11th Circuit Case Commentaries

Isolated Taliban Harm, Non-Immediate Death Threats, and Extended Post-Incident Residence Defeat Asylum; Reconsideration Cannot Merely Re-Argue Prior Points

Date: Mar 6, 2026

Isolated Taliban Harm, Non-Immediate Death Threats, and Extended Post-Incident Residence Defeat Asylum; Reconsideration Cannot Merely Re-Argue Prior Points 1. Introduction In Faridullah Liwan Khil v....

Single Taliban Beating/Threat + 18-Month Delay Does Not Compel Persecution; Reconsideration Cannot Rehash Prior Arguments (11th Cir.)

Date: Mar 6, 2026

Single Taliban Beating/Threat + 18-Month Delay Does Not Compel Persecution; Reconsideration Cannot Rehash Prior Arguments (11th Cir.) Case: Faridullah Liwan Khil v. U.S. Attorney General...

Unaccepted Jury Verdicts Do Not Trigger Double Jeopardy; Habeas Affirmance Despite District Court Misanalysis When Remand Would Be Futile

Date: Mar 6, 2026

Unaccepted Jury Verdicts Do Not Trigger Double Jeopardy; Habeas Affirmance Despite District Court Misanalysis When Remand Would Be Futile Introduction Frank J. Evans v. Secretary, Florida Department...

§ 841(b)(1)(C) Authorizes Up to Life Supervised Release After Revocation; § 3583(h) Subtraction Does Not Constrain a 36‑Month Reimposition and Mazarky’s “Notice-Based” Cap Is Narrow

Date: Mar 6, 2026

§ 841(b)(1)(C) Authorizes Up to Life Supervised Release After Revocation; § 3583(h) Subtraction Does Not Constrain a 36‑Month Reimposition and Mazarky’s “Notice-Based” Cap Is Narrow I. Introduction...

Upward Variance May Rest on § 3553(a) Factors Despite a Rejected Guideline Enhancement; “Coincidental” Alignment with the Rejected Range Does Not Show Reliance on Improper Facts

Date: Mar 6, 2026

Upward Variance May Rest on § 3553(a) Factors Despite a Rejected Guideline Enhancement; “Coincidental” Alignment with the Rejected Range Does Not Show Reliance on Improper Facts I. Introduction In...

Plain-Meaning Enforcement of “State Cases” Fee-Sharing Letters and Integration-Clause Supersession of Prior Oral Understandings in MDL-Adjacent Lawyer Disputes

Date: Mar 6, 2026

Plain-Meaning Enforcement of “State Cases” Fee-Sharing Letters and Integration-Clause Supersession of Prior Oral Understandings in MDL-Adjacent Lawyer Disputes I. Introduction Gordon Ball v. Patrick...

Sentencing Due Process in the Eleventh Circuit: Using Co-Conspirators’ Trial Evidence with a Rebuttal Opportunity; Unnoticed Unrelated Comparator Sentences as Non-Prejudicial Error

Date: Mar 6, 2026

Sentencing Due Process in the Eleventh Circuit: Using Co-Conspirators’ Trial Evidence with a Rebuttal Opportunity; Unnoticed Unrelated Comparator Sentences as Non-Prejudicial Error Introduction...

Compassionate Release Under U.S.S.G. § 1B1.13(b)(6): Non-Retroactive Guideline Changes and Unchallenged ACCA Predicates Defeat “Gross Disparity” Claims

Date: Mar 5, 2026

Compassionate Release Under U.S.S.G. § 1B1.13(b)(6): Non-Retroactive Guideline Changes and Unchallenged ACCA Predicates Defeat “Gross Disparity” Claims 1. Introduction In United States v. Eric...

Ancillary Jurisdiction to Enforce Criminal Restitution After Probation Ends

Date: Mar 5, 2026

Ancillary Jurisdiction to Enforce Criminal Restitution After Probation Ends 1. Introduction In United States v. Mikel Mims (11th Cir. Mar. 2, 2026), the Eleventh Circuit addressed a question of first...

Oral Testimony to the Magistrate Counts in § 1983 Malicious-Prosecution Review: A Bare Affidavit Is Not Constitutionally Infirm if Probable Cause Is Truthfully Supplied Orally

Date: Mar 4, 2026

Oral Testimony to the Magistrate Counts in § 1983 Malicious-Prosecution Review: A Bare Affidavit Is Not Constitutionally Infirm if Probable Cause Is Truthfully Supplied Orally I. Introduction In...

