11th Circuit Case Commentaries

Rule 11 Sanctions for Frivolous Civil Conspiracy Pleadings and No Recusal Based on Sanctions/Trial Frustration (11th Cir.)

Date: Apr 2, 2026

Rule 11 Sanctions for Frivolous Civil Conspiracy Pleadings and No Recusal Based on Sanctions/Trial Frustration (11th Cir.) Introduction In Kenneth Carey v. Jonathan Kirk (consolidated Nos. 25-10866...

Amendment 821 § 3582(c)(2) Reductions: District Courts May Deny Relief on § 3553(a) Grounds and May Consider Codefendant Cooperation for Disparity; Passing Deportation References Are Not Improper

Date: Apr 2, 2026

Amendment 821 § 3582(c)(2) Reductions: District Courts May Deny Relief on § 3553(a) Grounds and May Consider Codefendant Cooperation for Disparity; Passing Deportation References Are Not Improper 1....

Rule 408 Settlements May Prove Knowledge for Alabama Wantonness; Expert Causation Not Always Required in Stormwater Channelization Cases

Date: Mar 31, 2026

Rule 408 Settlements May Prove Knowledge for Alabama Wantonness; Expert Causation Not Always Required in Stormwater Channelization Cases Case: Matthew T. Winther v. United States Steel Corporation...

Revocation of Longstanding “Flextime” as a Materially Adverse Action Defeats Qualified Immunity in Public-Employee First Amendment Retaliation

Date: Mar 30, 2026

Revocation of Longstanding “Flextime” as a Materially Adverse Action Defeats Qualified Immunity in Public-Employee First Amendment Retaliation Case: Terry Joyner v. City of Atlanta Court: Court of...

Jackson Crossroads: Speculative “Megasite” and Quarry Hype Cannot Inflate Conservation-Easement Fair Market Value; Gross Overvaluation Triggers Mandatory § 6662(h) Penalty

Date: Mar 30, 2026

Jackson Crossroads: Speculative “Megasite” and Quarry Hype Cannot Inflate Conservation-Easement Fair Market Value; Gross Overvaluation Triggers Mandatory § 6662(h) Penalty I. Introduction In Jackson...

Short-Sale Denial Letters and Loss-Mitigation Merits Challenges Fall Outside FDCPA “Debt Collection” and RESPA/Regulation X NOE Coverage

Date: Mar 30, 2026

Short-Sale Denial Letters and Loss-Mitigation Merits Challenges Fall Outside FDCPA “Debt Collection” and RESPA/Regulation X NOE Coverage Case: Janice Ellery v. Fay Servicing, LLC Court: Court of...

Conservation-Easement Valuation: Highest-and-Best-Use Must Be Financially Feasible; Publicly Financed “Megasite” Pricing Is Not Fair-Market Evidence

Date: Mar 30, 2026

Conservation-Easement Valuation: Highest-and-Best-Use Must Be Financially Feasible; Publicly Financed “Megasite” Pricing Is Not Fair-Market Evidence 1. Introduction This Eleventh Circuit decision...

Restitution for Standalone 18 U.S.C. § 1035 Convictions Requires Proof of Actual Reliance and Loss Causation (Not Mere Materiality)

Date: Mar 26, 2026

Restitution for Standalone 18 U.S.C. § 1035 Convictions Requires Proof of Actual Reliance and Loss Causation (Not Mere Materiality) I. Introduction United States v. Lawrence Alexander (11th Cir. Mar....

MVRA Restitution for Standalone 18 U.S.C. § 1035 Convictions Requires Proof of Actual Causation (Not Mere Materiality)

Date: Mar 26, 2026

MVRA Restitution for Standalone 18 U.S.C. § 1035 Convictions Requires Proof of Actual Causation (Not Mere Materiality) Introduction In United States v. Lawrence Alexander (11th Cir. Mar. 24, 2026),...

Probable Cause for § 1983 Malicious Prosecution Turns on the Warrant Record—Victim Statements Suffice and Officers Need Not Adjudicate Affirmative Defenses

Date: Mar 26, 2026

Probable Cause for § 1983 Malicious Prosecution Turns on the Warrant Record—Victim Statements Suffice and Officers Need Not Adjudicate Affirmative Defenses Case: Mark Davis v. James DiStephano...

