Plaintiff appealed the imposition of the sanction. Upon review, the Eleventh Circuit vacated the sanction, finding "no procedural rule that sanctions the conduct involved" in this case.

Following a jury trial, Defendant Robert Daniels, a/k/a "Twin T" appealed his convictions and sentences for using a facility and means of interstate commerce to persuade, induce, entice, or coerce any individual who had not attained the age of eighteen, to engage in prostitution and any sexual activity for which any person can be charged with a criminal offense, in violation of 18 U.S.C. 2422(b); knowingly transporting an individual in interstate commerce with the intent that she engage in prostitution and any sexual activity for which any person can be charged with a criminal offense, in violation of 18 U.S.C. 2421-22. Defendant was sentenced to concurrent 78-month terms to be served consecutively to a prior sentence imposed by the Eastern District of Michigan. On appeal, Defendant raised six issues. The primary issue was one of first impression for the Eleventh Circuit: whether a conviction under 18 U.S.C. 2422(b) requires the government to prove that the defendant knew that the victim was a minor. Upon review, the Court declined to find knowledge a requirement under 2422(b). The Court concluded that this statute was written for the protection of minors caught in the web of these illicit activities, rather than for offenders choosing to turn a blind eye to the age of the victims they transport. The Court found no merit in the other five issues Defendant raised and affirmed his convictions.

Defendant Geoffrey West appealed the denial of his petition for post-conviction relief. He was sentenced to death. He raised three issues on appeal, all pertaining to his claim he received ineffective assistance of appellate counsel. Upon review, the Eleventh Circuit relied on the "lack of showing of prejudice" as grounds for its affirming the district court's decision to grant relief: "even if we suppose that [Defendant could] overcome the various technical and procedural hurdles to having the merits of his claims considered by federal courts and even if we suppose that his trial counsel performed in an objectively unreasonable way, Petitioner has entirely failed to show . . .how [he] prejudiced by his counsel's supposed inadequate performance."

Plaintiff-Appellant John Furry, as personal representative of the estate of his daughter Tatiana Furry, appealed a district court’s order granting the Miccosukee Tribe’s motion to dismiss his complaint. He complained that the Miccosukee Tribe violated 18 U.S.C. 1161 and Florida’s dram shop law by knowingly serving excessive amounts of alcohol to his daughter, who then got in her car, drove off while intoxicated, and ended up in a fatal head-on collision with another vehicle on a highway just outside Miami. The Miccosukee Tribe moved to dismiss the complaint on the jurisdictional ground that it was immune from suit under the doctrine of tribal sovereign immunity. In its order granting the tribe's motion to dismiss, the district court determined that tribal sovereign immunity barred it from entertaining the suit. Upon review, the Eleventh Circuit agreed: "The Supreme Court has made clear that a suit against an Indian tribe is barred unless the tribe has clearly waived its immunity or Congress has expressly and unequivocally abrogated that immunity. [Plaintiff argued] that both of these exceptions have been met here, but these arguments are ultimately without merit."

Defendants Randy Vana Haile and Mark Anthony Beckford were convicted of conspiracy and attempt to possess with intent to distribute marijuana and cocaine and knowing possession of several firearms in conjunction with their drug trafficking offenses. The district court sentenced Beckford to 438 months and Haile to 468 months of imprisonment. Beckford appealed his conviction and sentence, and Haile appealed his sentence. Haile and Beckford both contended that: (1) Count 4, knowing possession of firearms in furtherance of a drug-trafficking crime, was not properly before the jury; and (2) even if Count 4 was properly submitted to the jury, the jury instructions for that charge were erroneous. Beckford also contests: (1) the sufficiency of the evidence in his case; (2) the district court’s failure to give certain jury instructions; and (3) his 438-month sentence. After a thorough review of the record and the parties’ briefs, and with the benefit of oral argument, the Eleventh Circuit affirmed in part and reversed in part. The Court affirmed Haile's conviction. The Court affirmed Beckford's convictions on all but one count, a "knowing possession of a firearm with an obliterated serial number" charge. The Court affirmed Beckford's sentence and noted that his sentence on the serial number count was to run concurrently with his sentence on the remaining counts, therefore resulting in no 438-month sentence imposed by the district court.