Rooker-Feldman Bars Damages Claims That Functionally Undo State-Court Fee/Lien Judgments; Jurisdictional Dismissals Must Be Without Prejudice

Date: Mar 4, 2026

Rooker-Feldman Bars Damages Claims That Functionally Undo State-Court Fee/Lien Judgments; Jurisdictional Dismissals Must Be Without Prejudice Case: Robert Jones v. The Lamar Company, LLC, et al....

§ 4C1.1(a)(7) Requires Defendant-Specific Firearm Possession Findings; § 2D1.1(b)(1) Enhancement Alone Does Not Automatically Bar the Zero-Point Offender Reduction

Date: Mar 3, 2026

§ 4C1.1(a)(7) Requires Defendant-Specific Firearm Possession Findings; § 2D1.1(b)(1) Enhancement Alone Does Not Automatically Bar the Zero-Point Offender Reduction Case: United States v. Dominic...

United States v. Brice: Generally Applicable Federal Criminal Statutes Apply to Indian-on-Indian Crimes in Indian Country, Unconstrained by the Major Crimes Act

Date: Mar 3, 2026

United States v. Brice: Generally Applicable Federal Criminal Statutes Apply to Indian-on-Indian Crimes in Indian Country, Unconstrained by the Major Crimes Act I. Introduction United States v....

McDonnell Douglas “Drops Out” After Rebuttal: Summary Judgment Turns on a Rule 56 “Convincing Mosaic,” and Mixed-Motive Theories Must Be Properly Raised

Date: Mar 3, 2026

McDonnell Douglas “Drops Out” After Rebuttal: Summary Judgment Turns on a Rule 56 “Convincing Mosaic,” and Mixed-Motive Theories Must Be Properly Raised Court: U.S. Court of Appeals for the Eleventh...

When the Employer Rebuts, McDonnell Douglas “Drops Out”: Plaintiffs Must Prove a Convincing Mosaic (and Properly Raise Mixed-Motive) to Survive Summary Judgment

Date: Mar 3, 2026

When the Employer Rebuts, McDonnell Douglas “Drops Out”: Plaintiffs Must Prove a Convincing Mosaic (and Properly Raise Mixed-Motive) to Survive Summary Judgment Introduction In Larry Coleman v....

Probable Cause Defeats Retaliatory-Arrest and False-Arrest Claims Even When State “In-the-Presence” Limits Are Alleged; Municipal Liability Requires an Identified Policy or Custom

Date: Mar 3, 2026

Probable Cause Defeats Retaliatory-Arrest and False-Arrest Claims Even When State “In-the-Presence” Limits Are Alleged; Municipal Liability Requires an Identified Policy or Custom Introduction In...

Eleventh Circuit Enforces Knowing-and-Voluntary Sentence-Appeal Waivers and Channels Guilty-Plea Ineffectiveness Claims to § 2255 Absent a Developed Record

Date: Mar 3, 2026

Eleventh Circuit Enforces Knowing-and-Voluntary Sentence-Appeal Waivers and Channels Guilty-Plea Ineffectiveness Claims to § 2255 Absent a Developed Record Introduction United States v. Beatriz...

Judicial Fact-Finding May Support U.S.S.G. § 2D1.1(b)(13)(B) Enhancements Where the Statutory Range Is Unchanged

Date: Mar 3, 2026

Judicial Fact-Finding May Support U.S.S.G. § 2D1.1(b)(13)(B) Enhancements Where the Statutory Range Is Unchanged Introduction In United States v. Brendan Wells (11th Cir. Feb. 27, 2026)...

Florida Attempted Armed Robbery Is Not an ACCA “Violent Felony” After Taylor (Abrogating Joyner)

Date: Mar 3, 2026

Florida Attempted Armed Robbery Is Not an ACCA “Violent Felony” After United States v. Taylor (Abrogating United States v. Joyner) Case: United States v. Jimmy Lightsey Court: Eleventh Circuit Date:...

Res Judicata Bars Later “Fraud on the Court” Claims When Earlier Fraud Litigation Already Pleaded the Same Markman-Based Misrepresentation

Date: Mar 3, 2026

Res Judicata Bars Later “Fraud on the Court” Claims When Earlier Fraud Litigation Already Pleaded the Same Markman-Based Misrepresentation Introduction In Capital Security Systems, Inc. v. NCR...