Post-Transfer Settlement Communications Are Generally Irrelevant to § 2232(a) Intent; Prior Asset Concealment Under the Same Forfeiture Judgment Is Admissible Under Rule 404(b)

Date: Mar 26, 2026

Post-Transfer Settlement Communications Are Generally Irrelevant to § 2232(a) Intent; Prior Asset Concealment Under the Same Forfeiture Judgment Is Admissible Under Rule 404(b) Case: United States v....

Garrity Suppression Requires a Credible and Objectively Reasonable “Fired-if-Silent” Belief When No Direct Threat Is Made

Date: Mar 26, 2026

Garrity Suppression Requires a Credible and Objectively Reasonable “Fired-if-Silent” Belief When No Direct Threat Is Made Commentary on United States v. Henry Guice, Jr., No. 24-13110 (11th Cir. Mar....

Compassionate Release May Be Denied Solely on § 3553(a) Without a Sentencing Transcript; Non-Retroactive Law Changes Are Merely Permissive Considerations

Date: Mar 26, 2026

Compassionate Release May Be Denied Solely on § 3553(a) Without a Sentencing Transcript; Non-Retroactive Law Changes Are Merely Permissive Considerations I. Introduction In United States v. Daniel...

Post-Deadline “Corrected” Summary-Judgment Filings Require Both Good Cause and Excusable Neglect; Title VII Promotion Claims Must Tie Discriminatory/Retaliatory Motive to the Actual Decisionmaker

Date: Mar 26, 2026

Post-Deadline “Corrected” Summary-Judgment Filings Require Both Good Cause and Excusable Neglect; Title VII Promotion Claims Must Tie Discriminatory/Retaliatory Motive to the Actual Decisionmaker I....

Eleventh Circuit: A Major Upward Variance Requires Case-Specific Reasons Stated in Open Court, Not a Bare Recitation of § 3553(a)

Date: Mar 26, 2026

Eleventh Circuit: A Major Upward Variance Requires Case-Specific Reasons Stated in Open Court, Not a Bare Recitation of § 3553(a) I. Introduction In United States v. Cristino Mendoza Torres (11th...

PPIA Does Not Preempt Statewide Bans on Lab-Grown Chicken: Product Prohibitions Are Not “Facilities” or “Ingredients” Requirements

Date: Mar 26, 2026

PPIA Does Not Preempt Statewide Bans on Lab-Grown Chicken: Product Prohibitions Are Not “Facilities” or “Ingredients” Requirements I. Introduction Upside Foods Inc v. Commissioner, Florida Department...

Pre-Redemption Entitlement of Georgia Security Deed Holders to Tax-Sale Excess Funds Under O.C.G.A. § 48-4-5(a)

Date: Mar 26, 2026

Pre-Redemption Entitlement of Georgia Security Deed Holders to Tax-Sale Excess Funds Under O.C.G.A. § 48-4-5(a) I. Introduction Eddie Denhardt v. Wells Fargo Bank N.A. (11th Cir. Mar. 23, 2026) is an...

Eleventh Circuit: Federal-Statute Pleading Triggers § 1331 Jurisdiction and Rooker–Feldman Requires Claim-by-Claim Screening (Post-Foreclosure Suits)

Date: Mar 24, 2026

Eleventh Circuit: Federal-Statute Pleading Triggers § 1331 Jurisdiction and Rooker–Feldman Requires Claim-by-Claim Screening (Post-Foreclosure Suits) 1. Introduction Alice Bruce and Roy W. Bruce (the...

Negligent Diversity-Jurisdiction Misstatements, Without Bad Faith, Do Not Support Sanctions Under § 1927 or Inherent Power

Date: Mar 24, 2026

Negligent Diversity-Jurisdiction Misstatements, Without Bad Faith, Do Not Support Sanctions Under § 1927 or Inherent Power 1. Introduction In National Christmas Products, Inc v. OJ Commerce, LLC...

Rule 50(b) Requires Viewing Disputed “Coerced Resignation” Evidence in the Verdict-Winner’s Favor in § 1981 Retaliation Cases

Date: Mar 24, 2026

Rule 50(b) Requires Viewing Disputed “Coerced Resignation” Evidence in the Verdict-Winner’s Favor in § 1981 Retaliation Cases 1. Introduction Matthew Reed v. Beko Technologies Corp. is an Eleventh...