Justia Constitutional Law Opinion Summaries

After pleading guilty, Defendant-Appellant Silvano Jimenez-Cardenas appealed his 57-month sentence for illegal reentry, and possession of a firearm by an illegal alien. Defendant challenged the district court's refusal to group his illegal reentry and firearm convictions when calculating his sentence per the sentencing guidelines. After review, the Eleventh Circuit concluded that the district court properly refused to group the convictions, and affirmed Defendant's sentence.

This appeal involved a federal officer with limited authority who repeatedly usurped the power to patrol traffic, violated the civil rights of motorists, abused the public trust, and lied about it in official reports. Defendant, a former officer of the Federal Protective Service, appealed his convictions and sentences for eight counts of willfully depriving a person of the constitutional right to be free from unreasonable seizure by a law enforcement officer and four counts of making false statements in a matter within the jurisdiction of a federal agency. Defendant raised seven issues on appeal. The court affirmed four of defendant's eight convictions for willful unreasonable seizures and affirmed his four convictions for making false statements. The court vacated the remaining convictions for willful unreasonable seizures.

Defendant was convicted of two murders and sentenced to death. At issue was whether the Supreme Court of Florida unreasonably applied clearly established federal law, as determined by the Supreme Court of the United States, when it determined that defendant's attorney at his second penalty phase hearing made a reasonable strategic decision to present the expert testimony of a mental health expert who provided some damaging testimony during the first penalty phase. The court concluded that capital defense lawyers did not render deficient performance as a matter of law when they presented evidence of a defendant's antisocial personality disorder; the Supreme Court of Florida reasonably concluded that counsel satisfied the deferential standard of Strickland when they called the expert to testify again; and in light of defendant's statements that he did not want further testing, there were reasonable arguments that counsel satisfied the deferential standard of Strickland when they did not pursue different mental health theories at the resentencing. Accordingly, the court affirmed the denial of defendant's petition for a writ of habeas corpus.

Petitioner, a prisoner on Florida's death row, appealed the district court's denial of his 28 U.S.C. 2254 petition challenging his capital murder conviction. At issue was whether the Florida Supreme Court's decision denying petitioner's claim that the trial court erred when refusing to instruct the jury about other consecutive sentences was contrary to, or involved an unreasonable application of, the Supreme Court's decision in Simmons v. South Carolina. Petitioner based his claim on the trial court's refusal to inform the advisory jury of his multiple terms of incarceration that he would have to serve before becoming eligible for parole. The court held that petitioner could not prevail on his claim for relief because none of the Supreme Court precedent upon which he relied illustrated that the Florida Supreme Court rendered a decision that was contrary to, or an unreasonable application, of clearly established law under section 2254(d).

Petitioner appealed the district court's denial of his 28 U.S.C. 2254 petition for writ of habeas corpus. Petitioner was convicted of murdering his neighbor and attempting to murder six of her family members by adding the toxic element thallium to bottles of Coca-Cola in the victims' homes. On appeal, petitioner alleged that certain parts of a special agent's testimony were false and petitioner was thus entitled to a new trial under Giglio v. United States. The court held that, assuming that the false testimony violated Giglio, the error was harmless under the standard set forth in Brecht v. Abrahamson. Accordingly, petitioner was not entitled to habeas relief.

Petitioner, an Alabama prison inmate awaiting execution for a capital murder, appealed the denial of his petition for a writ of habeas corpus. Defendant's principal claims were that in requiring him to stand trial jointly with a co-defendant, the Alabama courts denied him due process of law, as guaranteed by the Fourteenth Amendment, and an individualized sentencing proceeding, as guaranteed by the Eighth Amendment. Defendant also argued that the prosecutor commented on his post-Miranda silence in violation of the Fourteenth Amendment. The court found no error in the district court's denial of the writ and affirmed the judgment.

Defendant appealed his convictions on one count of receipt of child pornography and two counts of possession of child pornography. The court rejected defendant's argument that his statements during two interviews should have been suppressed because the waiver form was "confusing, misleading and constitutionally deficient" where the language of the waiver forms reasonably, clearly, and accurately conveyed defendant's Fifth Amendment rights under Miranda and the waiver forms' qualifications of defendant's entitlement to a civilian lawyer did not invalidate the otherwise adequate statements of defendant's rights. The court also rejected defendant's claim that the district court abused its discretion by admitting defendant's statements at trial without first requiring the government to introduce evidence that defendant provided the statements voluntarily. Further, the child pornography statutes at issue were not unconstitutionally vague or overbroad; the indictment was not multiplicitous; the district court did not abuse its discretion by admitting certain testimony at issue over defendant's counsel's objections; the district court did not abuse its discretion by admitting evidence under rules 414 and 403 and by denying defendant's motion for mistrial; and defendant's claim of prosecutorial misconduct failed. Accordingly, the court affirmed defendant's convictions.

Plaintiffs appealed from the district court's dismissal of their amended complaint against Florida government defendants, SBHD, AHCA, and DCF. Plaintiffs alleged that defendants' billing practice violated both 42 U.S.C. 1396a(a)(25)(C), the "balance billing" provision of the federal Medicaid Act, and a similar Florida statute. The court concluded that section 1396a(a)(25)(C) did not confer upon plaintiffs a federal right enforceable under 42 U.S.C. 1983 and therefore, affirmed the district court's decision to dismiss the amended complaint.

Defendant was convicted for possessing with intent to distribute five grams or more of cocaine base and possessing with intent to distribute cocaine. On appeal, defendant argued that jury instructions were misleading, that the district court abused its discretion by admitting evidence of his prior drug-related offense, and that the evidence was insufficient. The court held that, although it disapproved of the constructive possession instruction given to the jury, the court did not find that, under the circumstances of this particular case, it mislead the jury or prejudiced defendant. The court also found that the district court committed no abuse of discretion in admitting Rule 404(b) evidence and that there was sufficient evidence to uphold defendant's convictions.

Defendant pleaded guilty to being a felon in possession of a firearm under 18 U.S.C. 922(g)(1), reserving the right to appeal the denial of his motion to suppress evidence. The court held that the district court's findings were supported by the evidence and its conclusion that defendant gave legally effacious consent to the search was correct. The court also held that the Florida robbery, both before and after Florida promulgated the "robbery by sudden snatching" statute, qualified as a violent felony under the Act.