11th Circuit Case Commentaries

Guidelines Commentary Error on § 2G2.2 Video “Image” Counting Is Not Plainly Reversible When Correct Frame-Based Counting Still Triggers the 600-Image Enhancement

Date: Jul 8, 2026

Guidelines Commentary Error on § 2G2.2 Video “Image” Counting Is Not Plainly Reversible When Correct Frame-Based Counting Still Triggers the 600-Image Enhancement Case: United States v. Lucio Daza...

Generalized Prison-Violence Eighth Amendment Claims: Contextualized Assault Rates, Judicial Notice of Population, and “Specific Features” Can Defeat Summary Judgment

Date: Jul 8, 2026

Generalized Prison-Violence Eighth Amendment Claims: Contextualized Assault Rates, Judicial Notice of Population, and “Specific Features” Can Defeat Summary Judgment I. Introduction Mitchell Marbury...

Public University Classroom Speech Is Not “Government Speech”: Florida’s Individual Freedom Act Likely Unconstitutional Viewpoint Discrimination

Date: Jul 8, 2026

Public University Classroom Speech Is Not “Government Speech”: Florida’s Individual Freedom Act Likely Unconstitutional Viewpoint Discrimination I. Introduction In consolidated interlocutory appeals...

Eleventh Circuit: Legislative Viewpoint Bans in Public University Classrooms Violate the First Amendment; Garcetti Does Not Swallow Academic Teaching

Date: Jul 8, 2026

Legislative Viewpoint Bans in Public University Classrooms Are Unconstitutional: The Eleventh Circuit Rejects “Salary-for-Speech” and Declines to Extend Garcetti to Teaching Case: LeRoy Pernell v....

Actual Notice via PACER Satisfies Due Process and Failure to Object Forfeits Bankruptcy Plan Challenges (Including Purdue-Pharma Third-Party Release Attacks)

Date: Jul 8, 2026

Actual Notice via PACER Satisfies Due Process and Failure to Object Forfeits Bankruptcy Plan Challenges (Including Purdue-Pharma Third-Party Release Attacks) Case: Acute, Inc. v. ECI Pharmaceuticals,...

Mid-Trial Flight as Waiver of the Right to Be Present and as Obstruction Under U.S.S.G. § 3C1.1

Date: Jul 8, 2026

Mid-Trial Flight as Waiver of the Right to Be Present and as Obstruction Under U.S.S.G. § 3C1.1 I. Introduction In United States v. Michael Monteith (11th Cir. July 7, 2026) (unpublished;...

Eleventh Circuit: Failure-to-Train Liability Requires Pattern or Obvious Need; Unbriefed Claims Are Abandoned on Appeal

Date: Jul 8, 2026

Eleventh Circuit: Failure-to-Train Liability Requires Pattern or Obvious Need; Unbriefed Claims Are Abandoned on Appeal I. Introduction Case: William P. Brown v. Sheriff, Hillsborough County Florida...

ACCA Predicate Drug Offenses in Georgia: Incorporation of Federal Drug Schedules Defeats “Broader Cocaine Definition” Overbreadth Challenges

Date: Jul 7, 2026

ACCA Predicate Drug Offenses in Georgia: Incorporation of Federal Drug Schedules Defeats “Broader Cocaine Definition” Overbreadth Challenges 1. Introduction In United States v. Emory Austin Carter...

Corroborated Controlled Buys and Collective Knowledge Establish Probable Cause for Warrantless Public Arrest; Resentencing After § 2255 Remains De Novo with Discretionary Weight to Rehabilitation

Date: Jul 7, 2026

Corroborated Controlled Buys and Collective Knowledge Establish Probable Cause for Warrantless Public Arrest; Resentencing After § 2255 Remains De Novo with Discretionary Weight to Rehabilitation I....

Private Accreditation as a Non-Delegative Funding Condition Under Title IV

Date: Jul 7, 2026

Private Accreditation as a Non-Delegative, Ascertainable Condition on Federal Student-Aid Eligibility Case: State of Florida v. Secretary, US Department of Education (11th Cir. July 6, 2026) Posture:...

