Justia Constitutional Law Opinion Summaries

Two defendants, Antonio Lemus and Carlos Daniel Canario-Vilomar, were convicted of cocaine-related charges under the Maritime Drug Law Enforcement Act (MDLEA). Lemus was apprehended on December 30, 2021, when U.S. Coast Guard officers intercepted a vessel north of Panama, found cocaine, and determined the vessel was without nationality after Colombia could not confirm its registration. Canario-Vilomar was arrested on December 6, 2021, when a similar vessel was intercepted north of Colombia, and the Dominican Republic could not confirm its registration. Both defendants were charged with conspiracy to possess and distribute cocaine on a vessel subject to U.S. jurisdiction.In the Southern District of Florida, Lemus pled guilty to both counts and was sentenced to 87 months in prison. In the Middle District of Florida, Canario-Vilomar pled guilty to conspiracy, and his motion to dismiss the indictment was denied. He was sentenced to 120 months in prison. Both defendants appealed, arguing that the MDLEA exceeded Congress's authority under the Felonies Clause of the Constitution and that their vessels were not stateless under international law. Canario-Vilomar also argued that his offense occurred in an Exclusive Economic Zone (EEZ), which he claimed was beyond Congress's regulatory authority.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that Congress's authority under the Felonies Clause is not limited by international law, affirming that the MDLEA's definition of a "vessel without nationality" and the inclusion of the EEZ within the "high seas" were constitutional. The court also rejected Canario-Vilomar's due process argument, citing precedent that the MDLEA does not require a nexus to the United States for jurisdiction. Consequently, the Eleventh Circuit affirmed the convictions of both defendants. View "USA v. Canario-Vilomar" on Justia Law

The case involves the appeals of Rolando Williamson, Hendarius Archie, Ishmywel Gregory, and Adrien Taylor, who were convicted of various drug distribution and conspiracy charges. Williamson argued that the district court erred in denying his motions to suppress evidence obtained from warrants to search his house and apartment, claiming the use of pole cameras violated the Fourth Amendment. Archie contended that the district court allowed improper opinion testimony from a case agent. Gregory challenged the district court’s findings on the type and amount of drugs attributable to him at sentencing. All defendants questioned the sufficiency of the evidence supporting their conspiracy convictions.The United States District Court for the Northern District of Alabama convicted the defendants on multiple counts. Williamson was sentenced to life imprisonment for several counts, including engaging in a continuing criminal enterprise and conspiracy to distribute drugs. Taylor was convicted of distributing methamphetamine and using a communication facility to commit a drug trafficking crime. Gregory was convicted of distributing cocaine and conspiracy to distribute drugs. Archie was convicted of conspiracy to distribute marijuana and possession of a firearm in furtherance of a drug trafficking crime.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that the use of pole cameras did not violate Williamson’s Fourth Amendment rights as they surveilled areas exposed to the public. The court found that the case agent’s opinion testimony did not affect Archie’s substantial rights. The evidence was deemed sufficient to support each defendant’s conspiracy conviction. However, Williamson’s conspiracy conviction was vacated as it was a lesser-included offense of his continuing criminal enterprise conviction. Gregory’s sentence was vacated and remanded for resentencing as it exceeded the statutory maximum. The court affirmed the remaining convictions and sentences. View "United States v. Gregory" on Justia Law

Tim Daniels, a commercial fisherman in Florida, challenged the constitutionality of regulations by Florida’s Fish and Wildlife Conservation Commission (FWC) that restrict where and how Florida-registered vessels can harvest Florida pompano in federal waters. Daniels argued that federal law preempts state regulations affecting fishing in federal waters and that Florida’s regulations violate the Equal Protection Clause by only restricting Florida-registered vessels.The United States District Court for the Southern District of Florida granted summary judgment for the FWC, concluding that Florida’s regulations do not violate the Privileges and Immunities Clause, the Supremacy Clause, the Commerce Clause, or the Equal Protection Clause. The court also determined that Daniels lacked standing to sue.The United States Court of Appeals for the Eleventh Circuit reviewed the case and concluded that Daniels has standing to sue because he faces a credible threat of prosecution under Florida’s regulations, which affects his commercial fishing activities. The court found that Daniels’s injury is directly traceable to Florida’s regulations and can be redressed by a favorable judicial decision.On the merits, the Eleventh Circuit held that the Magnuson-Stevens Fishery Conservation and Management Act does not preempt Florida’s regulations. The court reasoned that the Act allows states to regulate fishing vessels registered under their laws in federal waters when there is no federal fishery management plan or regulations in place. The court also held that Florida’s regulations do not violate the Equal Protection Clause because they are rationally related to the legitimate governmental purpose of conserving and managing pompano stock, and the regulations only apply to Florida-registered vessels, which are within the state’s jurisdiction.The Eleventh Circuit affirmed the District Court’s decision, upholding Florida’s pompano regulations. View "Daniels v. Executive Director of the Florida Fish and Wildlife Conservation Commission" on Justia Law

