Appellate Affirmance for Unchallenged Alternative Dismissal Grounds and Preclusive Amount-in-Controversy Findings in Diversity Cases Introduction Doretha Nichols v. Walmart, Inc. (11th Cir. Mar. 31,...
Compassionate Release May Be Denied Solely on § 3553(a) Factors with a Brief, Record-Based Explanation Introduction In United States v. Leoncio Perez (11th Cir. Mar. 31, 2026) (unpublished), the...
Consistent Diagnostic Testing and Reasoned Medication Limits Defeat Eighth Amendment Deliberate-Indifference Claims Based on Treatment Disagreement I. Introduction In Kenneth Mark Pohlmann v. Lisa...
U.S.S.G. § 3B1.1(b) “Manager/Supervisor” Enhancement Applies to a Technical “IT” Co-Conspirator Who Directly Controls Participants and Handles Operational Fraud Tasks Case: United States v. Carlos...
Waiver of the “Unable or Unwilling” Element Before the BIA as a Dispositive Bar to Asylum Review (and a Basis for Summary Affirmance) 1. Introduction In Marie Supreme v. U.S. Attorney General (11th...
Incarceration-Explained Gaps Can Preserve “Same Course of Conduct” for Multi-Firearm Enhancements Under U.S.S.G. § 2K2.1(b)(1) Case: United States v. Arthur Young (11th Cir., Mar. 30, 2026) (per...
Revocation Sentences May Run Consecutively to State Sentences for the Same Conduct, Despite Delay from Extradition 1. Introduction In United States v. Caleb Prince (11th Cir. Mar. 30, 2026) (per...
TVPRA § 1595 Beneficiary Liability Requires “Something More” Than Room Rentals, but Knowledge Need Not Be Victim-Specific; Trafficking Victims May Qualify as Georgia Invitees Introduction In A.G. v....
Eleventh Circuit: TVPRA § 1595 Beneficiary Liability Requires “Something More” Than Room Rentals, and Knowledge Need Not Be Victim-Specific Introduction In C.B. v. Naseeb Investments, Inc....
TVPRA § 1595 Beneficiary Liability Requires “Something More” Than an Arms-Length Room Rental, and Knowledge Need Not Be Victim-Specific Introduction In G.W. v. Northbrook Industries, Inc....
Second Amendment Challenges to § 922(g)(1) and § 924(c) Fail on Plain-Error Review Absent Abrogating or On-Point Precedent I. Introduction In United States v. Christopher Stanton, Jr. (11th Cir. Mar....
Training-Period Terminations and Rule 56(d): No Pretext Without Evidence Undermining Performance Rationale 1. Introduction In Keith Cooper v. Airbus Americas, Inc. (11th Cir. Mar. 27, 2026)...
Recidivist Fraud and Uncharged Conduct Can Justify a Major Upward Variance from a Low Guidelines Range Case: United States v. Frank Nickens (11th Cir., Mar. 26, 2026) (per curiam) (Not for...
Post-Judgment Amendments Require Rule 59/60 Relief and Must Cure Rule 12(b)(6)/PSLRA/Rule 9(b) Defects to Avoid Futility Introduction In Kevin L. Shehee v. Diana Lynch (11th Cir. Mar. 27, 2026)...
MDLEA Reach Confirmed: Foreign EEZ Treated as “High Seas,” No U.S. Nexus Required, and Statelessness Established by Failure to Claim Nationality I. Introduction United States v. Angel Luvi-Ramirez...
MDLEA Jurisdiction in a Foreign EEZ: EEZ Treated as “High Seas,” No U.S. Nexus Required for Stateless Vessels, and § 70502(d)(1)(C) Challenges Fail Where Jurisdiction Rests on § 70502(d)(1)(B) 1....
Failure to Object to a Magistrate Judge’s Rule 11 Report Waives Appellate Attack on the Guilty Plea; Clear Rule 11 Colloquy Renders Sentence-Appeal Waiver Enforceable Introduction In United States v....
MDLEA Jurisdiction in a Foreign EEZ: EEZ Treated as “High Seas,” No Nexus Required for Stateless-Vessel Drug Conspiracies Case: United States v. Wilmar Mosquera (consolidated with appeals by Angel...
Post–United States v. Kwai Fun Wong Treatment of § 2401(a): Untimely Little Tucker Act Claims Are Merits-Barred (With-Prejudice) While ATS “Routine Deportation” Allegations Fail Law-of-Nations...
Rule 11 Sanctions for Frivolous Civil Conspiracy Allegations Barred by the Intracorporate Conspiracy Doctrine; Late Recusal Denied Absent Extrajudicial Bias Case: Kenneth Carey v. Jonathan Kirk (11th...