All Parents Retain a Fundamental Right to Cohabit with Their Children; “Misconduct” Cannot Defundamentalize the Right (Strict Scrutiny Applies)

Date: Jul 7, 2026

All Parents Retain a Fundamental Right to Cohabit with Their Children; “Misconduct” Cannot Defundamentalize the Right (Strict Scrutiny Applies) 1. Introduction Bruce Henry v. Sheriff of Tuscaloosa...

Res Ipsa Loquitur Cannot Substitute for the Maritime “Notice” Prerequisite in Cruise-Passenger Negligence Claims

Date: Jul 7, 2026

Res Ipsa Loquitur Cannot Substitute for the Maritime “Notice” Prerequisite in Cruise-Passenger Negligence Claims Case: Maurice Cunningham v. Carnival Cruise Line (11th Cir. July 6, 2026) (per curiam)...

Non-Exhaustion Dismissal Improper Where Prior EEO Materials Show Investigation and Untimeliness Is Not Apparent on the Pleadings

Date: Jul 7, 2026

Non-Exhaustion Dismissal Improper Where Prior EEO Materials Show Investigation and Untimeliness Is Not Apparent on the Pleadings I. Introduction In Rajesh Patel v. Secretary, Department of Veterans...

Dismissal With Prejudice of a Pro Se In Forma Pauperis Shotgun Pleading After Notice and a Final Opportunity to Amend

Date: Jul 3, 2026

Dismissal With Prejudice of a Pro Se In Forma Pauperis Shotgun Pleading After Notice and a Final Opportunity to Amend 1. Introduction In Ivette Echenique v. Hamilton Hospital, the Eleventh Circuit...

Rutherford Bars Compassionate Release Based on Nonretroactive Statutory Sentencing Changes; Age Alone Does Not Satisfy § 1B1.13(b)(2)

Date: Jul 3, 2026

Rutherford Bars Compassionate Release Based on Nonretroactive Statutory Sentencing Changes; Age Alone Does Not Satisfy § 1B1.13(b)(2) I. Introduction United States v. Gilberto Chineag (11th Cir. July...

Temporal Proximity Does Not Prove Retaliation Causation When Discipline Was Already Underway

Date: Jul 3, 2026

Temporal Proximity Does Not Prove Retaliation Causation When Discipline Was Already Underway Introduction In Wanda Jean-Baptiste v. City of Miami (11th Cir. July 2, 2026) (unpublished), the Eleventh...

Drug-Dog Alert During an Ongoing Traffic Stop Establishes Automobile-Exception Probable Cause; Marijuana Odor and “Shake” Support Search and Arrest

Date: Jul 3, 2026

Drug-Dog Alert During an Ongoing Traffic Stop Establishes Automobile-Exception Probable Cause; Marijuana Odor and “Shake” Support Search and Arrest 1. Introduction In United States v. Nicholas Smith...

JSIN Sentencing Averages, Without Defendant-Specific Comparators, Do Not Show an Unwarranted § 3553(a)(6) Disparity

Date: Jul 3, 2026

JSIN Sentencing Averages, Without Defendant-Specific Comparators, Do Not Show an Unwarranted § 3553(a)(6) Disparity 1. Introduction United States v. Uwa Nosakhare (11th Cir. July 1, 2026) is an...

Seniority-Plan Changes Are Discrete Title VII Acts Triggering the 180-Day EEOC Clock; Speculative Race Inferences and a Single Non-Racial Text Cannot Plead Discrimination or Hostile Environment

Date: Jul 3, 2026

Seniority-Plan Changes Are Discrete Title VII Acts Triggering the 180-Day EEOC Clock; Speculative Race Inferences and a Single Non-Racial Text Cannot Plead Discrimination or Hostile Environment 1....

Years-Late § 853(n) Forfeiture Challenges Lack Statutory Standing, and Failure to Brief That Ground Warrants Summary Affirmance

Date: Jul 2, 2026

Years-Late § 853(n) Forfeiture Challenges Lack Statutory Standing, and Failure to Brief That Ground Warrants Summary Affirmance 1. Introduction In United States v. Misleidy Ibarra (11th Cir. July 1,...