Rhonda Fleming, an inmate at Federal Correctional Institution Tallahassee (FCIT), filed a pro se lawsuit against Warden Erica Strong and the United States, alleging Eighth Amendment violations due to her exposure to mold, asbestos, and COVID-19, which she claimed caused severe health issues. Fleming sought injunctive relief and damages under Bivens and the Federal Tort Claims Act (FTCA). She alleged that despite her complaints, the prison officials, including Warden Strong, failed to address the hazardous conditions, leading to her contracting COVID-19 twice and requiring hospitalization.The United States District Court for the Northern District of Florida partially granted and partially denied the defendants' motion to dismiss. The magistrate judge recommended dismissing most of Fleming's claims, including all claims against Strong, citing that Bivens did not provide a remedy for her Eighth Amendment claim. However, the district court disagreed, finding that Fleming's Eighth Amendment claim was similar to a previously recognized Bivens claim and allowed it to proceed. The district court did not address the issue of qualified immunity.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court had to determine whether it had jurisdiction to hear an interlocutory appeal from the district court's order recognizing a Bivens cause of action. The Eleventh Circuit joined four other circuits in holding that the collateral-order doctrine does not extend to Bivens-extension orders that do not address qualified immunity. The court emphasized that qualified immunity adequately protects government officials from the burdens of litigation and that separation-of-powers concerns with Bivens extensions do not justify immediate appeal. Consequently, the Eleventh Circuit dismissed the appeal for lack of jurisdiction. View "Fleming v. FCI Tallahassee Warden" on Justia Law

Plaintiff filed suit against the Georgia district attorney and others under 42 U.S.C. 1983, alleging that defendants conspired to violate his First Amendment rights. Plaintiff, employed as the director of the police department's crime lab, was terminated from his position after the district attorney contacted the police chief to express his concerns that plaintiff had written an expert report for and planned to testify on behalf of the defense in a criminal case. The Eleventh Circuit held that prosecutors were not entitled to absolute immunity for their alleged actions in this case because those actions were not taken in their role as advocates. However, the prosecutors were entitled to qualified immunity because they were acting within the outer perimeter of their discretionary skills in expressing concerns about plaintiff's outside work, and the law was not clearly established at the time. Accordingly, the court reversed the denial of the prosecutors' motion for judgment on the pleadings based on qualified immunity and remanded. View "Mikko v. Howard" on Justia Law

Georgia law by its terms does not provide for negligence actions directly against dogs. In this case, plaintiff filed suit against a police canine, Draco, and others after Draco inflicted serious damage to plaintiff when Draco refused to release his bite. The Eleventh Circuit held that the officers were entitled to qualified immunity because no binding precedent clearly established that their actions in allowing Draco to apprehend plaintiff violated defendant's Fourth Amendment rights; the County and Chief Ayers in his official capacity have sovereign immunity; and Defendants Fransen, Towler, Ross, and Ayers were entitled to official immunity for the claims against them in their individual capacities View "Jones v. Officer S. Fransen" on Justia Law

Federal tobacco laws do not preempt state tort claims based on the dangerousness of all the cigarettes manufactured by the tobacco companies. The Florida Supreme Court upheld the jury verdicts of negligence and strict liability in Engle v. Liggett Group, Inc., 945 So. 2d 1246 (Fla. 2006) (Engle III), and decertified the class to allow individual actions about the remaining issues. In this case, R.J. Reynolds and Philip Morris challenged the jury verdict against them in one of the individual actions. The Eleventh Circuit affirmed its holding in Walker v. R.J. Reynolds Tobacco Co., 734 F.3d 1278 (11th Cir. 2013), and concluded that giving full faith and credit to the Engle jury findings of negligence and strict liability does not deprive R.J. Reynolds and Philip Morris of property without due process of law, and that federal law does not preempt the Engle jury findings. Accordingly, the court affirmed the judgments against R.J. Reynolds and Philip Morris. View "Graham v. R.J Reynolds Tobacco" on Justia Law

The Eleventh Circuit denied J.W. Ledford, Jr.'s motion for an emergency stay of execution, holding that Ledford's 42 U.S.C. 1983 complaint challenging Georgia's method of execution was time-barred. The court further held that, even if the claims were not time-barred, Ledford's allegations and supporting documents did not establish a substantial risk of serious harm, much less a substantial likelihood of success on the merits of his claims; Ledford has not alleged sufficient facts to render it plausible that a firing squad was a feasible and readily implemented method of execution in Georgia that would significantly reduce a substantial risk of severe pain; and, under all the particular facts and circumstances of this case, Ledford failed to show that he has met the equitable requirements for a stay of execution. View "Ledford, Jr. v. Commissioner, GA Department of Corrections" on Justia Law

The Eleventh Circuit affirmed the district court's determination that granting Anthony Boyd leave to amend his complaint would be futile, and affirmed the dismissal of his suit alleging an Eighth Amendment violation regarding Alabama's new lethal injection protocol. Instead of identifying an alternative method of lethal injection that would be feasible, readily implemented, and substantially less risky than the midazolam protocol or opting for death by electrocution, Boyd alleged that Alabama should execute him by hanging or firing squad. The Eleventh Circuit held that Boyd has not come close to pleading sufficient facts to render it plausible that hanging and firing squad are feasible, readily implemented methods of execution for Alabama that would significantly reduce a substantial risk of severe pain. Alabama is under no constitutional obligation to experiment with execution by hanging or firing squad. Finally, Body's remaining claims were filed well beyond the two-year statute of limitations governing section 1983 claims in Alabama. View "Boyd v. Warden, Holman Correctional Facility" on Justia Law

The Eleventh Circuit affirmed the grant of summary judgment to defendants in a suit under 42 U.S.C. 1983, alleging inadequate medical care while plaintiff was in jail. Plaintiff was diagnosed with meningitis while he was a pretrial detainee in the jail and subsequently suffered multiple strokes resulting in permanent injuries. In this case, all of the health care providers acted within the course and scope of their discretionary authority in providing care to plaintiff. Nurse Wilt, Nurse Preston-Mayle, Nurse Scott, Nurse Roberts, Nurse Densmore, and Doctor Ogunsanwo did not violate plaintiff's constitutional rights by being deliberately indifferent to his serious medical needs and were entitled to qualified immunity. Because there was no constitutional deprivation, there was no basis for supervisor liability. View "Nam Dang v. Sheriff, Seminole County, Florida" on Justia Law