The issue on appeal before the Fourth Circuit in this case concerned whether the Supreme Court of Florida unreasonably applied clearly established federal law when it explicitly refused to consider relevant mental health evidence in its collateral review of a sentence of death. Defendant Dennis Sochor, a serial rapist, was sentenced to death after he confessed to the murder and kidnapping of an eighteen-year-old woman. Defendant applied to the Fourth Circuit for the writ of habeas corpus. He argued on appeal that the ruling of the Supreme Court of Florida that the failure of his trial counsel to present mitigating mental health evidence during the penalty phase of his trial did not prejudice him and was an unreasonable application of "Strickland v. Washington," (466 U.S. 668 (1984)). Although "Porter v. McCollum" ((Porter II),130 S. Ct. 447 (2009)) made clear that the Supreme Court of Florida unreasonably applied Strickland, the Fourth Circuit's de novo review of the record established that there was no reasonable probability that the trial court would have imposed a sentence other than death had Defendant's trial counsel not been deficient. Further, the Court ruled that "Sochor fail[ed] to offer clear and convincing evidence that the contrary findings of the Supreme Court of Florida [were] unreasonable." Accordingly, the Court affirmed the denial of Defendant's petition for a writ of habeas corpus.

When Defendant Ralph Merrill sold millions of rounds of ammunition to the United States Army, he concealed that the ammunition was manufactured by a Communist Chinese military company because his contract with the Army prohibited the delivery of that kind of ammunition. Defendant had the ammunition repackaged which made it unsafe for later use. Defendant was convicted for conspiracy to commit false statements, major fraud, and wire fraud against the United States and for major fraud and wire fraud. On appeal, Defendant argued that the district court misinterpreted the regulation that prohibited the Department of Defense from acquiring munitions manufactured by a Communist Chinese military company, that the regulation did not apply to the ammunition he sold, and that he did not defraud the government because he did not misrepresent a material fact when he lied about the origin of the ammunition. Upon review, the Eleventh Circuit concluded Defendant's arguments failed because his interpretation of the applicable statutes was flawed and, "more fundamentally, is irrelevant to his misconduct." Because all of Defendant's arguments failed, the Court affirmed his convictions.

This case arose from a foreign shipping contract billing dispute between Consorcio Ecuatoriano de Telecomunicaciones S.A. (CONECEL) and Jet Air Service Equador S.A. (JASE). CONECEL filed an application in the Southern District of Florida under 28 U.S.C. 1782 to obtain discovery for use in foreign proceedings in Ecuador. According to CONECEL, the foreign proceedings included both a pending arbitration brought by JASE against CONECEL for nonpayment under the contract, and contemplated civil and private criminal suits CONECEL might bring against two of its former employees who, CONECEL claims, may have violated Ecuador's collusion laws in connection with processing and approving JASE's allegedly inflated invoices. CONECEL's application sought discovery from JASE's United States counterpart, JAS Forwarding (USA), Inc. (JAS USA), which does business in Miami and was involved in the invoicing operations at issue in the dispute. The district court granted the application and authorized CONECEL to issue a subpoena. Thereafter, JASE intervened and moved to quash the subpoena and vacate the order granting the application. The district court denied the motion, as well as a subsequent motion for reconsideration. JASE appealed the denial of both. After thorough review and having had the benefit of oral argument, the Eleventh Circuit affirmed the orders of the district court. the Court concluded that the panel before which which JASE and CONECEL's dispute was pending acts as a first-instance decisionmaker; it permits the gathering and submission of evidence; it resolves the dispute; it issues a binding order; and its order is subject to judicial review. The discovery statute requires nothing more. The Court also held that the district court did not abuse its considerable discretion in granting the section 1782 discovery application over JASE's objections that it would be forced to produce proprietary and confidential information. The application was narrowly tailored and primarily requested information concerning JASE's billing of CONECEL, which was undeniably at issue in the current dispute between the parties." Finally, the district court did not abuse its discretion in denying JASE's motion for reconsideration.